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Guidance: Title III, Immigrant Obligations Report

2013-14 Consolidated Application guidance for the Title III, Part A Immigrant Obligations Report.

Please note: September 30, 2013, marks the end of the federal grant period for the Fiscal Year (FY) 2011–12 subgrant (July 1, 2011, to September 30, 2013). Any Local Educational Agency (LEA) reporting unobligated funds for this grant period will be invoiced by the CDE.

According to the California State Accounting Manual (CSAM), “Legal obligations are commitments made by an LEA to purchase goods or services immediately or in a future period.” To determine whether a financial commitment should be reported as an obligation, please refer to Title 34, Part 76, Section 707 from the Code of Federal Regulations External link opens in new window or tab. Web page. All obligations must be liquidated no later than 90 days after the funding period ends. For the Fiscal Year 2011–12 subgrant, all obligations need to be liquidated by December 30, 2013.

Obligations: Refer to ESEA, Section 3115 (e)(1) as a guide to determine allowable obligations for the relevant Title III Immigrant allocation. (See excerpt below.)

Administrative and Indirect Costs: Administrative costs include both direct and indirect costs. Administrative costs are any costs, indirect or direct, that are administrative in nature and support the management of a program. (See the CSAM [PDF; 3MB] Procedure 915.)

Costs must be necessary and reasonable for proper and efficient performance and administration of federal awards (per Appendix A subsection C.1(a) and C.2(a) of Code of Federal Regulations, Title 2, Part 225, Cost Principles for State, Local, and Indian Tribal Governments [Office of Management and Budget Circular A–87, Revised]).

For LEAs that consolidate administrative funds, the maximum amount available for administrative costs is what is reasonable and necessary for the proper and efficient administration of the programs provided that the LEA budgets and obligates at least 85 percent of the grant amounts at school sites for direct services to pupils (CSAM Procedure 780).

Allowable Costs: ESEA, Section 3114

  1. ACTIVITIES BY AGENCIES EXPERIENCING SUBSTANTIAL INCREASES IN IMMIGRANT CHILDREN AND YOUTH-
  1. family literacy, parent outreach, and training activities designed to assist parents to become active participants in the education of their children;
  2. support for personnel, including teacher aides who have been specifically trained, or are being trained, to provide services to immigrant children and youth;
  3. provision of tutorials, mentoring, and academic or career counseling for immigrant children and youth;
  4. identification and acquisition of curricular materials, educational software, and technologies to be used in the program carried out with funds;
  5. basic instruction services that are directly attributable to the presence in the school district involved of immigrant children and youth, including the payment of costs of providing additional classroom supplies, costs of transportation, or such other costs as are directly attributable to such additional basic instruction services;
  6. other instruction services that are designed to assist immigrant children and youth to achieve in elementary schools and secondary schools in the United States, such as programs of introduction to the educational system and civics education; and
  7. activities, coordinated with community-based organizations, institutions of higher education, private sector entities, or other entities with expertise in working with immigrants, to assist parents of immigrant children and youth by offering comprehensive community services
  1. SUPPLEMENT, NOT SUPPLANT- Federal funds made available under this subpart shall be used so as to supplement the level of Federal, State, and local public funds that, in the absence of such availability, would have been expended for programs for limited English proficient children and immigrant children and youth and in no case to supplant such Federal, State, and local public funds.

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