ARP Maintenance of Equity Test
The extra COVID funds sure are nice! But with them comes extra reporting. It’s kind of like those bills after Christmas. You probably haven’t had time to finish Title I Comparability Testing yet, and CSS has another test to warn you about that is called “MOEquity.” This is NOT to be confused with Maintenance of Effort (MOE is an acronym that was already taken in the SPED arena). The good news is that many Charters will be exempt, and no action will be required. Read on to see if you must complete the MOEquity reporting.
SUBMISSION DEADLINE: Dec. 3, 2021 for Qualtrics Survey; Dec. 10, 2021 Excel file, if required
The CSS federal team helps our clients sort through the numerous compliance testing requirements whether they be related to Title I or ARP funding.
What is the purpose of the MOEquity requirement?
MOEquity is intended to help ensure that LEAs and campuses that serve a large share of students from low-income backgrounds do not experience a disproportionate reduction in funding in fiscal years 2022 and 2023 (FY22 and FY23), that is, school years 2021–2022 and 2022–2023. (Yes, this means it will have to be done again next year.)
In addition, MOEquity is designed to ensure that LEAs serving the largest shares of students from low-income backgrounds do not receive a decrease in state funding below their FY 2019 level.
We got COVID money, but are we exempt from MOEquity testing?
First, let’s clarify the funding that is triggering the MOEquity requirement. The following grants that were all a part of the American Rescue Plan (ARP) of 2021 are the fund sources that are involved:
- 2020–2023 ARP ESSER III
- 2021–2023 ESSER Supplemental (ESSER-SUPP)
- 2021–2024 Texas COVID Learning Supports (TCLAS)
Second, check the published list of LEAs that are exempt from MOEquity testing. https://tea.texas.gov/sites/default/files/2021-2022-moequity-automatically-exempt-leas-by-lea.pdf
LEAs with certain criteria are automatically exempt, and NO FURTHER ACTION is required:
- LEA enrollment is less than 1,000 students
- Single campus LEA
- Multiple campuses, but no grade span overlap
- LEA was not in operation in the 2020-21 school year
If your LEA is NOT listed on the above link as exempt, please keep reading.
We are not exempt, now what?
If your LEA is not exempt, at a minimum you will need to submit the MOEquity Document Submission Plan, in the form of an online Qualtrics survey, no later than December 3. This may be all you have to submit if you can attest that your LEA will not implement a reduction in aggregate local per-pupil funding in the 2021-22 school year. If you can attest (self-certify) to this fact – that your LEA is not facing overall local budget reductions – then the Qualtrics survey will be your only requirement. If your Charter District DID in fact have local per-pupil reductions, you must continue.
Our charter district had local per-pupil funding reductions, we cannot self-certify, what do we do?
An LEA that is not automatically exempt and cannot self-certify its MOEquity compliance has two options remaining.
- Apply to the USDE for a waiver, or
- Calculate and submit proof of equity using the MOEquity Tool (The MOEquity Tool is available for download within TEAL in the secure GFFC Reports and Data collection application).
In short, to “pass” the calculation, you must demonstrate that your reductions were not greater at your highest poverty campuses. The Excel tool will perform the calculations, and the tool (Excel file) must be passing and loaded in GFFC in TEAL by December 10.
If you have gotten this far, this is where it really gets in the weeds, and CSS highly recommends reading the MOEquity Handbook located on the MOEquity Website AND watching a training video listed below.
Please refer to the TEA ARP Local Maintenance of Equity Requirement Website that includes links to guidance documents, forms, and training resources on every aspect of MOEquity testing.
Zoom Training Dates/Times (content in each session is identical):
- November 9, 2021, from 10:00–11:30 AM – Register (NEW!)
- November 12, 2021, from 11:00 AM–12:30 PM – Register
- November 17, 2021, from 1:30–3:00 PM – Register
Who can I contact with questions?
- Sharon Benka, Federal Programs Director:
- Jean Cornelius, Federal Programs Manager:
- Dr. Sheila K. Sherman, Federal & Special Programs Manager:
Want to discuss?