1.3 Strategies & Expenditure Allowability

Creating the Local Services Plan

The process of crafting a Local Services Plan (LSP) is a meticulous journey that requires foresight, collaboration, and strategic planning. Recognizing the significance of this endeavor, the Colorado Department of Education (CDE) recommends that Local Education Agencies (LEAs) initiate this process at least 10 months prior to the LSP due date. This proactive approach ensures ample time for a thorough community health needs assessment, community engagement, and iterative refinement. Remember that the CDE School Health Services Consultant is also a resource available to LEAs during this process.

The image below outlines the main steps in creating the Local Services Plan. Each step is further detailed below the image. For more information, click here to access the Local Services Plan Development Strategies (PDF)

Step 1: Develop an informational document

Building on the foundational understanding of the need for a Local Services Plan, this initial step focuses on creating a comprehensive informational document. This document will detail the district's School Health Services Program and set clear expectations for the subsequent stages of the LSP development process.

• Begin by detailing the state of the district's School Health Services Program.
• Outline the 5-year Local Services Plan development process, ensuring clarity and comprehensiveness. Processes assessing health needs, prioritizing those needs, and determining how funds will be assigned should be clearly detailed.
• Set clear expectations for participation on the Community Health Advisory Committee, detailing roles and responsibilities.
• Schedule dates for upcoming meetings, ensuring ample prior notification for all participants. Make sure to reserve meeting rooms ahead of time.

For assistance in thinking through what questions to ask, consider reviewing the CDE LSP Health Needs Assessment Support document. This document does not need to be turned in with the LSP. Click here to access this support document.

Step 2: Develop a Community Health Advisory Committee

With the informational document in place, the next crucial step is to foster community collaboration. This involves forming a Community Health Advisory Committee, with a diverse membership from the local community. The committee should not be exclusively composed of LEA staff. A diverse community can provide collective insights and expertise, which will be invaluable in ensuring the LSP is both comprehensive and relevant to the community's needs.

• Using the informational document developed in Step 1, identify potential local service providers and stakeholders to be part of the committee. This can include county agencies, Community Based Organizations, School Based Health Centers, parents, students, and many others.
• Create an email list of these community members, ensuring diverse representation.
• Inquire about any existing community health assessments from the county Department of Health and Environment to inform the LSP development process.
• Send out meeting invitations with dates, locations, and the informational document to prospective members, ensuring they are well-informed ahead of the meetings.

Step 3: Develop meeting agenda

Having established the Community Health Advisory Committee, it's time to facilitate productive discussions. This step involves crafting a structured meeting agenda that will guide the committee through the process. The agenda ensures that all pertinent topics are covered, building on the foundation set by the informational document and the diverse perspectives of the committee members.

• Building on the foundation set by the informational document and the formation of the Community Health Advisory Committee, draft a structured meeting agenda.
• Start the agenda with a welcome and introduction segment to foster a collaborative environment.
• Establish ground rules for the meeting to ensure productive discussions.
• Review the informational document together, clarifying goals, responsibilities, and addressing any queries.
• Identify and prioritize student health needs, including the needs of the uninsured/underinsured population. (Remember: Up to 30% of total funds can be allocated to the uninsured.) 
• Review the proposed budget for the five-year LSP and discuss the allocation of funds to each identified health need. (Remember: Reimbursement allocation percentages for health services do not need to be identified in the LSP.)

Step 4: Create Local Services Plan

After thorough discussions and collaborative efforts in the previous steps, the final stage is to consolidate all the insights and decisions into the Local Services Plan. This plan will detail the strategies, priorities, and actions that the district will undertake over the next five years, ensuring the health and well-being of its students.

• Using insights from the previous steps, especially the discussions from the Community Health Advisory Committee meetings, begin drafting the Local Services Plan. (Click here for the latest template of the Local Services Plan)
• Develop procedures for monitoring and reporting the delivery of LSP health services, ensuring transparency and accountability.
• Ensure that the LSP aligns with the guidelines provided by the Colorado Department of Education (CDE) and reflects the collective decisions made throughout the process.

	Remember that crafting the LSP is a collaborative community effort. In drafting the LSP, ensure clarity and comprehensiveness so that any member of the public can easily grasp how the plan to spend reimbursement dollars will satisfy the identified health needs.

Reimbursement Expenditure Allowability

When thinking about expenditure allowability, first ask two questions: (1) does it align with the Local Services Plan (LSP), and (2) is it satisfying a health need? LEAs receive many purchase requests. It is essential to be good stewards of these dollars and maximize the help provided to students in your district. The two questions are detailed further below:

1. Does it align with the Local Services Plan?

The Local Services Plan (LSP) serves as a roadmap for how funds should be allocated and used within a specific program or district. It's crafted with community feedback and outlines the priorities and needs of the community.

Some Considerations:

• Local Community Needs: Ensure that the expenditure addresses the needs highlighted in the LSP. These needs have been identified through local community feedback and are deemed essential. Review Part II of the LSP on file to review identified health needs.
• Strategic Alignment: The expenditure should fit within the broader strategies and objectives outlined in the LSP. It's not just about meeting a current need but ensuring it aligns with the long-term vision of the community.
• Review and Update: Regularly review the LSP to ensure it remains up-to-date with the community's evolving needs. An expenditure that aligns with an outdated LSP might not serve the current needs of the community.

2. Is it satisfying a health need?

In the context of the School Health Services Program, the primary focus is on addressing the health needs of your students. Expenditures should directly contribute to improving health outcomes or addressing health challenges.

Some Considerations:

• Direct Impact: The expenditure should have a clear impact on health. For instance, purchasing medical equipment or funding a health awareness campaign would directly satisfy a health need.
• Long-Term Benefits: Consider the long-term benefits of the expenditure. Will it provide ongoing health benefits, or is it a short-term solution? Aim for solutions that offer lasting positive impacts on student health.
• Cost-Effectiveness: While satisfying a health need is crucial, it's also essential to consider the cost-effectiveness of the solution. If there's a more affordable alternative that achieves the same health outcome, it might be preferable.

Expenditure Allowability Related Strategies

Ensuring that expenditures align with guidelines and serve the intended purpose is crucial for the effective management of funds. Here are some strategies to assist in determining the allowability of expenditures:

Regular Reviews of the LSP

The LSP is a guiding document that outlines how funds should be allocated. Community needs and priorities may change over time. Regularly reviewing it ensures that expenditures align with current community needs and priorities.

Potential Action Steps:

1. Schedule quarterly reviews of the LSP. This can be done through established health committee, or LSP committee, meetings.
2. Cross-check proposed expenditures against the LSP to ensure alignment. If not already in place, consider integrating this step into an established expenditure approval process.

Billing Considerations for Goods/Services

Goods/services that are allowable as billable items in the Medicaid program are also considered allowable expenditures and can be paid for using reimbursement dollars.

Potential Action Steps:

1. Maintain a list of goods/services that are billable under the Medicaid program.
2. Cross-reference proposed expenditures with this list.
3. Ensure that administrative costs remain within the CDE recommended 20% limit.

Considering Historical Approval

Past approvals can serve as a precedent for current and future expenditure requests. Oftentimes, past approvals can be found as examples in many CDE support documents such as the Expenditure Allowability Support document or listed in the LSP guidelines under the appropriate health service category.

Potential Action Steps:

1. Maintain a database or record of previously approved expenditures, along with why they were approved.
2. Regularly update the list with new approvals and any changes in guidelines.
3. Before approving a new expenditure, check if similar items have been approved in the past.

Consultation and Collaboration

When in doubt, seeking external input can provide clarity on the allowability of an expenditure. The CDE School Health Services Consultant is a great resource to assist with expenditure allowability-related queries.

Potential Action Steps:

1. Organize a meeting or call with CDE to discuss ambiguous expenditure requests.
2. Collaborate with other LEAs to share insights and best practices on expenditure allowability.

Lessons from Rejected Requests

To ensure that reimbursement funds are used in alignment with program requirements, it's essential to understand the criteria for expenditure allowability. By examining previously rejected requests, LEAs can gain insights into the nuances of what makes an expenditure allowable. Below are examples of previously rejected requests across five different examples, along with new examples that are similar to the original ones, but would be considered allowable. Note: The examples examine whether or not the expenditure is satisfying a health need. Remember, that expenditures must also align with the LEA Local Services Plan on file to be considered fully allowable.

Example #1: Transportation Costs

Original Example: Transportation FTE costs for the general population.

Allowable Example: Transportation FTE costs for specialized transport vehicle drivers. This can also include roles like bus aides, assisting a student with a health need.

Example #2: Student Incentives

Original Example: Student monetary "incentives" usually associated with a training or event.

Allowable Example: Providing students with health-related items, like resistance bands or water bottles, for attending a health and wellness seminar.

Example #3: General Education Programming

Original Example: General education programming like reading/math lessons or associated costs.

Allowable Example: Funding a series of workshops on mental health, stress management, and healthy living for students.

Example #4: Clothing Purchases

Original Example: Purchase of clothing for general reasons such as dress code violations.

Allowable Example: Purchase of clothing for the purpose or replacing those soiled by a student.

Scenario #5: Equipment for Non-Health Roles

Original Example: Laptop or other equipment purchased for non-school health services program roles, or non-health providing positions.

Allowable Example: Purchasing a new laptop to replace a non-functioning device for a nurse, who uses the device in their role.