ESSA - Financial Accountability

School districts in Texas may be subject to a number of financial accountability provisions.


Maintenance of Effort (MOE) is a federal requirement that school districts receiving federal funds under either the Every Student Succeeds Act, or the Individuals with Disabilities Education Act of 2004, Part B (IDEA-B), must maintain financial effort by spending a specified amount of their state/local funds on services required by the specific program. The Texas Education Agency ensures that districts maintain state/local effort by making comparisons based on financial information gathered through the Public Education Information Management System (PEIMS).

Comparability of Services

The ESSA Act of 2001 (NCLB) Title I, Part A requires that campuses must receive the same level of services through state and local funds as campuses that do not receive Title I, Part A funds. In other words, just because a campus is receiving Title I, Part A funds, it doesn’t mean the district can allocate less state/local funds to that campus. If all campuses in a district receive Title I, Part A funds, then the district must ensure that the state/local funds allocated to those Title I, Part A campuses are substantially comparable. A district’s compliance with Comparability of Services is determined through the use of a somewhat complex spreadsheet called a Comparability Computation Form (CCF) and involves a variety of options and methodologies for making the determination. While all districts are subject to comparability compliance, not all districts are required to submit the CCF.

Supplement, not Supplant

Financial accountability essentially boils down to this concept. The “supplement, not supplant” provision is common to many federal statutes so there is actually no single “supplement, not supplant” provision. The requirements can vary depending on the statute governing the program. Its basic, universal tenet is that grant recipients must use appropriate state/local funds for all educational services that are required by state law, State Board of Education (SBOE) rule, or local policy and ensure that those state/local funds are not diverted for other purposes just because federal funds are available. Supplement, not supplant” is applied at a Title I, Part A Targeted Assistance campus and a Title I, Part A Schoolwide campus with the same rules and requirements under the ESSA.

Administrative Procedures Manual (APM) – EDGAR Requirement

In the event your district gets audited for any of the ESSA programs, one of the main documents you will need to be able to reference is an Administrative Procedures Manual. This document will detail the procedures your business office follows to ensure effective internal controls regarding how to expend and account for federal grant funds in compliance with program requirements.It is highly recommended to be prepared to cite the page and paragraph that supports the business office’s procedures when accounting for grant funding. In most cases, the desk audit will require the submission of the entire APM.