Choosing a Consolidation Option for Schoolwide Programs

Local educational agencies (school districts and charter schools) that would like their campuses to take advantage of the flexibility offered by a Title I, Part A schoolwide program must choose the best way to consolidate funds. The chart below can help you and your local educational agency (LEA) decide which of the three possible consolidation options would be most beneficial for your campus.

Campuses can consolidate their Title I, Part A grant funds, or their Title I, Part A funds and other funds, into a single budget “pool.” Funds in the pool belong to the schoolwide program budget instead of many individual budgets, and the campus can use the pool to pay for any activity that improves the entire educational program of the campus. This consolidation eases some of the usual fiscal and programmatic requirements that apply to federal grant funds.

The options are as follows:

  1. Full consolidation. This option involves pooling some or all of your campus’s federal funds with some or all of your campus's eligible state and local funds, and provides the most flexibility in terms of operating schoolwide programs. The regulations given in the Education Department General Administrative Regulations (EDGAR) do not apply to the administration of federal grant funds in this consolidation option. Campuses that select this option, however, must still follow all applicable state regulations, including reporting requirements and the rules of accounting given in TEA’s Financial Accountability System Resource Guide (FASRG).
  2. Federal consolidation. This option involves pooling some or all of your campus’s federal funds, but does not involve state or local funds.
  3. Title I, Part A. This option does not pool any funds, but allows your campus to use its Title I, Part A allocation on a schoolwide basis.

Local educational agencies can choose different options and include different fund sources for each campus.

Please note that you must account for all expenditures for any federal funds that are not consolidated.

Consolidation Options

 Applicable Requirements

Option 1
Full Consolidation

Option 2
Federal Consolidation

Option 3
Title I, Part A Only

General fiscal activities

Most flexibility

Some flexibility

Least flexibility

Local control

Most flexibility

Some flexibility

Least flexibility

Ability to try innovative programs

Most flexibility

Some flexibility

Least flexibility

Before implementation

Eligible funds

All federal education funds (formula and discretionary) that come from programs administered by the US Department of Education are eligible. These funds must be used to carry out activities in a public elementary or secondary school. The US Department of Education does not administer Head Start and National School Lunch programs so their funds cannot be consolidated in a schoolwide program.

IDEA, Indian Education, Migrant Education, and Title III grants are eligible but have additional requirements.

Only Title I, Part A funds are eligible.

Identification of funds

Your campus improvement plan (CIP) must identify the specific programs being consolidated and the dollar amount each program contributes to the consolidated schoolwide budget.

Your CIP must demonstrate that your schoolwide program contains sufficient resources and activities to reasonably address the intents and purposes of each of the consolidated federal programs, particularly as they relate to your campus's lowest-performing students.

Your CIP must include the dollar amount of all Title I, Part A funds in the schoolwide budget.

Your CIP must specify each activity you will provide using Title I, Part A funds.

Implementation

How you must use the funds

For consolidated formula funds, you must address the intents and purposes of the programs and the needs of the intended beneficiaries of the programs. You do not need to meet most of the individual statutory and regulatory requirements of each program for funds that are consolidated.

For consolidated discretionary funds, you must carry out all of the activities described in the discretionary program grant application.

You must use Title I, Part A funds to address the specific educational needs of the campus that were identified in your needs assessment and listed in your CIP.

Activities and services are allowable as long as they meet the intents and purposes of the Title I, Part A program.

Specific allowable costs

The schoolwide budget may support any service or activity of your schoolwide program that was identified in your comprehensive needs assessment and included in your CIP, and that is allowed by state and federal law.

The schoolwide budget may only support a service or activity that supports the educational or instructional needs of the campus that were identified in your comprehensive needs assessment and included in your CIP.

Costs must meet any additional requirements given in Office of Management and Budget (OMB) Circular A-87.

Allowability of routine operating expenses (such as maintenance, repairs, and landscaping)

Fund sources lose their programmatic identity and it is impossible to know which specific funds paid for specific activities. Therefore, you may use schoolwide budgets for routine operating expenses. However, to pass the supplemental funds test, your campus must also have sufficient state and local funds in its consolidated pool to cover its noneducational activities. More detailed information is given below this chart.

Consolidated funds can only pay for educational or instructional expenses, so you may not use schoolwide budgets for basic operational expenses.

Basic operational expenses are also not allowable under OMB Circular A-87.

Accounting

You do not need to track consolidated federal funds to activities that are allowable under individual programs.

Because Title I, Part A funds are not consolidated with other federal, state, and local funds, you must account for and track the Title I, Part A funds separately, identifying the activities supported by the funds.

Records that must be maintained

Your campus does not need to maintain separate fiscal accounting records, by federal program, to demonstrate that an activity in your CIP may be supported by consolidated federal funds.

If you consolidate only federal funds, including Title I, Part A funds, you must keep records that demonstrate that you use federal funds, including Title I, Part A funds, to support activities that address the specific educational needs of your campus identified by your comprehensive needs assessment and included in your CIP.

If you consolidate only Title I, Part A funds, you must keep records that demonstrate that you use the Title I, Part A funds to support activities that address the specific educational needs of your campus identified by your comprehensive needs assessment and included in your CIP.

Advantages

Time and effort documentation

Employees paid entirely from the schoolwide pool are not required to maintain signed semi-annual certifications or any other form of time and effort records.

Employees paid partially from a federal fund that is not consolidated must maintain time and effort records in accordance with OMB Circular A-87 or a substitute time and effort system approved by TEA.

Employees paid entirely from the schoolwide pool must maintain signed semi-annual certifications. However, if the campus consolidates funds from programs covered by Ed-Flex, the semi-annual certification requirement is waived.

Employees paid partially from a federal fund that is not consolidated (or from a federal program not covered by Ed-Flex) must maintain time and effort records in accordance with  OMB Circular A-87 or a substitute time and effort system approved by TEA.

Budget amendments to the NCLB Consolidated Federal Grant Application

Amendments are not required if you budget consolidated funds using the 8911, Operating Transfers Out code. Changes related to funds not budgeted under 8911 may still require amendments.

Funds are budgeted using the usual process (by class-object code), so amendments are required.

Supplement, not supplant (see supplemental funds test)

Federal funds must supplement the state and local resources the campus would receive in the absence of Title I, Part A.

In other words, the campus does not need to demonstrate that any particular service is supplemental to state or locally funded services.

Federal funds must supplement the state and local resources the campus would receive in the absence of Title I, Part A.

In other words, the campus does not need to demonstrate that any particular federally funded service is supplemental to state or locally funded services.

Federal funds must supplement the state and local resources the campus would receive in the absence of Title I, Part A.

In other words, the campus does not need to demonstrate that any particular Title I, Part A–funded service is supplemental to state or locally funded services.

 

Routine Operating Expenses

Schoolwide campuses using the full consolidation option may use consolidated funds to pay for routine operating expenses, such as building maintenance and repairs, landscaping, and custodial services. If a campus chooses to take advantage of this flexibility, and include its routine operating expenses in its schoolwide budget, its LEA must pass the supplemental funds test and also take the following additional steps:

  • Calculate the amount of state and local funds the campus would otherwise need to operate in the absence of federal funds, which includes the state and local funds necessary to provide for routine operating expenses.
  • Ensure that the calculated amount is budgeted for that campus, and that the campus consolidates the amount in its schoolwide pool.
  • Ensure that the campus includes its routine operating expenses in its CIP.
  • For auditing and monitoring purposes, maintain documentation of its calculation.
  • For auditing and monitoring purposes, maintain documentation that shows that the campus’s routine operating expenses were paid from the schoolwide pool. If the LEA cannot demonstrate that the routine operating expenses were paid from the schoolwide pool, it cannot verify that it did not supplant federal funds.

Additional Guidance from TEA

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

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 I
This is the first 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 documentation requirements and the supplemental funds test.

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

TEA's web pages summarize 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 Fiscal Issues, Non-Regulatory Guidance, February, 2008 (Word, 995 KB, outside source)

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

Office of Management and Budget (OMB) Circular A-87

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.