In this video we will give an overview of Section 7003, Payments for Federally Connected Children. In the United States, most school district revenues come from local property taxes. This formula grant program replaces lost local tax revenue due to the presence of a federal activity. Land that the Federal Government owns cannot be taxed.

Grant payments are primarily based on the number of eligible federally connected children in a school district. There are several different categories of federally- connected children. These include children of members of the uniformed services, children who live on Indian lands, children who live on federal property, and children whose parents work on federal property.

Section 7003 grants may include supplemental payments for children with disabilities for certain categories of federally connected children.

This chart illustrates the annual application process from surveying the Federally-connected population to receiving payments.

The first step in the process is to select a survey date on which the local educational agency (LEA) will count the total membership and the federally connected children. The LEA has to do this every year. For more information on each step of the survey process, please see the video entitled “How to Conduct a Survey.”

Once the LEA has counted all of the children in the different categories, it will summarize the results of your survey on a grant application that you will submit in the Impact Aid Grant System (IAGS).

After the Impact Aid Program receives your application, an analyst assigned to your state will screen the application to make sure that the LEA has submitted all of the required documentation. Sometimes we will ask for more information or backup documentation.

If your LEA is selected for monitoring, your analyst will contact you and ask you to submit all of the backup documentation to support the number of children you claimed. You will generally have 30 days to get this information to us, so make sure to keep your data organized and on hand should you be selected.

If everything is approved and we get an appropriation from Congress, we will begin to make payments in the beginning of October.

The application becomes available every year at the beginning of December.

The application deadline is January 31st or the next business day if it falls on a weekend.

If you miss our on-time deadline, you still have until April 1st to submit a late application. The LEA will have a late penalty of 10% for all payments associated with that application.

If an LEA needs to change its data, it can amend its application by June 30th, or the next business day if it falls on a weekend.

There are two important items to consider as you are collecting and organizing data on your Federally connected children: the types of children that qualify for Impact Aid and how they are weighted in the payment formula.

Here you can see all of the categories of Federally connected children in the Impact Aid statute. In the first column, you’ll see that where the student lives affects their category, and in the second column, you’ll see that where the parent works affects the category. The categories are important to know because they determine your LEA’s eligibility for funding, as we will explain in the next slide, but they also determine how much weight the child receives in the payment formula. For example, a child who lives on a military installation and whose parent is in the uniformed services is in Category B and receives a weight of 1. A child whose parent is in the uniformed services but does not live on Federal property is in Category D(i) and receives a weight of 0.2. What this means is that for each child in Category D(i), your LEA would receive just 20% of the payment you would receive for one child in Category B. Consider these categories and weights when you are organizing your survey results, as you will report the number of children you have in each category on the annual Impact Aid application.

Qualifications for our 7003 grant are met in two ways.

The first is the basic eligibility threshold. To be minimally eligible, an LEA must have at least 400 or 3% eligible Federally connected children in average daily attendance, or ADA, in categories A through E (referenced in the chart on the previous slide). In the simplest possible terms, those categories can be summarized as:

1. The child lives on federal property AND the parent works on federal property
2. The parent is in the uniformed services, whether in the U.S. military or a foreign military officer
3. The child lives on Indian lands
4. The child lives in eligible low rent housing

The second way your LEA may qualify is by having enough children in Categories F & G.

To receive a payment for children who ONLY reside on Federal property, other than low rent housing or Indian lands (aka Category F) or ONLY work-on Federal property (aka Category G), your LEA must have at least 1,000 or 10 percent of these children in ADA.

If your LEA meets the basic eligibility requirement, but does not meet the F&G eligibility requirement, your LEA will not receive a payment for any children counted in categories F&G. You will only receive a payment for children in categories A through E.  However, if your LEA is eligible to be paid for category F and G children, your LEA will be paid for your category A through E children, even if you don’t meet the 3% or 400 in ADA requirement in those categories.

Don’t worry if you find that confusing. When you’re filling in your annual Section 7003 application, the application will tell you how many Federally connected children you need in categories F and G for those children to generate a payment. If you know you don’t have the required number of children, you can then skip that section of the application.

This concludes our brief overview of the Impact Aid, Section 7003, Payments for Federally Connected Children grant program. For more information, please visit us at our website. There you will find other training videos, user guides, and copies of our live webinar slides.

In this video, we will give an overview of how to conduct the annual Impact Aid survey in order to fill out a Section 7003 grant application. There are three main things to consider as you are planning for your survey:

First, when to select your annual survey date.

Second, which data your LEA is required to collect and from whom.

Third, which data source to use when surveying: a source check or parent pupil survey form?

We will cover all of these items in this video.

You are required to survey your Federally connected children every year before filling out the Impact Aid, Section 7003 application. When selecting a survey date you must choose a date between the 4th day of school and January 30^th. The final date you can possibly survey is January 30 because the application is due on January 31st of each year. We recommend choosing a date that will give you plenty of time to collect and organize your information before the application is due.

Then, you should consider if your state already has a mandatory count date for state aid purposes. If the answer is yes, it may be more convenient to survey for Impact Aid during that time because you are already doing a membership count.

Next, you should consider if your federally connected membership fluctuates over the year. If the answer is yes, try to target your survey date when your federally- connected membership is at its highest.

Now let’s discuss the steps to conduct a survey.

First, you must pick your survey date.

Second, pick your data collection method, either a parent pupil survey form or a source check form. We will discuss both of these methods in detail later in this video.

Third, you must send your forms out to parents and/or your certifying officials

And lastly, you are going to organize your survey results by Federally- connected category and then by property so that you are prepared to fill out the application for Impact Aid.

When conducting your survey, use this slide as a checklist for the information you need to collect on the survey date. When you fill out your Impact Aid application, you are going to be providing all of this information as it was on the survey date.

First, you should obtain a report that reflects your total enrollment on that date from your student information system.

Gather any supporting documentation that relates to tuition-in and out children. You should have a copy of the tuition agreement, and a list of the children you are sending to another organization for educational services (tuition-out), and a list of children you are receiving money from another organization to educate (tuition-in).

Your count of federally-connected children will come from your survey results.  You should only survey children who are enrolled in your district on the survey date, but you don’t need to have all of your results by the end of the day. Send out your survey forms on or after your survey date. Just make sure you have enough time to collect and organize your data before you need to submit your grant application.

You should not count any child for which you are receiving a tuition payment for any category on the application. The sending LEA should count those children.

On your survey date, if you claim children living on Indian lands or children with parents in the Uniformed Services, you should also get a list of children in your district who have an active Individualized Education Program (IEP) for special education services on that date. Federally connected children in those categories with an active IEP are eligible for additional special education dollars and you will need to report a count of those children on your application.

Remember all data must support the claims on your Impact Aid application as of your survey date!

Now let’s look at the two acceptable forms available to conduct your survey. The difference between the two methods comes down to who certifies that the child is Federally connected.

On a source check form, an employer or other Federal official certifies the information, and on a parent-pupil survey form, the parent certifies the information. While you can use a source check for any category of children, a source check form works best for your category C children that reside on Indian land or category E children who live in Low Rent Housing. This is because families living on Indian land may know that they live on a reservation, but they may not know the legal status of their property (whether it is held in trust, restricted from alienation, or fee simple property owned by themselves or the tribe) and how it qualifies for Impact Aid. See the video on Indian lands for more information.

Similarly, a parent living on low rent housing will be able to certify that they receive public assistance for housing, but they will not be able to tell you under which program, and specifically which statute, their assistance falls under. You need to always work with your local public housing authority to determine whether the property is in fact eligible under the Impact Aid property definition. If you have children in this category, see the video on low rent housing for more information.

The source check form allows you to capture in detail all required data and certifications. You may also certify your Children with Disabilities using this method.

We say that you may use source check forms AND/OR Parent Pupil Survey forms because you can also do a hybrid of the two. You have the option to choose a parent pupil survey form to confirm specific residence and employment information for children living on Indian lands and children living in low rent housing, but the additional land and housing eligibility certification is still required under Impact Aid guidelines.

The parent pupil survey form is an excellent option for counting your military connected children and your parents who work on Federal property. These categories would require no additional certifications, so you can take your survey results and add them directly to your application for Impact Aid.

How do I choose? We talked through the pros in our previous slide. Let’s discuss the cons on using a source check vs a Parent pupil survey form.

It is important to note that a paper parent-pupil survey form involves a lot of paper and may have a low rate of return, especially if you are relying on children to bring the form home and return it back to you.

A source check form can be burdensome for certifiers and requires planning and cooperation when obtaining certification of land and housing status.

Always, when in doubt contact your state assigned analyst.

You can use a source check to verify all categories of Federally connected children, but the person who certifies is going to vary by the type of property and its eligibility criteria. Remember that a source check can be used in lieu of or in addition to the parent-pupil survey form and may capture any required or missing data that you did not get on your survey form.

Since the person who certifies the information varies depending on the type of property where the student lives or where the parent works, please refer to our Impact Aid resources webpage, where you can obtain copies of blank survey form and source check templates. The sample source check forms will show you all of the required information by category as well as the proper signature statements at the bottom for each certifying official. Make sure you select the correct category for the type of child and the type of property and fill in the information completely.

We have more information about source check forms in the videos on Indian lands and Low rent housing, and there is a separate video on parent-pupil survey forms that goes into this method in more detail.

Remember you may add to the sample forms, such as a logo. Do not remove any data fields.  Doing so can result in an ineligibility for that federal property.

One of the questions we get most often is “can I use both types of forms?” Yes, emphasis on yes.  You may use both forms. You also have an option to go paperless, but you need to talk to us about it first to make sure your data collection system meets the program requirements. You should contact us well in advance of doing your survey for the year. For more information about the Electronic Data Collection (EDC) program and how to participate, visit our Impact Aid resources webpage.

This concludes our video on how to conduct a survey for the Impact Aid, section 7003 application. For more information, please visit us at our website. There you will find other training videos, user guides, and copies of our live webinar slides.

In this video, we will give an overview of the Membership Table on the annual Impact Aid, Section 7003 application.  In this table, the application will calculate the number of children for whom your Local Educational Agency also known LEA is financially responsible for providing a free public education.  We will talk about the definition of free public education and what it means to be financially responsible for educating a child, applying the definition to students in grades lower than kindergarten, homeschooled children, children for whom your LEA pays or receives tuition, and children attending schools in your LEA under an open enrollment policy.  

On the Impact Aid application, the membership table will calculate the children for whom your LEA is providing free public education on the survey date.  You will start by giving the number of children enrolled in your district on the survey date, and then you will subtract those attending under a tuition agreement with another school district, and add those children for whom your district is paying tuition.  You can find the definition of free public education in the program statute in section 7013, paragraph 6, and in the program regulations at 34 CFR section 222.30.  Essentially, to be free and public, the child’s education must be provided at public expense (and we’ll talk about financial responsibility later), as a complete elementary or secondary program (unless it’s preschool education), in a school of your district (unless provided under a tuition agreement), and under public supervision and direction (unless with respect to students with disabilities).

If you have preschool-aged Federally connected children, let’s talk about how to claim them on your application. The first question you might be asking is “Can I claim preschool or Pre-K students in my Impact Aid Application?”  Yes, you can claim them if they’re receiving a free public education.  Another question you might be asking is “Can infants and toddlers with Individualized Family Service Plans (IFSP) be claimed?” Yes, you can include all children for whom the eligible LEA is providing services under the Individuals with Disabilities Act.

Let’s go into more detail on Free and Public Education and what this means in this context. If it is free this means that there is no tuition being charged to the family. Also, it must be provided at public expense, which means most revenues for the program are provided through state or local funds or Impact Aid. Federal funds other than Impact Aid (such as Head Start. Early Education grants, or Title I) must not provide a substantial portion (more than 20%) of the cost of the educational program.

Now you might be wondering, where do I include Pre-K children in my Impact Aid application? If the LEA is providing a free and public education to Pre-K students, then you can include all Pre-K children in the LEA’s enrollment, the Average Daily Attendance, and in the categories of federally connected children such as Indian Lands, Uniformed Services, Foreign Military, and Low Rent Housing. 

With the increase in homeschooled students after the COVID-19 pandemic, we’ve received this question a lot.  Some LEAs provide supplementary educational services to students that are primarily taught at home, and these students should not be counted in an LEA’s enrollment or in the Federally connected student counts.  The one situation where a homeschooled child can be counted on the Impact Aid application, both in enrollment and the Federally connected student counts, is one where a child with disabilities is being educated at home and the LEA is completely covering the costs of that student’s educational program.  Generally, the LEA will also be receiving state aid for the child with disabilities.

Here are some definitions that are helpful as we dive into discussing Tuition in and out and Open Enrollment.

Tuition In: Your LEA must receive a tuition payment from the child’s home district under a written agreement to cover the cost of the child’s free, public education.

Tuition Out: Your LEA must pay the attending school or school district tuition under a written agreement to cover the cost of the child’s free, public education

Open Enrollment: When we’re talking about open enrollment, we’re generally talking about a situation where the child’s education is generally covered by an increase in state aid and no tuition agreements are required.

When you have a formal tuition agreement with another school district this means that tuition payments are being made or received that are comparable to the cost of educating the child in the receiving district. The LEA must track the children for which tuition is being paid with the child’s name, grade, and resident and receiving  school district.

In this example, there are two school districts, Blue School #1 and Red School #2. In this situation, each LEA is financially responsible for educating the children that live in their district. However, with tuition agreements in place, the child might not necessarily be attending a school in the district where they live.

In this case, Blue School #1 and Red School #2 have two tuition agreements in place, one for Peter and one for Richard. Peter lives in district #1 and will now be attending Red school #2 for their Special Education Program.  Richard lives in district #2 but will be attending Blue School #1 for their Magnet School Program.

If Blue School #1 applied for Impact Aid, they will count one Tuition In student, in this case Richard, in the membership table as Tuition In. Richard will be subtracted from the LEA #1’s enrollment when calculating the district’s membership, because another district is paying for him to attend.  If Richard’s parents live or work on Federal property, Blue School #1 would not claim him on their Impact Aid application. Red School #2 would count Richard on their Impact Aid application if they were to apply.

Blue School #1 will count one student, Peter, as a Tuition-out student in the membership table. Peter will be added to the school district’s enrollment when calculating their membership.  If Peter’s parents live or work on Federal property, Blue School #1 can count him as a Federally connected student on their Impact Aid application, as they are still financially responsible for providing his education. 

Reminder: In Open Enrollment situations, the cost of the child’s education is generally paid for through additional state aid and no tuition agreements are required. With Open Enrollment or School Choice, any child that attends your school district can be counted in your enrollment on the survey date and in the federally connected categories, whether or not they live in your district. If a student lives in your district but is attending another district under the open enrollment policy, you should not include them anywhere in your application.

Let’s talk about the Documentation you need to keep for Tuition in students. In order to count Tuition-in students, you will need a list that includes the name, grade, resident school district, and school attending of your LEA’s “tuition in” children. Also, we may ask to see a copy of the tuition agreement and/or payments if necessary. Just a reminder that “Tuition in” children cannot be claimed as Federally connected on your LEA’s application. Also, Please do not include open enrollment or school choice students.

Here is what you need to document for your tuition-out students. In order to count Tuition-out students, you will need to provide a list that includes the name, grade, resident school district and attending school district of your LEA’s “tuition out” children.

We may ask to see a copy of the tuition agreement and/or payments to show the amount paid that genuinely reflects the applicant’s complete financial responsibility for providing the child’s free public education. Just a reminder “Tuition Out” children can be included in your Federally connected child counts, but do not include open enrollment or school choice students.

This concludes our brief overview of the membership table on the Impact Aid, Section 7003 grant application and the definition of free public education. For more information, please visit us at our website.  There you will find other training videos, user guides, and copies of our live webinar slides.

In this video we will provide an overview of how to survey your Federally connected children using a parent-pupil survey form. In a parent-pupil survey, student resident and parent employment information is certified by the child’s parent as of your chosen Impact Aid survey date. This method of data collection is often easiest for surveying parents in the uniformed services or parents working on Federal property because these categories do not require any additional land status verifications.

Your LEA will use its own survey form. Don’t worry- if you need it, we have sample forms on our website that show you which questions are required in order to document that a student lives on Federal property and/or has a parent who works on Federal property. The program regulations at 34 CFR Section 222.35 specify the information required on a parent-pupil survey form. All of the items on our sample form are required if your LEA wants to count children in every category. Notice that the survey date is at the top of the form. The survey must ask parents to certify that the information is correct for the chosen survey date.

Make sure you send the parent-pupil survey form on or after your selected survey date. This is to ensure that you’re not asking parents to certify information about a future date. They will need to sign and date the form at the bottom. On the survey, you are essentially asking for three categories of information. First, there is information about the student, information about the parent’s active duty military status (if applicable), and lastly, parent employment information.

Here is the information required for each student. For the home address, it is important for us to know the student’s physical address so we can determine whether that location is on Federal property. A mailing address with a P.O. Box won’t work. Your school district may pre-fill this section with information in your student information system. However, you must instruct parents to correct the information if the pre-filled information is not accurate as of the survey date and leave room for them to do so. This is useful if a student has moved to a different neighborhood, for example, without updating the student’s registration information. If the parent corrects the information, you must use the corrected information to determine whether the child is Federally connected. You may find it helpful to list some of your school district’s most common residential Federal properties with a check box for each one under the pupil residence information. The parent can then simply check the box next to the property where they live. This will make your forms easier to sort into the correct category when you are filling out your application.

There should be a section that asks if the parent is on active duty in the uniformed services. Here again, you may find it helpful to list the most common branches of service in your locality with a check box to each one. For example, if you are located next to a large naval installation and most of your uniformed services parents are in the Navy, allow parents to check a box next to Navy or write in their branch of service if different. Customize your form in a way that makes sense for your district and the Federal properties you have nearby. Children of foreign military officers also qualify for Impact Aid funds. We’ll need their country of service in addition to branch and rank if that is the case. Also, please note, only National Guard and Reserves called to active duty by the President are eligible for Impact Aid. Usually, the National Guard are serving under Title 32, meaning that they were called up by their Governor for State service. They must provide orders showing that they were serving under Title 10 on the survey date. Reservists also need to provide orders to show they were on duty on the survey date. Training does not count. Reservists must be active for at least 30 days to be eligible. Children of retired military to not qualify as active duty.

Finally, the parent-pupil survey form should have a section that asks about the parent employment information. In this section, we need to know the physical address for the property on which the parent is employed. A P.O. Box will not work. As you are creating your form, you may create a list of the names and addresses of the most common federal properties in your district. It may help avoid incomplete information on the form. It may also help you quickly organize your survey forms before filling in your application. If you choose this option, be sure to include an “other” line where they can fill in the name and address of the property if not listed. We must also have the name of the parent’s employer. An employer could be the Department of the Army, a contractor such as Boeing or Northrup-Grumman. The name of the employer helps us distinguish between contractors and federal employees. We also have something called the Pentagon Rule. If there is a well known property for which there is no specific address (such as the Pentagon), we have the authority to accept just the name of the property. Many military installations, some national parks, forests, or national monuments fit under this rule. Installations that cross state lines cannot be identified by name only. For a list of these properties in your area, please ask your assigned analyst.

Your district may consider using a multiple child survey form. On this form, you may capture all of the enrolled students living at one home address on one form, with one parent signature. If you are sending the form home with every child in the family, you will need to set up a system for weeding out duplicate forms and identifying children with an IEP.

This was a brief overview of the requirements for using a parent-pupil survey to count Federally connected children before completing the annual Impact Aid application. For more information, please visit the Impact Aid Program at our website.  Go to the Resources page for copies of sample parent-pupil survey forms.  You will also find other training videos, user guides, and copies of our live webinar slides.

In this video we will review the Indian Lands source check forms, including an overview of Trust and Restricted Lands, Oklahoma Tribal Treaty Land, and land conveyed under the Alaska Native Claims Settlement Act. An Excel file of these source check forms is available under the Resources tab on our website.

There are three types of Indian Lands Source Checks, the most common is Trust or Restricted Land type. However, if you are in Oklahoma, you might have Oklahoma Tribal Treaty Land and if you are in Alaska, you might have ANCSA Land, and each requires different certifications, so each has their own source check form.

Oklahoma Tribal Treaty Land has housing owned by an Indian Housing Authority and is provided to families with income restrictions. In other states, this land would perhaps be considered low rent housing, but for Oklahoma only, tribal low-income housing, even if it is not located on land held in trust or with restrictions on alienation, is considered Indian land.

ANSCA land is land conveyed under the Alaska Native Claims Settlement Act that became law in 1971. ANSCA land is owned by Native Alaska regional and village corporations. Uniquely with this land type, the property qualifies for Impact Aid if it was ever conveyed in the past to a Native Corporation under the ANCSA statute, as long as it is not taxed. For the other types of Indian land, the land must be in the proper status on the survey date.

You do not need to submit supporting documentation for any land type, such as titles and treaties, unless we ask you for it.

We will review what is necessary for each source check on the following slides.

We are going to start with the most common, which is the trust or restricted Indian lands source check.  

For this source check, and for all source checks in general, the top section needs to be filled out completely with the necessary information.  This one asks for the LEA name, Impact Aid number, School Year, Survey Date, the name of the Federal Property the Source Check is for and the address or legal description.

The rest of the source check, which is the Excel sheet shown at the bottom, needs the information at the top of the columns.  This includes:

• Parent or Guardian information
• Address/Legal Description or Tract # for the child’s residence – Please NO P.O. BOXES
• Whether the property is held in Trust or restricted from alienation
• Student’s name and grade
• IEP date (only if the child has an IEP that is within 1 year of the survey date)

To validate the information on the source check form, it needs to be certified by these four officials.

BIA/Tribal Official certifies the land status, the Tribal Official certifies that the children listed live on that property on the survey date, the LEA Official certifies the children are enrolled on the survey date, and the SPED Director or Coordinator certifies the noted children have IEPs on the Survey Date.

LEA officials are legal representatives of the LEA.

To certify the source check form, each official needs to review the list of students you provide to them via the form, cross out any children that do not qualify as Federally connected, and fill out to appropriate box at the bottom of the form.  This asks for their name, title, email, phone number, signature and date.

If you are in Oklahoma, you might have Oklahoma Tribal Treaty Lands.

Similar to the Trust and Restricted Source Check that we just saw, the information at the top needs to be filled out however the required property and student information is different because the eligibility requirements are different.

The property information required is the name of the federal property where the parent resides, the name of the Indian Housing Authority, the Indian Housing Authority phone number, the name of the Low-Income Funding Program, and the address or legal description for the property as a whole.

The student information required is the parent or guardian name, address/legal description or tract # (please no P.O. Boxes), student’s name, grade and IEP Date. Again, the IEP date must be within one year of the survey date- it cannot be after the survey date.

Again, to verify this information signatures from appropriate officials are necessary. For this category of children, the signatures necessary are from an Indian Housing Authority Official, a LEA Official, and a Special Education Director or Coordinator.

Just like with Trust or Restricted, the LEA Official and Special Education Official certify student information. In this case the Indian Housing Authority Official certifies the property information and that the parent resided at the address on the survey date.

At the bottom of the form, each official will again need to fill out their name, title, email, phone number, signature and date.

If you are an Alaskan LEA you may have ANSCA Indian Lands so you will need an ANSCA Indian Land Source Check form.

Like the other two form types, the top section needs to be filled out including the townsite or village of ANSCA Property and the legal description, Interim Conveyance or Patent Number.

The address and legal description are important because they are how the Bureau of Indian Affairs or Bureau of Land Management can verify the status of the property.

For the rest of the form, fill in the necessary information such as:

• Parent or Guardian last name and first name
• Legal Description, Tract #, or Native Allotment number
• Student’s name and grade
• IEP date, again only if the child has an active IEP on the survey date

Once again, signatures from appropriate officials are necessary to verify this information. The signatures necessary are from a Bureau of Indian Affairs or Bureau of Land Management official, a Tribal or Village Council Official, an LEA Official, and a SPED Director or Coordinator.

Just like with the previous forms, the LEA Official and Special Education Official certify student information.

However, in this case the Bureau of Indian Affairs or Bureau of Land Management certifies the land as being ANSCA land and the Tribal or Village Council Official certify that the student resided on that property on the survey date. The ANCSA corporation may certify the status of the land ONLY if they have the land records necessary to make that determination. Please note that during a review, we may ask the corporation to provide copies of these documents if they certified your source check. If the corporation does not have copies of the conveyance documents, you must obtain certification from the Bureau of Indian Affairs or Bureau of Land Management. The Bureau of Land Management has the system of record for conveyances under ANCSA and will be your best source of information.

At the bottom of the form, each official will need to fill out their name, title, email, phone number, signature and date.

This concludes our video on the certifications required for different types of Indian lands. For more information, please refer to the resources page on our website. If you have any questions about any specific properties or source check types, please speak to your analyst.

In this video, we will give an overview of Indian Policies and Procedures, including waivers, required for Local Educational Agencies (or LEAs) that have Indian lands on their Section 7003 grant application. 

Impact Aid, Section 7003 formula grant funds provide general aid that can be used like local tax revenue. There is no requirement from the Impact Aid Program on how the funds can be spent.  However, the program statute and regulations require an annual process to ensure that local education agencies claiming children living on Indian lands on their Section 7003 application are consulting with tribes and parents of Indian children to ensure equal participation between Native American students and non-Native American students in the LEA’s educational program.  Indian Policies and Procedures or a waiver are required for any LEA claiming children in category C.  These are children who live on Indian land, meaning land held in trust or restricted from alienation from a Tribe, land conveyed under the Alaska Native Claims Settlement Act, or land in Oklahoma that is owned by an Indian Housing Authority and used for low-income housing.  LEAs upload this document or documents to their annual Impact Aid application due each year on January 31.  Please note that an LEA cannot switch from an IPP to a waiver midway through the application cycle; if you submit an IPP on your Impact Aid application, your LEA must implement those policies and procedures and cannot seek a waiver until the following year.

The requirements outlined in this presentation come from both the Impact Aid statute and implementing regulations.  If a tribe chooses Indian Policies and Procedures, the LEA must show how it is meeting the six regulatory requirements outlined in 34 CFR §222.94, CFR standing for Code of Federal Regulations.

Indian Policies and procedures serve a valuable purpose. The goal of IPPs is to ensure children living on Indian lands participate in the LEA’s programs and activities on an equal basis with other children. I want to highlight that the focus is on participation, not achievement, though LEAs may of course share achievement data in addition to participation numbers if that is of interest to a local tribe.  The IPPs make sure that LEAs share important information with tribes and parents of Indian children, and that tribes and parents are consulted and involved in planning and developing the LEA’s educational programs and activities.

There are six regulatory policy requirements outlined in 34 CFR §222.94. The six policies address the basic, three-part process outlined on this slide, including the sharing of data, soliciting feedback on the data, and following up. The procedures will provide a basic blueprint for how the LEA will follow each policy, including what will be done, when it will be done, and by whom.  In order to facilitate effective communication, the first thing the LEA must determine is the tribe’s preferred method of communication.  Whether it’s email, regular mail, a phone call, a text message, or any other method, the LEA needs to include this information in its IPP and use the preferred method to communicate with the tribe.

The first requirement is that the LEA will disseminate relevant applications, evaluations, program plans and information related to the LEA’s education program and activities with sufficient advance notice to allow tribes and parents of Indian children the opportunity to review and make recommendations. The procedures should outline what data will be shared and how much notice will be given.  Dissemination means the LEA must actively reach out to the tribe and parents.  Posting this information on a website or in a newspaper alone is not active dissemination. Sending this information home in backpacks, through mail, or giving out a website link in an e-mail are examples of active dissemination.

Policy number two is that you have to create opportunities for input on the educational program. The procedures must specify how the LEA will inform the tribe and parents of Indian children about opportunities to provide input, and a process for modifying the method or time given to solicit views, especially if you’re having low participation rates.

Policy 3 covers the participation data that must be provided.  The procedures will document how you will compare your Native participation to your non-Native participation in every academic program and every extracurricular activity. You need to actively disseminate this data ahead of the meeting to discuss the data, and also to establish a procedure for what will happen if gaps in participation are identified.

Policy 4 is review, revise, and disseminate the Indian Policies and Procedures. Here, you’re stating how you take recommendations for changes to the IPP document, who approves them, and when they will become effective.

 Policy 5 is that you are required to provide a written response to any feedback received through the consultation process to close the loop. When we were writing these regulations several years ago, we heard from tribal governments that they were providing recommendations to school districts, but never received a response or any follow-up.  What we want to see is evidence of a dialog.  You have to respond at least annually in writing, send this response out through the tribe’s preferred method of communication, and you can group your responses by topic or theme.

Then policy number 6 states that you’re going to send the tribe a copy of the IPPs before you submit your Impact Aid Application. Impact Aid Applications are due on January 31st, or the next business day if January 31st falls on a weekend. 

That was a lot, and if you’re just beginning the Impact Aid application process, or are going back to an IPP after several years of being under a waiver, I recommend starting with our IPP template. This is an example of an IPP template that can be found on our resources page. The procedures in the template have a sufficient level of detail to provide a clear plan for how the LEA will carry out the required policies.  As you can see, all text can be edited to meet the needs of a specific tribe or tribes. Your IPP will be uploaded to your annual application and reviewed by an Impact Aid analyst.  An IPP may not be approved if it does not contain the current six regulatory policies, if the school board has not adopted it within the year prior to the application submission date, or if it is missing relevant information necessary for an Impact Aid analyst to verify its adherence to federal regulation. If your LEA’s IPP is not approved, you will be notified in writing and given 90 days to bring the IPPs into compliance.

Not only do you need to approve your IPPs annually, but you also must implement the procedures.  We advise each LEA with an IPP to read through it at the beginning of the school year and make a detailed plan with tasks assigned to the responsible staff to ensure each procedure is followed by the deadlines described in the document.  As a way to stay organized regarding IPP implementation, an LEA can use the IPP implementation questionnaire which can be found on our resources page. Not only is this a good internal tracking tool, but in the event that your district is chosen for monitoring, you could use the questionnaire as evidence that you have met the IPP regulatory requirements. Please note that failure to carry out the procedures in your IPP could result in part or all of your LEA’s Indian lands payment being withheld.

If your local tribe or tribes are satisfied with your LEAs services and programs, they may waive the IPP requirements in writing. An IPP waiver has four required components. It is a voluntary written letter that states the tribe is satisfied with the educational services provided by the LEA, that the LEA does not need to comply with the Indian Policies and Procedures requirements listed in the regulations, that the tribe has been provided a copy of the regulations, and that the tribe understands it is waiving these requirements. An LEA must submit a waiver at the time of application. And if an LEA has the lands of multiple tribes on its application, all tribes must provide a waiver. If any tribe has not signed a waiver letter or does not agree to a waiver, an LEA must adopt Indian Policies and Procedures and upload an IPP to its annual Impact Aid application. There is space on the application to upload multiple waiver letters.

Here you can see an example of an IPP waiver template which can be found on our resources page. The waiver has to state the name of the tribe, the name of the school district, and the correct application year. The waiver must also have a signature from the tribal leader, including his or her name and title. Again, this is due at the time of the application and proactively seeking this document will aid your LEA in a timely submission of your Impact Aid Application.

This concludes our brief overview of Indian Policies and Procedures, including waivers. For more information, please visit us at our website. There, you will find other training videos, user guides, and copies of our live webinar slides.

In this video, we will cover Low Rent Housing properties and recommended source check forms used to capture the data on these properties.

Let’s begin by discussing what is eligible Low Rent Housing here in the Impact Aid Program, also known as traditional public housing. It’s important to know the type of properties because all properties are not eligible public housing.

Traditional Housing is owned and managed by a Public Housing Authority and funded under the Housing Act of 1937. These properties are generally identified by an Asset Management Project number, or what we like to call the “AMP”  number that is given by the U.S. Department of Housing and Urban Development.   If the property does not have an AMP number, it likely isn’t eligible.

Non-Traditional Low Rent Housing is generally not eligible for Impact Aid purposes. These are properties like Annual Contributions Contract, Housing Choice Voucher Program, Residential Assistance Demonstration program, Rental Assistance Payment, Section 8, and Low Income Tax Credit properties, just to name a few of the ineligible low rent housing. If you have any questions about what properties are eligible or ineligible in your district, please reach out to the Public Housing Authority in your area.

Now, let’s talk about the recommended source check form used to document children residing on Low Rent Housing.

The source check form must include the name of the federal property (for example: Red Robin Apartments, Langston Lane Apartments, etc.).  It must also include the Asset Management Project Number, Parent’s Name, of course child’s name, child’s residential address, child’s grade. This is all mandatory data. If the form is missing any of this mandatory data, your source check form and child associated with the form is ineligible. Remember, these forms should be signed on or after the survey date.

The source check form must be signed by the appropriate public housing agency certifying official.  This official confirms that the property is: 1) funded under the Housing Act of 1937 and 2) the child listed on the form resided on that property on the survey date.

The form must also be signed by the district’s official. This official confirms that the child was enrolled in the district on the survey date.

For more information, please visit us at our website. There you will find other training videos, user guides, and copies of our live webinar slides.

In this video we will discuss how to submit your Section 7003 Impact Aid application in the Impact Aid Grant System, also referred to as IAGS. We will provide an overview of the application process and show you how to access IAGS and enter your membership and federally connected child count data.

Before starting your application, there are a few things you should do.

Step 1- Accessing IAGS.  If you are an existing user, make sure you have an active account. If you are a new user, please visit www.impactaid.ed.gov. You may need the Impact Aid Program to set you up with an account, or you may be able to ask the core user in your school district to create an account for you.

Step 2. Make sure you have organized all your data so that you can enter it efficiently in IAGS. Please make sure you have access to documents you will need to enter the total membership data as well as the federally connected membership for each category. It helps to sort your federally connected membership by category and then by federal property. If you want to use total average daily attendance (ADA) or sample ADA because your attendance ratio is higher than the state average, have the supporting documentation to upload. Do NOT upload any other documents, for example source checks, parent pupil forms, unless specifically requested by the program.

Step 3. Begin your application by logging into IAGS. Scroll down to the Application Status box. Click on the “Start 7003 Application” link. On our website, under the training menu, there is a PowerPoint presentation with screenshots showing how to start and complete your application.

Step 4. The first section you will see is Membership and ADA. Enter your first day of school and your survey date. The survey date must be at least 4 days after the first day of school. Next, select the attendance ratio type using the drop-down menu.  Most LEAs opt to use the State Average Attendance Ratio. Finally, enter the total number of children enrolled in your LEA on the survey in the table on the right side, under current year. You must complete this page before you can move to the other sections.

Step 5. Next, enter the federally connected membership data for each category by property. The application will pre-populate with the federal properties claimed for each category based on your previous application. If you claim a category of child that qualifies for a supplemental special education payment, you need to give us the total number of children on the property in the first box and then in the second box how many of those children had an individualized education plan (IEP) on the survey date. For example, you may have 100 children living on trust property on the Zuni Reservation, and 15 children had an active IEP on the survey date. You would enter 100 total children and 15 Children with Disabilities. Tip: If you find that it is difficult to navigate through all the pages to enter the information, you can scroll through to the final page of the application, the Application Review page, where you can enter all of the information at the same time.

You may need to complete additional sections of the application, such as entering children with disability expenditures, or uploading an Indian Policies and Procedures document, as applicable.

Step 6. Once you have entered the membership and federally connected membership data, please select the submit button at the bottom right corner of the screen. This will send the application to the signatory, who will sign and submit the application and assurances.

This slide provides some key dates to mark on your calendar.  You can also find all of the key dates in the IAGS on your home page.

The application submission period begins in early December, usually in the first week. At that time, you will be able to log into IAGS and submit your application. The deadline to submit your application is January 31st.

The late submission deadline is April 1st and submitting your application late will result in a ten percent penalty.

The final deadline to be mindful of is the amendment deadline. If you wish to make changes to your application, you must do so by June 30th. You can let Impact Aid staff know of your intention to amend your application when submitting your application. There will be a small box on the bottom left of the screen asking if you intend to amend. You must select an answer, or you will not be able to move forward in your application. You may always submit an amendment before the deadline, even if you did not inform the program of your intention on the original application.

We will conclude this webinar with some important reminders when applying for Impact Aid funds.

First, you need to survey every year. If you use a source check it must be signed annually.

You cannot estimate child counts or use prior year data on your application.

Do not include incomplete forms. If information is missing on a survey form, work with the parent or guardian to get it corrected.

Absolutely do not alter any survey forms after a parent or guardian has signed the form. This will invalidate the form.

When requesting an official to certify a source check form, it is a good idea to contact the certifier early to see how long they will need to review the documentation and return it with their signature. Give your list of children to them with plenty of time to verify it before you submit your application in December or January.

Last, but not least, you must retain all documents related to the application for 3 years after receiving a final payment for the fiscal year.

This concludes our brief overview of the steps for submitting an Impact Aid application. For more information, please visit us at our website. There you will find other training videos, user guides, and copies of our live webinar slides.

In this video, we will review the Indian Policies and Procedures (IPPs) Monitoring Questionnaire. If your LEA is selected for monitoring and submitted IPPs at the time of application, this form will be required. We will discuss some tips to get started and instructions for completing each part of the form.

Begin by gathering documents related to the implementation of your IPPs during the targeted time frame listed on the form.  For the FY 2024 application year, this is February 1, 2022 – January 30, 2023. There are common examples of documents you may need listed on this slide and the specific documents you need will depend on your LEA’s community and IPPs. 

You may also find it helpful to have a copy of the current IPP regulations and Sample IPPs.

The questionnaire is broken down into three parts containing tables to report your implementation activities as described on this slide. A blank Word version of the questionnaire is available in the resources section of our website and is linked to the page where you found this video.

It is important to remember to list specific dates for actions taken rather than future planned dates when describing your implementation activities in Parts 1 and 2 of the questionnaire.  You will also attach a copy of your LEA’s written responses to tribal or parental feedback to this form. In the next few slides, we will cover the different parts of the questionnaire and how to complete each.

On the top of the form fill in basic information about your LEA and IPPs. This includes your LEA’s name and application number and the board approval date of the IPPs you submitted with your most recent application.  For the FY 2024 application year, your IPPs should have been board approved after February 1, 2022, to be considered current.  You may attach additional pages if the information you are providing does not fit on the form as needed.  On the next slides we will review how to complete the three parts of the questionnaire.

The table in Part 1 allows you to summarize the important actions of your implementation which include the dissemination, or sending, of documents and the consultation between the LEA, tribal members, and parents.

Start by listing the tribe’s preferred method of communication at the top of the table. The left columns outline the documents and the corresponding policies in the regulations and your LEA’s IPPs.  For each document you will need the date or dates of dissemination, the method used to send the document, the date or dates of meetings or input opportunities, and the participation of tribal members and parents. A survey is an example of another input opportunity that you may list on this table.

If there is missing information or another type of explanation needed, you will have room at the end of the questionnaire to include that information.

The table in Part 2 of the questionnaire allows you to record whether feedback was received and the ways your LEA sent written responses to that feedback. Please attach copies of your LEA’s written responses to the feedback received to the document based on the information you provide on this table.

The table in Part 3 of the questionnaire is dedicated to what your LEA will do in your next consultation year to address any procedures you didn’t follow in your IPPs, also known as corrective actions. This may involve making changes internally or to your IPPs document itself.  You can also use the space below this table to add any additional information or explanations as needed.

This concludes our review of how to complete the Indian Policies and Procedures (IPPs) Monitoring Questionnaire. For more information, please visit us at our website.  There you will find other training videos, user guides, and copies of our live Webinar slides.