ÁñÁ«ÊÓÆÁ

FY 2025 Preliminary Compliance Reviews for IDEA-B LEA MOE

The purpose of this letter is to alert school systems of the upcoming release of fiscal year 2025 (school year 2024–25) preliminary compliance reviews for Individuals with Disabilities Education Act, Part B (IDEA-B) local educational agencies (LEAs) maintenance of effort (MOE). This letter also provides guidance about MOE compliance and steps school systems should take to prepare for the preliminary compliance reviews.

IDEA-B LEA MOE Compliance Process

If a school system receives IDEA-B grant funds, the MOE requirement specifies that the school system must spend at least the same amount of state and local funds to provide services to students with disabilities that it spent in the previous fiscal year. Each fiscal year, ÁñÁ«ÊÓÆÁ analyzes financial data and uses four tests approved by the US Department of Education (USDE) to determine if school systems are in compliance with the MOE requirement. In late March, ÁñÁ«ÊÓÆÁ will release preliminary compliance reviews, which will notify school systems of the following:

• The school system passed at least one of the four tests, which means they are compliant with the MOE requirement.

or

• The school system failed all four tests, which means it is not compliant with the MOE requirement.

School systems will have an opportunity to respond to ÁñÁ«ÊÓÆÁ regarding their preliminary compliance review and submit exceptions and/or adjustments, with supporting documentation, which may change the outcome of one or more of the four compliance tests. School systems will have ten (10) business days to respond to ÁñÁ«ÊÓÆÁ after the preliminary reviews are released. Once all documentation has been reviewed, ÁñÁ«ÊÓÆÁ will issue final compliance reviews. School systems that are not compliant with the MOE requirement may owe a refund to ÁñÁ«ÊÓÆÁ.

What Should I Do Now?

School systems are strongly encouraged to begin collecting relevant data and performing their own MOE calculations before the preliminary reviews are released. ÁñÁ«ÊÓÆÁ provides an MOE calculation tool, which has been updated for the fiscal year 2025 (school year 2024–25) compliance cycle, on the IDEA-B LEA MOE page of the ÁñÁ«ÊÓÆÁ website. An additional data sources document is also available to help school systems identify the specific data you should use to perform the calculations.

When the preliminary compliance reviews are released in late March, school systems should compare ÁñÁ«ÊÓÆÁ’s results to their own MOE calculations and decide whether to accept ÁñÁ«ÊÓÆÁ’s compliance review or respond by submitting exceptions and/or adjustments for further consideration.

Release of Preliminary Compliance Reviews

ÁñÁ«ÊÓÆÁ will release fiscal year 2025 (school year 2024–25) preliminary compliance reviews for IDEA-B LEA MOE in late March 2026. At that time, school systems can view their compliance review reports by logging in to the secure GFFC Reports and Data Collections application, accessible through .

On the same day that ÁñÁ«ÊÓÆÁ releases the preliminary reviews, it will also make available the fiscal year 2025 (school year 2024–25) Exceptions/Adjustment Workbook. School systems must use the workbook if they choose to respond to ÁñÁ«ÊÓÆÁ and submit documentation. The workbook is available in GFFC Reports and Data Collections (in ) and on the IDEA-B LEA MOE page of the ÁñÁ«ÊÓÆÁ website. These resources can help school systems to identify any applicable exceptions and/or adjustments, which are also described below.

Due Date for Responses to ÁñÁ«ÊÓÆÁ

School systems that choose to respond to ÁñÁ«ÊÓÆÁ regarding the preliminary compliance reviews must do so within ten (10) business days of the release date of the preliminary reviews and workbook.

Why Should I Respond to ÁñÁ«ÊÓÆÁ?

School systems that fail all four compliance tests may want to respond to ÁñÁ«ÊÓÆÁ to demonstrate that they can pass at least one test and thus may avoid owing a refund.

School systems that pass at least one compliance test, but fail other tests, may also want to respond to ÁñÁ«ÊÓÆÁ to demonstrate that they can pass more tests, or all the tests; however, to be compliant, a school system is required to pass only one of the four tests.

School systems can also accept ÁñÁ«ÊÓÆÁ’s preliminary compliance review and take no further action. In this case, your school system’s final compliance review will include data identical to the preliminary compliance review.

Allowable Exceptions and Adjustments

School systems that choose to respond must use the Exceptions/Adjustment Workbook to submit at least one of the following, as applicable, with the appropriate supporting documentation:

• Applicable federal statutory exceptions. See specific exceptions below.
• Adjustment to fiscal effort (MOE voluntary reduction). See page 10 of the IDEA-B LEA MOE Handbook for additional information. A list of school systems eligible for MOE voluntary reduction is posted on the IDEA-B LEA MOE page of the ÁñÁ«ÊÓÆÁ website.
• SHARS Reimbursement Survey reporting errors. The survey can be resubmitted with corrected information.
• PEIMS reporting errors with the auditor’s supporting documentation. See page 12 of the IDEA-B LEA MOE Handbook for additional information.

Specific Federal Statutory Exceptions

If your school system has failed at least one of the four compliance tests, your school system may use one or more of the allowable federal statutory exceptions in as outlined below:

• The voluntary departure, by retirement or otherwise, or departure for just cause, of special education or related services personnel.
• A decrease in the enrollment of children with disabilities.
• The termination of the obligation of the school system, consistent with IDEA-B, to provide a  program of special education to a particular child with a disability that is an exceptionally costly program, as determined by ÁñÁ«ÊÓÆÁ, because the child has left the jurisdiction of the school system; has reached the age at which the obligation of the school system to provide FAPE to the child has terminated; or no longer needs the program of special education.
  • An exceptionally costly program to a particular child with a disability is a program with a cost greater than $13,642.
• The termination of costly expenditures for long-term purchases, such as the acquisition of equipment or the construction of school facilities.
• The assumption of cost by the high-cost fund operated by .
• The adjustment to the fiscal effort provision under .

Detailed information about allowable exceptions and/or adjustments is provided in the IDEA-B LEA MOE Guidance Handbook, posted on the IDEA-B LEA MOE page of the ÁñÁ«ÊÓÆÁ website.

Training Opportunities

ÁñÁ«ÊÓÆÁ’s Federal Fiscal Compliance and Reporting Division will provide online training via Zoom for school systems interested in learning more about the IDEA-B LEA MOE requirement, calculation, and exceptions process.

The training is scheduled on Thursday, April 2, 2026, from 9:30 a.m. –10:30 a.m. You can register for the Zoom training at: .

Online Resources

Please refer to the IDEA-B LEA MOE page of the ÁñÁ«ÊÓÆÁ website for further information and additional resources regarding IDEA-B LEA MOE. Several new training slide decks related to the submission of exceptions and PEIMS errors have been developed and are available on the webpage. Additional guidance will also be provided when ÁñÁ«ÊÓÆÁ announces the release of the preliminary compliance reviews and workbook.

Contact Information

If you have any questions regarding the IDEA-B LEA MOE compliance review process, please contact the Federal Fiscal Compliance and Reporting Division by email at compliance@tea.texas.gov.