IDEA & Maintenance of Effort FAQs

General Questions


General Questions

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. A good first step is to verify the numbers shown in the MOE web application.

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How does a treasurer know if their district failed IDEA MOE?

The district can check the IDEA MOE web application that is located within the CCIP. The district will be notified by the Ohio Department of Education’s Office for Exceptional Children if they failed IDEA MOE.
 

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I am the treasurer of a Board of Developmental Disabilities and I received notice that the DD failed to meet IDEA MOE. The DD does not report expenditures in EMIS. Where did the expenditure information come from to make this determination?
The data was manually loaded into the IDEA MOE system by Office for Exceptional Children staff based on a financial detail report detailing state and local expenditures that was uploaded by the DD.   Your DD may have additional expenditures from local funds for special education that are determined by subtracting the state disbursement funds. 
 
 

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My district failed IDEA MOE in FY17 and received the following message on the MOE data tab, **one or more years of failed MOE compliance checks exist between current (2018) and (2016) fiscal year data. ** . What does this mean?

This means the district failed FY17 and was unable to cover the variance between FY17 and FY16 with an allowable exception for IDEA MOE.  Therefore, the district will compare FY18 expenditures to the FY16 expenditures.  If any part of the district’s FY17 justification was an allowable exception for IDEA MOE, the amount attributed to the reason can be subtracted from the difference between FY18 and FY16.  Please send questions regarding what was acceptable for FY17 to IDEA.MOE@education.ohio.gov.  
 

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Special education staff voluntarily left the district and were not replaced. If ADM stayed flat or increased, can this justification/exception be used to support the reduction in IDEA MOE?

Yes, voluntary departures of special education staff who were paid from state and/or local sources as an allowable reason are not dependent on ADM fluctuations. The full amount paid to the departing staff is included minus the amount paid to the incoming staff. If the position was not replaced, the district can count the full amount paid to the departing staff.
 

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The district had a decrease in students with a disability 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, report the 2 high cost students in the third box - The termination of the obligation of the agency to provide a program of special education to a student with a disability that is an exceptionally costly program.  The remaining 8 students will be reported in the second box on the General tab.  To determine the amount 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. What is a valid response for IDEA MOE?

Voluntary departures of special education staff who were paid from state and/or local sources is an allowable reason. The full amount paid to the departing staff is allowable minus the amount paid to the incoming staff. If the position was not replaced, the district can count the full amount paid to the departing staff in the previous year. This information would be entered into the first box on the General tab.
 

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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 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 justify a reduction in MOE. If the district’s IDEA allocation did not increase then the district is not eligible to use 50% of the increase to reduce MOE. 
 

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My district failed IDEA MOE in FY17 and received the following message on the MOE data tab, **one or more years of failed MOE compliance checks exist between current (2018) and (2016) fiscal year data. ** . What does this mean?

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 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 must be paid from 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.

If 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 FY16 and failed FY17.  In FY18, the MOE data will be compared with the FY16 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 is then multiplied by Prior FY PPE to get the amount allowable because of a decrease in ADM for students with disabilities.
 

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Will my district be notified if we met MOE?

ODE does not email districts that meet the MOE requirement after the initial EMIS data load. The district can always refer the IDEA MOE web application that is located within the CCIP system to view their status.
 

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

The following expenditure data is included in the IDEA MOE calculation based on a district’s Period H EMIS submission:

  • Fund: 001-300, 400-499, 504 and 532.
  • Function: 1230-1239, 1240-1249, 1280, 1290, 1330-1339, 1350, 2140-2149, 2150-2159, 2180-2187, 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 student count calculated for the IDEA MOE?

Average Annual Enrollment (attendances plus absences) 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 Detail Report (expenditures) does not match the expenditures listed in the MOE tab. What do I do?

Check with your EMIS coordinator, perhaps there was a data entry error. Prior to closure of the EMIS financial reporting at the end of August, the district can correct the EMIS data and resubmit. After the EMIS has closed, report errors in expenditures on the MOE GENERAL tab and attach backup documentation to substantiate the error in the DOCS tab. Clearly identify the errors and highlight 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 because of funding constraints count as an allowable reason for IDEA MOE?

No.
 

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Do cost savings of any kind because of financial constraints count as an allowable reason for the reduction in IDEA MOE expenditures?

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

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After submitting the district’s justification for the reduction in MOE, how soon will the district receive a response?

OEC will review the IDEA 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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How do I respond to the MOE notification? What do you need from me?

Please read the instructions for submission of your IDEA 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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Last Modified: 12/13/2019 2:55:01 PM