IDEA MAINTENANCE OF EFFORT (MOE)
LEAs have the responsibility to meet eligibility and compliance standards for IDEA Maintenance of Effort (MOE). This involves ensuring proper funding levels and passing specific tests to receive IDEA funding without financial penalty. Learn about the methods to determine eligibility, compliance requirements, allowable exceptions, and the High-Cost Fund in special education.
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Presentation Transcript
IDEA MAINTENANCE OF EFFORT (MOE) LEA Responsibility to meet the Eligibility and Compliance Standards
LEA MAINTENANCE OF EFFORT Supplement not Supplant IDEA No Specific Cost Test CRP Application Process - LEAs Sign Assurance Statement that they will comply with the IDEA MOE requirements
IDEA (2) MOE STANDARDS ELIGIBILITY COMPLIANCE Test found within CRP (IDEA Part B) Application in AcceleGrants Test found as Performance Report in AcceleGrants Focus on Expenditures Focus on Budget Must pass avoid financial penalty Must pass to receive IDEA funding
4 METHODS TO DETERMINE ELIGIBILITY AND COMPLIANCE *Aggregate - Local funds only; Aggregate - The combination of State and Local funds; *Local funds only on a per capita basis; or The combination of State and Local funds on a per capital basis. 1) 2) 3) 4) * Use of district s State & Local revenue data to extrapolate local special education expenditure amount.
COMPLIANCE REQUIREMENT LEA must meet/pass at least one of the four test methods in order to be in compliance. Failure to meet the MOE compliance standard will result in the required payment by the LEA of non-federal funds in the amount of the failed measure that results in the smallest payback of the four failed MOE compliance measures. Financial penalty can not exceed the LEA s combined IDEA Part B and Preschool allocation for the FY of the failed compliance.
ALLOWABLE EXCEPTIONS Assumption of cost by the high cost fund operated by the SEA (RIDE). 1) Voluntary departure, by retirement or otherwise, or departure for just cause of special education or related services personnel. 2) Acquisition of high cost equipment. 3) Student(s) with disabilities that incur an exceptionally costly program, either leave the district, graduate, ages out, or no longer needs the special education program. 4)
HIGH COST FUND Use the amount from the state aid special education high cost categorical aid. Use the amount from comparison year For FY 2015 Test This is the FY 2014 state aid amount in this category to your LEA.
DEPARTURE OF PERSONNEL Departure must be voluntary or for cause Departure must be permanent (not on leave). Departure cannot be a reduction in work force. Allowable Exception is the amount of savings generated from an employee leaving (in comparison year) as compared to the cost the vacancy filled (if applicable) in year being tested. Must provide details on RIDE provided worksheet.
ACQUISITION OF EQUIPMENT Per unit cost must be at least $5,000.00 Must provide details on RIDE provided worksheet. UCOA Accounting Code Date of Purchase Item Description Total Cost of Item Asset tag Number
EXCEPTIONALLY COSTLY PROGRAM High Cost Special Education Student that either leaves the district, graduates, ages out, or no longer needs the special education program. RIDE sets threshold for high cost program Currently approximately $50,000.00 Must provide details on RIDE provided worksheet. SASID Date of Departure Reason for Departure Exit Code (If Applicable) Total Cost to Educate
VOLUNTARY REDUCTION OF MOE (50% RULE/ALLOWED ADJUSTMENT) Similar to an allowable exception, can reduce MOE level. By up to 50% of increase in an LEA s IDEA Part B (Section 611) allocation. To be eligible, an LEA must not required to reserve 15% of its IDEA allocation for Coordinated Early Intervening Services (CEIS) in the MOE Test Year. Voluntary CEIS expenditure will reduce or eliminate amount of allowed adjustment.
SUBSEQUENT YEARS RULE Level of effort an LEA must meet in the fiscal year after it fails to maintain effort is the level of effort that would have been required in the absence of that failure, not the LEA s actual reduced level of expenditures! The subsequent years rule applies individually to all four compliance methods that LEAs may use to meet this standard.
SUBSEQUENT YEARS RULE ILLUSTRATION WITHOUT USE OF EXCEPTIONS OR ADJUSTMENT Actual Level of Effort Required Level of Effort FY 2013 2014 2015 2016 2017 $100 $90 $90 $95 $100 $100 $100 $100 $100 $100 LEA has not met the MOE compliance requirement in 2014, 2015, and 2016 for this measure.
SUBSEQUENT YEARS RULE ILLUSTRATION WITH USE OF EXCEPTIONS AND/OR ADJUSTMENT Actual Level Required Level of Effort FY of Effort after exceptions & Adj. 2013 2014 2015 2016 2017 $100 $90 $90 $95 $100 $100 MOE met $100 MOE not met $85 MOE met with use of $15 exception $90 MOE met $95 MOE met For the 2015 compliance test the LEA utilizes $15 of allowed exceptions to reduce the calculated 2014 MOE threshold from $100 to $85 ($100 minus $15). The 2016 MOE compliance threshold becomes $90 which is the higher of the two 2015 amounts ($90 actual and $85 adjusted).
POINTS TO PONDER RIDE recommends that LEAs utilize the allowable exceptions if any of the 4 MOE test methods are not met. Use the subsequent year s rule to your advantage! RIDE recommends that at the end of each SFY before close-out, complete a preliminary test of IDEA MOE compliance. Complete Excel Version of MOE Test Why? It s a good review for UCOA coding errors! May want to consider moving IDEA expenses to local funds to cover MOE shortfall.
FY 2015 LEA MOE COMPLIANCE TEST If an LEA received IDEA funds in FY 2015, then the MOE Compliance Test must be completed. Performance Report FY 2015 LEA s must use their SFY 2015 Final, Audited, Adjusted and Allocated UCOA Data file received from RIDE. RIDE will be emailing these files to LEAs soon. Comparison SFY 2014 data will be preloaded by RIDE. Work Flow -> Draft Not Started, Draft Started, Draft Completed, District Business Manager Approved. If Applicable - Complete and Upload Allowable Exceptions Worksheet into Related Docs Page. Report is Due 30 Days after UCOA data file is received from RIDE. Completed 2015 MOE Compliance Test establishes the 2016 thresholds for the 4 compliance methods!
