What Are the Fiscal Responsibilities of Part C State Interagency Coordinating Councils?

State Interagency Coordinating Councils (ICCs) advise the state lead agency (LA) and help it meet the fiscal requirements under IDEA Part C. To do this, ICC members and state LA staff must understand and engage with each other about the regulations and how they translate into practice. This CIFR quick reference guide provides a foundational understanding and examples of the ICC’s role to advise and assist.

A new toolkit developed by the Early Childhood Technical Assistance (ECTA) Center in collaboration with CIFR and the Center for Early Childhood Data Systems (DaSy) helps states plan and implement Part C fiscal monitoring at the state and local early intervention system levels. It includes state Part C fiscal indicators, a checklist, and a template as well as sample EIS-provider fiscal monitoring indicators and considerations for developing them.

Until passage of the Consolidated Appropriations Act of 2021, states were prohibited from subgranting for the provision of early intervention services. Now that they may, with certain restrictions, a new guide from CIFR helps lead agencies understand the differences between a contract and a subgrant and decide whether to pursue subgranting and why.

 

This updated practice guide from CIFR helps state staff develop effective data notes to respond to LEA allocation, MOE reduction, and CEIS data warnings and data quality inquiries from OSEP. The guide helps Part B fiscal specialists understand OSEP’s data quality review process and provides examples of inadequate and exemplar data notes for two common warning messages. Contact your state TA liaison for assistance.

 

The IDEA Part C grant cycle has several stages and timelines. CIFR’s Understanding the IDEA Part C State Grant Funding Cycle and Different Fiscal Years helps Part C coordinators and fiscal staff understand each stage and visualize how they overlap across years. This new graphic-based guide demonstrates the timeline for each stage to help lead agencies ensure that each grant is fully obligated and expended by the end of the grant cycle.

 

CIFR’s newest quick reference guide helps SEA and LEA staff understand the requirements of the LEA MOE adjustment under IDEA. Questions and answers highlight the fiscal requirements, with calculation examples and suggested processes for SEAs to monitor the funds freed up by the adjustment.

 

 

In 2022, CIFR’s second round of four CoPs brings together state staff with shared interests in IDEA Part B fiscal issues:

• Coordinated Early Intervening Services (CEIS),
• IDEA Allocations to LEAs,
• LEA Maintenance of Effort (MOE), and
• New State Fiscal Staff.

Facilitated by CIFR staff, CoPs will meet monthly for 1 to 2 hours through November, depending on the needs and interests of participants. Each CoP will explore practical concerns and solutions for the topic of interest and will allow for discussion and questions about additional issues that address the needs of state participants. By meeting the networking and learning needs of state staff and tackling problems of practice, CoPs help improve the quality of states’ implementation and reporting around of IDEA Part B fiscal requirements.

State staff with IDEA fiscal responsibilities should register for as many CoPs as they have the time and interest to commit to. Please register to join us at the introductory sessions below! Members will set future dates at these kickoff meetings. Register here.

Upon registering, watch for a confirmation email from CIFR. The facilitator of the CoP(s) that you signed up for will contact you to coordinate your participation.

New State Fiscal Staff CoP: January 25, 4:00–5:30 (ET)

Are you new to IDEA fiscal work within the past 18 months? This CoP will be guided by the IDEA Part B Fiscal Timeline and the Understanding the IDEA Grant Funding Cycle and Different Fiscal Years resource. The focus will be on what states should be working on at any given time to meet IDEA fiscal requirements. New-to-fiscal staff will learn how to navigate the CIFR website and see demonstrations of CIFR’s most popular resources and tools. Most importantly, the CoP will respond to participants’ questions about the when, why, and how of meeting IDEA fiscal requirements and provide opportunities and support for developing state processes. Here are examples of questions that will be addressed:

• What should I be working on now?
• What comes next?
• What questions should I be asking?
• What resources are available to help me answer these questions and guide me with my tasks?

Please note: If you were a member of the New to Fiscal CoP in 2021, we welcome you to continue with us in 2022.

Coordinated Early Intervening Services (CEIS) CoP: January 26, 3:00–4:30 (ET)

LEAs implementing CEIS, either voluntary or comprehensive, are experiencing unprecedented circumstances amid the COVID-19 pandemic while planning how best to use their supplemental IDEA funds provided through the American Rescue Plan (ARP) Act. This CoP will focus on how SEAs can help LEAs understand the fiscal implications of CEIS and support their strategic use. SEA staff will share specific situations, strategies, and resources they have developed for addressing CEIS challenges. Facilitators from CIFR and NCSI FST will review relevant resources. Sessions will cover:

• Fiscal implications
  • Spending funds during the availability period
  • Potential effects on LEAs meeting maintenance of effort
  • Monitoring
• Allowable costs for voluntary CEIS
• Potential allowable costs by areas identified for significant disproportionality for comprehensive and voluntary CEIS
• Coordinating fiscal, program, and data offices to assist LEAs in implementing comprehensive and voluntary CEIS plans.

LEA Maintenance of Effort (MOE) CoP: January 27, 1:30–3:00 (ET)

LEAs across the country received supplemental IDEA funds through the American Rescue Plan (ARP) Act, and some states have added or reduced LEAs’ funding for special education. This CoP will focus on how SEAs can help LEAs meet LEA MOE requirements or minimize failures amid the shifting funding landscape and the continuing impacts of the COVID-19 pandemic. State participants will share challenges experienced by LEAs and strategies or resources they have developed for addressing them. CIFR facilitators will highlight CIFR resources on LEA MOE. Sessions will cover:

• Calculating adjustments resulting from an increase in IDEA allocation, including eligibility requirements and the use of freed-up funds,
• Calculating the five exceptions to LEA MOE,
• State special education funding methodologies and how each method impacts the tracking and reporting of special education expenditures used for LEA MOE calculation,
• Challenges of tracking and identifying local funds’ sources for the purposes of MOE, and
• Short- and long-term impacts of state funding increases and reductions on an LEAs’ ability to meet the MOE requirement.

Allocations CoP: January 31, 2:00–3:30 (ET)

SEA participants will identify, share, and respond to IDEA Part B subgrant allocation challenges. The emphasis will be on how SEAs can refine practices and procedures to ensure accurate calculation and distribution of IDEA Part B subgrants to LEAs. Participants will collaborate with their peers on current topics in their IDEA fiscal work generally and share challenges and successes. Participants will engage in conversation and share resources and ideas in both whole and small group virtual settings and contribute to the identification of topics and agendas for the community. Anticipated session topics include:

• Considerations related to population and poverty amounts, including revising allocations to new and expanding charter school LEAs during the year,
• Potential reallocation of available funds to other eligible LEAs or use of available funds for other state-level activities,
• Base payment adjustments because of changes in LEAs, including charter school LEAs,
• Supplemental funding amounts provided by the ARP, and
• Other timely topics and problems of practice identified by participants.

If you are interested in signing up for one or more CoP, please register here.

If you have any questions or need further assistance with the CoPs, please contact your state TA Liaison or Lizann Salazar at lsalaza@wested.org.

Thank you,

CIFR Part B TA Staff

When charging indirect costs an IDEA Part C grant, states must do so through an approved restricted indirect cost rate or a cost allocation plan that calculates costs on a restricted basis. To inform lead agency staff about these provisions, CIFR developed the Quick Reference Guide on Restricted Indirect Costs and Cost Allocation Plans for IDEA Part C Grants.

This resource provides state Part C and finance staff with information about restricted indirect costs that may be charged to the Part C grant, the regulatory requirements for calculating costs on a restricted basis, and the approval process.

If you have any questions or need further assistance related to restricted indirect costs, please contact your state TA Liaison.

CIFR’s Quick Reference Guide on the Use of IDEA Part C Funds provides lead agency staff, policymakers, and stakeholders a high-level overview of regulatory requirements related to the state’s management of IDEA Part C funds.

With this guide, readers will learn about the permissive use of Part C funds and costs that require prior approval. The resource also provides a summary of key reporting obligations relating to the use of funds in the federal Part C grant application and raises questions for states to consider. The guide may be particularly useful to new staff as they better understand the fundamentals, leading to improved data collection processes and state management of IDEA funds.

This graphic-based resource presents a foundational view of how states reserve state funds and allocate IDEA Part B subgrants to LEAs. It describes the key formula components, such as state set-aside, base payments and base payment adjustments, as well as population and poverty calculations. The one-page at-a-glance format can be used to communicate with key stakeholders and policymakers as well as orient new state fiscal staff to the process of allocating IDEA Section 611 and Section 619 grants.