A.

On the basis of previous years' data, estimate by State the ratio of average daily attendance to membership for use in processing the current year's applications. Thus, a firm (although estimated) determination of entitlement and payment would be made during the processing of an application (before the close of the school year) instead of changing when the school district files a final report of actual average daily attendance after the close of each school year. This would benefit districts by allowing them to know absolute amounts they can depend on for the current year. Possibly, we also might be able to provide the full payment before the close of the school year. The Division would benefit by fewer processings not only of regular entitlements and payments but of hold harmless payments as well. We are not certain at this time, but believe that this kind of firm (although estimated) determination is possible because the law presently provides the Commissioner authority to determine the average daily attendance of Federally-connected children.

B. Determine eligibility and payment on the basis of membership of federally-connected children on a single survey date rather than on the basis of average daily attendance. This would accomplish the same benefits as "A" without the necessity to determine a ratio for each State. This procedure would definitely require a change in the law that presently calls for determinations on the basis of average daily attendance. The

local contribution rate could be reduced (also by changing the law) to reflect the use of higher membership figures as compared to average daily attendance, or left unchanged, it would somewhat make up for the two year old fiscal data on which rates are based.

C. Upon the receipt of applications, but without analyzing them, provide an immediate payment based on some portion of the previous year's payment. This would provide timelier payments, although perhaps smaller than usual initial payments, but would not meet the need for districts to know firm amounts for the year. Inquiries might still be numerous from school districts wanting to know how soon they would be receiving more funds and more accurate payments.

however, would provide earlier payments.

This method,

Ꭰ . Appropriating funds for the program a year in advance of the current year, also, would assist local school districts in anticipating the amounts of entitlement and payment which would be available. This would permit local districts to more accurately reflect anticipated receipts from P.L. 874 in their annual budgets.

Question: To what extent do LEAs carry over impact aid funds?

Answer: We have little information that would answer this question.

P.L. 874 funds are deposited along with other resources, including State and local funds, in a general operating account that is used to pay for

Once funds

current expenses in accordance with State and local laws. have been commingled in this fashion, they tend to lose their identity. Even for those school districts that might receive a P.L. 874 payment just before school closes and carry over an identical amount, it would be difficult to say that the impact aid funds were being carried over. The expenses that may have been planned to be covered by the impact aid payment may have been paid from other funds; the impact aid payment simply reimbursed those other funds making them available for their intended purpose.

Most of our applicants lead us to believe that they have urgent need for the payment to meet expenses for the current year. Carry over balances of impact aid or other funds may be cases of unpaid bills. Not all school districts are required to settle their accounts by the close of the school year. On the other hand, a few school districts specifically request smaller payments to insure no carry over balances. It is difficult to get a true financial picture of a school district without individual analysis.

Question: What percentage of districts receiving impact aid funds use the various methods of determining payments, e.g. comparable districts, groupings, and State and national averages?

Answer: In 1975, 13% of school districts receiving impact aid funds received a local contribution rate higher than the minimums based on

individually selected comparable districts, 22% received a higher rate than the minimums based on State groupings, 16% received one-half the State average and 49% received one-half the national average. These percentages were most likely the same or quite similar in 1976. In 1977, however, California and Nebraska requested the use of individually selected comparable districts instead of State groupings.

The effect is

not precisely known at this time but is estimated to raise the percentage of districts receiving individually selected comparable district rates to 19% and lower the percentage receiving rates higher than minimums based on State groupings to 16%.

Question:

What is the role of the HEW regional offices regarding the impact aid program? Are they able to provide assistance in applications, questions of pupil eligibility, and computation of rates? Do you feel there is adequate staff in the regional offices working on this program?

Answer: The role of the HEW Regional Offices regarding the impact aid program is one of providing the Headquarter's Office with information relative to determining entitlements and payments made to local education agencies. The Regional Offices are assigned specific functions necessary to the processing of applications for Federal aid under the provisions of P.L. 874 and P.L. 815, including disaster aid. These include providing technical assistance to applicants, assuring compliance with the laws and regulations, and verifying pupil, financial and other data contained

in applications.

These activities are accomplished primarily by

on-site visits to local education agencies for the purpose of reviewing the data supporting impact aid applications, and reporting their findings to Headquarters. Such reviews, depending upon the sections of the Acts for which assistance is claimed, involve the examination and analysis of parent-pupil survey forms, attendance records, educational programs, school facilities, budgets, financial records, school board minutes, policies and procedures. In addition, the regional program officers provide liaison to and otherwise work closely with impact aid representatives in State Departments of Education.

With respect to P.L. 874 in those instances where SAFA Regional Program Officers have been able to visit local education agencies and make administrative reviews of the records, assistance has been provided to the school personnel relative to applications and pupil eligibility; some assistance on rates can be provided.

The SAFA staff has not been sufficient in number since 1967. Before then, from 40 to 50 SAFA Program Officers were able to keep current with the required workload under Public Laws 874 and 815. Since that time, the staff has been reduced to 24 program officers who now report directly to Regional Commissioners of Education; sometimes duties other than impact aid require more immediate attention. There has been an annual increase in the backlog of cases to be reviewed and less assistance to State and local education agencies in recent years.