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Act 20 and Federal Funds

Frequently Asked Questions

This document is a list of frequently asked questions (FAQs) regarding how Act 20 and federal funds can support student needs. Federal grants referenced in this document include; Elementary and Secondary Education Act (ESEA) and Individuals with Disabilities Education Act (IDEA). The information in this document includes existing statutes, regulations, and program guidance available to the Wisconsin Department of Public Instruction. If you have additional questions about Act 20, please visit https://dpi.wi.gov/wi-reads or reach out to early.reading@dpi.wi.gov.

Table of Contents

 

Federal Funding Basics

How do I determine what is an allowable cost for federal funds?

Follow your written procedures to determine allowable costs.

Allowable Cost Checklist for Federal Awards. Costs must be:

  • Reasonable and Necessary

  • Conforming to limitations or exclusions (allowed under statute)

  • Consistent with policies and procedures

  • Accorded consistent treatment (direct vs. indirect cost)

  • Allocable

  • Determined in accordance with General Accepted Accounting Principles (GAAP)

  • Not used for cost sharing or matching requirements

  • Adequately documented

  • Supplemental

What is considered a supplemental purchase?

In the context of federal funds, supplemental purchases are generally purchases “above and beyond” local and state investments. For most federal programs, grant funds must add to (or supplement) and not replace (or supplant) other state/local funds in providing general educational services.

Supplement not supplant (SNS) is a statutory provision across numerous federal grant programs to ensure that federal funds are utilized to benefit the intended population in the statute and not being used to fund the basic education that the district would have provided in the absence of federal funds.

However, each federal grant program has a different set of standards to determine if a cost is supplemental.

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Purchasing Reading Curriculum, Intervention or Supplementary Resources

Can a Local Educational Agency (LEA) use federal funds to purchase, in whole or in part, a reading curriculum, intervention, or supplementary instructional resource/materials that meets the requirements of Act 20 and does not incorporate three-cueing?

First, the LEA should either review an existing school plan (such as a school improvement plan or the Title I schoolwide plan) or develop a school plan with key collaborators (teachers, administrators, families, other school staff) that meets students’ needs. If a strategy to implement plan includes the need to purchase a reading curriculum, intervention, or supplementary instructional resources/materials, then the LEAs must answer, “Yes” to the following questions:

  • Does the curriculum, intervention, or supplementary instructional resource follow a specific scope and sequence?
  • Does the curriculum, intervention, or supplementary instructional resource require the learner to apply their knowledge of phonics to solve an unknown word?
  • Is the purchase an allowable cost for the federal funds identified for use?

Can ESEA or IDEA grant funds be used to purchase a three-cueing curriculum, resources, or materials?

No, the federal Uniform Grant Guidance prohibits the use of federal funds for costs that are prohibited by state statute (2 CFR 200.403).

Can an LEA use Title I funds to purchase a reading curriculum, intervention, or supplementary instructional resource that meets the requirement of Act 20?

LEAs must provide Title I schools enough resources to implement state requirements, and Title I funds must supplement (be in addition to) state and local funds. Title I funds may not be used to supplant (take the place of) state and local funds.

  • Title I Schoolwide School - Costs may be allowable if the purchase meets the needs addressed in the Schoolwide Plan.
  • Title I Targeted Assistance School - Costs may be allowable but must be prorated based on the number of identified Title I students who have identified literacy needs. Also, the curriculum must address the identified needs of the eligible Title I students. Contact your Title I Consultant at the Department of Public Instruction (DPI) to ensure this is calculated and documented appropriately.
  • Title I Centralized Service Reservation - This may be an allowable cost if all the schools in the LEA are served Title I Schoolwide programs; AND curricula are purchased for all the elementary schools; AND it addresses the needs addressed in the schoolwide plans. Contact your Title at DPI to ensure this is documented appropriately.
  • Title I, Part A Neglected Reservation - This may be an allowed cost if the purchase addresses the identified needs of students living in neglected facilities.
  • Title I, Part A Homeless Reservation - No, this is not allowed as it does not meet the purpose of the reservation.
  • Title I, Part D - No, this is not allowed as it does not meet the purpose of the reservation.
  • Comprehensive Support and Improvement/Additional Targeted Support and Improvement (CSI/ATSI) - Allowed for CSI or ATSI identified elementary schools if the cost ties to an evidence-based improvement strategy (EBIS) in the school’s approved school improvement plan that addresses the school’s results of their root cause analysis tied to Every Student Succeeds Act (ESSA) identification.

Can an LEA use Title II, Part A funds to purchase a reading curriculum, intervention, or supplementary instructional resource that meets the requirement of Act 20?

No, this is not allowed as it does not meet the purpose of the grant (20 U.S.C. 6691).

Can an LEA use Title III, Part A funds to purchase a reading curriculum, intervention, or supplementary instructional resource that meets the requirement of Act 20?

No, this is not allowed as it does not meet the purpose of the grant (20 U.S.C. 6812).

Can an LEA use Title IV, Part A funds to purchase a reading curriculum, intervention, or supplementary instructional resource that meets the requirement of Act 20?

No, this is not allowed. It is supplanting because it’s required in state statute (20 USC 7120).

Can an LEA use Title IV, Part B - 21st Century Community Learning Center Grants (21st CCLC) to purchase a reading curriculum, intervention, or supplementary instructional resource that meets the requirement of Act 20?

No, this is not allowed as it does not meet the purpose of the grant (2 C.F.R. 200.403).

Can an LEA use Title V-Rural Low-Income Schools (RLIS) funds to purchase a reading curriculum, intervention, or supplementary instructional resource that meets the requirement of Act 20?

No, this is not allowed. It is supplanting because it’s required in state statute (20 U.S.C. 7355a).

Can an LEA use Education for Homeless Children and Youth (EHCY) funds to purchase a reading curriculum, intervention, or supplementary instructional resource that meets the requirement of Act 20?

No, this is not allowed as it does not meet the purpose of the grant (2 C.F.R. 200.403).

Can an LEA use IDEA funds to purchase a reading curriculum, intervention, or supplementary instructional resource that meets the requirement of Act 20?

  • IDEA - Flow Through Funds - This is not allowed. This is not an excess cost of special education instruction or related services.
  • IDEA Preschool Funds - This is not allowed. This is not an excess cost of special education instruction or related services.
  • IDEA Voluntary Coordinated Early Intervening Services (CEIS) Funds - This is not allowed. This does not meet the purpose of the grant.
  • Title I Schoolwide Set Aside Portion of the IDEA Funds - This may be allowable if the curriculum meets the needs addressed in the Schoolwide Plan.
  • IDEA Comprehensive CEIS Funds (This funding is available to LEAs identified as Racially Disproportionate in Special Education.) - This may be allowable, if the curriculum addresses the results of the racial disproportionately root cause analysis. 

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Funding the Act 20 Professional Development Requirement

Can an LEA use federal funds to pay for professional development that meets the requirements of Act 20 (training for K5-3 teachers, principals, and district reading specialists)?

First, the LEA should either review an existing school plan (such as a school improvement plan or the Title I schoolwide plan) or develop a school plan with key collaborators (teachers, administrators, families, other school staff) that meets students’ needs. If a strategy to implement plan includes the need to for professional development, then the LEAs must answer, “Yes” to the following questions:

  • Does the curriculum, intervention, or supplementary instructional resource follow a specific scope and sequence?
  • Does the curriculum, intervention, or supplementary instructional resource require the learner to apply their knowledge of phonics to solve an unknown word?
  • Is the purchase an allowable cost for the federal funds identified for use?

Can an LEA use Title I funds to support, in whole or in part, professional development in reading that meets the Act 20 professional development requirement?

LEAs must provide Title I schools enough resources to implement state requirements, and Title I funds must supplement (be in addition to) state and local funds. Title I funds may not be used to supplant (take the place of) state and local funds.

  • Title I Schoolwide School - This may be allowable for school staff (including principals, etc.) if the training meets the needs addressed in the Schoolwide Plan. This is not allowed for district level administrators.
  • Title I Targeted Assistance School - This may be allowable in some circumstances, but costs must be prorated and properly documented. Allowability is based on the teacher’s experience and literacy needs of the Title I students in their classroom. This is not allowed for district level administrators. Please call your Title I Consultant at DPI to discuss.
  • Title I Professional Development Reservation - This may be allowable in rare circumstances and with adequate documentation. Please call your Title I Consultant at DPI to discuss.
  • Title I, Part A Neglected Reservation - This may be allowable but only for the teachers in the institutions and only if the training meets students’ needs. This is not allowed for district level administrators.
  • Title I, Part A Homeless Reservation - No, this is not allowed as it does not meet the purpose of the grant. 20 U.S.C. 6301and 2 C.F.R. 200.403.
  • Grants for CSI or ATSI Schools - This may be allowed for CSI or ATSI identified elementary schools if the cost ties to an EBIS in the school’s approved school improvement plan that addresses the school’s results of their root cause analysis tied to ESSA identification. For district level administrator training, please call your Continuous Improvement Consultant at DPI.

Can an LEA use Title II, Part A funds to support, in whole or in part, professional development in reading that meets the Act 20 professional development requirement?

No, this is not allowed for 5K - 3 teachers. It is supplanting because it’s required in state statute (20 U.S.C. 6691). Costs for professional learning would be allowed for teachers instructing grades 4 and above but the professional learning must address students’ needs.

Can an LEA use Title III, Part A funds to support, in whole or in part, professional development in reading that meets the Act 20 professional development requirement?

No, this is not allowed as it does not meet the purpose of the grant (20 U.S.C. 6812).

Can an LEA use Title IV, Part A funds to support, in whole or in part, professional development in reading that meets the Act 20 professional development requirement?

No, this is not allowed for 5K - 3 teachers. It is supplanting because it’s required in state statute. Costs for professional learning would be allowed for teachers instructing grades 4 and above but the professional learning must address students’ needs and would need to tie these costs back to a Specific, Measurable, Action-oriented, Realistic, Time-based, Inclusion and Equitable (SMARTIE) goal in WISEgrants (20 U.S.C. 7120). 

Can an LEA use Title V - Rural and Low-Income School (RLIS) funds to support, in whole or in part, professional development in reading that meets the Act 20 professional development requirement?

No, this is not allowed. It is supplanting because it’s required in state statute (20 U.S.C. 7355a).

Can an LEA use EHCY Grant funds to support, in whole or in part, professional development in reading that meets the Act 20 professional development requirement?

No, this is not allowed as it does not meet the purpose of the grant (2 C.F.R. 200.403).

Can an LEA use IDEA funds to support, in whole or in part, professional development in reading that meets the Act 20 professional development requirement?

  • IDEA Flow-Through - This is not allowed for general education staff as it is not an excess cost of special education. This may be an allowable cost for special education staff.
  • IDEA Preschool Funds - This is not allowed for general education staff as it is not an excess cost of special education. This may be an allowable cost for special education staff.
  • IDEA Title I Schoolwide Set Aside - This may be an allowable cost for school staff (principals, etc.) if the training meets the needs addressed in the Schoolwide Plan.
  • IDEA Voluntary CEIS Funds - This may be an allowable cost if the training meets the needs of the students who have been screened and identified for not meeting academic benchmarks AND The LEA did not use any other federal funds (including Title I) for the same cost in the current or prior year.
  • IDEA Comprehensive CEIS (This funding is available to LEAs identified as Racially Disproportionate in Special Education.) - This may be an allowable cost if the cost qualifies as an EBIS addressing the LEA's results of their root cause analysis tied to the identified student group.

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Funding Act 20 Professional Development for Equitable Participation in Private Schools

Can a Private School use Title I, Part A funds to support, in whole or in part, professional development in reading that meets the Act 20 professional development requirement?

Title I services in private schools are student specific (not school specific). If this is necessary to address Title I students’ needs, LEAs will need to follow the guidelines for Title I targeted assistance in public schools.

Can a Private School use Title II, Part A funds to support, in whole or in part, professional development in reading that meets the Act 20 professional development requirement?

This may be allowable if science-based literacy instruction will meet the academic needs of the students AND teachers need professional development for this purpose, then the LEA may use the equitable share from Title II to cover those costs.

Can a Private School use Title III, Part A funds to support, in whole or in part, professional development in reading that meets the Act 20 professional development requirement?

This is not allowed. This does not meet the purpose of the grant (20 U.S.C. 6812).

Can a Private School use Title IV, Part A funds to support, in whole or in part, professional development in reading that meets the Act 20 professional development requirement?

This may be allowable if science-based literacy instruction will meet the academic needs of the students AND teachers need professional development for this purpose, then the LEA may use the equitable share from Title IV to cover those costs.

Can a Private School use IDEA funds to support, in whole or in part, professional development in reading that meets the Act 20 professional development requirement?

This is not allowed. This does not meet the purpose of the grant (2 C.F.R. 200.403).

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Personal Reading Plans

Can an LEA use Title I, Part A funds to support the costs to implement personal reading plans for 5K-3 students?

LEAs must provide Title I schools enough resources to implement state requirements, and Title I funds must supplement (be in addition to) state and local funds. Title I funds may not be used to supplant (take the place of) state and local funds.

  • Title I Schoolwide School - This may be allowable if the costs meet the needs addressed in the Schoolwide Plan.
  • Title I Targeted Assistance School - This may be allowable if the costs address the identified needs of identified Title I students who have reading needs and costs must be prorated.
  • Title I, Part A Centralized Service Reservation - This may be allowable if all the schools in the LEA are served Title I Schoolwide programs; AND the cost(s) are for all the elementary schools; AND the cost(s) address the needs addressed in the Schoolwide Plans.
  • Title I, Part A Neglected Reservation - This may be allowable if the cost(s) addresses the identified needs of students living in neglected facilities.
  • Title I, Part A Homeless Reservation - The LEA must exhaust all other funding sources first and document that no other funding is available. This may be allowable if the cost(s) addresses the identified needs of students experiencing homelessness including those students attending non-Title I schools.
  • Grants for CSI or ATSI Schools - This may be allowable for CSI or ATSI identified elementary schools if the cost(s) ties to an EBIS in the school’s approved school improvement plan that addresses the school’s results of their root cause analysis tied to ESSA identification. Contact your Continuous Improvement Consultant to discuss further.

Can an LEA use Title II funds to support the costs to implement personal reading plans for 5K - 3 students?

No, this is not allowed as it does not meet the purpose of the grant (20 U.S.C. 6691).

Can an LEA use Title III funds to support the costs to implement personal reading plans for 5K - 3 students?

No, this is not allowed. It is supplanting because it’s required in state statute. If a student is an English learner and has a personal reading plan, local funds must be utilized to support the personal reading plan (20 U.S.C. 6812).

Can an LEA use Title IV, Part A funds to support the costs to implement personal reading plans for 5K - 3 students?

No, this is not allowed. It is supplanting because it’s required in state statute (20 U.S.C. 7120).

Can an LEA use Title IV, Part B (21st CCLC) funds to support the costs to implement personal reading plans for 5K - 3 students?

No, this is not allowed. It is supplanting because it’s required in state statute (20 U.S.C. 7174(b)(2)(G)).

Can an LEA use Title V - RLIS funds to support the costs to implement personal reading plans for 5K - 3 students?

No, this is not allowed. It is supplanting because it’s required in state statute (20 U.S.C. 7355a).

Can an LEA use IDEA funds to support the costs to implement personal reading plans for 5K - 3 students?

  • IDEA Flow-Through Funds - This may be allowable if the costs are used to provide specialized reading instruction to students with disabilities per the students’ Individualized Education Programs (IEPs).
  • IDEA Preschool Funds - This may be allowable if the costs are used to provide specialized reading instruction to students with disabilities (who are age 5) per the students’ IEPs.
  • IDEA Title I Schoolwide Set Aside - This may be allowable if the costs address the needs addressed in the schoolwide plan.
  • IDEA Voluntary CEIS Funds - This may be allowable if the LEA did not use any other federal funds (including Title I) for the same costs in the current or prior year.
  • IDEA Comprehensive CEIS (This funding is available to LEAs identified as Racially Disproportionate in Special Education.) - This may be allowable if the costs qualify as an EBIS addressing the LEA's results of their root cause analysis tied to the identified student group.

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