Grants Management Manual

Transcription

1 2602 S. Belt Line Rd. Grand Prairie, Texas DEPARTMENTS of Education Support and Finance Grand Prairie Independent School District Grants Management Manual

2 CONTENTS Purpose of Grants Management Manual Primary Contact Information GPISD Goal Statements Descriptions of Major Grants Section One: Preparing for a Grant a. Grant Development Process b. Request for Grant: Intent to Apply c. Grant Guidelines for Grand Prairie ISD d. Comprehensive Needs Assessment e. Campus Improvement Plans/District Improvement Plan Section Two: Common Grant Requirements a. Federal Legislative Requirements b. Site Based Decision Making (SBDM) and Parent Involvement c. Private School Participation d. Scientifically Based Research Programs e. SBR Documentation Form f. Supplement vs. Supplant g. Staff Development Section Three: Grant Financial Management and Accounting a. Internal Controls b. TEA Update 15 c. Budget Code Structure Section Four: Expending Grant Funds a) Documentation of Expenditures b) Guidelines for Specific Costs 2 P a g e

3 c) Title I / SCE Field Trip Request Form d) Allowable Costs e) Allocable Costs f) Cash Management g) Obligation of Funds Section Five: Records Requirements a. Records Retention Guidelines b. Time and Effort Record Keeping Section Six: Reporting Requirements a. Program Reports b. Expenditure Reports Section Seven: Enforcement for Noncompliance a. Compliance Provisions and Assurances b. Principals and Managers Responsibility Section Eight: Grant Close-Out a) Program Documentation b) Financial Documentation Attachments Documents on Demand Related GPISD Board Policies Web Link Resources TEA Grantee Handbook Additional Resources 3 P a g e

4 Purpose of Grants Management Manual The Grand Prairie ISD Grants Management Manual provides basic information on the major grants in place within the district and serves as a guide to policies and procedures regarding requests for and use of grant funds. Adherence to grant policies and procedures ensures compatibility with district goals and compliance with legal requirements for programmatic and financial accountability. This manual is not all inclusive and careful reading of the requirements of each grant acquired by the district is required. Web links, appendices and attachments are also provided for further guidance. Primary Contact Information Patricia Lewis (972) Chief School Improvement Officer Responsibilities: Program oversight for all grant funded programs Initial point of contact for all grant proposals Title I, Part A program management NCLB program coordination with Titles II, III NCLB application and compliance report process State Compensatory Education program management McKinney-Vento Homeless Education / Connections Program Linda Ellis (972) Executive Director of Teaching and Learning Responsibilities: Title II, Part A program manager Dorothea Gordon (972) Executive Director of Special Education Responsibilities: IDEA-B and Pre-K program management Magda Schenck (972) Director of Bilingual/ESL Programs/LOTE/Pre-K/Multicultural/American Indian Responsibilities Title III program management Bilingual/ESL/Dual Language program management Michael McSwain (972) Director of Career and Technology Education Responsibilities: Career and Technology Education (CTE) Ray Wilks (972) Director of Finance Responsibilities: Budget development and accounting for special revenue Compliance monitoring and technical assistance 4 P a g e

5 GPISD Goal Statements These goal statements focus all instructional efforts within GPISD, regardless of funding. They are included here for reference and to document that grant programs are to enhance and supplement the full instructional program. Connections to the Texas Education Code and the 10 Components of a Title I, Part A Schoolwide program are noted. These statements are the basis for the Campus Improvement Plans and the District Improvement Plan noted in Section One of this manual. DIP Goal Area 1, Student Achievement: Students will demonstrate exemplary performance in comparison to national and international standards in the areas of reading and writing of the English language and in the understanding of mathematics, science and social studies. [TEC 4.001(b)(7)] [TEC ] (T1,A SW #1, #2, #8, #9, #10) (GPISD 5 Plays: Engaged Instruction via the 5E Model) (SIP Requirements: 1, 2, 4, 5, 6) DIP Goal Area 2, Curriculum and Instruction: Students will be encouraged and challenged to meet their full educational potential, with a well-balanced and appropriate curriculum provided to all students. [TEC 4.001(b)(2)(4)] (T1, A SW #1, #2, #7, #8, #9, #10) (GPISD 5 Plays: Vertically and Horizontally Aligned Curriculum) (SIP Requirements: 1, 2, 5) DIP Goal Area 3, Fiscal Responsibility: GPISD will exercise financial responsibility and increase fiscal transparency to ensure well planned, reasonable and necessary expenditures to support facilities and programs for teaching and learning. [TEC ] (FAR Module 2, 2.6) DIP Goal Area 4, Highly Qualified/Effective Personnel: Qualified and highly effective personnel will be recruited, developed and retained, with educators keeping abreast of the development of creative and innovative techniques in instruction and administration, using those techniques as appropriate to improve student learning. [TEC 4.001(b)(6)(9)] (T1,A SW #3, #4, #5) (GPISD 5 Plays: Intentional Leadership, Data Driven Management, Engaged Instruction via the 5E Model) (SIP Requirements: 3, 7) DIP Goal Area 5, Parent/Community Involvement: Parents and community members will be full partners with educators in the education of GPISD students. [TEC 4.001(b)(1)] (T1,A SW #6) (GPISD 5 Plays: Relationship Capacity, Intentional Leadership) (SIP Requirement: 8) DIP Goal Area 6, Instructional Technology: Instructional Technology will be incorporated to increase the effectiveness of teaching and learning, instructional management, staff development and student progress assessments. [TEC 4.001(b)(10)] (T1,A SW #2, #10) (GPISD 5 Plays: Engaged Instruction via the 5E Model, Instructional Leadership, Data Driven Management) (SIP Requirements: 2, 3) DIP Goal Area 7, Safe and Disciplined Environment: GPISD will continue to improve and maintain a safe and disciplined environment conducive to teaching and learning, promoting physical and mental health in all students, their families and employees. [TEC 4.001(b)(8)] [TEC (3)(B)(E) and (8)] [HB 1041 (reducing sexual abuse of children] [TEC Coordinated health services] (GPISD 5 Plays: Relationship Capacity, Engaged Instruction via the 5E Model, Intentional Leadership) (SIP Requirements: 2, 6) DIP Goal Area 8, Dropout Prevention: Through enhanced dropout prevention efforts, all students will remain in school until they obtain a high school diploma. [TEC 4.001(b)(3)] (T1, A SW #2, #6, #8, #9, #10) (TX H.B. 5) (GPISD 5 Plays: Relationship Capacity, Data Driven Management) (SIP Requirements: 1, 2, 5) 5 P a g e

6 Descriptions of Major Grants Many of the grant programs in GPISD are generated by federal legislation, No Child Left Behind, P.L and Individuals with Disabilities Education Act, P.L and others. These grant funds are often referred to as entitlement programs because they are not competitive grants but are generated by formula according to student data. Many of these federal funds are managed and delivered via the Texas Education Agency (TEA) to local education agencies (LEAs) such as Grand Prairie ISD. Title I, Part A Improving Basic Programs (Program Manager: Patricia Lewis) Title I, Part A funding is for resources to help schools with high concentrations of students from low-income families provide a high-quality education that will enable all children to meet the state s student performance standards. Title I, Part A supports schools in implementing either a schoolwide program or a targeted assistance program. Currently, all eligible schools receiving Title I, Part A funds in GPISD have elected to implement a schoolwide program to serve all students. These programs must use effective methods and instructional strategies that are grounded in scientifically based research (SBR). GPISD campuses currently focus on three basic areas: - highly effective and qualified personnel to provide accelerated instruction to students to meet or exceed the state s performance standards, - supplemental programs and materials with documented evidence of success in accelerating instruction for students, and - coordinated activities to involve parents and community, teachers and students in the teaching and learning process. The program also addresses early identification, prevention, intervention, counseling and support to address emotional and behavioral problems that may negatively impact academic success. Title I, Part C Education of Migratory Children (Program Manager: Patricia Lewis) These funds support high-quality educational programs for migratory children and help ensure that students who move among states are not penalized in any manner by disparities among states in curriculum, graduation requirements, or state academic content and student academic achievement standards. Programs include participation in a communication system between states with high numbers of migratory children to better inform receiving teachers of student progress and special needs. GPISD participates in a shared services agreement with Region 10 Education Service Center to better serve these students and their families by coordinating services throughout the region. Title II, Part A Improving Teacher Quality (Program Manager: Linda Ellis) The purpose of Title II, Part A is to increase the academic achievement of all students by helping campuses and districts improve teacher and principal quality and ensure that all teachers are highly qualified. School districts that receive these funds are held accountable to the public for improvements in academic achievement. GPISD has the flexibility to use these funds creatively to address challenges to teacher quality, whether they concern teacher preparation and qualifications of new teachers, recruitment and hiring, induction, professional development, teacher retention, or the need for more capable principals and assistant principals to serve as effective school leaders. 6 P a g e

7 Title III, Part A English Language Acquisition, Language Enhancement, and Academic Achievement (Program Manager: Magda Schenck) The purpose of Title III, Part A is to ensure that children who are limited English proficient, or English Language Learners (ELL), including immigrant children and youth, attain English proficiency, reach high levels of academic achievement and meet the challenging State academic content and academic achievement standards expected of all students. Many of the federal requirements for Title III, Part A funds are already implemented in Texas as part of State statutes [TEC ]. Texas requires school districts to provide bilingual education programs and English as a Second Language (ESL). State general education funds provide for many of these related costs, requiring school districts to utilize Title III, Part A funds to truly expand the basic programs grounded in scientifically based research. GPISD provides a dual language program as this enhancement to the State required program. GPISD focuses on providing funding for supplemental training on effective instructional techniques for this scientifically based research effort and supports the program with necessary materials. IDEA-B Formula and IDEA-B Preschool (Program Manager: Dorothea Gordon) Federal funds provide supplemental resources to help GPISD ensure that students with disabilities (ages 3-21) are provided with a free appropriate public education as required by federal statute. Funds are used for support and direct services including teacher preparation and training for regular and special education teachers who teach students with disabilities, appropriate accommodations for identified students, alternative assessments that are valid and reliable and the implementation of scientifically based research instructional methods or programs to improve academic achievement to meet or exceed objectives established by the State. Career and Technology Education Carl D. Perkins (Program Manager: Michael McSwain) These federal funds are provided to fully develop the academic, career and technical skills of secondary students. Programs provide students with strong experiences and understanding of a particular industry to integrate core academic subjects into Career and Technology Education (CTE) programs through a coherent sequence of courses. Programs develop, improve or expand the use of modern technology as related to specific industries. CTE also provides activities to prepare special populations for high skill, high wage, or high demand occupations that will lead to self-sufficiency. Funds also support professional development programs for teachers, counselors and administrators. McKinney-Vento Homeless Education (Program Manager: Patricia Lewis) These federal funds are generated by Title X, Part C of No Child Left Behind, P.L to ensure educational rights and protections for children and youth experiencing homelessness. The Connections Program assists with identification and enrollment procedures for these students. Children and youth who have lost their housing live in a variety of places including motels, shelters, shared residences, cars, campgrounds and others. Their lack of permanent housing can lead to potentially serious physical, emotional and social consequences. State Compensatory Education (Program Manager: Patricia Lewis) Funds are provided to GPISD to serve students identified as at risk of dropping out of school. There are thirteen at risk criteria utilized by the state. Identified students must meet one or more at risk criteria that range from unsatisfactory performance on early childhood readiness tests and assessment instruments to failing End of Course examinations. Funds must be utilized to increase academic achievement for at risk students. 7 P a g e

8 SECTION ONE: Preparing for a Grant Grant Development Process Any GPISD campus or department seeking an opportunity to apply for grant funds from any source must first complete the Request for Grant: Intent to Apply form and fax or deliver the signed form to the Chief School Improvement Officer at (972) After reviewing this information, the Chief School Improvement Officer assigns approved requests to the appropriate Executive Director to provide technical assistance for the development of a full grant proposal. Upon completion of a full grant proposal, the Executive Director assigned to the grant will process the proposal through the required review by the Chief School Improvement Officer and Finance. No grant applications that require matching funds from GPISD or additional personnel will be submitted without prior review and approval from the Chief School Improvement Officer and Finance. Approved proposals are then submitted for the Superintendent s signature and submitted to the grantor. Only the Superintendent or designee(s) may sign a grant proposal for submission. Grant development and writing technical assistance provided by the assigned Chief School Improvement Officer may include the following: Review and complete the Official Use Only section of the Request for Grant: Intent to Apply form. Review the grant purpose, guidelines, components and submission deadline with the campus and/or central administrators responsible for grant submission and implementation. Develop a grant writing team appropriate to the grant. Contact departments such as Technology and Curriculum as necessary to ensure the grant proposal is compatible with current content, policies and procedures. Establish development and writing timeline to ensure that all approvals and signatures are obtained allowing a timely submission of the grant proposal. Conduct review session with Finance Department to ensure compliance with budgetary requirements. Process final grant proposal and supporting documentation for final approvals and signatures for mailing and/or electronic submission. Monitor communication with the grantor for any necessary negotiations. Supervise the Notice of Grant Award process to ensure that awarded grant funds are available. Review provisions and assurances with the campus and or department administrators responsible for grant implementation. Special revenue funds, whether obtained through competitive grants or federal and state entitlements, are accepted by the GPISD Board of Education from private, local, state or federal sources. If selected for funding, the request, proposal or application becomes a legally binding agreement between GPISD and the granting agency or private grantor. The grantor approves the amount of the award, the funding time period and any conditions related to the approved grant. Final approval is executed through the formal 8 P a g e

9 Notification of Grant Award (NOGA). Upon receipt of the NOGA, the approved budget is loaded into the GPISD financial system and available to the campus and/or central departments. The grant activities as promised in the request, proposal or application begin as scheduled. GPISD offers grant writing training. Campuses and central departments are encouraged to designate one representative to attend this training. The training covers critical components involved in reading announcements or requests for proposals or applications from granting agencies or foundations. Critical components of writing, submitting and implementing grants are also covered in the training sessions. Contact the Chief School Improvement Officer at (972) for more information regarding this training. 9 P a g e

10 Fax completed form to , Attention Patricia Lewis School or Department: Principal/Designee/Contact Person: Phone: Fax: Source of Potential Grant Funds: State Federal Unknown, seeking grantor Corporate or Private Foundation Other, specify: Funds will be used for: (Check all that apply) Request for Grant: Intent to Apply District procedures require campuses and departments to notify the Chief School Improvement Officer of their intent to apply for grant funding prior to the development and submission of any grant proposal. Completion of this form does not obligate the campus or department to submit an application. ELA/Reading/Literacy Social Studies Technology P.E./Athletics Curriculum Instruction Math/Science Fine Arts Innovation/Reform Effort Other, specify: Brief description of school/department need: Name of Grant: Signature: Date: OFFICIAL USE ONLY CDFA or RFA #: Matching Requirements: Personnel Requested: Amount Requested: Approved Denied More information requested Finance review Assistant Superintendent of Education Support Approval: 10 P a g e

11 Grant Guidelines for Grand Prairie ISD 1. Commitment of District match in funds for any grant requires pre-approval by the Superintendent or appointed designee via Chief School Improvement Officer. 2. Commitment of additional personnel positions for any grant requires pre-approval by the Superintendent or appointed designee via Chief School Improvement Officer. 3. All personnel benefit costs must be included in all grants. 4. A grant that is written to provide stipend/extra-duty pay to the team of writers of the grant is prohibited. 5. All technology grants must be pre-approved by the Technology Department (including grants for software or hardware). 6. Grants written to Foundations must receive pre-approval by the Superintendent or designee via Chief School Improvement Officer. 7. Only the Superintendent or appointed designee may sign a grant. (Campus/Central Administrators cannot sign off on any grant.) 8. All grants will either be designated as District Grants or Campus Grants. 9. Training Guidelines will be provided by the Chief School Improvement Officer to campus based and district based grant-writing teams. 10. Grants that require approval by the Board of Education require pre-approval by the Superintendent or appointed designee. 11. A campus or department that receives a grant must make a commitment to complete all reports and data requirements of the grant. Failure to comply could result in disciplinary actions. 12. All grants must comply with District policies and procedures. 13. All grants must comply with the Grants Management Manual and Business Operations Handbook. 14. All employees requesting a grant must complete the Finance Department Request for Grant form with assistance from the Chief School Improvement Officer. 15. Campuses will be required to send a minimum of one person to the grant training provided by the Chief School Improvement Officer and Business Operations. 11 P a g e

12 Comprehensive Needs Assessment A Comprehensive Needs Assessment (CNA) is required of all GPISD schools to ensure that the Campus Improvement Plan is based on careful review of the needs of the individual campus. The same process is then utilized for the development of the District Improvement Plan. Federal and state statutes require site based decision making (SBDM) that shows a documented review of campus data by a team of teachers, administrators, parents and community representatives. Members of the SBDM Committee, with ad hoc members as necessary, serve as the CNA Committee. Applications for competitive grants or state and federal entitlement funds must reflect the input of the CNA. The CNA process is continuous and should be revisited throughout the school year. GPISD requires a preliminary CNA near the end of each school year prior to the submission dates for the applications for state and federal funds and another CNA review at the beginning of each school year when newer student data is available to drive the implementation of the program activities. Campuses must also review the CNA data prior to the development and submission of a competitive grant application to document the need for the funds. Training and technical assistance are provided by GPISD on the CNA process and required documentation. Campus Improvement Plans/District Improvement Plan Documented results of the CNA process drive the development of the Campus Improvement Plans (CIPs) and the District Improvement Plan (DIP). Campuses or departments utilizing private, state or federal funds must document in the CIP the program activities to be implemented with these funds. Expenditures cannot be approved unless the activity is clearly noted in the CIP. Example 1: Excel Elementary School documents a need in the CNA process to offer tutoring with a focus on at-risk students and LEP students, and the need for additional supplemental math and science classroom manipulatives to support instruction. Excel Elementary School then notes in the CIP their decision to operate a Title I, Part A Schoolwide program. Further CIP entries would note part time teachers for tutoring and supplemental math and science manipulatives. Excel Elementary then submits their documentation and the necessary budget information to Education Support as requested for the entitlement application. Example 2: Outreach Elementary School finds notice that the Farmers Foundation is announcing grant funding for afterschool gardening programs to support earth sciences. Outreach SBDM/CNA Committee confirms the need for activities supporting science classes as well as demographic data to support the need for safe after-school projects for students of working parents. Outreach submits the Request for Grant: Intent to Apply form to the Assistant Superintendent of Education Support. If approved, the grant is assigned to an Executive Director for development. Upon receipt of the Notice of Grant Award (NOGA), Outreach adds the program activities and expenses to their CIP. 12 P a g e

13 SECTION TWO: Common Grant Requirements Grant applications become legal contractual documents when awarded or approved. They are usually several pages long and will specify numerous provisions and assurances. Most common requirements come from the United States Department of Education (USDE), The Texas Education Agency (TEA) and the federal Office of Management and Budget (OMB). This document references only a partial list of common grant requirements. Further information is available from the TEA Grantee Handbook. Federal Legislative Requirements Numerous federal legislative requirements are included in most applications for grant funds. The submission of the application signifies the district s obligation to adhere to these legislative requirements. Examples include the Gun Free Schools Act of 1994 and the Texas Education Code (TEC) requiring school districts to have a policy in place requiring expulsion and referral to the juvenile justice system for any student bringing a firearm to school. Requirements of the Americans with Disabilities Act prohibit the district from denying services or participation in programs or activities that are available to students without disabilities. Grant applications often ask how these students will benefit from a proposed activity. The Family Educational Rights and Privacy Act of 1975 requires the district to have a policy allowing parents the right to inspect and review the education records of their children, including the records of the child s participation in a grant funded program. GPISD keeps documentation of adherence to these requirements. However, a grant funded program requires some additional documentation by the program manager and the campus administration. Site Based Decision Making and Parental Involvement Site Based Decision Making (SBDM) is required by the Texas Education Code for all schools. TEC Campus Planning and Site-Based Decision Making (a) Each school district shall maintain current policies and procedures to ensure that effective planning and site based decision making occur at each campus to direct and support the improvement of student performance for all students. (b) Each district s policy and procedures shall establish campus-level planning and decision-making committees as provided for through the procedures provided by Sections (b)-(e). (c) Each school year, the principal of each school campus, with the assistance of the campus-level committee, shall develop, review, and revise the campus improvement plan for the purpose of improving student performance for all student populations, including students in special education programs under Subchapter A, Chapter 29, with respect to the academic excellence indicators adopted under Section and other appropriate performance measures for special needs populations. (d) Each campus improvement plan must: (1) assess the academic achievement for each student in the school using the academic excellence indictor system as descried by Section ; (2) set the campus performance objectives based on the academic excellence indicator system, including objectives for special needs populations, including students in special education programs under Subchapter A, Chapter 29; 13 P a g e

14 (3) identify how the campus goals will be met for each student; (4) determine the resources needed to implement the plan; (5) identify staff needed to implement the plan; (6) set timelines for reaching the goals; (7) measure progress toward the performance objectives periodically to ensure that the plan is resulting in academic improvement; (8) include goals and methods for violence prevention and intervention on campus; and (9) provide for a program to encourage parental involvement at the campus. (e) In accordance with the administrative procedures established under Section (b), the campus-level committee shall be involved in decisions in the areas of planning, budgeting, curriculum, staffing patterns, staff development, and school organization. The campus-level committee must approve the portions of the campus plan addressing campus staff development needs. (f) This section does not create a new cause of action or require collective bargaining. (g) Each campus-level committee shall hold at least one public meeting per year. The required meeting shall be held after receipt of the annual campus rating from the agency to discuss the performance of the campus and the campus performance objectives. District policy and campus procedures must be established to ensure that systematic communications measures are in place to periodically obtain broadbased community, parent, and staff input, and to provide recommendations of the campus-level committee. (h) A principal shall consult the campus-level committee in the planning, operation, supervision, and evaluation of the campus educational program. Parental involvement is required in regular, two-way, meaningful communication involving student academic learning and other school activities, ensuring the following: a. Parents play an integral role in assisting their children s learning. b. Parents are encouraged to be actively involved in their children s education at school. c. Parents are full partners in their children s education and are included, as appropriate, in decision making and on advisory committees to assist in the education of their children. Private School Participation GPISD is required to provide services from federally funded programs to students living within the GPISD boundaries who choose to attend area private schools or are home schooled. It is the responsibility of the school district to provide information for area private schools and home school families regarding these services. GPISD opts to provide the required services through a shared services agreement with Region 10 Education Service Center. 14 P a g e

15 Scientifically Based Research Programs Federal and state funding sources, as well as many local and private grantors, require school districts to verify that any programs they purchase and implement are scientifically based research programs (SBR). SBR programs involve the application of rigorous, systematic, and objective procedures to obtain reliable and valid knowledge relevant to education activities and programs, including research that does the following: Employs systematic, empirical methods that draw on observation or experiment Involves rigorous data analyses that are adequate to test the stated hypotheses and justify the general conclusions drawn Relies on measurements or observational methods that provide reliable and valid data across evaluators and observers, across multiple measurements and observations, and across studies by the same or different investigators Is evaluated using experimental or quasi-experimental designs in which individuals, entities, programs, or activities are assigned to different conditions and with appropriate controls to evaluate the effects of the condition of interest, with a preference for random-assignment experiments, or other designs to the extent that those designs contain within-condition or across-condition controls Ensures that experimental studies are presented in sufficient detail and clarity to allow for replication or, at a minimum, offer the opportunity to build systematically on their findings Has been accepted by a peer-reviewed journal or approved by a panel of independent experts through a comparably rigorous, objective, and scientific review When reviewing research findings to determine whether they meet the criteria for scientifically based research, SEAs, LEAs, and schools should consider the extent to which the research meets each of the defined elements listed above. The following questions will be helpful in evaluating research findings: 1. Systematic and empirical methods Does the research have a solid theoretical foundation? Were methodology, subject, and researcher clearly identified? Was the study conducted in a consistent, disciplined, and methodical manner? Were the data obtained using observation or experiment? Was the research grounded in data that are factual rather than opinion-based? Are the research findings supported by tangible, measurable evidence? 2. Rigorous data analyses Did the research test the stated hypotheses and justify the general conclusions drawn? Does the research report the sample size and the statistical procedures used? Were the data analyzed using methods that were appropriate for the task? Did the methods correspond to the nature and structure of the data? Did the research minimize alternative explanations for observed effects? Did the research findings present convincing documentation that the observed results were caused by the intervention? 15 P a g e

16 3. Reliable and valid data collection Did the data result from a study involving multiple investigators in a number of locations? Were research biases minimized? Were the data measured consistently? Did repeated measurements on subjects taken under similar circumstances produce similar results? 4. Strong research design Does the design describe a random assignment experiment in which subjects are assigned to different conditions with appropriate controls? Do the controls allow for the evaluation of the condition(s) of interest? Was the study designed to optimize the investigator's ability to answer the research question? 5. Detailed results that allow for replication Are the findings clearly described and reported? Are the results of the research sufficiently detailed so that replication of the design is possible? Can the findings be enhanced with additional research? 6. Results subjected to scrutiny Has the research been accepted by a peer-reviewed journal or approved by a panel of independent experts? Has the research been reviewed by unbiased experts who were not a part of the research study? Have reviewers applied strict standards of scholarship and provided quality controls for the research they reviewed? Has the research been subjected to external verification? SBR Documentation Prior to including any vendor based programs in a grant proposal, the district must determine evidence of scientifically based research (SBR) for the program. The form included below should be completed by the vendor and on file with Education Support and the Purchasing Department prior to submission of the grant proposal. 16 P a g e

17 Determining Evidence of Scientifically Based Research Program/Instructional Material To maintain compliance with the No Child Left Behind Act of 2001, all activities and programs should be supported by Scientifically Based Research. Scientifically Based Research involves the application of rigorous, systematic, and objective procedures to obtain reliable and valid knowledge relevant to education activities and programs. This form is to be completed by the company representative and submitted to the Purchasing Department prior to the purchase of the program. The program manager/principal is to verify that YES is checked at least once in each section for the research of the activity/program to be considered scientifically based. Additionally, the program manager/principal is to verify the research data show the program to be effective. A. SYSTEMATIC AND EMPIRICAL METHODS YES NO Does the research have a solid theoretical foundation? Were methodology, subject, and researcher clearly identified? Was the study conducted in a consistent, disciplined, and methodical manner? Were the data obtained using observation or experiment? Was the research grounded in data that are factual rather than opinion-based? Are the research findings supported by tangible, measurable evidence? B. RIGOROUS DATA ANALYSIS YES NO Did the research test the stated hypotheses and justify the general conclusions drawn? Did the methods correspond to the nature and structure of the data? Did the research minimize alternative explanations for observed effects? Did the research findings present convincing documentation that the observed results were caused by the intervention? C. RELIABLE AND VALID DATA COLLECTION YES NO Did the data result from a study involving multiple investigations in a number of locations? Were research biases minimized? Were the data measured consistently? Did repeated measurements on subjects taken under similar circumstances produce similar results? D. STRONG RESEARCH DESIGN YES NO Does the design describe a random assignment experiment in which subjects are assigned to different conditions with appropriate controls? Do the controls allow for the evaluation of the condition(s) of interest? Was the study designed to optimize the investigator s ability to answer the research question? E. DETAILED RESULTS THAT ALLOW FOR REPLICATION YES NO Are the findings clearly described and reported? Are the results of the research sufficiently detailed so that replication of the design is possible? Can the findings be enhanced with additional research? F. RESULTS SUBJECTED TO SCRUTINY YES NO Has the research been accepted by a peer-reviewed journal or approved by a panel of independent experts? Have unbiased experts who were not a part of the research study reviewed the research? Have reviewers applied strict standards of scholarship and provided quality controls for the research they reviewed? Has the research been subjected to external verification? The undersigned verifies that the research methodologies for the activity/program listed above are true and accurate. Company Representative s Signature Date Purchasing Department: Keep copy on file for 7 years for audit purposes. 17 P a g e

18 Supplement vs. Supplant The purpose of the fiscal requirement of supplement, not supplant is to ensure that the level of state and local support for programs remains at least constant and is not replaced by federal funds. Documentation must be maintained which clearly demonstrates the supplemental nature of grant funds and/or activities, as appropriate. Federal funds may not be used to provide services required by state law, State Board of Education rule, or local policy. General funds may not be diverted for other purposes because of the availability of supplemental federal funds. Campuses and departments receiving federal funds, such as Title I, Part A, must document that all expenditures are planned for supplemental services. Documentation begins with the Comprehensive Needs Assessment and the resulting Campus Improvement Plan entries for these funds. The same documentation is required at the district level for any reserved funds. To determine whether supplanting will occur, ask whether the service or material would, in the absence of supplemental funds, have been supported with state or local funds. If you did not have supplemental funds, would you still buy/pay for (service/material)? If you did not have Title I funds, would you still buy student desks for each regular classroom? If you did not have Title I funds, would you still purchase the XYZ software package for your program? Does the state or the district require this (service/material)? Did we buy this last year with state or local funds? If the answer is YES, this is supplanting. State and local funds which previously funded activities cannot be diverted to another purpose simply because grant funds are available to support those activities. If the answer is NO, the funds are being used to supplement the educational program. Assume that state law requires GPISD to provide at least five hours of classroom instruction each semester on conflict resolution to all ninth grade students. Because GPISD is required to provide the five hours of instruction from its own resources, regardless of the existence of other supplemental funds, GPISD may not use supplemental funds to comply with the state mandate. Supplemental funds are intended to supplement state and local expenditures; they are not intended to replace state or local funds that would have been spent for the purposes in the absence of supplemental funds. The supplemental funds could be used to supplement the expenditure of state and local funds for instruction on conflict resolution to ninth grade students and to expand programs and services beyond the level that would be provided in the absence of supplemental federal funds. The supplemental funds could not be used to provide the five required hours of instruction. Suppose that TEA requires all teachers to participate in a minimum number of in-service professional development days each year. Would a local education agency s use of Title II, Part A funds to pay for some of this state mandated professional development in order to free up local funds for other discretionary district initiatives violate the statute s supplement, not supplant requirement? Yes. The program s supplement, not supplant provision requires that Title II, Part A Improving Teacher Quality funds be used only to supplement the training program activities provided with state and local funds. This provision prohibits a local education agency from using federal funds to pay for activities that, in the absence of these program funds, would be provided with state and local funds. Federal funds may be used to fund only the professional development activities that supplement those mandated by state law or district minimum requirements for all teachers. 18 P a g e

19 For more detail about supplement vs. supplant, see the discussion in the A-133 compliance supplement at Page 14. Staff Development Professional development and training opportunities are supported by No Child Left Behind, P.L Many other funded programs and all major Titles of NCLB also require professional development and training. It is important to note that neither Title II nor any other grant funded program can pay costs associated with state or locally required training. That would constitute supplanting. Supplemental funds must be used to provide supplemental training. Professional development and training may include activities that do the following: Improve and increase teachers knowledge of the academic subjects taught to enable teachers to become highly qualified as defined by federal legislation. Address supplemental strategies noted in the Campus Improvement Plan or the District Improvement Plan. Give teachers, principals and administrators the knowledge and skills to provide students, including those at-risk of dropping out and with special needs, the opportunity to meet or exceed challenging state standards for content and student achievement. Provide strategies to address the needs of students who are Limited English Proficient, including the use of appropriate curricula and assessments. Provide strategies to address special needs students, including the use of appropriate curricula and assessments. Improve classroom management skills. Advance teacher understanding of instructional strategies based on scientifically based research programs. Provide alternate routes for teacher certification. Provide practice in the use of technology applications in the classroom. Provide instruction in the use of data and assessments to inform and instruct classroom practice. Provide strategies for teachers, principals and staff to work more effectively with parents. Coordinate training programs with local institutions of higher education. Professional development and training activities must be high quality, intensive, classroom focused and ongoing. Staff development strategies must be regularly evaluated for their impact on improved leadership, teacher effectiveness, parent involvement and improved student achievement. 19 P a g e

20 SECTION THREE: Grant Financial Management and Accounting Internal Controls GPISD must ensure grantors that internal controls are in place to manage grant funds. These internal controls provide reasonable assurance that grant funds are expended only for allowable activities and that the costs of goods and services are allowable and in accordance with applicable cost principles. Federal regulations define five components of internal control. GPISD strives to exemplify these five components. 1. Control Environment GPISD administrators exhibit respect for and adherence to program compliance requirements. Key campus and department managers are required to attend annual training and information sessions regarding the compliant implementation of grant programs such as Title I, Part A and IDEA as well as competitive grants. Key managers are given the responsibility to communicate all instances of noncompliance to central program managers in Education Support and Finance. 2. Risk Assessment Procedures are in place to identify and analyze risks relevant to the achievement of grant objectives. During annual training and information sessions, identified risks are discussed for better management of these risks. Key compliance objectives are clearly defined. Potential risks such as new employees responsible for implementing grant programs are reviewed. The amendment process is in place to implement changes in program objectives and procedures as needed and allowed. 3. Control Activities GPISD ensures the adequate separation of duties for program performance, program review and program accounting. Current activities include periodic budget and expenditure report reviews with key managers, program managers and accounting managers. Additional control activities include the annual training and information sessions and equipment inventories. 4. Information and Communication GPISD processes and procedures are defined to ensure effective information and communication. The Grants Management Manual and Business Operations Handbook communicate basic information for grant applications, implementation and management. Timely budget and expenditure reports are provided electronically to key managers. Reconciliations and reviews are implemented to ensure report accuracy. Key managers are responsible for communicating any improprieties to the central program manager, the assigned Executive Director from Education Support. The central program manager is responsible for appropriate action to correct noncompliant activities or expenditures. The central program manager is responsible for reviewing purchase requisitions for compliance. 5. Monitoring Program monitoring is in place for campuses and departments receiving grant funds. Periodic budget and expenditure report reviews address program implementation progress and identify risks to compliance. These reviews may also identify the need for an amendment. Central program managers meet with program and financial auditors as required. Corrective actions are taken as identified. GPISD maintains a financial management system that provides for accurate, current, and complete disclosure of the financial results of each grant project. The financial management system records adequately identify the source and application of funds and contain information pertaining to grant awards, authorizations, obligations, unobligated balances, assets, outlays (i.e., expenditures), income, and 20 P a g e

21 interest. Fiscal control and accounting procedures permit the tracking of funds to a level of expenditure adequate to establish that funds have been used in accordance with the approved grant application. GPISD maintains effective control over and accountability for all funds, property, and other assets. TEXAS EDUCATION AGENCY FINANCIAL ACCOUNTABILITY SYSTEM RESOURCE GUIDE Update 15 The purpose of financial accounting and reporting by state and local governmental entities is to accumulate and provide information to facilitate decision making by various user groups. Certain requirements have been established for school districts to maintain proper budgeting and financial accounting and reporting systems. In addition, principles and policies to ensure uniformity in accounting have been developed. Budget Code Structure Budget development for grant applications follows a standardized budget code structure. For a full explanation of the budget code structure refer to the GPISD Business Operations Handbook. A budget line code consists of a series of nine categories and a total of 21 numbers. 21 P a g e

22 The most basic components of the budget code structure utilized with most grant applications are the fund code, function codes and object codes, the first three categories in the graphic above. A three digit fund code is assigned to every grant or entitlement received by GPISD. The most commonly used fund codes in GPISD are 199 for general funds (not from grants), 211 for Title I Part A funds, 224 for IDEA-B Formula and 244 for Career and Technology funds. The second set of digits in the line code denotes a function code that shows the particular focus of the funds budgeted in that line code. These function codes are used for general operating funds, not from grants, also. These same functions describe supplemental expenses from grant funds. The most commonly used function codes for supplemental expenses from grant funds are: Function 11: Instruction Notes funding for activities that deal directly with the interaction between teachers and students: teachers salaries, classroom instructional materials, science laboratory supplies, etc. Function 12: Instructional Resources Notes funding for resource centers, libraries and other facilities dealing with educational resources and media: library books, online databases for research, video library CDs, etc. Function 13: Curriculum and Staff Development Notes funding for expenses specifically related to planning, developing and evaluating the processes of teaching and learning: training session materials, extra-duty pay for supplemental training, supplies for developing and providing training sessions, etc. Function 21: Instructional Leadership Notes funding for expenses related to central management: part time program supervisor salary, supplies for documentation and record keeping, etc. Function 23: School Leadership Notes funding for expenses related to campus management: extra duty pay for a teacher working on management activities like reports for parents or auditors, supplies for documentation and record keeping, etc. Function 31: Guidance, Counseling and Evaluation Notes funding for expenses such as assessment tools, supplies for occupational counseling activities, etc. Function 32: Social Work Notes funding for expenses directly related to activities such as casework and group work services for the child, parent or both, interpreting the social needs of students for other staff members and truant/attendance officers, etc. Function 33: Health Services Notes funding for expenses for direct health services, not health instruction. Function 34: Student (Pupil) Transportation Notes funding for transporting students to locations for teaching and learning activities. 22 P a g e