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.
Independent Charter Schools (ICS): We received a Paycheck Protection Plan (PPP) loan under the CARES Act to help maintain payroll through the COVID-19 disruption. How does this affect School Level Reporting?
The AICPA released accounting guidance on recording PPP loans as grants or liabilities in June 2020. Because these are forgivable loans, payroll expenditures funded with PPP loan proceeds should be reported as State/Local costs for ESSA School Level Reporting. ICS will need to work with their auditors on recording the repayment and/or forgiveness of their PPP loans. Any expenditures related to PPP repayment and/or forgiveness should be identified as exclusions for the school year they are recorded; the ICS could use the Debt Service recommended standard exclusion or create an optional exclusion for this purpose.
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?
As with School Report Cards, enrollments for multi-district virtual charter (MVC) schools are reassigned from the resident district to the host district. What this means for a given MVC depends on whether the reporting district is the host district or a participating district:
- Host district: The MVC is shown with an enrollment count of all its students from participating districts. The full costs of operating the MVC are included in the host district's ESSA School Level Report, and it will have per-pupil expenditure amounts in the public reporting.
- Participating district: The MVC is shown with an enrollment count of zero. The payment to the host district for participating students are reported as a cost for the MVC, rather than including it as a district-level cost. The per-pupil amount shown for the MVC in the participant district will be zero.
I'm completing the School Level Annual and don't believe the enrollment for a school is correct. Can the enrollment data be changed?
Enrollments shown for schools in a School Level Reporting Annual Report are based on the audited and certified WISEdata Third Friday data snapshot. Districts have an opportunity to review and confirm or correct those enrollments, which are used for public reporting and school accountability, throughout the WISEdata review period. By the time the School Level Annual is being completed, WISEdata is closed and cannot be modified. Minor corrections for a few students are not allowed.
If there was a significant, systematic issue with the enrollment data reported at the time, you may request an enrollment modification. The district/LEA must first submit a Data Errata for the affected enrollment information before a request will be accepted. See the next Q&A for details on submitting an enrollment modification.
NOTE: School Level Reporting assigns students at multi-district virtual charter schools to the host district, as is done for School Report Cards.
I'm completing the School Level Annual and believe there are students who should not be included in a particular per-pupil denominator. Can the enrollment denominator be changed?
If your district/LEA has a group of students associated with a particular cost where you believe it would be inaccurate to include them in a per-pupil calculation, it is possible to adjust the enrollment denominators. For example, a district with community 4K that assigns students to the school where they would attend kindergarten for reporting purposes, rather than reporting a community 4K "school," may believe it more accurate to identify payments to community 4K providers at the district/LEA level and remove the 4K students from the district's elementary school enrollments.
A district/LEA may request an enrollment denominator modification by emailing email@example.com with the following information:
- District/LEA name,
- The number(s) of students to be removed from or added to school enrollments, along with the names of those schools,
- The number of students to be removed from or added to the district/LEA enrollment, and
- An explanation for the denominator modification.
The SFS Team will review the request and follow up with the district/LEA. If the request is granted then we will make the enrollment adjustment in the application and per-pupil calculations.
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.