Fiscal Monitoring

The Oregon Department of Education, as part of receiving IDEA Part B funds, is required to monitor subrecipients' fiscal responsibilities under the following authorities:

• IDEA Title 34 Code of Federal Regulations Part 300
• 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements
• Education Department General Administrative Regulations (EDGAR) 34 CFR Part 76 State-Administered Programs

Fiscal monitoring is carried out through, but not limited to, fiscal risk self-assessments, IDEA Part B Maintenance of Effort, the IDEA Excess Cost report, Electronic Grants Management System (EGMS) claim documentation, single audits, LEA budget reports, field reviews, and desk audits.

IDEA Fiscal Risk Self-Assessment

The fiscal risk self-assessment is an annual form included with and completed at the same time as the LEA IDEA Application for funds. This form is intended to alert the LEA to any potential risks in its fiscal practices and to assist ODE in determining the fiscal monitoring level an LEA may need. 

Risk Based Monitoring

The risk-based monitoring method will be used on an on-going basis. The IDEA Part B Administrators will perform an annual risk assessment of all LEAs and sub recipients receiving IDEA Part B 611 & 619 Funds. A fiscal risk assessment form (Appendix III) will be completed annually. This score sheet consists of indicators and graded rubrics using several metrics in line with federal compliance requirements, generally accepted accounting principles, and internal control best practices.

Any LEA identified as “high risk” for the fiscal compliance and accountability requirements will be subject to review and analysis of the high-risk indicators and the top 10% of the high-risk category will be considered for Focused Fiscal Monitoring. The ODE will notify the LEA of the noncompliance, identifying the level of noncompliance and the required actions to correct the noncompliance.

IDEA Maintenance of Effort (MOE)

With only a few exceptions, IDEA Part B funds allocated to districts and LEAs each year cannot be used to reduce the level of expenditures from state funds (general fund maintenance and operations expenditures) for special education made by the LEA below the level from the previous fiscal year (34 CFR §300.203). MOE must be maintained through both eligibility (i.e., budgeted expenditures) and compliance (i.e., actual expenditures) standards.

The Eligibility requirement can be met if the LEA budgets, for the coming fiscal year, at least as much as it expended in the last year it met MOE compliance. The eligibility requirement is collected and reviewed during the IDEA Application process.

The Compliance requirement can be met if the LEA expended in the most recently audited fiscal year an amount equal to or greater than the amount it expended in the last prior fiscal year it met MOE compliance. MOE compliance is collected and reviewed annually between April and October.

IDEA Excess Costs

Excess costs are those costs for the education of an elementary school or secondary school student with a disability that are in excess of the average annual per student expenditure in an LEA during the preceding school year for an elementary school or secondary school student, as may be appropriate. An LEA must spend at least the average annual per student expenditure on the education of an elementary school or secondary school child with a disability before funds under Part B of the Act are used to pay the excess costs of providing special education and related services (34 CFR §300.16).

Data on Excess Cost is reported to the ODE through an annual data collection which opens in January and closes in March.

Coordinated Early Intervening Services (CEIS)

CEIS are services provided to students in kindergarten through grade 12 (with a particular emphasis on students in kindergarten through grade three) who are not currently identified as needing special education or related services, but who need additional academic and behavioral supports to succeed in a general education environment.

Schools should be aware of the connections between the typical uses of CEIS and the mandatory use of CEIS if a district is found to be significantly disproportionate. Please see this chart [pdf, 147 KB] developed by the IDEA Data Center (IDC) comparing the primary differences.

The CEIS data collection is managed by the IDEA data team. Details about the collection, including manuals, guides, and frequently asked questions can be found on the collection's web page.

Private School Proportionate Share

Every year each LEA must expend a proportionate share of federal IDEA funds on equitable services for parentally placed private school children with disabilities. Each LEA must, after timely and meaningful consultation with representatives of parentally placed private school children with disabilities, determine the number of parentally placed private school children with disabilities attending private schools located in the LEA.

Through the Private School Data Collection, LEAs report on the private schools in their area, the number of children enrolled in those schools, and the timely and meaningful consultation the LEA had with those schools. Please see the Private School Data Collection web page for user guides, overviews, and frequently asked questions.

General IDEA Fiscal Principles

Use of IDEA Funds

IDEA funds must only be used to pay for the excess costs of providing special education and related services to children with disabilities. To determine if a cost is allowable, the ODE relies on the Uniform Grant Guidance (UGG) at 2 CFR §§ 200.403 - 405. Costs must be necessary, reasonable, allocable, and adequately documented.

Allowable Cost Test

Obligation of IDEA Funds

It is important to understand that “obligated" does not necessarily mean “spent".

Obligation occurs when the non-Federal entity has entered into a binding commitment to pay out money, such as entering into a contract to pay for supplies or services (34 CFR § 76.707).

Obligations means the amounts of orders placed, contracts and subgrants awarded, goods and services received, and similar transactions during a given budget period that will require payment by the grantee during the same or a future budget period.

When Does an Obligation Occur?

The point in time when an obligation occurs depends on the type of property or services for which the obligation is made. The following table illustrates when an obligation that is directly charged is considered to occur (i.e., to be made) for various kinds of property and services: