Developed in collaboration with OSEP and the Office of General Counsel, this guide from CIFR outlines key differences between contracts and subgrants for Part C, highlights questions for states to consider as they determine whether to pursue subgranting, and describes the initial steps of planning and decision-making.
Maintenance of Effort (MOE)
Letter to Moser and Kuester
This OSEP letter responds to questions about the consequences of MOE failure under Part C of the IDEA. It explains the state must pay back the amount by which it failed to maintain effort, that the state may not decline to draw down all of its federal IDEA Part C award funds to offset the amount of the failure, and that repayment must be made with non-federal funds or federal funds for which accountability to the federal government is not required.
Please also see Letter to Wilden.
Collecting and Tracking Maintenance of Effort Data
This web-based resource is designed to assist lead agencies in establishing a process for annually collecting and tracking the budgeting and expenditures of state and local funds to determine if MOE is met for IDEA Part C. The resource provides an overview of the IDEA regulatory requirements for MOE, steps for developing a methodology for calculating and tracking MOE, answers to critical questions, and links to resources including an Excel-based MOE calculator.
This product was jointly developed by the Early Childhood Technical Assistance (ECTA) Center, the Center for IDEA Early Childhood Data Systems (DaSy), and the IDEA Infant & Toddler Coordinators Association.
Part C Fiscal 101 Modules: Federal Fiscal Requirements
The Early Childhood Technical Assistance (ECTA) Center developed 10 modules to help Part C lead agency staff understand the federal fiscal requirements associated with IDEA Part C funding as well as requirements that apply to all federal funding. Each module addresses a specific component of the fiscal requirements, providing an overview of each topic.
Module 4 covers use of funds, allowability and prior approval.
Module 5 covers the indirect cost requirements found in Subpart E of the Uniform Guidance and Sections III and IV of the state grant application.
Module 10 covers the MOE requirement, located in the supplement not supplant requirement under 34 CFR ยง 303.225(a)(2).
Letter to Willden
This OSEP letter clarifies the liability a state faces if it fails to meet the MOE requirement under Part C of the IDEA. It describes how the payback amounts are calculated when a failure occurs and explains how the state must pay back the amount by which it failed to maintain effort. The state may not decline to draw down all of its federal IDEA Part C award funds to offset the amount of the failure, and the repayment must be made with non-federal funds or federal funds for which accountability to the federal government is not required. Please also see Letter to Moser and Kuester.
Quick Reference Guide on Restricted Indirect Costs and Cost Allocation Plans for IDEA Part C Grants
The guide provides an overview of the IDEA requirements for restricted indirect costs that a state may wish to charge to its Part C grant. The guide reviews terminology and key concepts for understanding the components of the IDEA no-supplanting provisions that require indirect costs to be charged on a restricted basis. It includes questions for states based on their lead agency type and suggestions for helpful resources.
Quick Reference Guide on the Use of IDEA Part C Funds
This CIFR-developed reference guide provides an overview of the requirements regarding the use of federal IDEA Part C funds. The guide highlights the permissive use of funds and costs that require prior approval. It provides a summary of key reporting obligations relating to the use of Part C funds in the federal grant application and concludes with questions for states to consider and resource suggestions.
Finance Glossary
This glossary contains terms relevant to finance for IDEA Part C and Part B Section 619 programs. The terms include those related to IDEA and other related federal fiscal requirements as well as those specific to billing public and private insurance for IDEA services.
System Framework for Building High-Quality Early Intervention and Preschool Special Education Programs: Finance Component
The Early Childhood Technical Assistance Center (ECTA) and the Center for IDEA Early Childhood Data Systems (DaSy) developed a System Framework that details six components of a high-quality IDEA early childhood program. Each component includes indicators of quality and the elements that need to be in place to achieve each indicator. This web page reviews the Finance Component, its sub-components, and quality indicators which address strategic planning and forecasting; access and use of fiscal data; securing funds and resources; and the allocation, use, disbursement, and monitoring of funds.