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Improving America's Schools Act (IASA)

New Jersey Department of Education
Improving America’s Schools Act (IASA)
Local Education Agency (LEA) Consolidated Application
Fiscal Year 2000

Frequently Asked Questions


Application Questions

General

Q1: Where can LEAs access the IASA application and guidelines?

A: The application, guidelines and this frequently asked question document are available on the NJDOE website (http://www.state.nj.us/education; Select grants; Select entitlement; Select Improving America’s Schools Act).

Q2: What is the due date for submission of the IASA application?

A: The IASA application is due for submission to the county office of education and to the Office of Grants Management and Development (OGMD) on August 20, 1999. Any IASA application that is date stamped or post-marked after November 1, 1999 will not be considered for IASA funding during the 2000 fiscal year. This does not prohibit an applicant from filing in subsequent years.

Q3: Can the LEA board of education approve an incomplete application so the LEA can meet the submission deadline?

A: No. The LEA board of education can only approve an application that is ready for submission to the Department of Education. The board of education must be in agreement with the content of the application prior to submission. If an application is incomplete, the board of education could not certify its agreement with the entire application.

Q4: If the application is completed and ready for submission but the LEA board of education will not be meeting until after the submission due date, can the application be submitted anyway?

A: Yes. The completed application may be submitted without prior board approval. The minutes or a copy of the board resolution from the board meeting at which the application submission is approved must be forwarded to both the county office of education and OGMD. Approval of the application cannot proceed without this board approval.

Q5: Which application pages are required for submission this year (FY 2000) if the LEA is not making any changes in the program?

A: Not all application pages need to be submitted on an annual basis if no changes have been made in this application year. The pages that do not need to be submitted annually are clearly noted in a text box at the top of each page of the application.

Fiscal

Q6. After the Title Page Funds Requested Worksheet is completed, why doesn’t it match the title summary page of the consortium applicant?

A. Since each participant LEA must complete a worksheet, it reflects the funds of the participant LEA, not the funds of the consortium applicant.

Q7: When are the Final Reports due and will the LEA be notified of the due date in advance?

A: The Final Report for the FY 1999 grant is due on December 10, 1999 and for FY 2000, it is due on December 11, 2000. Final Report information is located in the FY 2000 IASA Guidelines, pages 81-88. The required forms for the Final Report are: Title Page; Status Report; Budget Statement; Budget Detail; and Federal Equipment Inventory (if necessary). These forms are located in the FY 2000 IASA Guidelines-Appendix N. Final Reports for the FY 1998 approved carry-over are due on December 10, 1999. All documents are available on the NJDOE website.

Q8: Can LEAs use carry-over funds to pay for the TPAF/FICA costs for the next fiscal year?

A: No. Since the FY 2000 IASA Application is due prior to the FY 1999 Carry-Over Application, it is not possible to verify the appropriate percentages and the amount of TPAF/FICA to be charged.

Q9: For FY 1999, the adjusted TPAF/FICA percentage is 14.13%. Since this amount exceeds the 12% that has been required to be allocated in FY2000, what percentage should the LEA use for FY 2000?

A: The LEA must budget at least 12% as per the FY 2000 IASA Guidelines or may budget up to 14% as per the adjusted FY 1999 rate and make the necessary adjustments in the spring of 2000 when the notification of the actual percentage is determined. The 12% is used as an estimate for budgeting purposes.

Q10. Must employee benefits be charged to the grant for TPAF salaried staff?

A. Yes. A minimum of 12% of each salary must be budgeted for these employees. For those employees who work beyond their base salary, 7.65% must be budgeted for FICA.

Q11. Does the 12% allocated for benefits include health and dental?

A. No. The 12% is for TPAF/FICA costs only. Any other costs for benefits charged to the grant must be in proportion to the salary charged to the grant.

Q12: If the LEA has a neglected/delinquent (N/D) facility in its jurisdiction and there are unexpended carry-over funds that the N/D facility will not use, does the LEA have access to these funds for public school use?

A: No. Funds allocated for N/D must be utilized for those students eligible for services in the N/D facility. Any unexpended funds may be requested as carry-over for N/D use in the following fiscal year. If any of those carry-over funds are still not expended in the following fiscal year, the funds must be refunded to the NJDOE.

Q13: Should the salary and FICA for the program director and secretary who work beyond their regular work hours to prepare the IASA application be shown on the Title I Eligibility page in row f-administration?

A: Yes. These expenses are considered administrative and must be shown on the Title I Eligibility of Schools form. Administrative costs charged to all Titles should be shown on the Budget Detail-Administrative Costs page.

Q14: What does the term carry-over mean?

A: If grant funds are not obligated by the LEA by the end of the project period for which funds were awarded, the LEA may apply to the NJDOE to expend these funds in the next project period. Funds expended in the next project period are called "carry-over" funds. Carry-over funds are subject to the individual program regulations and guidelines that are in effect during the carry-over period.

Q15: Are there any restrictions for carry-over?

A: Carry-over funds may be expended for allowable costs as specified by the individual Title. Use of these funds is subject to the guidelines in effect for the carry-over project period. The FY 2000 IASA Guidelines, page 81-82, provides specific information regarding carry-over funds. Under Title I, a waiver is required for the carry over of funds in excess of 15% and a waiver can only be approved once every three years. Under Title IV, not more than 25% of the grant award may be used for carry-over without Department of Education approval. Under Titles II and VI, there are no restrictions on the amount of funds that may be carried over into the next project period.

The LEA is not restricted to use carry-over funds in the same budget categories approved in the original application or subsequently approved amendment. Once the total amount of available carry-over funds is known, the LEA may budget these funds according to the needs of the LEA. The LEA must allocate carry-over funds for services that are supported by the program plan. If the program plan does not contain the program activities to be supported during the carry-over project period, the plan may be revised to include these carry-over activities.

The LEA may choose to transfer up to 5% of any unneeded carry-over funds from Titles II, IV and VI to any of the covered Titles. Funds may not be transferred from Title I.

Q16: Why is it necessary for the LEA's business administrator to sign the Budget Detail and Budget Statement pages?

A: The LEA's business administrator is an important participant in the development and fiscal management of the grant. The LEA’s business administrator is also responsible for completing the Final Report and is the lead fiscal contact during the audit process. The business administrator’s signature will insure the correct categorization of funds in accordance with the Generally Accepted Accounting Principles (GAAP).

Q17: What is the allowable amount of administrative costs that may be charged to the grant?

A: A 5.0% limit has been established for the percentage of funds that may be charged for administration for each Title.

Q18. What are the categories most used for administrative costs and calculated in the maximum 5.0%?

A. Salaried positions for secretary/clerk, program director and supervisor are the most commonly used administrative cost categories. More information regarding administrative costs is available on page 66 in the FY 2000 IASA Guidelines.

Q19. Can an LEA pay the costs for substitutes in a private school while the teachers attend a Title II professional development activity?

A. Yes. However, the LEA may provide these substitute services only if the personnel are employed by the LEA or under contract with the LEA.

Q20: What are the requirements for submitting an amendment?

A: An amendment to the approved grant application must be submitted: 1) for changes between expenditure categories (measured cumulatively throughout the project period) in excess of 10% of the total award by Title or $50,000 per Title, whichever is less; 2) when budgeting expenditures in a category for which no funds were previously budgeted or approved; 3) for any changes in the scope of activities being implemented; or 4) approval for Title I-Schoolwide Program designation. An Amendment Application must be submitted to the county office of education (see page 78 and Appendix M in the FY 2000 IASA Guidelines).

The LEA may revise an approved carry-over grant application. The same requirements apply for an amendment to the carry-over as indicated above. The 10% cumulative change is based upon the approved carry-over amount by Title.

Q21: When is the last date that funds may be encumbered and expended?

A: Funds must be encumbered by the last date of the project period (August 31) and liquidated within the next 90 days (November 30). All services must be provided during the project period.

Q22: How are teachers’ salaries shown on the Budget Detail?

A: Teacher salaries for instructional services should be categorized as 100-101, according to GAAP, for the "Function Object Code." The expenditure category is "Salaries of Teachers." The "Description/Itemization" should be as detailed as possible since the allocation of employee benefits depends on the salary description. For example, specify whether the position is for a substitute, summer, or full-time/part-time teacher.

Program Plan

Q23: If the program plan does not change, are the consultation requirements still in effect?

A: Yes. It is important to continue to consult with the LEA’s participant groups to discuss the progress of the three-year plan and to determine if any revisions or changes to the plan are needed. This is a good time to assess the LEA’s progress in meeting the objectives of each of the goals and to evaluate the need to modify or add activities to ensure achievement of the objectives.

Q24: Do the program plan objectives need to be measurable (outcome-based)?

A. Yes. These objectives must be clearly written and based upon the needs of the LEA that were determined during the assessment and reassessment. Measurable objectives are necessary for the LEA to determine if the activities have been effective in achieving the desired outcomes. Establishing annual benchmarks to achieve these objectives is important for the LEA to assess the progress toward meeting the desired outcomes of the program.

Q25. Who is the target population in the IASA Program Plan?

A. The target population may be students, children who attend high poverty schools, migrant, neglected or delinquent, limited English proficient, teachers, parents, private school students or students with alcohol, tobacco and other drug (ATOD) problems. For Title II, the target population may be teachers, administrators, other school staff or parents. However, one of the benchmarks must be based on student achievement. The target population must be identified in the objective.

Q26: If one or two activities are revised or an objective is added, is it permissible to add the additional information without resubmitting the entire program plan?

A: Yes. The district may edit the appropriate program plan page or submit a new program plan page as needed.

Q27: If an LEA received Title I funds last year and is ineligible for Title I this year, does the program plan need to be revised to exclude Title I objectives and activities?

A: The IASA program plan is a three-year comprehensive plan. It is the annual budget that indicates which of the activities is included in the plan that will be supported by the federal funds. The plan does not need to be revised to eliminate the activities previously supported by Title I funds, as the LEA may choose to support the activities using Title I carry-over funds, if available, or funds from one of the other IASA programs. The program plan needs to be revised if the budget is supporting activities that were not previously approved in the three-year plan.

Private Schools

Q28: A private school is closing and has a balance of funds to carry over from the prior year. What happens to those unused funds if most or all of those students will be absorbed into the public school?

A: The funds can only be designated for private school use. Therefore, any unexpended funds must be returned to the NJDOE.

Q29: Can an LEA use unexpended private school funds at the end of the project period?

A. No. The LEA must consult with the private school during the entire process. If there are unexpended private school funds, after consultation, the LEA may request to carry over funds for use by the private school or refund these funds.

Q30: Under what circumstances would a private school not be listed on an LEA's allocation notice?

A. If a private school did not submit a Nonpublic Enrollment Form or, if a form has been submitted and the private school is listed as "for profit," the private school will not be listed on the allocation notice.

Q31: How does the LEA reimburse a private school teacher or a guidance counselor for services provided to private school students? What GAAP account number should be used?

A: The LEA is responsible for the administration of grant funds and may not reimburse a private school. If a teacher or guidance counselor is a salaried employee of the private school and is implementing activities that are allowable under the Titles, that person must develop a purchased contractual relationship with the public school. Examples of GAAP codes are available on the NJDOE website. The public school has fiscal/programmatic responsibilities and the private school has the responsibility to ensure that the appropriate services are provided.

Q32: Is it permissible for public schools to budget small amounts of private school funds in a miscellaneous account instead of using budget categories?

A: No. The LEA must use the correct GAAP account for each budget item.

Q33: How does the LEA obtain drug and violence statistics from the private schools for Title IV?

A: The LEA has a consultation requirement with respect to the private schools. At the time of this consultation, the LEA should request this information directly from the private school. If no data is kept by the private school, the LEA has no further responsibility.

Q34: How does Assurance #32 in the IASA application apply to private schools?

A: Private schools are not required to have a student code of conduct.

Q35: If two LEAs work together to provide Title I services to a private school, which LEA reports the program plan results?

A: Each LEA is responsible for providing equitable services for the respective private school students located within the eligible attendance areas, even if two or more LEAs have combined their resources to provide the services. Therefore, each LEA would indicate the services that it is providing for the private school students on the respective program plan.

Q36: How does a private school become eligible to receive Titles II, IV and VI funds?

A: The private schools must report their enrollment and at-risk data to the Department of Education using the Nonpublic Enrollment Form. The NJDOE's, Nonpublic School Services staff is responsible for the collection of this data.

Q37: Does an LEA need to complete the Title I Program Description and Titles II, IV, VI-Services for Private School Students (Appendix J, page 11) if it is not receiving Title I funds and receives funds for private schools?

A: Yes. The LEA must complete the following columns: "Section One" and "Section Three" on the Title I Program Description and Titles II, IV, VI - Services for Private School Students.

 

Program-Specific Questions

Title I

Q38: To determine eligibility, if LEAs use free and reduced lunch as the poverty indicator, what date should be used as a benchmark to capture this data?

A: If the LEA uses free and reduced lunch data as the poverty indicator, the most current free and reduced lunch data must be used. The most current data is collected by October 15 of the preceding year. Therefore, for the FY 2000 IASA Application (1999-2000), the October 15, 1998 data would be used.

Q39: To determine eligibility, how does the LEA use composite information?

A: The FY 2000 IASA Guidelines, page 35, indicates that an LEA must select a poverty measure from the following options: children ages 5 – 17 in poverty counted in the most recent census data; children eligible for free and reduced-price lunch; children in families receiving AFDC; children eligible to receive medical assistance or a composite of any of these measures. If the LEA selects a composite of poverty criteria, two or more of the poverty criteria may be combined. For instance, the LEA may use AFDC for one school and free and reduced-price lunch for another school.

Q40: To determine eligibility, how does the LEA obtain the necessary information from the private schools?

A: The LEA is responsible for contacting the private schools in writing and consulting with the private school officials before the LEA makes any decision that affects the opportunities of the eligible private school children. The consultation would include the criteria for determining low-income eligibility. If the same criteria of poverty are not available, then the LEA must collect similar data that is comparable and documentable. This data may be obtained through the use of a survey. Appendix H in the FY 2000 IASA Guidelines contains a sample survey form and an accompanying sample letter that may be sent to private school parents.

Q41: If a school in the LEA has less than the LEA average poverty, may low-income or academically deficient students be serviced in that school?

A: An LEA may only serve a school attendance area that is at or above the district level of poverty or above 35 % poverty. The Title I statute requires allocations to be based on the percentage of low-income children in the school attendance area. Therefore, poverty is the only factor on which an LEA may determine funding. In other words, an LEA may not allocate funds based on the instructional model, educational need, or any other nonpoverty factor.

Q42: Schools with a higher than 50% poverty level are eligible to become a Title I schoolwide program. Are there any federal requirements for an individual school to be eligible for a schoolwide program, if it exceeds the poverty-level requirements?

A: No. There are no additional requirements for a school to be eligible to become a schoolwide program. In order for a school to qualify to be a schoolwide program, the federal requirement states that the eligible school attendance area must have at least 50 % low-income children. Any school exceeding the poverty level is also eligible for this designation. See page 101-105 of the FY 2000 IASA Guidelines.

Q43: Is a school required to obtain a schoolwide designation to participate in the Whole School Reform program? Does the school remain a targeted assistance school when it is approved as a schoolwide program?

A: No. The school is not required to obtain a schoolwide designation to participate in the Whole School Reform program. The school does not remain a targeted assistance school when it is approved as a schoolwide program. See page 103 of the FY 2000 IASA Guidelines.

Q44: For LEAs with an approved schoolwide program, does the supplement/supplant requirement and comparability apply?

A: Yes. The supplement/supplant and comparability requirements apply to schoolwide programs. See pages 61 and 103 and Assurance #21 in the FY 2000 IASA Guidelines and Section 1114 of the IASA legislation.

Q45: On the Title I Eligibility of Schools page, should the amount in item F-Administration, agree with the total amount allocated for administrative costs as shown on the Budget Detail-Administrative Costs page?

A: Yes. The administrative costs indicated on the Title I Eligibility page must equal the cost listed on the Budget Detail Administrative Cost page for Title I.

Q46: To determine Title I eligibility, are vocational school students counted by the vocational school or the resident school?

A: Full-time vocational school students are counted by the vocational school, and part-time vocational students are counted by the resident school district.

Q47: After the attendance allocation is satisfied with the all eligible schools in the LEA, can the remaining funds be redistributed to eligible schools in academic greatest need, or are the remaining funds allocated to eligible schools based on the highest poverty level?

A: Funds must be allocated to eligible schools based on the highest poverty level. The LEA must allocate a higher per-pupil amount to those eligible school attendance areas or schools with higher poverty rates than it allocates to areas with lower poverty rates. See answer to Q48.

Q48: Should funds remaining from the program be redistributed?

A: Title I funds should be distributed according to the criteria established in the IASA legislation 1113 with priority given to the schools with the highest poverty rates. The redistribution of funds is in accordance with the following criteria: Funds must be distributed to all eligible school attendance areas (from highest to lowest) in which the concentration of children from low-income families exceeds 75%. An LEA must allocate a higher per-pupil amount to schools with higher poverty rates than it allocates to schools with lower poverty rates. Finally, Title I funds can be distributed to all remaining eligible school attendance areas that have been ranked from highest to lowest, either by grade span or for the entire LEA, according to the percentage of children from low-income families.

A method of calculating the distribution of program funds is to allocate the per-pupil amount to all eligible school attendance areas. The funds that remain would be used to increase the per-pupil amount to the schools with the highest concentrations of poverty.

These criteria do not apply to an LEA with a total enrollment of less than 1,000 children or one school per grade span.

Q49: Should there be an explanation for the redistribution of remaining program funds?

A: Yes. There should be an explanation provided regarding the redistribution of remaining program funds to assure that the schools with the highest poverty levels received the highest per-pupil amount. All of the distributed funds must add up to the original Title I allocation.

Q50: If the program amount is not sufficient to service all eligible schools, should the public and private school students be serviced by distributing the funds equally to all eligible schools based on a percent?

A. If remaining funds are not sufficient to fully fund the next ranked eligible school attendance area and private school, the LEA may serve the area or school if it determines the funds are sufficient to enable children to make adequate progress toward meeting the state’s challenging standards. The LEA should consult with the private school regarding the amount of funds available and the provision of equitable services.

Q51: Should private schools be listed on the Eligibility form?

A. No. Private schools should not be listed on the Eligibility form. Private school students are accounted for in the public school resident attendance area and listed under the appropriate private column on the resident attendance area row of the form.

Q52: Do single attendance area school districts have to complete the Eligibility form?

A. Yes. Single attendance LEAs must complete all of the required information on the Eligibility form including the status, poverty criteria, per-pupil expenditure and, if appropriate, the per-pupil expenditure calculation for LEAs below 35% poverty. Single attendance LEAs do not have to rank schools by poverty [see IASA 1113(a)(6)]. However, all schools must be listed on this form, even if there is only one school in the LEA. Information for the school or schools must be completed by grade span, resident students, number of low-income students public and private, percentage of poverty, and attendance area allocation for both public schools and private school students.

Q53: For Title I purposes, if the LEA has one grade span, is the correct designation TA (targeted assistance) or SW (schoolwide)?

A: If the LEA does not have a Title I-approved schoolwide program (see Appendix D) the appropriate designation is targeted assistance (TA).

Q54: Can funds be allocated to schools below the district level of poverty?

A. Title I funds can be allocated to schools below the district level of poverty if the schools are at or above the 35 % poverty level.

Q55: Must all of the schools in the district be listed on the Eligibility form?

A. Yes. All of the schools must be listed on the Eligibility form. Not listing all of the schools in the district affects the resident student count, student poverty figures used in deriving the per-pupil amount, the district level of poverty, and other associated calculations.

Q56: Must the schools be ranked on the Eligibility form from highest to lowest?

A. Yes. The schools must be ranked by poverty level from highest to lowest.

Q57: How do the funds allocated for parent involvement that are identified on the Title I Eligibility form (item 4c) need to be described on the Budget Detail page?

A: All parent involvement costs identified on the Title I Eligibility form should be categorized and clearly described by GAAP function/object code. The subtotal for parent involvement activities in the budget detail must match the indicated amount on the Eligibility form.

Q58: How are the funds allocated to the ranked schools when the schools with the highest percentage of poverty have fewer students who are poor than the larger schools? This results in an excess of funds.

A: An LEA is not required to provide the same per-pupil amount to each school. However, an LEA must allocate a higher per-pupil amount for a school or attendance area with higher poverty rates than it allocates to areas or schools with lower poverty rates. See page 34 of the FY 2000 IASA Guidelines for instructions on how to distribute Title I funds.

Q59: In the FY 2000 IASA Guidelines on page 35, item 5b refers to the percentage of low-income children and item 6 refers to the total number of low-income children. What should be used, the number or the percentage?

A: Items 5b and 6 on page 35 are referring to two different issues. Item 5b is referring to how to determine the eligibility of schools in which the number of low-income students is used to determine the percentage of poverty for each school. Item 6 is referring to the allocation of funds to eligible schools in which the per-pupil amount would be multiplied by the number of low-income students in the eligible school attendance area. See pages 34 - 39 of the FY 2000 IASA Guidelines for complete instructions for determining the eligibility of Title I schools.

Q60: What action does the LEA take if a parent refuses Title I services other than citing a local school board policy?

A: None. There is no federal requirement that parents must accept Title I services.

Q61: How does a consortium applicant complete the forms required for Title I if not all of the participant districts are eligible to receive Title I funds?

A: A consortium application is a joint application submitted by a lead LEA in which two or more eligible LEAs combine their allocations to provide comprehensive services. The consortium participants submit the required pages to the consortium applicant for the Title funds that are being submitted jointly. If a participant is not eligible for Title I funds, funds from the other Titles may be contributed to the consortium. See page 15 of the FY 2000 IASA Guidelines for the list of pages that need to be completed.

Q62: How does the LEA calculate the parent involvement set-aside if some of the schools in the LEA are approved schoolwide programs and are participating in the Whole School Reform program?

A: All schools receiving over $500,000 in Title I funds must reserve 1% of the allocation for parent involvement even if the school is participating in the Whole School Reform program.

Q63: If the LEA is funding services to the neglected population from an agency that also provides services to out of county children, should the other counties and LEAs contribute funds?

A: No. Other counties and LEAs do not have to contribute funds for their children that are attending an agency outside of the LEA. The neglected institutions provide the services regardless of resident district. These children are funded by the Title I formula through the LEAs providing the funding for those institutions.

Title I Capital Expense

Q64: Can services be provided at a neutral site if the program is split-funded with Chapter 192-193, if they cannot be held in the religious school?

A: If a program is split-funded with Title I Capital Expense funds and Chapter 192-193 funds, the services may be provided in either the religious school or at a neutral site, depending upon the consultation results and the agreement between the LEA and the religious school. Both Title I Capital Expense funds and Chapter 192-193 funds can be used to provide services in the religious school facility after consultation and agreement with the school.

Q65: Please explain how the reduction of funds for Title I Capital Expenses will impact on the LEAs.

A: There is no reduction of funds for Title I Capital Expenses at the current time.

Title II

Q66: Title II requires an LEA match. How does the LEA calculate the match and where is it shown in the application?

A: The match should be calculated as an amount equal to 50% of the LEA’s allocation, not including the private school amount. The law does not require a private school match. The LEA match is shown in the "LEA Match" column on the Budget Statement page of the IASA application.

Q67: Is family math an allowable activity for Title II?

A: Yes. Title II funds may be used to provide services to students and their parents for family math activities.

Q68: If some teachers from each school in an LEA participate in a math or science professional development workshop, does this comply with the school-level professional development stipulation?

A: If some teachers from each school in an LEA participate in an Eisenhower grant-assisted professional development workshop, this activity is in compliance with the school-level professional development stipulation, as long as it is in accordance with the needs assessment for professional development and the professional development plan.

Title IV

Q69. Is the parent/guardian signature acknowledging having received the school’s student codes of conduct (Title IV, Item #33) required?

A. No. The NJDOE recommends that each parent be asked to read and sign an agreement supporting the defined obligations and indicating willingness to abide by the system of recognition and penalties that is outlined in the LEA’s code of conduct.

Q70: Assurance #32 states that the "LEA has adopted written, board-approved student codes of conduct, with parent/guardian signature of agreement provision." Does the parent/guardian actually signify that they are in agreement with the policies or just that the policies have been received? Is this only for Title IV? Does the policy apply to lower elementary schools too?

A: The parent/guardian’s signature indicates that the parent has read the student codes of conduct of the school district. The student codes of conduct applies to all of the schools within the district. This is a requirement for Title IV only.

Q71: How frequently does the LEA need to distribute copies of student codes of conduct? Are they required to be distributed annually or just to new students?

A. The State Board of Education adopted a resolution in 1980 recommending that all districts distribute codes of conduct. The resolution specifically suggests that distribution be at no cost to pupils, staff, parents or guardians at least once every three years. It further states that the codes of conduct should be distributed to all new staff and pupils, and to parents or guardians of new students whenever they enter the school district.

Q72: How does the applicant district in a consortium compile the Objective Analysis data?

A: The Objective Analysis data is submitted separately for each district within the consortium. If the members share common objectives and activities, then the Objective Analysis should reflect a synthesis of the data from the participant districts.

Q73: Is it permissible to form a single committee to comply with the consultation requirements?

A: It is permissible to form a single committee. However, Title IV regulation identifies specific representatives whose participation is not required by the other Titles but who must be included, to the extent possible, in the development of the application as noted on the bottom of the "Participant in Application Development" (Appendix J, page 8) of the FY 2000 IASA Application.