Memo from Russell Johnston, IDEA Proportionate share calculations for FY18 and FY19

To:	Special Education Directors and School Business Officials
From:	Russell Johnston, PhD., State Director of Special Education
Date:	June 22, 2018

The Department of Elementary and Secondary Education (DESE) appreciates your ongoing efforts to provide equitable services to eligible students who attend non-public schools. DESE requires districts to submit proportionate share calculations and expenditure forms on an annual basis in order to document equitable services for parentally placed private school students. All districts are required to submit proportionate share forms with their grant application for Fund Code 240 (IDEA Part B funds for eligible students ages 3-21). The requirements for equitable services and proportionate share procedures are included in an advisory posted on our website, Administrative Advisory SPED 2018-1: Guidance and Workbook for Calculating and Providing Proportionate Share Services for Students with Disabilities Enrolled by Their Parents in Private Schools.

We anticipate the FY19 Fund Code 240 grant application ("240 funds") will be available in July. This memo will assist you in preparing the required proportionate share forms for submission with your district's FY19 240 grant application, which will include a recalculated FY18 form and the FY19 form. The instructions below apply to actions that you should take now, in preparation for submission of a complete and accurate grant application this summer.

Instructions:

Recalculate FY18 Fund Code 240 Proportionate Share

Districts received an opportunity to apply for an increase to their FY18 Fund Code 240 grant this spring. The increase resulted from changes to fiscal procedures that the DESE made at the direction of the US Department of Education. Going forward, supplementary funds may again become available during the year due to the revised procedures that require the DESE to set aside a small portion of IDEA entitlement funds until final allocations for all districts are determined later in the year.

The increase to the FY18 240 funds affected districts' overall entitlement amounts and, therefore, their proportionate share obligations. As a result, DESE is requiring all districts that claimed the increase to recalculate their FY18 Fund Code 240 proportionate share obligation based on their total entitlement amount, which includes this spring's increase. (See list)

To do so, use the digital copy of the FY18 proportionate share form you provided to the DESE as part of your FY18 Fund Code 240 application and revisit the tab entitled, "Part III Calculation." Locate Line D, and enter your full entitlement amount, which includes the recent increase. Line E will auto calculate and display the district's updated proportionate share obligation for FY18. This recalculated FY18 proportionate share form must be uploaded and attached to your FY19 Fund Code 240 application. Note: the child count that occurred between October 1 and December 1, 2016, found in Part II of this form, does not need to be revised. You need only update your district's entitlement amount to reflect the recent increase in the FY18 entitlement.

After this recalculation is performed, a district will have to determine whether it has met the level of required expenditure for FY18 proportionate share or not by comparing the updated FY18 proportionate share obligation to the actual FY18 expenditures. According to 34 CFR 300.133(a)(3), "If an LEA has not expended for equitable services all of the [obligated] funds… by the end of the fiscal year…, the LEA must obligate the remaining funds for special education and related services (including direct services) to parentally-placed private school children with disabilities during a carry-over period of one additional year." Since the Fund Code 240 grant technically spans two years, the carry-over period would be year 2 of the grant. See the chart below:

Fund Code	Upon approval – June 30, 2018	Upon approval – June 30, 2019	Upon approval to June 30, 2020
FY18 240 Grant	Year 1*	Year 2**(grant rollover year)
FY19 240 Grant		Year 1	Year 2(grant rollover year)

* Year 1 of a grant is the original fiscal year in which the funds are appropriated (obligations through June 30th).
**Year 2 of a grant is the rollover year, which is the following fiscal year.

If a district determines it has not yet spent its required amount of proportionate share for FY18, whether because of the supplementary Fund Code 240 allocation or any other reason, any funds the district has not spent must be obligated first in year 2 of the FY18 grant toward the FY18 proportionate share requirement. This must happen prior to the obligation of FY19 year 1 funds for proportionate share.

Example:

Fund Code	Upon approval – June 30, 2018	Upon approval – June 30, 2019	Upon approval to June 30, 2020
FY18 240 Grant	Year 1: A district calculated and spent their proportionate share obligation of $12,000 for the fiscal year. When the district recalculated their proportionate share with their new total entitlement amount, they determined they must spend an additional $250 to meet their obligation for FY18.	Year 2 (grant rollover year): $250 is spent from the FY18 funds on the proportionate share obligation from FY18.
FY19 240 Grant		Year 1 The district calculates their FY19 proportionate share obligation and fulfills their required expenditures for the FY19 year.	Year 2 (grant rollover year) If not all of the proportionate share obligation for FY19 was spent, account for that amount here.

In the future, if DESE offers supplementary allocations to the original Fund Code 240 entitlement amounts to a district, DESE will request the district to recalculate its proportionate share obligation and re-submit its proportionate share form with its Fund Code 240 increase amendment documents.

Prepare and verify FY19 child count information

In addition to the FY18 recalculation described above, which is required for those districts that claimed an increase in their 240 grant this spring, DESE is requiring all districts to verify the accuracy of their child count and proportionate share calculation for FY19. This means districts must verify the child count conducted between October 1 and December 1, 2017, and the resulting calculation of FY19 Fund Code 240 proportionate share obligation which is based on this child count. Districts must confirm that the child count includes all eligible parentally placed private school students attending a private school or home schooled within the geographic boundaries of the district. Such students should be counted regardless of whether they are receiving or have ever received services from the district, and regardless of whether they reside in the district or outside the district. This information should include students known through child count activities and those made known to the district through meaningful consultation with the private schools.

Districts will then use this verified child count as part of their FY19 Fund Code 240 grant applications on the FY19 Proportionate Share Calculation form entitled, "Required Record-Keeping and Proportionate Share Calculation Form for Parentally-Placed Children With Disabilities Enrolled by Their Parents in Private Schools."
Maintain proper documentation of these activities

Please retain all documentation used to review the child count conducted this school year and the re-calculation of FY18 proportionate share. DESE will review this documentation during its compliance monitoring and audit processes.

Please begin the activities outlined above as soon as possible. This will ensure that the required information is readily available for inclusion in the district's FY19 240 grant application when it becomes available later this summer.

If you have any questions about the information contained in this memorandum, please contact us at: IDEAEquitableServices@doe.mass.edu .

Thank you for your attention to this important matter.

Last Updated: August 17, 2018