IDEA-B Maintenance of Effort (MOE) Compliance
TEA has calculated IDEA-B LEA maintenance of effort (MOE) compliance reviews for school year 2018–2019.
What is IDEA-B Maintenance of Effort (MOE)?
MOE is a federal requirement that affects how an LEA (i.e. Charters) budgets and spends their state and local funds on special education students. Charter School Success helps our charter school clients in both the budgeting and monitoring process with this compliance check. This helps ensure that the charters are maintaining fiscal effort for their special education population.
What does using IDEA-B federal funds have to do with IDEA-B MOE?
With the help of our Federal Grant Specialist, CSS assists in the guidance and application process of IDEA-B federal funds and if a Charter is awarded, applies, and uses IDEA-B federal funds (Fund 224), it is required to maintain the same or more effort from the previous year from state and/or local funds (Fund 199/420).
Be on the lookout for our IDEA-B Maintenance of Effort (MOE) webinar coming soon!
What does “maintain the same or more effort” mean?
It means that the charter is required to spend/expend/code to program intent code (“PIC”) 23/33 the same or more from state and/or local funds (fund 199/420) from one fiscal year to the next. Or to put it another way, before you can use the federal funds in 224 for an expenditure, you have to show you have spent/coded the same or more from fund 199/420 to PIC 23/33. Especially during this time of year as budgets are being prepared for the next school year, CSS works to ensure that this level of effort is budgeted to help ensure compliance annually. In our back-office processing (and throughout the year since we helped with the budget), we also help in ensuring items are properly coded to maintain compliance.
Compliance is met if total dollar amount meets or exceeds the previous year, OR the dollar spent per special education student (total dollars/SPED student) is equal to or greater than the previous year. For our CSS clients, we monitor these numbers quarterly and then annually to ensure compliance.
Does MOE apply to charters in a shared service arrangement (SSA)?
Yes, it still applies. Your fiscal agent will still need the answers to the above questions from each LEA under the SSA. When the fiscal agent completes the BS6016, they will have a drop-down for each LEA in the SSA and will enter in your charter’s answers to the above four questions to determine eligibility.
How is compliance measured?
For our CSS clients, preliminary and final compliance reports are reviewed for accuracy. Compliance is completed after final reporting has been submitted to TEA via your Mid-Year PEIMS submission for the previous year in January. TEA will begin calculating compliance and issue preliminary and final reports in the spring of the following fiscal year. (Example: The 2018-2019 Mid-Year PEIMS reporting will be submitted January 2020, and the preliminary report and final report will be issued in Spring 2020 comparing last compliant year to 2018-2019 audit data.) Your current compliance can be found in your GFFC Reports & Data Collections in your TEASE account.
When will the 2019-2020 IDEA-B Preliminary Maintenance of Effort results be issued?
The 2019-2020 IDEA-B Preliminary Maintenance of Effort results are anticipated to be released in April 2021. LEAs will access the reports through the secure GFFC Reports and Data Collections application. For our CSS’s back-office & reporting clients, we first build a budget to meet compliance at the start of the year, then monitor this on a quarterly basis so it is not a surprise when the preliminary and final reports are issued starting in April 2021.
What happens if I am NOT in compliance with MOE? What can I do?
When preliminary reviews are released, the 2019-2020 Exceptions/Adjustment Workbook will also be available in GFFC Reports and Data Collections and on the IDEA-B LEA MOE page of the TEA website. LEAs will have five business days from the date the 2019–2020 preliminary IDEA-B LEA MOE compliance reviews are published in GFFC Reports and Data Collections to submit any of the following:
- Applicable federal statutory exceptions
- Adjustment to fiscal effort
- Local methodology with supporting documentation for validation and approval in the final calculation
To help LEAs ensure they are prepared to respond within the required five business days, TEA encourages LEAs to begin reviewing and compiling any documentation planned to be submitted to TEA when the Exceptions/Adjustments Workbook becomes available.
Does MOE apply to new charters?
It is required when the Charter begins to use federal IDEA-B funds (Fund 224). For CSS clients, who have not used IDEA-B funds in the past or are new charters, we help in establishing and monitoring for future compliance. As we do with our clients, we highly encouraged that you budget and code conservatively and appropriately the first year, as it sets the level of spending or MOE you will need to maintain for future years.
Where can I find guidance to ensure maintenance of effort compliance?
For TEA information on Maintenance of Effort (MOE) Compliance, click here.
Need More Training?
Email Kari Hoefnagels, Finance Director, who helps Charter School Success clients with budgeting and monitoring compliance.