- Introductions and Welcome to New Salmon State TIPD Coordinators
Recent TA Requests and Timely Topics
- Annual Count Prep and Procedural Strategies
- Handling Tough Use of Funds Requests
- Follow-ups: OJJDP Act 2018/ Requirements of Title II, DSAs & SAG
- Ask Your Fellow Salmonites
- Confirming Hot Topics & Suggestions for Next Year
- Recent & Upcoming NDTAC Resources and Activities
- For the Good of the Salmonites & Close
Welcome and introductions
- New ND coordinator: Heidi Clyborne, NH
Recent TA requests and timely topics
Annual Count timeline
- During the summer, SEAs begin planning for the Annual Count by deciding which SEA staff will be engaged in the count this year; verifying that they have an updated list of subgrantees and facilities; and beginning communication with subgrantees to let the know that the SEA will be requesting count from them in coming months.
- Murray (UT): Contact data gurus from Adult Ed (age appropriate data), Human Services, Department of Juvenile Justice Services or related agencies.
- Colin (NV): Tip: Make sure you separate the count data from the other data elements we collect.
Christy (MT): Does anyone collect the data in a different way besides a survey (online)?
- Murray (UT): I send the collection criteria to other state agencies, including Adult Ed and Department of Juvenile Services. They crunch the numbers and send the data back to me, where I add the numbers together.
- Kenneth (NM): Here in NM we use an online tool that IT built for us. Our online tool is used for both SP1 and SP2. It is a site that was built by our IT department. If you would like, we can schedule a webinar to walk through. Ken offered his e-mail to share the tool with colleagues.
What about states that have Subpart 2?
- Jessica (WY): In Wyoming, we collect a spreadsheet through our online Data Collection Suite for Subpart 2. For Subpart 1 we collect via a survey, but are looking to put that into the Data Collection Suite
- Annual Count timeline
Heidi (NH): Is it appropriate to gather information directly from the facility/group home rather than going through the LEA?
- Murray (UT): That is an issue of trust and ability to verify
- Colin (NV): That’s a matter of working closely with state agency partners and contacts at the local level.
- Suzanne (ID): We are reworking on our online tool for both SP1 and SP2. For some facilities we work directly with them. It depends on the relationship.
Heidi (NH): Do the LEAs have to be involved?
- Suzanne (ID): One of the things I try to do is build relationships between the districts and facilities, to see how they are partner programs. It depends on the relationship I have built with them.
- Rob and others: Given that they are primarily responsible, LEAs should be involved in all Title I, Part D processes from application on.
Handling Tough Use of Funds Requests and Potentially Problematic Situations
What are the first steps you take in situations?
- Colin (NV): When I first started, I did a lot of research, like in the New Coordinators Orientation Handbook. I also recommend reaching out to a more experienced ND coordinator as well as NDTAC. I reached out to NDTAC a lot at the beginning. Rarely, I felt the need to reach out to the U.S. Department of Education unless I felt the need to get their input on something.
- Ken (NM): I ty to first go to the non-regulatory guidance, reach out to my supervisor, then NDTAC
- Suzanne (ID): There are many things to consider, including whether they are allocable, etc.
- Murray (UT): I list what is allowable and not allowable, etc. In the detailed documentation for requests for reimbursements, we disallow matters. However, I hardly ever have disallowed anything because initial clarity helps eliminate 99% of potential issues.
- What are the first steps you take in situations?
What questions guide your decision-making?
- See guiding rules and factors to consider below
How do you frame your responses to subgrantees?
- Suzanne (ID): One thing I am doing this year is asking clarifying questions as part of the approval process.
- Christy (WY): I am also asking for more detail so I can understand what exactly they are buying
- Colin (UT): I ask the subgrantees to identify what is allowable.
- Stephanie (RI): Start out with, ‘It's not clear if this is - insert concern - reasonable and necessary' of sufficient site, scope and quality to improve student academic achievement, etc.) then given them a change to make a better argument and provide additional details.
- Alison (DC): One thing I try to do is ask if the subgrantee would want others to know how they will use their funds – the scared straight method (i.e., it’s best for everyone if all expenditures are allowable, prudent and clearly tied to TIPD’s goals and outcomes).
- Who else do you (or should you) loop in and why?
How have potentially sticky situations played out?
- Stephanie (RI): We try to seek consistently across agencies so that we can identify when issues are bubbling up in one area.
- Murray (UT): Agreed! And to extend that, part of it is requiring consistent paperwork across Title I programs. We now have one person who is the key point among all Title I programs. Therefore, there are consistent, clear rules and responses.
- Stephanie (RI): LEAs shop around the Department until they get the answer they want. Communication is important.
- Suzanne (ID): All of our Federal Program team co-wrote guidance this past year on use of funds.
- Kenneth (NM): One of my biggest issues is around the use of funds for things like yoga, pet therapy, play therapy. Does anyone else work with similar programs?
Kenneth (NM): Does anyone currently fund yoga, pet therapy, play therapy through Part D funds?
- Murray (UT): No, we fund 4 programs through Subpart 1, including curriculum, career and technical education that leads to credits, transition services, and others.
- Suzanne (ID): They would have to use local funds for this kind of use of funds.
- Murray (UT): There are other considerations, such as the presence of an IEP or 504, but even then, the funding should come from those themes if these interventions are documented SPED or 504 services (supplement, not supplant)
- Do the proposed uses comply with Federal requirements regarding the use of TIPD funds?
- Do the proposed uses align with goals and objectives of the TIPD part of the State plan?
- Do the proposed uses align with the requirements for and the needs expressed (through a needs assessment) in the subgrantee’s application?
- Do the proposed uses comply with other applicable Federal regulations for the uses of Title I grant funds?
- Do the proposed uses of funds comply with applicable State or local laws and regulations?
Key Factors to Consider
- Will the proposed use of funds improve outcomes for the students served, and how?
- Is the amount of TIPD funds to be spent on this suggested use reasonable given its proportion of the agency’s or facility’s overall TIPD allocation?
- Are there other potential funding sources (e.g., State or district funds) available to pay for the proposed use of funds?
Follow-Ups: OJJDP Act 2018/Requirements of Title II, Designated State Agencies & State Advisory Groups
- Suzanne (ID): Had follow-up with state advisory group following the National Conference.
- Christy (MT): Had a meeting just yesterday with Montana Crime Council. I’ll be on the agenda of their next meeting in September. Also, our Montana Youth Justice Council has a program called "Do the Right Thing." I am going to be judging the essays.
Hot Topics and Suggestions for Next Year
- Christy (WY): Can we have a “newbie’s” group?
- Facility and program types and eligibility
- Kenneth (NM): I would like to explore the use of technology for transitions (i.e.-online mentoring programs)
- Subpart 2 at-risk programs
- Community day programs
- High quality evidence-based educational/instructional strategies that are successful with students in correctional or delinquent facilities
- Continue follow-up information on Juvenile Justice Reform Act of 2018
Place to share SEA tools/resources with all ND coordinators (i.e., ND Communities page)
- Suzanne (ID): A place to post resources would be awesome. Title IV-A has an online discussion forum.
- Christy (WY): An online discussion portal would be great!
- Post currently TA/Q&A requests to SEAs
Vangie (HI): If I sanctioned one of my Agencies and reduced allocation by 50% and I found another Subpart 1 agency eligible, can I allocate this extra funding to them?
- Rob will follow-up with a response to Vangie
*Please contact your TA liaison for the recording and slides.