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NC DPI Title III Monitoring Plan of 25 January, 2017

Monitoring Plan 2016-17Title III, Part A: English Language Acquisition, Language Enhancement, and Academic Achievement

The North Carolina Department of Public Instruction (NCDPI), together with the US Department of Education and the Office of Civil Rights (OCR), is charged with the responsibility of enforcing Title VI of the Civil Rights Act of 1964, which prohibits discrimination based on race, color, or national origin. In Lau v. Nichols, the U.S. Supreme Court affirmed the U.S. Department of Education's May 25, 1970 Memorandum that directed LEAs to take steps to help English Language Learners overcome language barriers and to ensure that they can participate meaningfully in the educational programs.

The Elementary and Secondary Education Act (ESEA) Title III, Part A requires the State Educational Agency (SEA) to monitor the implementation of Title III program requirements and the expenditure of federal funds by all subgrantees. Monitoring Title III at the local level ensures compliance with regulations and assures the quality of the program and the instructional delivery being utilized with English Language Learners.

Title III, Part A provides supplemental financial assistance to States and eligible LEAs to develop and enhance their capacity to provide high-quality instructional programs designed to prepare limited English proficient children and immigrant children and youth to enter all-English instructional settings. Title III assists States in helping Local Educational Agencies (LEAs) increase their capacity to establish, implement, and sustain language instructional educational programs for limited English proficient students - “ The purposes of this part , Part A, are to help ensure that children who are limited English proficient, including immigrant children and youth, attain English proficiency, develop high levels of academic attainment in English, and meet the same challenging State academic content and student academic achievement standards as all children are expected to meet.” (Title III, §3102)

I. DEFINITION AND PURPOSE OF MONITORING

Monitoring is the regular and systematic examination of an LEA/Charter’s administration and implementation of a Federal education grant administered by NCDPI. Monitoring emphasizes accountability for using resources wisely in educating and preparing North Carolina’s students. As a result of monitoring, NCDPI is able to gather data about local needs and use that data to design technical assistance initiatives and statewide initiatives. Thus, monitoring serves not only as a means for helping LEAs/Charters achieve high-quality implementation of educational programs, it also helps NCDPI to be a better advisor and partner with LEAs/Charters in that effort.

Title III Tier III (Onsite) Monitoring Instrument and Report 2016-2017


NCDPI’s monitoring process will include technical assistance through Onsite Monitoring visits, Targeted Technical Assistance and Modified Desk Monitoring for identified LEAs/Charters. Monitoring outside of the scheduled cycle may be arranged as needed if an LEA/Charter has serious or chronic compliance issues or has unresolved issues identified during the monitoring process. The state wide monitoring plan will be reviewed and revised annually and/or as needed.

II. MONITORING INDICATORS

The content of NCDPI’s monitoring is based on States’ responsibilities to provide guidance and support to LEAs/Charters and schools based on the requirements of the ESEA. Monitoring LEA/Charter implementation of Title III means closely examining LEA/Charter policies, systems, and procedures to ensure school compliance with federal and state statutes and regulations.

NCDPI uses monitoring indicators to determine the degree and quality of implementation of Title III programs. Following the federal monitoring plan, indicators have been developed in each of the four monitoring areas (Standards, Assessment and Accountability; Instructional Support; and Fiduciary). The use of such criteria ensures a consistent application of these standards across monitoring teams and across LEAs/Charters. The published indicators provide guidance for all LEAs/Charters regarding the purpose and intended outcomes of monitoring by describing what is being monitored and providing the criteria for judging the quality of implementation (acceptable evidence).

Please note that the indicators are written broadly to cover all the requirements of each topic. Examples of documentation and evidence that LEAs/Charters can provide to show compliance with these requirements are listed for each indicator. These are examples and are not all required. Additional evidences can be submitted, as well.

III. THE MONITORING PROCESS

Monitoring LEAs’/Charters’ implementation of Title III provides an opportunity to examine how LEAs/Charters have instituted policies, systems, and procedures to ensure LEA/Charter and school compliance with the statutes and regulations. Monitoring serves many purposes:

Formalizes the shared responsibility of North Carolina and the LEAs/Charters to improve student achievement and close the achievement gap in order to have all students reach proficiency.

Provides a vehicle to North Carolina’s legal responsibility to monitor the implementation of Title III. Leverages support for broad scale implementation in all districts that receive these funds.



Ensures that school districts provide critical information to parents that enable them to be full partners in their children’s education.

Provides data that inform technical assistance that supports North Carolina’s and school districts’ efforts to improve teaching and learning.

Provides data to inform state policy and leadership activities.

A. Description of the Monitoring Process

North Carolina’s monitoring plan involves a 2-tiered system: Tier I: Onsite Monitoring; Tier II: Targeted Technical Assistance. Tier III: Modified Desk Monitoring.

This approach helps LEAs/Charters build capacity to improve student achievement and ensure program compliance. A risk-based analysis of program components and characteristics is used to identify subgrantees for Tier I and Tier II monitoring. All Title III subgrantees will participate in Tier III. Risk factors include:

size of subgrantee grant award, percentage of EL students, program performance based on meeting what was previously known as AMAOs 1 and 2, student subgroup academic performance based on AMOs for EL students, change in program or leadership, and the length of time since previous onsite monitoring.

Tier I – Onsite Monitoring

LEAs/Charters are selected for onsite monitoring based upon the annual risk-based assessment of subgrantees. During the site visit, the NCDPI Monitoring Team will review documentation, observe classrooms and interview LEA/Charter staff, principals, teachers, parents, and other stakeholders. This multi-level interview strategy will allow the monitors to gather information from a variety of perspectives and better evaluate the impact of the LEA’s/Charter’s administration on the implementation of Title III at the LEA/Charter and school levels. This strategy will also allow the monitoring team to conduct a thorough review of the indicators, and acquire a more complete picture of the degree of program implementation.



Tier II – Targeted Technical AssistanceTargeted Technical Assistance is provided to subgrantees with specific identified risks. The risks may include:

Provisions for supplementing, not supplanting services for English language learners, Descriptions of LIEP services provided, Appropriateness of expenditures for technology, Failure to test all EL students enrolled during the English language proficiency testing window, Failure to meet the 95% participation expectation on state reading and mathematics end-of-grade/end-of-course tests for EL

students, New leadership for Title III subgrantees, Challenges with data integrity, and/or Any other critical needs as revealed from Title III Application, Improvement Plan or State Technical Assistance.

Tier II monitoring will occur during the same time frame as Tier I.

Tier III – Modified Desk Monitoring

Title III funded job descriptions were not required as additional documents in the NCCCIP as part of Title III application process for 2016-2017. As an adjusted form of previous Title III Tier III/Desk Monitoring, the NCDPI will use the following process to offer technical assistance to LEAs/Charters in regards to Title III funded staff positions for 2016-2017:

1. Job descriptions for Title III funded staff will be submitted to NCDPI by Wednesday, January 25, 2017.a. WORD format b. Email to [email protected] c. Subject line: Job Descriptions for X LEA/Charterd. Include contact name, email and phone in the body of the email.e. Indicate if positions are fully or partially funded by Title III. For partially funded, include percentage and job

descriptions for other parts of job.

NCDPI will review the job descriptions and craft guidance based on trends found among the job descriptions.

NCDPI will release the technical assistance via a webinar on May 9th and by posting the information on the ESL Wiki.


mailto:[email protected]


The turnaround time is short, but time involved in submission should be minimal since no changes are needed to the documents for submission.

B. Onsite Monitoring

1. Preparation for Onsite Monitoring

LEAs/Charters to be monitored will be contacted after the official release of AMAO data. LEA/Charter EL Coordinators will be contacted by DPI Title III Staff, followed by an official letter to LEA/Charter Superintendents. A conference call will be scheduled with the LEA/Charter Title III Coordinator prior to the visit to ensure LEA/Charter staff is familiar with the monitoring process including a review of the monitoring indicators, guidance regarding documentation required during the monitoring visit, and the two-day monitoring schedule. Documents to assist the LEA/Charter in preparing for the onsite visit can be downloaded at http://eldnces.ncdpi.wikispaces.net/EL+Coordinators under Title III Monitoring.

Prior to the monitoring visit, LEA/Charter staff will compile specific documentation providing evidence to address the monitoring indicators. Ideally this collection of documentation supporting compliance with Title III and state and local regulations should be an ongoing process.

2. Onsite Monitoring Process

The DPI Monitoring Team, typically consisting of a DPI Title III Consultant (or designee) and an LEA/Charter Representative, conducts the onsite monitoring by reviewing documentation, observing classrooms and interviewing LEA/Charter staff, principals, teachers, parents, and other stakeholders and collecting other evidence as indicated on the North Carolina Title III Monitoring Instrument and Report.

Indicators are rated on a scale of 1-3. The rating NA is only appropriate for item 2.3, when the LEA/Charter does not receive significant increase Immigrant Funds (PRC 111) and 2.4 for Charter Schools who do not serve Private Schools.

i. A rating of “3” is optimum. Meets requirement. ii. A rating of “2” indicates that a requirement is met in a minimal manner and that improvement is needed.

iii. A rating of “1” indicates that a requirement has not been met and that corrective action must be taken. Not in compliance.


http://eldnces.ncdpi.wikispaces.net/LEP+Coordinators


An exit conference is held at the conclusion of the onsite review for the purpose of reporting the preliminary results of the monitoring visit to the LEA/Charter. Typically, the DPI monitoring team meets with the LEA/Charter Title III Coordinator and the Superintendent or Superintendent’s designee to discuss potential findings and recommendations that the team will likely cite in the monitoring report. The team will summarize the visit’s activities, the potential findings and recommendations, and timeline for developing the monitoring report. The team also responds to questions posed by the LEA/Charter (both related to process and content). The team leader emphasizes that the information presented at the exit conference is preliminary, and explains that during the development of the monitoring report, the team will continue to review data and contact the LEA/Charter for additional information, as required.

3. Follow Up

The NCDPI Title III Monitoring Team will prepare a written report within 30 business days of the onsite monitoring visit. The final report will be sent to the LEA/Charter from the NCDPI Chief Academic Officer. The monitoring letter and report will be e-mailed to the LEA/Charter Superintendent. In conjunction with this mailing the letter and report will be emailed to the LEA/Charter EL Coordinator. The entire process may take up to 3 months.

Within 30 business days from receipt of the Monitoring Report, the LEA/Charter will submit a written response with proposed resolutions to any findings from the monitoring visit to the DPI ESL Consultant. The DPI ESL Consultant will respond to the proposed resolutions as to whether or not they are satisfactory. If the proposed resolutions are not satisfactory, the DPI ESL Consultant will provide technical assistance to the LEA/Charter so that acceptable resolutions are identified.

C. Targeted Technical Assistance

1. Preparation for Targeted Technical Assistance LEAs/Charters to receive Targeted Technical Assistance will be contacted after the official release of AMAO data. The LEA/Charter EL Coordinators will be contacted by DPI Title III Staff, but no official letter will be sent to LEA/Charter Superintendents. A conference call will be scheduled with the LEA/Charter Title III Coordinator prior to the technical assistance visit or virtual meeting to review monitoring indicators, finalize the Focus Topic(s), and to determine dates for the technical assistance. The technical assistance may be supported by the Title III Monitoring Visit documents which can be downloaded at http://eldnces.ncdpi.wikispaces.net/EL+Coordinators under Title III Monitoring.

Prior to the technical assistance meeting, LEA/Charter staff will compile specific documentation providing evidence to address Title III Tier III (Onsite) Monitoring Instrument and Report 2016-2017

http://eldnces.ncdpi.wikispaces.net/EL+Coordinators


the Focus Topic(s). Ideally this collection of documentation supporting compliance with Title III and state and local regulations should be an ongoing process.

2. Targeted Technical Assistance Process

How the DPI Consultant conducts the technical assistance will differ based on the Focus Topic(s). The NCDPI Consultant and EL Coordinator, as well as other vested stakeholders, will work together to address the Focus Topic(s). This may include reviewing documentation, observing classrooms and/or interviewing LEA/Charter staff, principals, teachers, parents, and other stakeholders and collecting other evidence as indicated on the North Carolina Title III Monitoring Instrument and Report or in State and Federal guidance. Next steps will be determined and documented by the conclusion of the visit.

3. Follow Up

The NCDPI Consultant and EL Coordinator, as well as other vested stakeholders, will continue to work together to address the Focus Topic(s). The DPI ESL Consultant will provide technical assistance to the LEA/Charter until acceptable resolutions are identified or determine that a full monitoring visit is needed in the next school year.

D. Modified Desk Monitoring

1. Preparation for Modified Desk Monitoring

Title III funded job descriptions were not required as additional documents in the NCCCIP as part of Title III application process for 2016-2017. They will be collected as part of the Modified Desk Monitoring for 2016-2017.

LEAs/Charters who are Title III subgrantees should prepare copies of Title III funded job descriptions and non Title III job descriptions that are part of a split funded position with partial Title III funds in WORD format to be submitted to NCDPI. Time involved in submission of job descriptions should be minimal since no changes are needed to the documents for submission.

2. Modified Desk Monitoring Process

Job descriptions for Title III funded staff will be submitted to NCDPI by Wednesday, January 25, 2017.Title III Tier III (Onsite) Monitoring Instrument and Report 2016-2017


a. WORD format b. Email to [email protected] c. Subject line: Job Descriptions for X LEA/Charterd. Include contact name, email and phone in the body of the email.e. Indicate if positions are fully or partially funded by Title III. For partially funded, include percentage and job

descriptions for other parts of job.

3. Follow Up

NCDPI will review the job descriptions and craft guidance based on trends found among the job descriptions, release the technical assistance via a webinar on May 9th and by posting the information on the ESL Wiki.


mailto:[email protected]


North Carolina Title III Monitoring Instrument and ReportTier I - Onsite Monitoring Instrument and Report

LEA/Charter Name: RATING SCALE 1 - Does Not Meet Requirements. Out of Compliance.2 - Meets Requirements But Improvements Needed 3 - Meets RequirementsNA* - Not Applicable

*NA is only allowable on 2.3 for LEAs/Charters who do not receive Immigrant Funds and on 2.4 for Charter Schools who do not serve Private Schools

LEA/Charter #: Contact Person: e-mail:Work Phone: Cell Phone: Date(s) Conducted: Date of Report:

Members of monitoring team: (Names may be added, as appropriate.)

(Printed name) (Position) (Signature)

(Printed name) (Position) (Signature)

Note: The NC Department of Public Instruction is required to monitor all federal programs. The State shall advise subgrantees of requirements imposed on them by Federal laws/regulations and monitor the activities of subgrantees as necessary to ensure that Federal awards are used for authorized purposes. (Office of Management and Budget Circular A-133) References for Program Requirements: Title III Language Instruction for Limited English Proficient Students Public Law 107-110, Sections 3001 – 3304; EDGAR; OMB Circular A-87; ED Compliance Supplement; Office of Management and Budget Circular A-



Monitoring Indicators for Title III Standards



Monitoring Indicators for Title IIIAssessment and Accountability


1.1: English Language Proficiency (ELD) Standards. [§3113]Guiding Questions Acceptable Evidence Compliance Indicator(s) Rating

Questions: Has the LEA/Charter implemented the State

established ELD Standards that are derived from the four domains of speaking, listening, reading, and writing and cover grades K-12?

Has the LEA/Charter participated in State training and/or technical assistance for implementation of State ELD Standards?

Has the LEA/Charter disseminated the ELD Standards to content and ESL teachers, and provided training and technical assistance on implementation of the standards?

Possible Documentation:

Workshop announcements

Workshop agendas

Workshop evaluations

Sign-in sheets from workshops

Teacher reflections

Professional Development plan on ELD Standards

Evidence of continued application of training

Pacing guide/documentation tool noting use of ELD Standards (WIDA Standards)

Evidence of participation in State training and/or technical assistance for implementation of State ELD Standards

Staff describes how the State ELD Standards have been implemented at the district level, including professional development provided to teachers and other staff, and curriculum development activities

Other relevant documents/resources notingevidence of ELD Standards implementation

Rating:______For a rating of ‘2’, list the change(s) suggested to be implemented.For a rating of ‘1’, list the action(s) required to be taken to meet compliance requirements.


1.2: English Language Proficiency (ELP) Assessment. [§3113 and §3116(b)(3)(A,B,C)]Guiding Questions Acceptable Evidence Compliance Indicator(s) Rating

Questions: Does the LEA/Charter have a process

for verifying number and percentage of Title III EL students tested on ELP assessment and method for reporting results to the State?

Describe the process for providing technical assistance to schools in your jurisdiction on how to administer the ELP assessment.

What is the LEA’s/Charter’s process for initial identification and placement of EL students?

Possible Documentation from previous and current school year:

W-APT score data

ACCESS testing schedules

Documentation of LEA/Charter process for identification and placement

Documentation of number of students not tested under state ELP Assessment by grade including reasons for non-assessment

Other relevant documents/resources


Monitoring Indicators for Title IIIAssessment and Accountability (Included for discussion purposes ONLY)



1.3: Annual Measurable Achievement Objectives (AMAOs). [§3122(a)(1)(2)(3) and §1111(b)(2)(B)]Guiding Questions Acceptable Evidence Compliance Indicator(s) Rating

Questions: How does the LEA/Charter ensure

students receive testing accommodations during the administration per testing documentation? (ELP for Students with disabilities & EOG/EOC for Students with disabilities and for EL students)

What criteria are being used to select instructional & assessment accommodations for individual students?

Are those accommodations documented in the student’s EL documentation?

Are accommodations that will be provided to students on state assessments being used routinely during classroom instruction?

Did the LEA/Charter meet all three AMAOs?

Participation targets met? Did the LEA/Charter follow its

improvement plan related to two-year /or four-year accountability provisions, if applicable?

LEA notification letters to parents regarding LEA/Charter has not met AMAOs, if applicable.

Does LEA staff demonstrate knowledge of subgrantee’s AMAO status, and any applicable sanctions for not meeting AMAOs for two or four consecutive years?


State content assessments data

Documentation of testing accommodations

Agendas from teacher meetings where AMAOs and related issues are discussed

Agendas from principal meetings where AMAOs and related issues are discussed

Staff demonstrates an understanding of AMAOs

Minutes from meetings

Sign-in sheets from meetings

Analysis of AMAO data

Plan for improvement



Monitoring Indicators for Title IIIAssessment and Accountability



1.4: Data Collection and Reporting. [§3121 and §3123; EDGAR 34 CFR 76.731]Guiding Questions Acceptable Evidence Compliance Indicator(s) Rating

Questions: Has the LEA/Charter established and

implemented data collection methods in order to provide complete and accurate data to meet all Title III reporting requirements?

How does the LEA/Charter ensure that it tracks and reports academic content performance of students for two years after they exit a Title III language instruction educational program (MFELs)?

What are challenges to maintaining accurate data?


Evidence that subgrantee has procedures in place to collect data on individual EL students from schools and report these data to the SEA

Evidence that subgrantee tracks and reports data for MFELs

Evidence that LEA/Charter reports EL testing accommodations in the state approved reporting tool

Staff gives an overview of the process for collecting and reporting ELP assessment data to the SEA, including how staff has addressed any discrepancies in these data, such as any student records that cannot be matched or any partial scores due to child absences

Data quality protocol



Monitoring Indicators for Title IIIInstructional Support



2.1: This indicator does not apply to LEAs.2.2: LEA Local Plans: Process, Collaboration, Assurances and Certification [§3116(a) and §3115(c); EDGAR 34 CFR 76.770]

Guiding Questions Acceptable Evidence Compliance Indicator(s) Rating Questions: Describe process used for subgrantee

submission and SEA review of subgrantee local plan(s), and any plan amendments.

Does the LEA’s/Charter’s submitted plan contain the information, assurances and certification required in section 3116?

Was the Title III Plan developed in consultation with teachers, researchers, school administrators, parents, and other education-related community groups as appropriate?

Is the language instructional program differentiated to target the needs of students such as long term ELs (LTELs), ELs with severely interrupted formal education (SIFE), and refugees?

Does the LEA/Charter use funds for required activities described in Section 3115(c)?

. Does the LIEP clearly demonstrate

appropriate criteria for determining the type of instructional services provided to ELLs?

Does the LEA/Charter offer a high quality LIEP based on scientifically-


LIEP Services Chart

Meeting notices of collaboration

List of attendees

Surveys from educators or parents

Documentation of educator or parent committees (e.g., EL Task Force)

Documentation of collaborative planning

LEA’s/Charter’s approved plan containing the information required in section 3116

Feedback from the SEA regarding LEA’s/Charter’s local plan

Copy of signed assurances and certification from subgrantees as outlined in sections 3116(d) and 3116(c)

Certification process to ensure teacher fluency in English (Rubric/checklist to assess oral fluency and written skills)

Research Based Multi-tiered Professional Development plan(s) targeting EL students (ESL Department)

Research Based Multi-tiered Professional Development plan(s) targeting EL students




2.1: This indicator does not apply to LEAs.2.2: LEA Local Plans: Process, Collaboration, Assurances and Certification [§3116(a) and §3115(c); EDGAR 34 CFR 76.770]

Guiding Questions Acceptable Evidence Compliance Indicator(s) Rating based research?

Is the explanation of how technology purchases contribute to the overall objective of providing a LIEP and how it is used to provide supplemental services for EL students?

(District-wide)

Detailed description of instructional programs in Local EL Plan or ESL handbook including specific activities targeting various EL subgroups: long term ELs (LTELs), ELs with severely interrupted formal education (SIFE), and refugees

ESL teacher schedules - elem., middle, high

Sample lesson plans – elem., middle, high

Local curriculum guides that include EL modifications





2.3: Activities by Agencies Experiencing Substantial Increases in Immigrant Children and Youth. This item is completed only by LEAs/Charters receiving PRC 111 funds for significant increase of immigrant students. [§§3114—3115 (e)(1)]

Guiding Questions Acceptable Evidence Compliance Indicator(s) RatingQuestions: How does the LEA/Charter ensure that the

funds received for immigrant children and youth are used to pay for activities outlined under section 3115(e), which may include–A. Family literacy, parent outreach,

training activities for parentsB. Support for personnel to provide

services to immigrant children and youth

C. Tutorials, mentoring, academic or career counseling

D. Identification and acquisition of curricular materials, educational software, technologies

E. Basic instruction services directly attributed to the presence of immigrant children and youth

F. Other instruction services such as civics, intro to the educational system

G. Activities offering comprehensive community services

LEA/Charter staff describes the guidance and oversight received from the SEA regarding this grant as well as the types of activities offered and students served.

How are immigrant students who are not EL served?


Evidence that activities conducted by LEA/Charter are those outlined under section 3115(e)

ESL staff demonstrates an understanding that the immigrant grant program is distinct from the Title III formula grant program

Records of the immigrant students being served by this grant

Copy of subgrantee plan approved by the State






2.4: Private School Participation. [§9501] The LEA has consulted with nonpublic schools to identify their EL students and provides equitable participation of eligible students within the LEA’s school attendance area. [http://www2.ed.gov/policy/elsec/leg/esea02/pg111.html ]

Guiding Questions Acceptable Evidence Compliance Indicator(s) Rating Questions: How does LEA/Charter ensure that

private schools are sufficiently notified of choice to participate in Title III services?

Is there a follow up procedure in place to inform private schools that do not attend the meeting?

If Serving Private Schools: How does the LEA/Charter ensure

that EL students in participating private schools are identified?

How does the LEA/Charter ensure that it complies with ESEA requirements regarding participation of EL students, their teachers, or other educational personnel in private schools in areas served by the subgrantee?

How does the LEA/Charter monitor services to private school students and evaluate effectiveness of services?


Documentation of sufficient notification of opportunity to participate in Title III Services

Documentation indicating that all private schools within the LEA/Charter intended to/did not intend to participate in Title III

The number of eligible students participating in each private school If Serving Private Schools:

Evidence of “timely and meaningful” consultation with appropriate private school officials during all stages of service

Written policies and procedures for provision of equitable services

General consultation timeline (before, during, after)

Subgrantee assessment of services provided and how the results of the assessment are used to improve services

Documentation of needs assessment and program development plan

Documentation of funding allocations



http://www2.ed.gov/policy/elsec/leg/esea02/pg111.html



2.5: Parental Notification and Outreach. [§3302)]Guiding Questions Acceptable Evidence Compliance Indicator(s) / Rating

Questions: How does the LEA/Charter notify parents

of each child identified as EL within 30 Days (or 2 weeks for students enrolled after the beginning of the school year) of the following: reason for identification, level of English proficiency, method(s) of instruction, how the program will meet the needs of their child, how the program will help their child learn English and meet standards for graduation, specific exit requirements, rate of transition out of LIEP services, rate of graduation, parental rights to waive types of services in section 3302(a)?

How does the LEA/Charter comply with the parental notification provisions for failure to meet Title III AMAOs in section 3302(b)?

How does the LEA/Charter ensure that the notifications are in an understandable and uniform format and, to the extent practicable, in a language that the parent can understand?

How does the LEA/Charter ensure that it implements an effective means of outreach to parents of EL children regarding their education as specified in section 3302(e)?


Sample parent notification containing all components required under section 3302(a) (1-8)

Parent notification forms in other languages, as available

If applicable, samples of parental notifications regarding subgrantee failure to meet Title III AMAOs (Discussion)

Evidence of implementation of an effective means of outreach to parents of EL children (sample notices)

Meeting notices

Meeting agendas

Minutes from meetings

Sign-in sheets from meetings

Questionnaires / Surveys





Monitoring Indicators for Title IIIFiduciary

3.1: State Allocations and Carryover. This includes PRC 111 if the LEA/Charter receives funding for significant increase of immigrant students. [§3111(b); 20 USC 6821(b)(3); §3114(a)-(d); 3115]

Guiding Questions Acceptable Evidence/ Compliance Indicators Compliance Indicator(s) / Rating

Does the LEA/Charter have documentation of the count of EL students?

For consortia: Is there a designated fiscal agent?


Budget including breakdown of funds

Grant award notification

Notification of LEA’s/Charter’s Title III Immigrant subgrant, if applicable

Explanation of headcount procedure

Document of the count of EL students submitted to SEA






3.2: LEA Allocations and Carryover. This includes PRC 111 if the LEA/Charter receives funding for significant increase of immigrant students. [§3115]

Guiding Questions Acceptable Evidence/ Compliance Indicators Compliance Indicator(s) / Rating

Is there evidence that the LEA/Charter has reserved no more than 2% of its allocation for administrative personnel? (Purpose Code 6200)?

Are there ‘overspent’ lines in the budget vs. expenditures printout? Note: monitor expenditures because amendment needed if overspent is more than 10% at end of year to avoid audit finding.

Is there evidence that the LEA/Charter has included both direct (administrative personnel) and indirect costs in the 2% reservation?

Is there evidence that the LEA/Charter is implementing required activities?

Is there evidence that the LEA/Charter is implementing activities that are authorized per approved Title III plan?


Budgets vs. expenditure printout

Documentation of BAAS submissions of planning allocations and amendment with carryover






3.3: Maintenance of Effort: LEA Title III expenditures meet federal fiscal requirements, including time and effort, equipment records, detailed invoices, and documented internal controls of the LEA/Charter. This includes PRC 111 if the LEA/Charter receives funding for significant increase of immigrant students. [§1120A and §9021, EDGAR OMB Circular A-87]

Guiding Questions Acceptable Evidence/ Compliance Indicators Compliance Indicator(s) Rating How do LEA/Charter Title III expenditures

meet federal fiscal requirement (Supplement, Not Supplant)?

How does equipment benefit the Title III program? How it is used to provide services for EL students?

Are equipment disposition procedures being followed correctly: request, response form?

Is the equipment inventoried at least once every two years? (Tagging & Tracking)

Does LEA/Charter have time and effort documentation for all salary codes/positions, except for substitutes?

Do invoices clearly explain the “who, what, when and where” funds of how funds were expended?


Time and Effort forms - Personnel Activity Reports (PARs)

Semi-annual certification forms

Job descriptions

Payroll printout for PRC 104 (PRC111 if applicable) which shows 100% of pay for employees paid from these funds

Records of equipment inventory (for any equipment with a useful life greater than a year, i.e., consumables); Tagging; and Tracking

Records of equipment disposition

Copies of Invoices for contracted services (object code 311)

List of payments of contracted services (object code 311) for PRC 104 (PRC 111 if applicable). Select a sample to review

A copy of the LEA’s/Charter’s policies/procedures for purchasing/procurement, fixed assets, and other internal control policies.






3.4: Supplement Not Supplant – General - The LEA only uses funds under Title III, Part A to supplement the level of Federal, State and local public funds that, in the absence of the Title III funds, would have been provided for programs for limited English proficient children and immigrant children and youth, including PRC 111 if the LEA/Charter receives funding for significant increase of immigrant students. [§3115(g)]

Guiding Questions Acceptable Evidence Compliance Indicator(s) / Rating What is the basic instructional program/service

provided to all students (e.g., to meet Lau requirements)? How are Title III funds providing activities/services that are supplemental?

What funds is the LEA/Charter using to provide the basic language instruction educational program for EL students?

How has the LEA/Charter demonstrated that services provided with Title III funds are in addition to services that students would otherwise receive from State, local or other Federal funds?

What services is the LEA/Charter required by other Federal, State, local laws or regulations to provide?

How has the LEA/Charter demonstrated that it is not using Title III funds to provide services that it is required to make available under State or local laws or other Federal laws?

How has the LEA/Charter demonstrated that it is not using Title III funds to provide services that it provided in the prior year with State, local or other Federal funds?


Budgets and records of expenditures (e.g., Local, PRC 54, Title III) (LEA did not use Title III funds to provide services that were provided with non-Title III funds in the prior year Record verifies that funds have not supplanted other Federal, State, and local funds.)

Inventory records

Evidence that the LEA has not reduced State or local funds expended to implement language instruction programs serving EL students based on the amount of Title III funds the LEA/Charter receives

Contracts for appropriate Title III services

List of all ESL staff with funding sources for current and previous school years. (LEA did not use Title III funds to provide services that were provided with non-Title III funds in the prior year.)

Detailed job descriptions

LEA/Charter and school staff demonstrate an understanding of supplement not supplant requirement






3.4A: Supplement Not Supplant – Assessment. [§1111(b)(7) and §3113(b)(2)]Guiding Questions Acceptable Evidence Compliance Indicator(s) / Rating

Use of Funds to Administer ELP Assessments What funds has the LEA/Charter used to

identify EL students who may need language services, including the development of ELP screening or placement assessments?

What funds does the LEA/Charter use to pay for the costs of administration, scoring or reporting of ELP assessment, and materials or equipment related to the administration of annual ELP assessments?

How are personnel administering the ELP assessment documented?

What funding source is used for personnel?

What funds does an LEA/Charter use to develop and administer assessments to identify EL students and place them in basic language programs?

Possible Documentation

Letters/memos

Documentation of BAAS submission

Documentation of Assessment Funding (including positions and job descriptions of staff involved in testing)

Documentation of ELP testing plan

Documentation verifying that no Title III funds are expended for the purpose of state testing





Summary for Exit ConferenceThis may include or be in addition to monitoring findings as indicated by a rating of 1 or 2.

Title III Program Strengths

1.

2.

3.

Title III Program Opportunities for Improvement

1.

2.

3.
