ARP Maintenance of Equity Test
Note: CSS is re-running this Tip from November because MOEquity testing was delayed by TEA, and now is up and running again.
We are seeing red this February –red tape that is! The extra COVID funds sure are nice, but with them comes extra reporting. CSS has another compliance 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: March 4, 2022 for Qualtrics Survey; March 11, 2022 Excel file, if required (by 5PM Central for both deadlines)
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. Did you receive any of the funds bulleted below? 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.
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 March 4, 2022 (5:00 PM). This may be all you have to submit if you can attest that your LEA “will not implement an aggregate reduction in combined State and local per-pupil funding” in the 2021-22 school year (FY22 as compared to FY21). If you can attest (self-certify) to this fact – that your LEA is not facing overall State/local budget reductions – then the Qualtrics survey will be your only requirement. If your Charter District DID in fact have State/local per-pupil reductions, you must continue.
Note: When comparing budget year data, you must use your Board-adopted budget in effect at the PEIMS snapshot date on FY21 and FY22.
Our charter district had State/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 March 11, 2022 at 5 PM.
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.
- A video of the Feb 7, 2022 updated training will be posted on the TEA YouTube channel located here: https://www.youtube.com/playlist?list=PLYCCyVaf2g1tZei97d_h5FeRXIK_1oCps
Who can I contact with questions?
- Sharon Benka, Federal Programs Director:
- Jean Cornelius, Federal Programs Manager:
- Natalie Guerra, Federal Programs Manager:
- Dr. Sheila K. Sherman, Federal & Special Programs Manager: