Title IV-A

Important Updates – 15% Rule

Dear Colleagues,

In a continuous effort to provide our students with the best possible access and opportunity to an enriched and Well-Rounded education, we are providing updated information made available to us regarding the new funding source known as the Student Support & Academic Enrichment Grants, or Title IV-A:

The 15% Technological Infrastructure Rule (ESSA 4109):

As previously understood, the 15% Technology Rule applied to all technological purchases; the 15% was derived from the portion of funds allocated toward the Effective Use of Technology portion of the grant.


UPDATE:

Due to multiple inquiries from the field both in Arizona and across the nation, US ED has since provided clarification of this rule:

For the ‘safe and healthy’ and ‘well-rounded education’ content areas, technology purchases are not limited or restricted, but the technology purchase would need to be consistent with the purposes of the content area. What LEAs propose as activities will be informed by the comprehensive needs assessment (required for LEAs with an allocation of at least $30,000), stakeholder engagement, and prioritization of schools. The SEA’s determination of allowability of SSAE funds will depend on a number of factors, starting with whether all statutory requirements are met.

Generally, in reviewing an LEA’s application, an SEA will first consider whether a proposed activity is consistent with the purposes of at least one of the three content areas in the SSAE program (well-rounded education in section 4107, safe and healthy students in section 4108, or the effective use of technology in section 4109). Assuming that the activity is consistent with the purposes of one of the three content areas, as applicable, the SEA must make further determinations as to allowability of costs in accordance with the cost principles in the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) at 2 CFR Part 200, Subpart E. Specifically, the cost of an activity is allowable under the SSAE program if it is reasonable and necessary for performance of the grant (i.e., it is of a type generally recognized as ordinary and necessary for operation of the grant) and allocable to the grant (i.e., it is chargeable to the grant award in proportion to the benefits received by the grant award as a result of the cost).

Also, because section 4110 of the ESEA prohibits supplanting, the proposed use of funds for the activity must supplement, and not supplant, other State or local funds that would otherwise be used to pay for the allowable activity. Finally, SEAs must check to ensure that the activity is not one of the prohibited activities in section 4001(b) or 8526 of the ESEA, as amended by the Every Student Succeeds Act (ESSA).

With this new understanding, you may be able to identify technological solutions for your Well-Rounded Education and Safe & Healthy Students needs and NOT activate the 15% Rule. The 15%, when activated, will still be derived from the portion of funds you allocate to the Effective Use of Technology category and NOT the total allocation.



Well-Rounded Education, part of our students Civil Rights (ESSA 4107):

As we all are aware, the transition from NCLB to ESSA came with the transition from research-based activities to evidence-based activities. Under ESSA, activities or programs funded through federal dollars must have an evidence-based claim that the strategy will improve student academic achievement.


UPDATE:

Under Title IV-A, both the Safe & Healthy Students (ESSA 4108) and the Effective Use of Technology (ESSA 4109) sections of the grant come with the evidence-based requirement, however, the Well-Rounded Education section mentions no such language. Instead, the Well-Rounded Education section (ESSA 4107) emphasizes student access and opportunity to activities and programs that are defined as well-rounded (ESSA 8201). This in essence equates the Well-Rounded education prevision of Title IV-A as a Civil Right and therefore should be approached as such.

Please also understand that, while this allows for a certain increase of flexibility, it is best practice that evidence-based strategies are identified to support the development of our students.

We are excited about these developments and encourage LEAs to “revision” the capabilities of Title IV-A funds. Your ADE Title IV-A Program Area staff are dedicated to providing you the best resources, guidance, and technical assistance as you continue to identify innovative solutions to your local needs.

This information will soon be made available on our website, and will be shared in person at this year’s ESSA Conference on both Wednesday, November 14th and Thursday, November 15th.

Dustin Loehr
Director of Arts Education & Title IV-A
Well-Rounded Education, Safe & Healthy Students, Digital Literacy
Arizona Department of Education
[email protected]
602.364.3015
www.azed.gov/artseducation/
www.azed.gov/titleiv-a/
www.azed.gov/gifted-education/

FY19 Title IV-A Final Allocations

We are pleased to announce that Final FY19 Title IV-A allocations have been posted in the ESEA Consolidated application in GME on the “Allocations” link. Additionally, all LEA Title IV-A allocations are posted on the Title IV-A website under the “Allocations” tab. The Title I-A, Title I-D, and Title II-A allocation files are also available on the Title I Allocations page.

The Title IV-A allocations for LEAs are calculated by formula, based on the proportion of those LEAs’ prior year’s Title I, Part A allocation. SEAs are further required to ensure no LEA receives an allocation less than $10,000 (minus any required Maintenance of Effort reductions), and must ratably reduce LEAs accordingly to ensure the minimum amount requirement is met.

• FY19 Title IV-A Final Allocation Notification
  
  
• FY19 Title I Allocation Release Notification

Huge Increase for FY19!

What’s in ESSA’s Big Flexible-Spending Pot

The Student Support and Academic Enrichment Grants—better known as Title IV of the Every Student Succeeds Act—is one of the most flexible federal programs around. And it just got a huge increase, from $400 million in the 2017-18 school year to $1.1 billion for the 2018-19 school year. The program is closely watched by advocates and district officials alike, in part because the dollars can cover such a wide array of needs—from school safety training to drama clubs to science programs to suicide prevention. Read full Education Week article, published June 5, 2018

Allocation Worksheet for 20-20 & 15% Rule

In an effort to streamline the program creation and grant review processes for the Title IV-A Student Support & Academic Enrichment Grant, we have created a simple to use tool that assists in calculating the 20-20 Rule and the 15% Technology Rule. We are encouraging all LEAs to access the “Title IV-A Allocation Worksheet” and to use this tool during the planning stages of the budgeting process.

This form can be found within the Resource Library under the Title IV-A heading in GME and on the Title IV-A website under Guidance & Resources tab.

How Do I Transfer Funds?

1. Open the ESEA Consolidated Application
2. Click on Allocations
3. Determine the amount of Title IV money you wish to transfer and to which location(s) (e.g., Title I, TItle II, etc.)
4. Scroll down to the bottom of the page where you will see all of your LEAs grants
5. On the “From STUDENTSAEG” line, enter the amount you wish to transfer under your intended grant. Once you save & continue, you’ll see that amount deducted from the STUDENTSAEG column and the same amount added to the other funding total.
6. Save and continue
7. Finally, amend in the transferred funds to the funding source you choose and update your IAP to reflect budgeted expenditures for all funding sources.
   
   Note: Funds transferred to Title I may not be transferred again later in the year.

Special Rules: 20-20 with 15%

Key Questions for Activities to Support the Effective Use of Educational Technology

1. What is the scope and applicability of the Special Rule in section 4109(b)?
   At least 85 percent of the educational technology funds must be used to support professional learning to enable the effective use of educational technology. LEAs or consortiums of LEAs may not spend more than 15 percent of funding in this section on devices, equipment, software applications, platforms, digital instructional resources and/or other one-time IT purchases.
   
   Specifically, the statute states that LEAs may not use more than 15 percent for purchasing technology infrastructure as described in section 4109 (a)(2)(B) which states: “purchasing devices, equipment, and software applications to address readiness shortfalls” and in section 4109 (a)(4)(A) which states: “blended learning technology software and platforms, the purchase of digital instructional resources, initial professional development activities, and one-time information technology purchases.”

Reference: Non-Regulatory Guidance, Student Support and Academic Enrichment Grants

The 20-20 Rule

LEAs that receive an allocation of $30,000.00 or MORE must:

1. Allocate no less than 20% toward well-rounded education activities
   
2. Allocate no less than 20% toward safe and healthy students
   
3. Allocate a portion of funds to support effective use of technology
   
   ∗ The remaining 60% can be used toward any combination of:
   • Well-rounded Education
     
   • Safe & Healthy Students
     
   • Effective Use of Technology (please note, of this 60% you must allocate a portion to the Effective Use of technology)
     Of the portion allocated toward the Effective Use of Technology, only 15% may fund technological infrastructure expenses
     

The 15% Rule

LEAs that receive an allocation that is LESS than $30,000.00 may:

1. Place the entire allocation in any ONE of the content categories, OR
   
2. Activate any combination of the three categories (well-rounded, safe and healthy, effective use of technology)
   Of the portion allocated toward the Effective Use of Technology, only 15% may fund technological infrastructure expenses
   
   

   

Dustin Loehr – Letter of Transition