IDEA & Maintenance of Effort FAQs

General Questions


General Questions

    How do I know if my district failed MOE?

    You will be notified by the Ohio Department of Education’s Office for Exceptional Children.

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    I failed MOE in FY13 and received the following message on the MOE data tab, **one or more years of failed MOE compliance checks exist between current (2013) and baseline (2011) fiscal year data. ** . What does this mean?
    This means the district failed FY12 and was unable to cover the variance between FY12 and FY11 with an allowable exception for MOE.  Therefore, the district will compare FY13 expenditures to the FY11 expenditures.  If any part of the district’s FY12 justification was an acceptable exception for MOE the amount attributed to it can be subtracted from the difference between FY13 and FY11.  Please send questions regarding what was acceptable for FY12 to IDEA.MOE@education.ohio.gov.  
     

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    I’m new to this…where do I begin?

    Please review the instructions for submission available via the IDEA MOE USER’s MANUAL tab.  There is also a brief unofficial guidance document available it is by no means an exhaustive guide just some ideas to get you started based on our experience with the process.

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    Please explain the IDEA MOE justification option - "Adjustments (also called Local Replacement) 300.205 Adjustment to local fiscal efforts in certain fiscal years."

    This section applies to the use of 50% of an increase in the district's IDEA allocation to cover an expense previously paid by local or state funds in the prior year. Districts can only use up to 50% of the increase in their IDEA Allocation for this purpose.  This only applies if the district IDEA allocation increased on from year to the next; carryover does not count as an increase to the IDEA allocation.

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    The district had a decrease in ADM that included high cost students. Does that impact the accepted method to calculate a simple decrease in ADM?

    If the district has a decrease of 10 students with disabilities and 2 are high cost please report the high cost students in section 3 – The termination of the obligation of the agency to provide a program of special education to a particular child with a disability that is an exceptionally costly program.  The remaining 8 students will be reported in section 2.  Multiply 8 by the prior year’s PPE.

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    The district had a teacher voluntarily retire and we did not fill the position. Is this a valid response for IDEA MOE?

    If ADM decreased significantly then the district can justify the vacancy. Please note if you choose to use this as the response for MOE then the change in ADM response will be impacted. You should not double count the salary and the ADM calculation.  If there is a difference between the two then that amount can be included in the appropriate section.

    If ADM did not decrease then the savings created by the vacancy must be used to support students with disabilities. You may want to consider using the savings to purchase equipment that the district may need to support students with disabilities.

    Generally, when ADM does not decrease districts fill the vacancies with teachers at the lower end of the salary scale.   The difference between the senior teacher’s salary and the replacement teacher’s salary is the amount to report in the affect amount for MOE purposes.

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    The district used a combination of local and state funds to support students with disabilities but failed to meet the maintenance of effort requirement. Which difference is the district required to justify, FY13 minus FY12 Local expenditures or FY13 minus FY12 Local and State expenditures?

    The district must justify the smaller of the two variances.

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    The district used IDEA funding in the current review year to cover an expense paid with local or state funds in the prior year that is why our MOE decreased. But the district received notice that the district supplanted and did not meet MOE, Why?

    Adjustments (also called Local Replacement) only apply when an LEA receives an increase in their IDEA allocation from one year to the next.  Only then can 50% of the increased allocation be used to cover an expense previously paid with local, or state and local, funds to meet the IDEA MOE standard. If the district’s IDEA allocation did not increase then the district is not eligible to locally replace.  If the district’s IDEA allocation did increase but the district used more than the eligible amount (50%) then the amount in excess is considered supplanting.

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    The district’s MOE decreased because we contracted for services for students with disabilities in the previous fiscal year. During the fiscal year currently under review for MOE, the district no longer contracted for these services, either because the services were no longer available or the district decided to bring the students back into the district to save money. Why is this not a valid justification for IDEA MOE?
    Cost savings are not one of the allowable exceptions for IDEA MOE. Per federal regulations “all Local Educational Agencies (LEA) budget and expend for the education of children with disabilities in local, or state and local funds, an amount which is at least the same in total or per capita, as the amount spent in the most recent fiscal year for which information is available. This is known as Maintenance of Effort (MOE).”  The savings achieved from the change in service providers must be used to support student with disabilities in order to maintain effort. You may want to consider using the savings to purchase equipment that the district may need to support students with disabilities.

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    What are the consequences for not meeting IDEA MOE?

    The district will owe a refund to the federal government in the amount of the variance between the two fiscal year’s expenditure totals under review.  Repayment of the amount due must be repaid by state and/ or local funds.  Federal funds may not be used.  If the district cannot pay the full amount due within 60 days of the determination the district may request to repay via a repayment plan through the end of the current fiscal year.  The repayment plan is first submitted to IDEA MOE contact for review and approval.

    When a district fails MOE the following year’s MOE data is compared against the last year the district passed IDEA MOE.  For example:  The district passed FY12 and failed FY13.  In FY14 the MOE data will be compared against the FY12 MOE data.

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    What is the accepted method to calculate a simple decrease in ADM for students with disabilities?

    First review the data available on the MOE tab in the IDEA MOE system.  Then use that data to complete the formula below:
    Prior FY ADM – Current FY ADM = X
    X multiplied by Prior FY PPE = $ Change due to decrease in ADM.

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    Why is my expenditure data for FY12 different when comparing it to FY13 than it was in the previous comparison year, FY12 to FY11?

    The data in the previous comparison year, FY12 to FY11, did not include function codes 2821 and 3412 or object codes 600-690 and 844.  These changes will NOT impact the results of the FY12 to FY11 comparison year.

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    Will my district be notified if we met MOE?

    No, we do not notify districts that meet the MOE requirement.

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    What expenditure data does OEC pull for the IDEA MOE report?

    We pull the following expenditure data from EMIS for FY12 and FY13:

    • Fund: 001-300, 400-499, 504 and 532.
    • Function: 1230-1239, 1240-1249, 1280, 1290, 1330-1339, 1350, 2140-2149, 2150-2159, 2180-2189, 2215, 2216, 2416, 2417, 2821 and 3412.
    • Object: 100 -190, 200-292, 400-499, 500-590, 600-690 and 844.

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    How is the enrollment calculated for this report?

    Average Annual Enrollment is the number used as the denominator for the count of students with disabilities. Districts should already be familiar with the concept of Average Annual Enrollment, which is available as a “drill down” metric on the district’s enrollment report. The number is calculated as follows:

    For each student with a disability condition (FD130) as reported in the Student Attributes—Effective Date Record in EMIS:

    (Attendance Days [FS320] + Excused Absence Days [FS330] + Unexcused Absence Days [FS340])

    ÷

    Annual Days in Session [DL120]

    Some Community Schools report their session in hours (Annual Hours in Session [DL110]), which is converted into days and used as the denominator instead.

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    My expenditure reports do not match the expenditures provided in the detailed expenditure report on the MOE tab. What do I do?

    Check with your EMIS coordinator, perhaps there was a data entry error. Report errors in expenditures on the MOE GENERAL tab and attach backup documentation to substantiate the error on the DOCS tab. Clearly identify the errors and pencil in the correct coding. Be sure you clearly explain the error and the impact, by fiscal year, on the expenditures.

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    Do layoffs due to funding constraints count?

    No.

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    Do cost savings of any kind due to financial constraints count as a valid reason for the reduction in local expenditures?

    No, districts must spend equal to or greater than the previous year if none of the IDEA MOE exceptions apply.

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    I provided the district’s justification for the reduction in MOE when can I expect to receive a response?

    OEC makes every effort to review the MOE responses in a timely manner, usually within a day of submission.  Please check the COMMENTS/HISTORY tab for guidance if you have not received a PASS notification.

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    I want to respond to the MOE notification what do you need from me?

    Please read the instructions for submission of your MOE justification available via the USER’s MANUAL tab in the MOE electronic system.  Justifications are to be entered on the GENERAL tab of the IDEA MOE system.

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    Can you tell me why the adjustment of local effort resulting from IDEA ARRA funds only applies to FY10 when I had carryover in FY11?

    FY11 ARRA funds cannot be used to replace local funds that year because they weren't a new allocation, they were carryover and carryover does not count as an increase in your allocation.

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    I used ARRA funds to adjust local fiscal effort (local replacement) in FY10. What level of detail does OEC require when I provide the justification for the reduction of local and state (or local or state) expenditure in FY10?

    Please provide the total amount expended from ARRA for the replacement of local costs.  The district must keep back-up to substantiate the replaced expenditures on file for potential future audits.

    Note: Only 50% of the total FY10 allocation increase may qualify for use for local replacement.  The full amount of ARRA does not qualify for local replacement.  In addition if the district elected to use IDEA to support CEIS in FY10 the amount for local replacement will be impacted.

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    OEC accepted the district’s justification for the reduction in MOE in April or May of 2012 why am I receiving another notice?

    The data and assumptions used to review MOE in April were incorrect.  Please review the current data available on the spreadsheet to determine if one of the exemption reasons listed above apply in this case.  If so please resubmit the district’s rationale for the reduction in local expenditures for students with disabilities.  Please indicate the total dollar amount per exemption reason given.  Feel free to include the clearance letter you received from OEC as well.  Some districts were incorrectly notified in April that they missed MOE for Grades 7-12.  As a result OEC issued approval letters.  Those letters do not apply in the case of the revised MOE data.

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    I received a letter dated April 3, 2012 that my district missed MOE, what do I do?

    Disregard the letter dated April 3, 2012.  We determined that the process used to determine which districts missed MOE had a flaw.  We have since worked out the issues/errors.  Any communication regarding MOE as of May 9, 2012 relates to the revised MOE review standard and requires your attention and a response.

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Last Modified: 8/1/2014 1:53:34 PM