Monday, April 27, 2020
Weekend Extension for Membership Audits
We are extending the deadline for school district membership audits to noon on Monday, May 4th. Audit reports must be submitted as searchable PDFs to dpiauditreports@dpi.wi.gov.
Eligibility for State Categorical Aids
After reviewing state statutes, DPI has determined that personnel and transportation costs incurred during the COVID-19 health emergency will remain eligible for certain state categorical aids. In order for salaries, wages, paid leave, and other employee benefits to remain aid-eligible, compensation must be paid consistent with the LEA’s policies and procedures for paying compensation from all funding sources, federal and non-federal, under unexpected or extraordinary circumstances. The LEA must also continue to pay for similarly situated employees whose compensation is not aid-eligible.
Employees being redeployed to other roles and serving the greater good in a meaningful capacity (e.g. deep cleaning, delivering meals) may continue to be paid with funds eligible for state categorical aids, assuming those employees would otherwise be eligible for paid leave and are not required for direct services under their usual aid-eligible positions. LEAs do not need to create or maintain time and effort documentation for aid-eligible employees redeployed to other roles during the health emergency.
The state categorical aids falling under this determination, and the specific eligibility details for each, are listed below:
Special Education and School-Age Parents Aid
- Salaries, benefits, and paid leave for Fund 27 employees who are eligible (project 011) under normal circumstances.
- Payments to transportation contractors. The Fund 27 portion of contractor payments during the health emergency should be proportional to the average Fund 27 portion billed for the period when school was physically in session this year.
- Unemployment compensation to former staff for up to one year from the date of termination, provided that the cost is not offset by a credit from the Families First Coronavirus Relief Act (FFCRA), CARES Act, or other COVID-19 relief and grant programs. Unemployment compensation recorded as an expenditure against credited revenue from a COVID-19 program must be coded as non-eligible (project 019).
Bilingual-Bicultural Aid
- Salaries, benefits, and paid leave for bilingual teachers, aides, and counselors.
Aid for School Mental Health Programs
- Salaries, benefits, and paid leave for school social workers.
High Cost Transportation Aid
- Salaries, benefits, and paid leave for pupil transportation employees (Fund 10 only).
- Payments to transportation contractors. The Fund 10 portion of contractor payments during the health emergency should be proportional to the average Fund 10 portion billed for the period when school was physically in session this year.
Due to the student-driven nature of High Cost Special Education Aid, we are not able to include it in this determination. Categorical aids based on counts (e.g. Per Pupil Aid, Pupil Transportation Aid, Sparsity Aid) are not affected by cost changes during the health emergency.
This determination applies to eligibility of costs for these state categorical aid programs. Actual funds received next year depend on appropriations and other provisions of law. Any reductions from the current 2019-2021 biennial budget would require an act of the State Legislature.
No Delays in State Financial Reports and Year-End Audits
The financial reporting cycle for state aids paid in 2020-21 begins with the PI-1547 Pupil Transportation Report, which opens May 11 and is due on July 17. The PI-1505, PI-1505-AC, and PI-1505-SE annual school district reports will open in early July and be due in September as usual. Determination of state aid payments, especially the crucial October 15 certification of general school aids, relies upon accurate data submitted within established deadlines.
Auditors have begun contacting school district clients about scheduling their June pre-audit work and July-August field work. As a reminder, Emergency Order #28 (April 16, 2020) closes schools for instruction and extracurricular activities through the end of June, but it also specifies that essential governmental functions “needed to ensure the continuing operation of the government body” are to continue. Nothing in Emergency Order #28 suspends the need for school districts to conduct their year-end fiscal activities, nor does it prevent auditors and employees from accessing buildings and records for business purposes.
PI 14 requires that school district audits be conducted on-site, but we understand that the current situation calls for being flexible in the interpretation of “on-site.” The SFS Team recommends that districts work with their auditors to identify audit processes that will maximize health and safety while maintaining operations. For example, an auditor could conduct field work remotely with an employee on-site to locate and scan invoices or other needed financial records.
GASB Proposes Postponing Statements 84 & 87
The Governmental Accounting Standards Board (GASB) is proposing to postpone implementation of newer GASB Statements. GASB 84 (Fiduciary Funds) and its associated Implementation Guide (IG) 2019-2 would be postponed to 2020-21, while GASB 87 (Leases) and IG 2019-3 would be delayed to 2021-22. GASB is taking comments through April 30, with a final decision expected by May 8.
Regardless of their decision, GASB encourages early implementation of these statements. If your district has implemented GASB 84 for 2019-20 then you will not have to undo that work. School districts’ 2019-20 financial statements should indicate whether or not they reflect GASB 84 in their presentation of fiduciary funds.