SACS Forum Meeting Minutes, February 2018

Meeting held via Webinar at the California Department of Education (CDE), Sacramento

Meeting Agenda

Announcements and Information

• Section 508 – Accessibility

• Validation Table Update

Accounting Issues

• Special Education Individuals with Disabilities Education Act (IDEA) Section 611 Resource Codes Update

• Every Student Succeeds Act (ESSA) Per-pupil Expenditure (PPE) Reporting Update

• Governmental Accounting Standards Board (GASB) Statement 74 and 75 Update

• 2016-17 Unaudited Actuals Data Review – Observations

SACS Software Issues

• SACS2018 Software Release – Proposed Criteria and Standards Changes

Other Issues

• Next Meeting

Meeting Minutes

The February 6th SACS Forum PowerPoint presentation outline (Attachment A) (DOCX) is available for download.

Announcements and Information

• Section 508 – Accessibility

In March 2017, federal Section 508 of the Rehabilitation Act of 1973 was updated to clarify that all Information and Communication Technology (ICT) must be made accessible to persons with disabilities. As a recipient of federal funds and also per California Government Code Section 7405, the CDE is required to comply with federal Section 508. As of January 18 of this year, all of the CDE’s electronic communication must be accessible to persons with disabilities. As a result of this requirement, future electronic information provided by our office, School Fiscal Services Division, and the CDE overall may look different. For example, because the California School Accounting Manual is made available for download on the CDE Web site, it must be compliant with Section 508. This means the next edition will more than likely require formatting changes that result in a slightly different look than the current (2016) edition.

• Validation Table Update

A validation table update was released on January 17, 2018. The tables are available for download on the CDE SACS Valid Codes and Combinations Web page.

The Master List of Resources, which provides the history of all resource codes assigned by the CDE, is updated and posted to the SACS Resource Spreadsheets Web page in conjunction with each validation table release. It is currently available in Excel and Portable Document Format (PDF) formats; however, due to accessibility issues, the PDF version of this list will no longer be available with future updates.

Accounting Issues

• Special Education Individuals with Disabilities Education Act (IDEA), Part B, Section 611 Resource Codes Update
  
  At the November 7, 2017 SACS Forum meeting, it was discussed that CDE program staff requested the following resource codes be consolidated into existing Resource 3310, Special Education: IDEA Basic Local Assistance, Part B, Sec 611, effective 2018–19:
  
  
  • Resource 3320, Special Ed: IDEA Preschool Local Entitlement, Part B, Sec 611
  • Resource 3400, Special Ed: Disabled Children State Institutions, Part B, Sec 611

Also, Resource 3332, Special Ed: IDEA Part B, Sec 611, Preschool Local Entitlement Early Intervening Services, will be eliminated since it was used to track expenditures associated with Resource 3320 funds.

Note that the level of funding will not change under the consolidation. In addition, the private school proportionate share will be calculated on the consolidated total.

The CDE will not have to differentiate how much is spent on preschool vs K–12 students. This means that local educational agencies (LEAs) will have flexibility in determining how much to spend on preschool and K-12 students. LEAs will use the goal code to indicate the student populations served, e.g., Goal 5730, Special Education Preschool Students, to indicate preschool students served.

For clarification, Resource 3315, Special Ed: IDEA Preschool Grants, Part B, Section 619, is not part of the consolidation because the consolidation only impacts Special Education Section 611 resource codes.

Any grant calculation or funding related questions should be directed to the Special Education program office contact, Chris Essman, at cessman@cde.ca.gov.

• Every Student Succeeds Act (ESSA) Per-pupil Expenditure (PPE) Reporting Update
  
  The CDE has convened a workgroup of LEA representatives to explore alternatives and discuss calculating LEA and school-level expenditures. The first meeting is scheduled for the end of February.
  
  Subsequent to the meeting, the CDE learned that U.S. Department of Education is no longer providing an estimated timeline for the issuance of non-regulatory guidance. If and when the non-regulatory guidance is issued, the CDE expects it will not be prescriptive and will provide flexibility to states for determining PPE.
  
  CDE’s goal is to provide final guidelines no later than July 1, 2018.
  
  Summary of important points regarding the ESSA PPE:
  
  
  • The PPE data will be reported as a component of LEA and State report cards, in conjunction with other required data elements, as prescribed in ESSA.
  • PPE information will be reporting beginning with report cards provided for the 2018–19 school year. Please note that report cards containing all other required information must be provided for the 2017–18 school year.
  • LEA and school-level PPE will be calculated by LEAs and reported to CDE. Collection method is still to be determined.
  • The CDE is not required to prescribe a calculation methodology. That requirement was included in the now-rescinded federal regulations.  
  • The CDE will not require LEAs to implement the School field of the standardized account code structure (SACS) to collect school-level data. However, LEAs may use the school field locally for such purpose.
  • The PPE data will not be used to ensure compliance with federal laws (e.g., supplement not supplant) or to determine funding.

Governmental Accounting Standards Board (GASB) Statement 74­ and 75 Update

The CDE asked Webinar participants to provide information about the types of Postemployment Benefits Other Than Pensions (OPEB) plans offered by LEAs. The types of OPEB plans are:

• Defined Contribution OPEB plan
• Insured plan
• Defined Benefit OPEB plan
  • Single-employer OPEB plan
  • Agent OPEB plan
  • Cost-sharing OPEB plan
• Special Funding Situations

The CDE is still seeking this information from LEAs. Please e-mail the requested information to sacsinfo@cde.ca.gov. If the CDE does not receive sufficient feedback, accounting guidance will be developed per GASB 75 based on single-employer and agent OPEB plans, using the current assumption that most LEAs do not have defined contribution, insured, or cost-sharing OPEB plans, or special funding situations.

Subsequent to the November 7 SACS Forum meeting, the CDE clarified and received confirmation from the California Public Employees' Retirement System (CalPERS) that the CalPERS California Employers’ Retiree Benefit Trust Fund (CERBTF) is considered a qualified trust per GASB 74, paragraph 3 and GASB 75, paragraph 4.

The CDE offered the following accounting guidance related to the CERBTF:

• Balances and activities of the CERBTF are reported by CalPERS in their financial reports; therefore, these amounts should not be reported in the employer’s fiduciary fund, i.e., Fund 71, Retiree Benefit Fund.
• CERBTF assets are included in an OPEB plan’s fiduciary net position for calculation of the net OPEB liability.

Contributions to the CERBTF should be recorded as OPEB expenditures using objects 3701–3702, and/or objects 3751–3752. It has been brought to CDE’s attention that some LEAs recorded the contribution to the CERBTF as interfund transfers or other outgo, e.g., using Object 7299, All Other Transfers Out to All Others. As a reminder, contributions to a qualified trust such as the CERBTF, including large-sum contributions for prefunding purposes, should be accounted for as OPEB expenditures.

• GASB 74 and 75 related SACS Software Changes
  
  Due to the implementation of GASB 75, the following changes will be made to the SACS2018 software:
  
  
  • Object 9664 – title change from Net OPEB Obligation to Total/Net OPEB Liability.
  • Fund forms and other supplemental forms (e.g. Form DEBT) – title change for Object 9664.
  • Criteria and Standards – see below for details.
  • Government-wide conversion entries and reports:
    • Revise the current net OPEB obligation conversion entry (CE021).
    • Add a new entry for adjusting employer’s OPEB contribution subsequent to the OPEB plan measurement date.
    • Include other corresponding changes, e.g., revise reconciliation for the statement of activities and the statement of net position.
      
      
• 2016-17 Unaudited Actuals Data Review – Observations

The CDE provided and discussed a list of accounting and reporting observations made during the 2016–17 unaudited actuals data review. A focus of the review was the indirect cost rate calculation, and several items observed during these reviews are noted on the Coding/reporting issues observed in 2016–17 unaudited actuals data submissions (Attachment B) (DOCX).

SACS Software Issues

• SACS2018 Software Release – Proposed Criteria and Standards Changes
  
  Criterion 7/5–Facilities Maintenance – for Districts/County Offices:
  
  The CDE incorporated the restricted maintenance account (RMA) contribution requirement for Proposition 51 funding, which is 3% of total general fund expenditures. Once Proposition 51 funding is received, the 3% RMA contribution requirement applies in the fiscal year subsequent to the fiscal year the LEA receives funding. Due to differing RMA contribution requirements currently in place, CDE added a new section in criterion 7A/5A, for the District/County Office to select its School Facility Program funding in order to determine the minimum applicable contribution requirements. The funding selections are as follows:
  
  
  • Proposition 51 Only
  • Proposition 51 and All Other School Facility Programs
  • All Other School Facility Programs Only

Based on the funding option selected, the applicable required RMA contribution calculation will be applied and the actual contribution verified to determine whether the criterion is met or not met.

Supplemental Information S7–Unfunded Liabilities–County Offices and Districts:

Per GASB 74 and 75, the draft proposed changes to the Criteria and Standards, Supplemental Information for Unfunded Liabilities section include changes for the following:

1. Remove: annual required contribution
   Replace: actuarially determined contribution (if available)
2. Remove: OPEB actuarial accrued liability (AAL)
   Replace: Total OPEB liability
   
3. Remove: OPEB unfunded actuarial accrued liability (UAAL)
   Replace: OPEB plan(s) fiduciary net position (if applicable)
   
4. Add new line: Total/Net OPEB liability (key entered data)
   
5. Remove: Are AAL and UAAL based on the district’s/county office’s estimate or an actuarial valuation?
   Replace: Is total OPEB liability based on the district’s/county office’s estimate or an actuarial valuation?
   
6. Remove: OPEB annual required contribution (ARC)
   Replace: OPEB actuarially determined contribution (ADC), if available

Other Issues

• Next Meeting

The next SACS Forum is tentatively scheduled for Tuesday, May 8th, 2018. The CDE is again planning to offer this forum as a Webinar only.