Comprehensive School Reform Program

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Guidance on the Comprehensive School Reform Program
Updated August 2002
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G. Local Use of Funds

G-1. For which of its schools may an LEA apply for CSR funds?

CSR funds awarded to an LEA under Title I, Part F may be used only in schools that are eligible for assistance under Title I, Part A. Funds awarded under the FIE authority may be used for comprehensive school reform programs in any school, whether or not it is eligible for Title I, Part A assistance.

G-2. For what activities may a school use CSR funds?

A school may use CSR funds to support the costs associated with implementing the reform program it has designed, and SEAs and LEAs should work with schools to ensure that they implement a coherent set of activities that incorporates the eleven components of the legislation.

However, CSR funds are not intended to support fully all aspects of a school's reform efforts. Rather, in implementing comprehensive reforms, a school must determine how all available Federal, State, local and private resources can be used to coordinate services that will support and sustain comprehensive reform efforts. Thus, schools with comprehensive school reform programs must, from their inception, consider how those programs will be maintained after CSR funding expires.

G-3. May a school apply for additional funding through a new competition after receiving funds for three years?

No. The Comprehensive School Reform program operates on the premise that three years of funding is sufficient to launch a well-prepared school in its reform efforts. If a school is clear about its needs when it receives CSR funds and has designed a comprehensive program to address them, the three-year funding period allows time for strengthening infrastructures and aligning and reallocating resources. By the end of three years of CSR funding, schools should have made significant progress in institutionalizing reform and are no longer eligible for CSR start-up funds.

G-4. Must CSR funds be used to supplement other Federal, State, and local funds?

Yes. CSR funds must supplement, and not supplant, funds that LEAs and schools otherwise receive. Unlike most provisions that address this issue, the CSR supplanting prohibition applies to Federal funds as well as State and local funds. An SEA or LEA may not decrease the resources that would otherwise be available from Federal, State, or local sources because that school is receiving CSR funds.

G-5. How long are CSR funds available for obligation by SEAs and LEAs?

SEAs and LEAs can initially obligate CSR funds from the time they become available through September 30 of the following fiscal year, a fifteen-month period. If unobligated funds remain after this initial period of availability, the Tydings Amendment provides SEAs and LEAs with an additional twelve-month period to obligate the funds. For example, CSR funds that become available on July 1, 2002 remain available for obligation through September 30, 2004.

G-6. What constitutes an obligation of funds?

SEAs and LEAs must obligate CSR funds during the period of fund availability. An SEA's awarding of a subgrant does not constitute an obligation. Funds are obligated only when they are committed to specific activities.

The Department's regulations at 34 CFR 76.707 describe when an obligation occurs with respect to various categories of activities:

??76.707 of the Education Department's General Administrative Regulations (EDGAR)
When Obligations Are Made

If the obligation is for --

The obligation is made-

(a) Acquisition of real or personal property

On the date on which the State or subgrantee makes a binding written commitment to acquire the property

(b) Personal services by an employee of the State or subgrantee

When the services are performed

(c) Personal services by a contractor who is not an employee of the State or subgrantee

On the date on which the State or subgrantee makes a binding written commitment to obtain the services

(d) Performance of work other than personal service

On the date on which the State or subgrantee makes a binding written commitment to obtain the work

(e) Public utility services

When the State or subgrantee receives the services

(f) Travel

When the travel is taken

(g) Rental of real or personal property

When the State or subgrantee uses the property

(h) A preagreement cost that was properly approved by the State under the cost principles identified in 34 CFR 74.171 and 80.22

On the first day of the subgrant period

G-7. What is the appropriate LEA subgrant period for CSR awards?

CSR legislation identifies no specific initial subgrant period for LEAs; each SEA defines its own award period, consistent with its regulations. In general, SEAs should make the initial grant period long enough to give schools time to obligate CSR funds in a timely, yet responsible, way. It is also important that LEAs and schools have sufficient time to complete their necessary planning and prepare comprehensive reform designs before applying for CSR funding.

G-8. May pre-award costs be charged to the CSR grant?

The legitimacy of charging costs to the CSR grant depends on when the charges are incurred. If a school incurs costs related to its CSR program after being notified that it will receive CSR support, but before the subgrant has been awarded, CSR funds may absorb these costs, assuming that they are allowable expenses. The SEA must provide written approval of this use of funds.

However, if costs are incurred before the school is notified that it will receive CSR support, those costs may not be charged to CSR. They must be viewed as costs that would have incurred whether or not the grant was awarded. Using CSR funds to pay for these costs would violate the supplanting prohibition that applies to CSR funds.

G-9. Can an SEA permit an LEA to carry over unobligated CSR funds from one year to the next?

Yes. If a school fails to use its entire grant award within the initial grant period, an SEA may permit the LEA to carry over the unobligated CSR funds and to use those funds through the end of the Tydings period of fund availability. (See G-5.) Alternately, the SEA may redistribute the unobligated funds to support activities at other CSR sites. If a CSR school is making substantial progress in reform implementation, an SEA must not reduce the school's award below the minimum amount needed to support the initial costs of comprehensive school reforms. As stated previously, this minimum award amount may not be less than $50,000 annually for three years. (See F-6.)

G-10. May a school that is in the early planning stages of comprehensive reform and has not yet completed the design of its comprehensive reform program receive CSR support to continue this planning?

No. CSR funds are intended to support the implementation of comprehensive school reform programs, not the prior planning that is needed to create them. In order to apply for a CSR grant, a school must complete an in-depth needs assessment and analysis and design a comprehensive school reform program for schoolwide change.

G-11. May a school that has already begun to implement a reform program with other Federal, State and local funds receive CSR support?

The purpose of the CSR legislation is to stimulate schoolwide change in schools that need to substantially improve student achievement, particularly Title I schools. If such a school has made some attempts at reform, but those improvements are not comprehensive and are isolated from each other, then CSR funds could provide the incentive needed to take that school from partial reform to whole school reform. However, before an LEA applies for CSR funding on behalf of such a school, the school must create a comprehensive program that addresses the eleven components required by the CSR legislation. In short, the school must be committed to whole school reform, and must have created an implementation design to achieve it before it can be eligible for a CSR grant.

G-12. May a school use CSR funds to pay or reimburse a proposal-writing firm for developing a school's application?

No. LEAs and schools may not use CSR funds to cover the cost of proposal development, nor may they reimburse themselves for those costs after they receive a CSR award. CSR funds may be used only for necessary and reasonable costs in operating the CSR program.

G-13. Can a Title I targeted assistance school make effective use of CSR funds?

When a targeted assistance school participates in comprehensive school reform, its Title I, Part A funds must still be used in accordance with the Title I, Part A requirements--i.e. for supplemental activities for eligible children in greatest need of assistance.

This limitation, however, should not interfere with a school's ability to implement comprehensive school reform using CSR funds and other resources. The learning activities in CSR schools that are funded by Title I, Part A to address the needs of the school's eligible children can be integrated into a comprehensive program that is designed to bring all students to high standards.

G-14. If a school that has received CSR funding determines, in consultation with its LEA, that it needs to make major revisions to its whole school reform program, can this school continue to receive CSR funds?

When applying for CSR funds, the school's primary goal must be to help all children meet challenging State academic content and achievement standards. By working with their LEAs and external technical assistance providers, and by completing the essential preparation work prior to applying for funds, most schools will make satisfactory progress in implementing comprehensive reforms and see positive results. Careful monitoring of implementation will help CSR schools and their districts to identify problems early on and seek solutions.

If the plans and strategies initially proposed fail to meet expectations, the school and its LEA should analyze the causes of the deficiencies, correct the problems, and, with the permission of the SEA, adjust the original plan. The SEA should review the school's new proposal, applying the same competitive criteria applied to other applications during the sub-granting process. SEAs must determine if the school's alternative program is truly comprehensive, shows strong evidence that it will significantly improve the academic achievement of participating children, and that it meets all of the other CSR legislative requirements before it can make a decision about continued funding.

G-15. May a school that failed to make substantial progress and did not receive three years of funding reapply to receive CSR funds?

If a school fails to make sufficient progress in reform implementation, the SEA discontinues its CSR funding. If the school reevaluates its needs assessment, reassesses its strategies, and increases its internal capacity to undergo schoolwide, comprehensive reform, it may reapply for CSR funding through its LEA. The State should consider the quality and comprehensiveness of this school's application as it does other subgrant proposals.

G-16. To what extent may waivers be sought to facilitate the implementation of a school's comprehensive school reform plan?

Consistent with waiver provisions as outlined in section 9401 of the ESEA, a school that receives CSR funds may apply for waivers of requirements of the CSR legislation and of other major Federal education program legislation if those requirements impede the school's ability to carry out its comprehensive school reform program.

A school in an Ed-Flex State would apply directly to its SEA for a waiver. A school in a non-Ed-Flex State would apply for a waiver, through its LEA, to the Department.

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Last Modified: 12/03/2004