Schoolwide Programs: Funding and Accounting Decisions, Part I

Once a local educational agency (school district or charter school) has determined which of its eligible campuses will operate Title I, Part A schoolwide programs, it must work with each campus to make basic funding and accounting decisions related to consolidating funds. This page is the first in a series that provides the basic steps that your local educational agency (LEA) may follow to implement the funding and accounting components of schoolwide programs. This page covers Step 1. The second page covers Steps 2, 3, and 4 and the third page covers Steps 5 and 6. There are links at the bottom of this page to other web pages about schoolwide programs.

Please note that all of the examples on these pages are provided by TEA for informational purposes only. You should not interpret the items or amounts as anything other than sample data.

Documentation Requirements

These pages also identify the key pieces of documentation that your LEA must maintain to demonstrate that its Title I, Part A schoolwide campuses comply with applicable rules. While schoolwide programs provide great programmatic flexibility in terms of how campuses can spend their consolidated funds, each campus must still:

  1. Demonstrate in its Title I, Part A schoolwide campus improvement plan (CIP) that its schoolwide program contains sufficient resources and activities to reasonably address the intents and purposes of programs whose funds are consolidated, particularly as they relate to the lowest-performing students.
  2. Identify in its CIP the programs that have been consolidated and the amount each program contributes to the schoolwide pool.
  3. Demonstrate that it received at least the same amount of state and local funds that, in the aggregate, it would have received in the absence of Title I, Part A funds (see Step 1 below).

TEA is required to uphold its administrative responsibilities by ensuring that federal grant subrecipients comply with applicable statutes and regulations, including the rules that apply to schoolwide programs. If your LEA is selected for a review of its administration of federal grant awards, your LEA must provide TEA monitors with adequate documentation to demonstrate that its schoolwide campuses comply with the requirements listed above, and any others associated with operating a schoolwide program. Please note that while these web pages provide guidance about the documentation that is required, they are not intended to limit the documentation maintained by your LEA. As a best practice, your LEA should maintain all documentation that it believes is necessary to demonstrate compliance with applicable rules.

Your LEA must also maintain the required documentation for its own independent auditor. 

Step-by-Step Guidance

This guidance is designed for LEAs with campuses that have already operated Title I Part A schoolwide programs. Most of the funding decisions about schoolwide campuses must be made during the spring, after the LEA creates a preliminary budget of all federal, state, and local funds (planning amounts) that will be available for the following school year. By that time, each campus should have conducted its comprehensive needs assessment and determined its educational needs, and should be finalizing its schoolwide program CIP for the next school year.

If a campus operated a schoolwide program in the previous year, it should also have conducted its annual evaluation of the previous school year and modified its CIP as necessary.

If your campus has not previously operated a Title I, Part A schoolwide programs, you should view the introductory guidance available online from TEA.

Step 1: Allocating Funds to Each Campus

Based upon the district and campus comprehensive needs assessments, your LEA matches its resources to its prioritized educational needs and allocates funds from each of its federal, state, and local funding sources to each of its campuses for the following school year.

Under federal law, LEAs must demonstrate that campuses eligible to receive Title I, Part A funds comply with the supplement, not supplant requirement to ensure that they do not use federal funds to perform services that would normally be paid for with state or local funds. Compliance with supplement, not supplant is usually determined on a cost-by-cost basis to ensure that each cost charged by a campus to federal funds is supplemental or "extra" in relation to costs charged to state or local funds.

LEAs with campuses that operate Title I, Part A schoolwide programs, however, must demonstrate that they comply with supplement, not supplant in a different way. LEAs with schoolwide campuses must pass a test called the supplemental funds test. Instead of demonstrating that specific costs are supplemental, the supplemental funds test ensures that LEAs allocate funds appropriately to campuses that operate Title I, Part A schoolwide programs.

In a schoolwide program, federal funds must supplement the state and local resources the campus would receive in the absence of federal funds. To pass the supplemental funds test, an LEA must demonstrate that the method it uses to allocate state and local funds to its campuses is applied consistently and does not reduce the allocation of state and local funds to a schoolwide campus because of Title I, Part A funds.

When an LEA passes the supplemental funds test, its campuses can use their funds to improve their entire educational program without having to demonstrate that each expenditure is "supplemental." However, the LEA must maintain documentation that verifies that it passed the supplemental funds test and that it applied the same funding methodology to all of its campuses, including those that do not receive Title I, Part A funds.

The following examples show how an LEA may demonstrate that it has used a fair and consistent method to allocate funds to its campuses and passed the supplemental funds test. Please note that none of the schoolwide campuses in the example districts will choose to consolidate federal, state, and local funds (the full consolidation option). More information about full consolidation and the supplemental funds test is available online.

Step 1, Example 1

Rokesmith Independent School District has five campuses. In order to pass the supplemental funds test, the district has decided that for the upcoming school year, it will allocate state and local funds to all of its campuses based upon its student-per-teacher ratio, which is 22 to 1, and how much it usually pays for staff and supplies, which is as follows:

  • each teacher position = $60,000
  • each principal position = $80,000
  • technology cost per student = $50
  • instructional materials per student = $61

Hexam Elementary School has 300 students and operates a Title I, Part A schoolwide program. The district will make the following allocation of state and local funds:

Hexam Elementary School
Allocation of State and Local Funds
(Supplemental Funds Test)
Funding Category
CalculationAmount Allocated
Funding for 14 teachers
(based upon student-per-teacher ratio)
14 × $60,000
$840,000
Funding for 1 principal
1 × $80,000
$80,000
Technology costs
300 × $50
$15,000
Instructional materials costs
300 × $61
$18,300
Total allocation of state and local funds
$953,300

 

Wilfer High School has 600 students and does not receive Title I, Part A funds. The district will make the following allocation of state and local funds:

Wilfer High School
Allocation of State and Local Funds
(Supplemental Funds Test)
Funding Category
CalculationAmount Allocated
Funding for 27 teachers
(based upon student-per-teacher ratio)
27 × $60,000
$1,620,000
Funding for 1 principal
1 × $80,000
$80,000
Technology costs
600 × $50
$30,000
Instructional materials costs
600 × $61
$36,600
Total allocation of state and local funds
$1,766,600

 

The district uses the same method for all five of its campuses and therefore passes the supplemental funds test. The district maintains documentation of its method and its calculations for auditing and monitoring purposes.

Please note that while this district's calculation model is based upon staffing, the district does not necessarily have to use the allocated funds according to the model. The figures in the calculation model are used to generate a fair and consistent allocation amount, but the district can use its discretion to pay a teacher, for example, more or less than $60,000.

Step 1, Example 2

Wegg Independent School District has five campuses. In order to pass the supplemental funds test, the district has decided that it will allocate state and local funds to its campuses based upon a weighted per-pupil formula, according to the following:

  • standard per-pupil allocation = $4,000
  • additional allocation for each low-income student = $400
  • additional allocation for each limited English proficient student = $600
  • additional allocation for each special education student = $900

Wren Elementary School has 300 students, which includes 200 low-income students, 100 limited English proficient students, and 20 special education students. The campus operates a Title I, Part A schoolwide program. The district will make the following allocation of state and local funds:

Wren Elementary School
Allocation of State and Local Funds
(Supplemental Funds Test)
Funding Category
CalculationAmount Allocated
Standard funding for all students
300 × $4,000
$1,200,000
Funding for low-income students
200 × $400
$80,000
Funding for limited English proficient students
100 × $600
$60,000
Funding for special education students
20 × $900
$18,000
Total allocation of state and local funds
$1,358,000

 

Wrayburn High School has 600 students, which includes 450 low-income students, 200 limited English proficient students, and 75 special education students. The campus does not receive Title I, Part A funds. The district will make the following allocation of state and local funds:

Wrayburn High School
Allocation of State and Local Funds
(Supplemental Funds Test)
Funding Category
CalculationAmount Allocated
Standard funding for all students
600 × $4,000
$2,400,000
Funding for low-income students
450 × $400
$180,000
Funding for limited English proficient students
200 × $600
$120,000
Funding for special education students
75 × $900
$67,500
Total allocation of state and local funds
$2,767,500

 

The district uses the same method for all five of its campuses and therefore passes the supplemental funds test. The district maintains documentation of its method and its calculations for auditing and monitoring purposes.

Please note that while this district's calculation model is based upon a per-pupil formula, the district does not necessarily have to use the allocated funds according to the model. The figures in the calculation model are used to generate a fair and consistent allocation amount, but the district can use its discretion to spend, for example, more or less than $4,000 on each low-income student.

Please go to the web page Schoolwide Programs: Funding and Accounting Decisions, Part II, for Steps 2, 3, and 4 in this process.

Additional Guidance from TEA

Additional guidance about Title I, Part A schoolwide programs is available at the following web pages:

Choosing a Consolidation Option for Schoolwide Programs
This page contains a chart showing the differences between the three ways you can consolidate funds in schoolwide programs.

Fiscal Issues Related to Operating a Schoolwide Program
This page describes various fiscal issues related to operating a schoolwide program, including accounting methodologies and specific fiscal requirements such as set-asides; supplement, not supplant; and time and effort.

General Information about Schoolwide Programs
This page describes the general purpose, goals, and fundamental principles of Title I, Part A schoolwide programs.

Schoolwide Programs
This is the home page for Title I, Part A schoolwide programs, and provides general information about choosing to implement a schoolwide program, eligibility, and basic requirements.

Schoolwide Programs: Accounting for Expenditures, Part I
This is the first of three web pages that provide information about accounting for schoolwide program expenditures. This page describes fund code 282.

Schoolwide Programs: Accounting for Expenditures, Part II
This is the second of three web pages that provide information about accounting for schoolwide program expenditures. This page provides examples of how to account for an actual schoolwide program expenditure by using fund code 282 in a general ledger.

Schoolwide Programs: Accounting for Expenditures, Part III
This is the third of three web pages that provide information about accounting for schoolwide program expenditures. This page provides examples of how to account for an actual schoolwide program expenditure by using fund code 282 in a general ledger.

Schoolwide Programs: Annual Evaluation Plan
This page provides detailed information about the required annual evaluation plan, including recommended steps to follow.

Schoolwide Programs: Campus Improvement Plan
This page provides detailed information about the required campus improvement plan, including the required accounting and program components.

Schoolwide Programs: Comprehensive Needs Assessment
This page provides detailed information about the required comprehensive needs assessment, including recommended steps to follow.

Schoolwide Programs: Funding and Accounting Decisions, Part II
This is the second in a series of web pages that provide the basic steps to follow to implement the funding and accounting components of a schoolwide program. This page covers allocating funds to a schoolwide program.

Schoolwide Programs: Funding and Accounting Decisions, Part III
This is the third in a series of web pages that provide the basic steps to follow to implement the funding and accounting components of a schoolwide program. This page covers following an accounting methodology, proportionality tables, and committing to a schoolwide program on a grant application.

Additional Guidance from USDE

This page summarizes the information and requirements given by the US Department of Education. The source documents are available at the links below:

Section 1114 of the Elementary and Secondary Education Act (ESEA)  

Designing Schoolwide Programs, Non-Regulatory Guidance, March 2006 (Word, 452 KB, outside source)

Title I, Part A Fiscal Issues, Non-Regulatory Guidance, February, 2008 (Word, 995 KB, outside source)

Federal Register, July 2, 2004 (Volume 69, Number 127)

Contact Information

For more information about Title I, Part A schoolwide programs, please contact Anita Villarreal in the Division of Federal and State Education Policy at nclb@tea.texas.gov.

For more information about the TEA federal flexibility initiative, please contact Terry Reyes in the Office for Grants and Federal Fiscal Compliance at terry.reyes@tea.texas.gov.