What makes a cost "federal"?
For SLR, we are interpreting "federal" to mean a cost where specific budgeted expenditures are paid for with federal program revenues. The most common programs for Wisconsin LEAs are the various federal grant programs administered by the Department of Public Instruction (DPI) such as Title I or IDEA, where districts submit budgets, make expenditures and submit claims for reimbursement.
The only specific guidance DPI has received on this topic is that costs supported by P.L. 874 Federal Impact Aid are not considered "federal" for SLR, since these are essentially payments in lieu of property taxes. We are also not considering Medicaid to be associated with "federal" costs for SLR because Medicaid revenues are fee-for-service and administrative payments which cannot be tied back to specific budgeted expenditures.
What makes a cost "school" or "district/LEA"?
Where to draw the line between school and district/LEA costs is a local decision. We recommend that you start with the easy cases, costs that would obviously be associated with a particular school (such as a second grade teacher at the elementary school) or the LEA as a whole (such as the superintendent). Once those are identified, you will be left with the cases falling into your "gray area" between school and LEA and you can work through what makes the most sense for each cost.
If you choose to code and report ALL your costs as LEA-wide, be aware that your school-level reporting will show identical per-pupil spending amounts for each school.
How do we allocate costs?
If you allocate a cost among specific schools, have a good reason and a clear methodology for doing so. This is one area that is easy to overthink; use an existing resource--such as a position description--or apply a straightforward method such as numbers of grades at each school.
If there is a cost you are considering allocating across your entire LEA by enrollment, just code and report it at the LEA level. The math works out the same either way.
What about "equitable services" provided to private school students under Title I, IDEA and other federal grants?
The SLR workgroup determined that equitable services are a cost of doing business for receipt of federal funds and should therefore be included in SLR.
Should we exclude costs paid with private gifts and grants, fundraising or student fees? Should we exclude "Fund 21" costs?
The only distinction in funding source in ESSA is between federal or state and local costs. At present, there is nothing in law or guidance to exclude a cost because it is funded with private gifts and grants, fundraising or student fees, including costs coded to the Special Revenue Trust Fund (Fund 21). The analysis on whether to exclude such costs is no different than with costs paid with federal dollars, state aids or local property taxes. Exclusions are based on the purpose and nature of an expenditure, not its funding source.
How are schools defined for SLR?
Schools are defined by the LEA and reported to DPI via the School Directory application. Once the School Directory is closed for changes in the current school year, your LEA is committed to reporting for all DPI programs based upon the schools you have identified. As always, your LEA will have the ability to update the school directory for the next school year, but you should be aware that the change would affect all DPI reporting, including school report cards, and may impact any school-specific federal or state funding you receive.
We report student data with multiple schools and receive multiple school report cards but we are really one LEA in one building. Can we report costs as one school?
SLR for a given school year should be consistent with a district's other reporting using the schools reported to DPI via the School Directory application. If your LEA chooses to report all its costs at the district/LEA level, then your public reports will show the same per-pupil dollar amount for every school. You may update the school directory for the following year.
We have multiple buildings in multiple locations but one building contains two schools. How do we code and report costs there?
The building essentially has three levels of costs associated with it: school-level, building-level, and LEA-wide. We are not collecting that in-between building level, so you will need to decide what makes the most sense for your LEA and your financial software.
We have reported a "school" to DPI but it is really a program. How do we report its costs?
DPI does not recommend identifying programs as "schools." The expectation for SLR is that an LEA will report enrollments and costs for all the schools it has defined via the school directory application. If your LEA chooses to report zero enrollment and costs for a school, it will show up on your public reports and you may be asked for an explanation.
We participate in a multi-district virtual charter school. How do we report its costs? How does enrollment factor into this?
DPI has not yet finalized our business rules on how multi-district virtual charters will be reported. Over the winter, we will discuss the matter with participating districts, but for now school districts should still report their costs for their shares of the school.
Which school do we use for a student in deciding where to report them for enrollment?
In general, a student should be included in a school's enrollment count if the LEA identifies them as enrolled at that school in their student information system (SIS). We would expect a school's enrollment for SLR to be approximately the same as the enrollment appearing on its School Report Card for the same year.
What if a student is officially recorded as attending a school in our district/LEA but is actually enrolled out with a tuition payment to a technical college or private school?
Your LEA can choose to identify the tuition cost associated with a particular student with the school they attend or at the "district level" with the LEA as a whole, whichever is most appropriate for your situation.
Which types of students are associated with the "Certain Non-Accountability Students" exclusion?
There are five types of students where, if your LEA has any actual, additional costs for providing them with services, those costs can be identified by the "Certain Non-Accountability Students" exclusion. These are:
- adult students completing an HSED program;
- services to homeless youth not enrolled as students but required under the federal McKinney-Vento Act;
- home-based private students taking one or two classes part-time under s. 118.53, Wis. Stats.;
- resident students attending a multi-district virtual charter school operated by another school district; and
out-of-state residents enrolled for the purpose of receiving special education and related services under their IEP.
We provided limited services to certain Amish children in our district, as agreed with their parents and allowed by law. Are they included in SLR?
There is no general answer for situations where districts have Amish or other communities whose children are not always enrolled full-time in district schools but receive particular services (such as special education) in certain situations. Whether to include or exclude costs associated with those services is a local decision, but we recommend using a two-part analysis for doing so:
- Are there specific, actual, additional costs incurred by your district for serving these students which would go away if the community was not present?
- If so, do you formally enroll those students and include them in your reporting to DPI?
How does SLR impact special education?
There is no connection between special education funding or program requirements and SLR. Like your LEA's other costs, you will need to consider how to code and report special education, depending on how your program is run. For example, if a cross-categorical teacher is assigned to a particular school, their salary and benefits would probably best be coded to that school. On the other hand, if all of an LEA’s educational assistants are managed as a "pool" with staff allocated based on student need, they may more appropriately be coded as LEA-wide.
There is no exception in ESSA allowing an LEA to exclude costs associated with a "high need" or "high cost" student. We would question it were an LEA to report costs for serving these students as an optional exclusion. An LEA concerned about the impact on a school's calculated per-pupil cost has the option to report tuition for these students at the district/LEA level rather than at a particular school.
Should we include the costs of summer school?
Yes. Summer school is an instructional program and therefore should not be excluded. SLR is based on enrollment, not membership, so you should not add the summer membership FTE to your enrollment count. Where to code and report summer school costs is a local decision. A recommended best practice is to identify summer school costs at the district/LEA level, unless there are specific costs for a summer program held at an individual school that is targeted for only the students who attend there during the school year.
Should we include the costs of athletics or other co-curricular activities?
Yes. Co-curricular activities are an instructional cost.
Is transportation a "school" or "district/LEA" cost?
How transportation is coded and reported is a local decision. It will depend upon the LEA's desire and ability to associate transportation costs with particular schools. Depending on how you are billed by your contractor or track costs for your own fleet, you may make different coding and reporting choices for morning/afternoon routes, midday 4K buses, field trips, sports and other co-curricular activities, or specialized transportation.
How are virtual charter school costs reported?
Under s. 115.385(1g)(d), Wis. Stats., a virtual charter school enrolling half or more of its students through Open Enrollment is not included for state school and district accountability. However, there is no such exemption for SLR. DPI has implemented business rules assigning the students attending a virtual charter school to the district that hosts the program and we are implementing those same rules for SLR. The expectation is that the enrollment and expenditures of a virtual charter school will be reported by the host district, not the home district.