1
CIFR PRACTICE GUIDE
Developing Wrien Procedures for the
Allocation of IDEA Part B Subgrants to
Local Educational Agencies
CIFR Practice Guides assist states and other stakeholders to beer understand how states may
implement fiscal reporting requirements set forth in the Individuals with Disabilities Education
Act (IDEA). The guides may be developed in collaboration with other national technical assistance
centers. This informal guidance does not represent an interpretation of IDEA by the Oce of
Special Education Programs (OSEP) or the U.S. Department of Education.
Background
The federal government provides funding through two types of IDEA Part B grants to
states and territories that then flow to local educational agencies (LEAs) as subgrants.
Every eligible state or territory receives an annual federal grant under IDEA, called an
IDEA section 611 grant, to support special education and related services for children
ages 3 through 21. All 50 states (as well as the District of Columbia and Puerto Rico)
also receive IDEA section 619 grants, which are IDEA funds to support the education of
children ages 3 through 5.
Each state educational agency (SEA) may reserve a portion of its IDEA section 611 and
section 619 grants for administrative and other state-level activities. Aer reserving grant
funds for state-level activities, SEAs must use a specific formula to allocate the remaining
funds as subgrants to LEAs, including charter school LEAs. This formula, required by
IDEA regulations, consists of a base payment amount and amounts that are determined
by student population and poverty measures for each LEA. The formula is applied
separately to IDEA section 611 and section 619 subgrants. More information can be found
in the Center for IDEA Fiscal Reporting (CIFR) Quick Reference Guide on the Allocation of
IDEA Part B Subgrants to Local Educational Agencies.
Purpose
CIFR recommends that each state develop high-level wrien procedures that describe
how the state allocates IDEA Part B subgrants to LEAs in accordance with 34 CFR
§§300.705 (subgrants of IDEA section 611 funds) and 300.815 and 816 (subgrants of IDEA
section 619 funds). High-level procedures do not typically provide details about internal
The Center for IDEA Fiscal
Reporting helps states improve
their capacity to report special
education fiscal data. The center
is a partnership among WestEd,
American Institutes for Research
(AIR), Technical Assistance
for Excellence in Special
Education (TAESE) at Utah State
University, and Westat.
The contents of this document
were developed under a grant
from the U.S. Department of
Education, #H373F140001.
However, these contents do
not necessarily represent the
policy of the U.S. Department
of Education, and you should
not assume endorsement by the
Federal Government. Project
Ocer: Daniel Schreier.
July 2018
CIFR PRACTICE GUIDE
Developing Allocation Procedures
2
processes but are intended to help state sta who are new to allocating Part B funds, as well as sta who need an
overview of the state’s allocation procedures, understand and implement the actions necessary to demonstrate how the
state complies with IDEA requirements for allocating subgrants to LEAs.
High-level procedures also can be shared with external stakeholders — such as LEA superintendents and business
ocers, state legislators, and auditors — to build understanding of subgrant allocation and help document compliance.
This practice guide is designed to help states develop these high-level wrien procedures. Specifically, the guide
provides guiding questions, sample language, and related resources for states to consider when developing their wrien
procedures. The guide may also be helpful in evaluating whether existing state procedures address the recommended
content and guiding questions. If you have questions or need help when developing or reviewing your state’s wrien
procedures, please reach out to CIFR (cifr_info@wested.org).
Please note that this resource focuses on the broad principles that guide the state's allocation of IDEA Part B subgrants
to LEAs and is not intended to replace a step-by-step internal process manual that details how state sta calculate
and allocate the subgrants. Such a manual should provide detailed information on the internal processes and controls,
including how to update the state's spreadsheet or other soware used to calculate the subgrants. By nature, this type
of manual must be intensely individualized by state. CIFR sta are available to help individual states develop a more
detailed document to ensure accurate and sustainable implementation.
Although the purpose and target audience dier between high-level wrien procedures and internal process manuals
(table 1), both documents, when developed and implemented correctly, help ensure:
ƍ LEAs receive the correct amount of IDEA subgrants.
ƍ Continuity of operations.
ƍ Consistent practice over time.
ƍ Consistent communication among partners.
ƍ The use of valid and reliable data.
Both sets of documentation could be submied to the Oce of Special Education Programs (OSEP) as part of fiscal
monitoring of the state.
Table 1: High-level procedures and internal process manual: Audience and purpose
Allocations documentation Audience Purpose
High-level procedures
Internal and external
stakeholders
Demonstrate compliance with
IDEA requirements and build
stakeholder understanding.
Internal process manual
State educational agency
(SEA) sta
Document detailed internal
processes and responsibilities for
implementing regulations and
high-level procedures.
CIFR PRACTICE GUIDE
Developing Allocation Procedures
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Using This Practice Guide to Develop State Procedures
This practice guide provides a model to help individual states develop their high-level procedures and is organized by
eight recommended components:
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1: Purpose of and Authority for Procedures
2: Applicability of Procedures to Eligible LEAs, including Eligible Charter School LEAs
3: Sta Responsibilities and Timeline for Calculating and Allocating Subgrants to LEAs
4: IDEA Part B Base Payments
5: Base Payment Adjustments
6: Allocations Calculated Using Student Population and Poverty Measures
7: Reallocation of Available Funds
8: IDEA Section 619 Subgrants to LEAs when the State Award Is Below the 1997 Funding Level
Each component section contains the following:
ƍ Brief description of the component.
ƍ Guiding questions that a state may use when draing or evaluating procedures.
ƍ Sample starter language designed to help states begin to respond to some of the guiding questions.
ƍ Related resources.
Many of the guiding questions in this practice guide are adapted from sample questions in OSEP’s Part B OSEP 2017
Fiscal Monitoring Protocol: LEA Allocations. Responding to the guiding questions may help states ensure that wrien
procedures meet OSEP’s expectations.
Please note that the sample language included in this guide provides examples of how a state may begin to address one
or two of the guiding questions related to a component and is not intended to be comprehensive for any particular
component. Because states dier considerably in the procedures they use to implement IDEA’s allocation regulations,
we have not included sample language for each question. The sample language should be used only as a starting point
to develop or revise procedures. State sta responsible for allocating IDEA Part B subgrants should carefully consider
each guiding question and develop their own responses that meet the needs of their state. Those responses should include
citations of and links to relevant state statutes, rules, and other documents that support the procedures.
Within each component section, notes to practice guide users are indicated in italics. Brackets are used to denote language
that should be updated to be state-specific (e.g., [state] or [state department of education (SDE)]).
Related Resources
Related resources are included at the end of each recommended component. As states use this guide to develop
state-specific procedures, they may wish to link to these resources as well as other state-specific resources. All of the
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This guide oers a suggested organization of the recommended components; however, states may find that a dierent way of
organizing beer reflects their allocation processes and calculations.
CIFR PRACTICE GUIDE
Developing Allocation Procedures
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referenced resources and tools in this practice guide can be accessed through CIFR’s catalog of resources on allocation
of IDEA Part B subgrants to LEAs at hps://cifr.wested.org/resources/allocation-of-idea-part-b-subgrants-to-leas/.
In addition, the links at the end of each component in this practice guide lead to the full text of related IDEA, Every
Student Succeeds Act (ESSA), and Education Department General Administrative Regulations (EDGAR) regulations on
the Electronic Code of Federal Regulations website, hps://www.ecfr.gov/, that provides updated regulatory language.
For United States Code (statutory) citations, links are provided to the Oce of the Law Revision Counsel’s United States
Code website, hp://uscode.house.gov/.
Recommended Components of High-Level
Wrien Procedures
CIFR recommends that wrien allocation procedures address the following components:
1: Purpose of and Authority for Procedures
2: Applicability of Procedures to Eligible LEAs, including Eligible Charter School LEAs
3: Sta Responsibilities and Timeline for Calculating and Allocating Subgrants to LEAs
4: IDEA Part B Base Payments
5: Base Payment Adjustments
6: Allocations Calculated Using Student Population and Poverty Measures
7: Reallocation of Available Funds
8: IDEA Section 619 Subgrants to LEAs when the State Award Is Below the 1997 Funding Level
Each recommended component — including guiding questions, sample language, and related resources — is described below.
1: Purpose of and Authority for Procedures
This component provides an introduction to the state’s procedures that cite the IDEA requirements for the allocation of
IDEA Part B section 611 and section 619 subgrants to LEAs, and summarizes the content of the wrien procedures.
Guiding Questions Adapted from OSEP’s LEA Allocations Monitoring Protocol
ƍ What federal regulations govern the SEA’s allocation of IDEA subgrants to LEAs?
ƍ Besides the federal regulations, are there additional state requirements these procedures must address?
ƍ What state statute gives the SEA authority to govern how the SEA allocates IDEA Part B subgrants to LEAs and
other agencies?
ƍ What are the major elements of the annual subgrants to LEAs?
CIFR PRACTICE GUIDE
Developing Allocation Procedures
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Sample Language
Purpose and Authority
The federal authority for these procedures is at 34 CFR §300.705 (subgrants of IDEA section 611 funds) and 300.815 and
816 (subgrants of IDEA section 619 funds). [State’s] authority for making subgrants to other agencies including LEAs is
at [state code citation(s)].
[State] receives federal grants each year under section 611 of IDEA to provide special education and related services
to children ages 3 through 21. The federal determination of the amount of that state grant is outlined in the IDEA
regulations at 34 CFR §300.703. [SDE] receives SEA allocation tables from OSEP, generally by [date]. If [SDE] does not
receive the allocation tables by [date], [SDE] will contact OSEP to determine the status of the allocation tables. Aer
seing aside necessary and allowable amounts for state administration and other state-level activities, [SDE] calculates
and allocates the remainder of the grant as subgrants to LEAs.
In addition, [state] receives an annual grant under section 619 of IDEA. This is a smaller grant that the state receives to
provide special education and related services to children ages 3 through 5. The federal determination of the amount of
that state grant is outlined in the IDEA regulations at 34 CFR §§300.807-810. [SDE] receives SEA allocation tables from
OSEP, generally by [date]. If [SDE] does not receive the allocation tables by [date], [SDE] will contact OSEP to determine
the status of the allocation tables. An IDEA section 619 subgrant may be used for specific activities related to special
education (e.g., child find, evaluations) for children ages 3 through 5 served in preschool or in kindergarten, regardless of
whether they are children with disabilities. LEAs that do or could serve five-year-old children in kindergarten receive
a subgrant under IDEA section 619, even if they have no preschool program.
[SDE] reserves a portion of its IDEA section 611 and section 619 funds for administrative and other state-level activities
(34 CFR §§300.704, 300.812-814). The amounts reserved are restricted by IDEA regulations and reported annually in
[SDE]’s application for federal Part B funds on the OSEP Excel Interactive Spreadsheet provided to each state. This
state-specific worksheet provides the state immediate feedback as to whether the amounts it intends to set aside for
specific activities are in accordance with the limitations of IDEA. OSEP provides the spreadsheet to states annually
upon confirmation of final allocation amounts.
Aer reserving an amount for state-level activities, [SDE] uses a specific formula to allocate the remaining funds as
subgrants to LEAs, including charter school LEAs that submit an application to the state requesting IDEA funds. This
formula, required by IDEA regulations, consists of a base payment amount and amounts that are determined by student
population and poverty measures for each LEA. The formula is applied separately to IDEA section 611 and section 619
subgrants (34 CFR §§300.705, 300.815-817).
These procedures describe how [SDE] allocates annual subgrants to LEAs.
Related Resources
ƍ IDEA Regulations (current full text of these regulations can be found at hps://www.ecfr.gov): 34 CFR §§300.228,
300.703, 300.704, 300.705, 300.807, 300.809, 300.810, 300.812, 300.813, 300.814, 300.815, and 300.816
ƍ Quick Reference Guide on the Allocation of IDEA Part B Subgrants to Local Educational Agencies, CIFR
CIFR PRACTICE GUIDE
Developing Allocation Procedures
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2: Applicability of Procedures to Eligible LEAs, including Eligible Charter School LEAs
This component describes how these procedures, for both IDEA section 611 and section 619 funds, apply to each LEA in
the state, including charter school LEAs.
Guiding Questions Adapted from OSEP’s LEA Allocations Monitoring Protocol
ƍ How is “LEA” defined for the purpose of allocating IDEA Part B funds?
ƍ How does the state determine whether each LEA is eligible for an IDEA Part B subgrant?
ƍ Which LEAs in the state are responsible for providing a free appropriate public education (FAPE) to children with
disabilities ages 3 through 21 and would be eligible for an IDEA section 611 subgrant?
ƍ Which LEAs in the state are responsible for providing FAPE to children with disabilities ages 3 through 5 and
would be eligible for an IDEA section 619 subgrant?
ƍ If the state has charter school LEAs, how do these procedures apply to those LEAs?
ƍ If the state has intermediate units (e.g., educational service agencies) that function as LEAs for the purpose of
IDEA, how do these procedures apply to those intermediate units?
Sample Language
In [state], LEAs that are responsible for providing free appropriate public education (FAPE) to children with disabilities
under IDEA may be eligible to receive IDEA subgrants. This includes school districts, charter school LEAs, educational
service agencies (ESAs) and other state agencies that serve as LEAs and are responsible for providing FAPE to children
with disabilities. These procedures apply to all eligible LEAs in the state, including charter school LEAs. Charter school
LEAs are defined in state regulation at [add state citation]. Under IDEA, charter schools that are not LEAs under state
law are not eligible for an IDEA subgrant (34 CFR §300.209). [SDE] allocates subgrants to charter school LEAs in the
same manner that it allocates subgrants to other LEAs in the state.
LEAs do not need to be currently serving children with disabilities to be eligible for IDEA section 611 and section 619
subgrants. LEAs that serve children ages 3 through 5 are eligible for both IDEA section 611 and 619 subgrants. LEAs do
not need to have preschool programs in order to be eligible for IDEA section 619 subgrants — the subgrants are made
based on the ages of children served, not grade levels. If an LEA could serve 5-year-old children in kindergarten,
regardless of whether the children have disabilities, the LEA is eligible for an IDEA section 619 subgrant. However, if an
LEA is not responsible for educating children ages 3 through 5, such as an LEA with only a high school, it is not eligible
for an IDEA section 619 subgrant.
To receive IDEA section 611 and section 619 subgrants, the LEA must submit an annual Part B application to the state.
The application provides assurances that the LEA meets specific requirements (listed in 34 CFR §300.200 – 213) about
the use of funds and has policies and procedures in place to ensure that children with disabilities receive FAPE. [State]
reviews each LEA’s application according to the internal LEA eligibility application processes. Under 34 CFR §300.221,
an LEA may appeal the state’s determination that the LEA is not eligible for IDEA section 611 or section 619 funds
through the state's appeals process.
Reader note: Each state should have procedures for reviewing LEA applications for IDEA Part B subgrants and
determining whether each LEA is eligible.
LEAs may not subgrant IDEA funds to another LEA. If an ESA serves as an intermediary LEA, Part B funding may
be provided to the ESA, which in turn provides Part B funds to member districts through a contract, interagency
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CIFR PRACTICE GUIDE
Developing Allocation Procedures
agreement, or reimbursement for services provided. The LEA that establishes eligibility under IDEA and receives a
Part B subgrant is the LEA responsible for ensuring Part B requirements are met.
Related Resources
ƍ IDEA Regulations (current full text of these regulations can be found at hps://www.ecfr.gov/): 34 CFR §§300.7,
300.12, 300.28, 300.209(c), and 300.221
ƍ Leer to Hokenson (2013), OSEP
ƍ Dear Colleague Leer to States on Funding Charter Schools, Oce of Special Education and Rehabilitative Services
(OSERS), U.S. Department of Education
3: Sta Responsibilities and Timeline for Calculating and Allocating Subgrants to LEAs
This component provides an overview of the timeline and oce(s) or position(s) responsible for calculating and allocating
IDEA Part B subgrants to LEAs each year.
Guiding Questions Adapted from OSEP’s LEA Allocations Monitoring Protocol
ƍ What is the state’s fiscal year?
ƍ Do state procedures specify the period of availability of IDEA funds, including the obligation and liquidation
deadlines?
ƍ What is the state’s timeline for calculating and allocating Part B subgrants to LEAs?
ƍ Are the timelines the same for IDEA section 611 and section 619 subgrants?
ƍ Are the timelines the same for traditional LEA and charter school LEA subgrants?
ƍ Is there any provision of state law that permits or prohibits retroactive adjustment of funds, including base
payments, beyond the close of the fiscal year?
ƍ Which oces or positions are responsible for implementing these procedures?
ƍ Which oces or positions are responsible for reviewing and verifying the work of others? What specific positions
have final oversight?
ƍ What type of training is provided to the responsible sta, including LEA sta responsible for submiing data used
to calculate subgrants?
ƍ How and when are LEAs notified of their IDEA section 611 and section 619 subgrants (both estimated and final
amounts)?
Sample Language
The [Special Education Oce] is responsible for implementing these procedures. Sta will maintain capacity through
annual training and review of the requirements related to the allocation of Part B subgrants to LEAs.
The period of availability for IDEA subgrants under both IDEA section 611 and section 619 is up to 27 months, from July 1
of the award year until September 30 two years subsequent. This period may be shorter if the LEA does not submit its
subgrant applications within the state’s timelines. This means that federal fiscal year (FFY) 2017 IDEA funds are available
for obligation from July 1, 2017, to September 30, 2019. Funds obligated by September 30, 2019, must be liquidated by
December 30, 2019. See table 2 for the annual timeline, detailed activities, and responsible sta or oce.
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CIFR PRACTICE GUIDE
Developing Allocation Procedures
Table 2: [State’s] annual timeline and activities to allocate IDEA Part B section 611 and section 619 subgrants
Date Activity Responsible sta/oce
By April 1
Receive projected IDEA section 611 and section 619 state
grant amounts from the U.S. Department of Education to
be made available on July 1.
State Special Education Director
and Special Education Finance
Division
By May 1
Publish and open annual LEA application for funds to
determine eligibility for Part B subgrants.
State Special Education Director
By May 1
Request list of new, significantly expanding, and/
or closing charter school LEAs from the State Charter
School Oce. Determine whether base adjustments will
be needed.
Special Education Finance
Division
First Friday in May
Calculate needed preliminary adjustments to base
payments.
Special Education Finance
Division
By May 15 or upon
receipt of final grant
amount from the
U.S. Department of
Education
Calculate preliminary state set-aside amount. Calculate
base payment and population/poverty subgrant amounts
for each eligible LEA. Provide preliminary subgrant
amounts to LEAs for budgeting purposes.
Special Education Finance
Division
By June 1
Review initial LEA applications to determine eligibility
for Part B subgrants. Help LEAs complete applications
and demonstrate eligibility.
Special Education Finance and
Monitoring Divisions
First Friday in June Close annual LEA application. State Special Education Director
July 1
Notify each eligible LEA of the initial annual subgrant
amounts and release partial funds.
State Special Education Director
By August 1
An LEA must notify the state if it is appealing eligibility
for either the IDEA section 611 or section 619 subgrant.
LEA Sta
By September 30 Communicate final decision of any LEA appeals. State Special Education Director
October 1 Release additional funds to LEAs.
Special Education Finance
Division
November 2
Recalculate IDEA section 611 and section 619 subgrants
for each eligible LEA, including eligible new and
expanding charter school LEAs using current year
data. Adjust amounts including recovering from and
redistributing to LEAs as needed.
Special Education Finance
Division
March 1
Complete final subgrant calculations for each eligible
LEA, including eligible new and expanding charter
school LEAs using current year data and adjust the
subgrants. These redistribution steps must be completed
before allocating the following year’s subgrants.
Special Education Finance
Division
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CIFR PRACTICE GUIDE
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Charter School LEA Funding Timelines
Reader note: This section should reference broader state requirements for new and significantly expanding charter school
LEAs, including definitions and timelines established in general for charter school LEAs and not just for special education.
A new or significantly expanding charter school LEA must notify [SDE] at least 120 days before it plans to open or
significantly expand.
If a charter school LEA notifies [SDE] and opens or significantly expands on or before November 1 of the school year,
[SDE] will provide the charter school LEA the full amount of IDEA section 611 and section 619 funds for which it is
eligible for the year, including the base payment amount, within five months of the date the charter school LEA opens
or significantly expands.
If a charter school LEA notifies [SDE] and opens or significantly expands aer November 1 but before February 1, [SDE]
will provide the charter school LEA at least a pro rata portion (based on the opening or expansion date) of the amount
of IDEA section 611 and section 619 funds for which it is eligible for the year, including the base payment amount, on or
before the date the [SDE] allocates funds to LEAs for the succeeding year.
If a charter school LEA opens or significantly expands on or aer February 1, [SDE] will provide the charter school LEA
the proportionate amount of IDEA section 611 and section 619 funds for which it is eligible in the following year, but will
not provide any IDEA section 611 or section 619 funds in the current year.
Related Resources
ƍ IDEA Regulations (current full text of these regulations can be found at hps://www.ecfr.gov/): 34 CFR §§300.221,
300.705, 300.815, and 300.816
ƍ Charter School Expansion Act Regulations (current full text of these regulations can be found at hps://www.ecfr.gov/
under 34 CFR 76 Subpart H)
ƍ Leer to Walk, OSEP
ƍ Oce of Special Education and Rehabilitative Services (OSERS) Frequently Asked Questions about the Rights of
Students with Disabilities in Public Charter Schools under the Individuals with Disabilities Education Act, OSERS
ƍ Nonregulatory Guidance: Allocating Federal Funds to Charter Schools, U.S. Department of Education
4: IDEA Part B Base Payments
This component defines base payments in accordance with 34 CFR §§300.705(b)(1) and (2), 300.816(a) and (b); and describes
the state’s procedures for calculating the base amounts.
Guiding Questions Adapted from OSEP’s LEA Allocations Monitoring Protocol
ƍ Does the state perform separate base payment calculations for IDEA section 611 and section 619 allocations?
ƍ Do the state’s procedures describe how and when the amount of each eligible LEA’s base was calculated? Where
are records on which the base amounts were based maintained?
ƍ How does the state calculate the base amount for IDEA section 619 subgrants to all eligible LEAs, including eligible
charter school LEAs, that:
• Are responsible for providing education to children ages 3 through 5, including preschool programs and
5-year-old children in kindergarten?
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CIFR PRACTICE GUIDE
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• Are responsible for providing education to 5-year-old children in kindergarten, but do not serve children ages
3 through 5 in preschool programs?
ƍ In calculating each LEA’s subgrant, does the state check that the base amount for each LEA remains constant
unless adjusted?
Sample Language
In allocating IDEA Part B subgrants to its LEAs, including charter school LEAs, each fiscal year, [SDE] uses a three-part
formula that consists of (1) a base, including any applicable base adjustments, and amounts calculated using student
(2) population and (3) poverty measures. This section covers procedures for establishing the base payment amount for
each LEA. The statewide total available for the base payments remains constant (except when federal appropriations for
IDEA section 619 fall below the 1997 appropriation level). Individual LEA base payments stay constant from year to year
except in cases where adjustments are required (see “Base Payment Adjustments” section).
The original base payment amount for each eligible LEA was:
ƍ The amount the LEA would have received under IDEA section 611 if [state] had distributed 75 percent of the state’s
FFY 1999 IDEA section 611 grant using the December 1, 1998 child count.
ƍ The amount the LEA would have received under IDEA section 619 if the [state] had distributed 75 percent of the
state’s FFY 1997 IDEA section 619 grant using the December 1, 1996 child count.
Base payment amounts are calculated by the [Special Education Finance Division] and are stored in hard copy in the
[Special Education Finance Division] and on [SDE]’s secure shared network in the IDEA Part B Allocations folder. Base
payment amounts are adjusted as required, according to the circumstances detailed in the “Base Payment Adjustments”
section of these procedures.
Related Resources
ƍ IDEA Regulations (current full text of these regulations can be found at hps://www.ecfr.gov/): 34 CFR §§300.705
and 300.816
ƍ Quick Reference Guide on the Allocation of IDEA Part B Subgrants to Local Educational Agencies, CIFR
ƍ Examples of Adjustments to IDEA Subgrant Base Payment Allocations to Local Educational Agencies, CIFR
5: Base Payment Adjustments
This component describes when and how the state adjusts LEAs’ base payment amounts, including in the case of a new
or significantly expanding charter school LEA.
Guiding Questions Adapted from OSEP’s LEA Allocations Monitoring Protocol
ƍ How does the state determine if LEA base payment adjustments need to be made?
ƍ If base payment adjustments are needed, who makes them, and when?
ƍ What sources of data/information systems does the state rely on for making decisions about base payment
adjustments?
ƍ How does the SEA determine which LEAs are aected by a circumstance requiring a base payment adjustment?
ƍ Once a new LEA, including a new charter school LEA, is formed, how is the base payment adjustment calculated?
ƍ If one or more LEAs are combined into a single LEA, how is the base payment adjustment calculated?
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ƍ If two or more LEAs’ geographic boundaries or administrative responsibility for providing services change
(including when an LEA closes or dissolves), either for children ages 3 through 21 for IDEA section 611, or for
children ages 3 through 5 for IDEA section 619, how is the base payment adjustment calculated for aected LEAs?
ƍ When an LEA that received a base payment of zero in its first year of operation is now serving children with
disabilities, how is the base payment adjustment calculated?
ƍ How does the state define significant expansion of charter school LEAs for the purposes of IDEA?
• Is that definition the same for all federal programs? If no, how does the IDEA definition dier?
ƍ What agency, oce, or board has the authority to grant new charter school LEAs or charter school LEA
expansions?
ƍ How and when does the state learn about new and significantly expanded charter school LEAs?
• Do the state’s procedures specify the dates that base payment adjustments are made depending upon when
the notification is received?
ƍ What are the state’s rules about when, during the year, new charter school LEAs can open?
• Do the state’s procedures describe the options for a newly opened charter school LEA to receive its first IDEA
allocation?
ƍ When an LEA significantly expands in accordance with [SDE]’s definition, how is the base payment adjustment
calculated?
ƍ Is there a process for an LEA to appeal its base payment amount, and if so, what is the process?
Sample Language
In accordance with 34 CFR §§300.705(b) and 300.816, the [Special Education Finance Division] adjusts IDEA section 611
and section 619 base amounts for aected LEAs in any or all of the following circumstances:
ƍ A new LEA, including a new charter school LEA, is created, and is serving children with disabilities.
ƍ Two or more LEAs are combined into a new, single LEA.
ƍ Two or more LEAs have changed geographic boundaries or administrative responsibility for providing services
to children ages 3 through 21 for IDEA section 611, or to children ages 3 through 5 for IDEA section 619, including
when an LEA closes.
ƍ An LEA that received a base payment of zero in its first year of operation is now serving children with disabilities.
In addition, base payment amounts must be adjusted when a charter school LEA significantly expands in accordance
with [SDE]'s ocial definition. Subgrants are made to a new charter school LEA in the same manner they are made to a
new LEA.
[SDE’s] definition of “significantly expanded” charter school LEA requires that the charter school LEA meet one of the
following: adds at least one grade to the charter school LEA or increases the enrollment of the charter school LEA by at
least 20 percent.
Reader note: This is one example of a definition of significant expansion. Each state has the authority to establish a definition
of significant expansion.
Notification of any planned opening or significant expansion must be submied by the charter school LEA to the
[State Charter School Board] by at least 120 days in advance of the date the charter school LEA is scheduled to open
or significantly expand. The [Charter School Division] is responsible for informing the [Special Education Finance
Division] when a new charter school LEA or a significant expansion of a charter school LEA has been approved by the
[State Charter School Board].
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Each year, prior to calculating the LEA allocation amounts under IDEA section 611 and section 619, the [Special Education
Finance Division] reviews its LEAs to determine whether IDEA section 611 or section 619 base payment adjustments are
necessary and which LEAs are aected.
The [Oce of the Commissioner of Education and the SDE Charter School Division] provide the [Special Education
Finance Division] with data on any new LEAs or changes in the configuration of LEAs in the state. When [SDE] determines
that a base payment adjustment is necessary, the LEA that assumes responsibility for children with disabilities must
provide reports to the [Special Education Finance Division] that include the numbers of children with disabilities for
whom responsibility is assumed by the LEA and identify the LEA that would have been responsible for providing FAPE
for each child with a disability. Failure to provide the required data, and to do so in a timely manner, may result in a delay
in the base payment adjustment.
Adjustments are performed separately for IDEA section 611 and section 619 subgrants.
Adjustment Methodology
Reader note: In this section, the state should describe its methodology for how it calculates base payment adjustments. For
methodology options, please see the CIFR Practice Guide: Examples of Adjustments to IDEA Subgrant Base Payment
Allocations to Local Educational Agencies.
Related Resources
ƍ IDEA Regulations (current full text of these regulations can be found at hps://www.ecfr.gov/): 34 CFR §§300.705
and 300.816
ƍ EDGAR Regulations (current full text of these regulations can be found at hps://www.ecfr.gov/): 34 CFR §§76.788,
76.789, 76.791, 76.792, 76.793, 76.794, 76.796, and 76.797
ƍ Charter School Expansion Act Regulations (current full text of these regulations can be found at hps://www.ecfr.
gov/ ): under 34 CFR 76 Subpart H
ƍ Every Student Succeeds Act (ESSA) Statute (current full text of this code can be found at hp://uscode.house.gov/):
20 U.S.C. §7221(e)
ƍ Examples of Adjustments to IDEA Subgrant Base Payment Allocations to Local Educational Agencies, CIFR
ƍ Oce of Special Education and Rehabilitative Services (OSERS) Frequently Asked Questions about the Rights of
Students with Disabilities in Public Charter Schools under the Individuals with Disabilities Education Act, OSERS.
(In particular, see “How Does a State or Local Educational Agency Allocate Funds to Charter Schools that are
Opening for the First Time or Significantly Expanding their Enrollment?”)
6: Allocations Calculated Using Student Population and Poverty Measures
This component describes how the state allocates the remaining IDEA section 611 and section 619 funds using student
population and poverty measures.
Guiding Questions Adapted from OSEP’s LEA Allocations Monitoring Protocol
ƍ At what point in the calculation process does the portion of subgrants based on student population and poverty
occur?
ƍ Do the state’s procedures detail how the state calculates the population and poverty amounts?
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CIFR PRACTICE GUIDE
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ƍ What sources of data/information systems does the state rely on for calculating the population and poverty
amounts?
ƍ What is the procedure for allocating subgrants when an LEA is eligible for a population/poverty payment, but not
for a base payment?
ƍ Is there a process for an LEA to appeal its population and poverty amounts?
ƍ How and when does the state learn about new and significantly expanded charter schools?
• Do the state’s procedures specify the dates that the population and poverty amounts should be revised based
upon when the notification is received?
ƍ What are the state’s rules about when, during the year, new charter schools can open?
• Do the state’s procedures describe the options for a newly opened charter school to receive its first IDEA
allocation including the population and poverty amounts?
Sample Language
Aer subtracting the state set-aside (the amount set aside by the state from the grants for state-level activities) and the
total base payment amount, SDE allocates the remaining IDEA section 611 and section 619 funds according to population
and poverty measures as defined at 34 CFR §§300.705(b)(3) and 300.816(c):
ƍ Allocate 85 percent of any remaining funds to eligible LEAs on the basis of the relative numbers of children
enrolled in public and private elementary schools and secondary schools within the LEA’s jurisdiction.
ƍ Allocate 15 percent of those remaining funds to eligible LEAs in accordance with their relative numbers of
children living in poverty, as determined by the SEA.
The [Special Education Finance Division] calculates the population and poverty amounts by May 15 each year, or
upon receipt of the proposed IDEA section 611 and section 619 (if funds are available) awards from the U.S. Department
of Education, and aer subtracting the state set-aside and base payment amounts. The same data are used to make
calculations for traditional and charter school LEAs. Eligible LEAs that do not receive a base payment are still eligible
for population and poverty subgrants.
Reader note: It is possible that there will not be funds available for the population and poverty allocation for IDEA section 619
subgrants. In that case, LEAs will receive only the base payment amounts. See Component 8 below.
Population calculations are made using the most recent available enrollment data on students enrolled in public and
private elementary and secondary schools in each LEA and student enrollment in a charter school LEA. For new and
significantly expanding charter school LEAs, enrollment data from the year in which they open or expand must be used.
Poverty calculations are made using data on the proportion of children enrolled in the LEA that are eligible for free
and reduced lunch for the most current year available, as obtained from [Federal Programs Unit]. [SDE] requires charter
school LEAs that do not provide school lunch to submit a statement on the number of children that would be eligible if
the charter school LEA participated in the free and reduced lunch program.
The state applies on a uniform basis, across all LEAs, the best data that are available to them on the numbers of children
enrolled in public and private elementary and secondary schools, and the numbers of children living in poverty.
Related Resources
ƍ IDEA Regulations (current full text of these regulations can be found at hps://www.ecfr.gov/): 34 CFR §§300.13,
300.36, 300.705, and 300.817
ƍ Charter School Expansion Act Regulations (current full text of these regulations can be found at hps://www.ecfr.
gov/ under 34 CFR 76 Subpart H)
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CIFR PRACTICE GUIDE
Developing Allocation Procedures
ƍ Leer to Chief State School Ocers on School Lunch Program, OSEP
ƍ Leer to Bass, OSEP
ƍ Oce of Special Education and Rehabilitative Services (OSERS) Frequently Asked Questions about the Rights of
Students with Disabilities in Public Charter Schools under the Individuals with Disabilities Education Act, OSERS
7: Reallocation of Available Funds
This component describes when and how IDEA Part B section 611 and section 619 funds are reallocated.
Guiding Questions Adapted from OSEP’s LEA Allocations Monitoring Protocol
ƍ Does the state generally choose to reserve the maximum amount of its state set-aside funds or reserve less than
the maximum and allocate the remaining funds to LEAs?
• If the state reserves the maximum amount, how does the state plan for any reallocation of funds that are
unused by LEAs?
ƍ What is the process for reallocation of unused Part B funds?
ƍ How does an LEA inform the SEA that funds are not needed and thus are potentially available for reallocation?
ƍ How does an SEA determine if an LEA is adequately providing FAPE to children with disabilities in order to allow
reallocation of funds?
ƍ How does the SEA determine that LEAs receiving the reallocated funds are not adequately providing special
education and related services to all children with disabilities (or all children with disabilities ages 3 through 5 if
reallocating IDEA section 619 funds) residing in the areas served by the receiving LEAs?
Sample Language
Each year, [SDE] determines an amount of funds to set aside from its federal Part B state award for state-level activities
as allowed by 34 CFR §300.704 and 300.813-814. [State] generally sets aside [X percent] of the maximum amount of funds
for state-level activities from its IDEA section 611 grant and does not set aside funds from its IDEA section 619 grant.
If [SDE] determines that an LEA is adequately providing FAPE to all children with disabilities residing in the area served
by that agency with state and local funds, the SEA may reallocate any portion of the funds under this part that are not
needed by that LEA to provide FAPE.
[SDE] may make the reallocation decision based on information gathered through its general supervision system or based
on notification from an LEA that it is providing FAPE but will not use the full amount of its allocation. If [SDE] receives
notification that an LEA will not use its funds, it consults with the [Special Education Monitoring Division] to determine
if the LEA is adequately providing FAPE to children with disabilities.
When the [SDE] determines that the LEA is adequately providing FAPE, it may:
ƍ Reallocate the unused funds to eligible LEAs that are not adequately providing special education and related
services to children with disabilities (reallocation is required if the state set aside the maximum amount for state-
level activities).
ƍ Use the funds for allowable state-level activities if the state did not set aside the maximum amount for state-level
activities, up to the point where the maximum amount is reached.
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CIFR PRACTICE GUIDE
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[Special Education Finance Division] consults with the [Special Education Monitoring Division] to determine whether
an LEA is not adequately providing special education and related services to children with disabilities and is eligible to
receive reallocated funds.
If [SDE] determines that one or more LEAs are not adequately providing special education and related services to children
with disabilities, it will reallocate funds to those LEAs based on multiple factors including the amount of funds needed to
adequately provide special education and related services, child count, or corrective actions required by the state.
Related Resources
ƍ IDEA Regulations (current full text of these regulations can be found at hps://www.ecfr.gov/): 34 CFR §§300.227,
300.704, 300.705, and 300.817
8: IDEA Section 619 Subgrants to LEAs when the State Award Is Below the FFY 1997
Funding Level
This component describes how the state allocates IDEA section 619 subgrants to LEAs when the state’s federal IDEA
section 619 award is below the amount allocated in FFY 1997.
Guiding Questions Adapted from OSEP’s LEA Allocations Monitoring Protocol
ƍ What was the amount of the FFY 1997 federal IDEA section 619 award to the state?
ƍ How will the state make IDEA section 619 subgrants to LEAs if the state’s federal IDEA section 619 award is below
the amount allocated in FFY 1997?
ƍ Does the state generally choose to reserve the maximum amount of its state set-aside IDEA section 619 funds or
reserve less than the maximum and allocate the remaining funds to LEAs?
Sample Language
The amount of [state]’s FFY 1997 federal IDEA section 619 award was [$XXX,XXX]. In any year when the federal IDEA
section 619 award to the state is below that level, special circumstances apply to how the state allocates IDEA section 619
subgrants to LEAs. There are three possible cases, each described below.
ƍ If, aer the state set-aside amount is subtracted from the total IDEA section 619 award, the amount available for
making IDEA section 619 subgrants is less than 75 percent of the state’s FFY 1997 IDEA section 619 award, then
the state will:
• Ratably reduce each LEA’s base payment by the percentage of the reduction in the total amount actually
available for making base payments.
• Aer making base payments, if necessary, make base adjustments using the ratably reduced base payments.
The state will not have any remaining IDEA section 619 funds available aer making base payments, and,
therefore, will be unable to make population/poverty payments from IDEA section 619 funds.
ƍ If, aer the state set-aside is subtracted from the total award, the amount available for making IDEA section 619
subgrants is equal to 75 percent of the state’s FFY 1997 IDEA section 619 award, then the state will:
• Make base payments and, if necessary, base payment adjustments in accordance with 34 CFR §300.816(a)
and (b).
The state will not have any remaining IDEA section 619 funds available aer making base payments, and,
therefore, will be unable to make population and poverty payments from IDEA section 619 funds.
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CIFR PRACTICE GUIDE
Developing Allocation Procedures
ƍ If, aer the state set-aside is subtracted from the total award, the amount available for making subgrants is greater
than 75 percent of the state’s FFY 1997 IDEA section 619 award, then the state will:
• Make base payments and, if necessary, base payment adjustments, and then allocate any remaining funds
using population and poverty measures in accordance with 34 CFR 300.816(c).
Related Resources
ƍ IDEA Regulations (current full text of these regulations can be found at hps://www.ecfr.gov/): 34 CFR §§300.810,
300.815, and 300.816
ƍ Budget History Tables, U.S. Department of Education: hps://www2.ed.gov/about/overview/budget/history/
index.html (see 1997 grant awards for Special Education – Preschool Grants on page 19)
Conclusion
This practice guide provides recommended content for individual states to consider when developing wrien procedures
that describe how the state allocates IDEA Part B subgrants to LEAs.
We recommend that states use the guiding questions to dra and evaluate procedures that reflect the state’s unique
context. The sample language provides text that should be modified for specific states and expanded upon to describe
how the state addresses each component. Because states dier in their procedures for allocating IDEA Part B subgrants
to LEAs, each state that uses this guide will have unique wrien procedures. CIFR technical assistance sta are
available to help state sta consider each guiding question and develop state-specific responses. Please contact CIFR
(cifr_info@wested.org) for assistance.
Many CIFR sta contributed to this work. Sara Doutre led the development team. Carol Cohen, Deborah Morrow, Tom Munk, and Steven Smith were
contributing authors. Sanjay Pardanani was production coordinator. CIFR co-directors Cecelia Dodge, Jenifer Harr-Robins, and Dave Phillips guided its
development.
Suggested Citation: Center for IDEA Fiscal Reporting. (2018). Developing wrien procedures for the allocation of IDEA Part B subgrants to local educational
agencies. San Francisco, CA: WestEd.