Title I Coordinator TrainingEquitable Services

December 7, 2010

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Essential Questions

What are the roles of the SEA, LEA, private school officials and vendors?

How do I calculate equitable services and utilize the funds?

How do I design a program for private school students?

How are the services delivered?

What are some best practices to ensure compliance?

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Defining Roles

• SEA• LEA• Private School Officials• Vendors

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Calculating Equitable Services

LEAs must provide an equitable share of funds reserved for:• parent involvement;• non-improvement related professional development; and • LEA-wide instructional activities to participating private schools.

• LEAs calculate the proportion of low income private school children to the total of all low-income children (public and private) in participating attendance areas.

• This proportion is then applied to the total set-aside to calculate the amount that must be made available to the private schools.

Low income private school students from participating public schools generate the same PPA as public school students from that participating public school.

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Availability of Funds

• Services should begin at the same time as the Title I program for public school participants.

• Funds are available as soon as consolidated grant is processed (July –Sept)

• Expenditures can be re-coded to grant start date

• Funds are available for obligation through December 15 of following year unless extension is granted.

• Funds must be liquidated by March 30 of the second year of the grant (unless extension is granted).

ARRA Funds are available for obligation through September 15, 2011 and must be liquidated by December 15, 2011.

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Unobligated/Unexpended Funds

Scenario 1: Equitable services are fully delivered– LEA can reallocate funds for public school Title I program to be used prior

to the end date of the grant (Dec. 15)*

OR– LEA can request an amendment to extend funds to be added to private

school program for the following year. First in, first out rule applies.

Scenario 2: Equitable services are delayed and/or not fully delivered– Funds must be carried over and added to the next year’s pool that private

school students generate. First in, first out rule applies. – The funds must be used to make up for the lack of equitable services

during the previous year and cannot be used by the public school Title I program.

*Equitable services apply, if applicable

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Interlocal agreements

LEAs operating as consortia should develop MOUs outlining:•The obligations of each participating LEA including which LEA will serve as fiscal agent

•How and when charges and reimbursements will be made (Ex. Through an IV, based on cost of service divided proportionally by the number of students or parents of students served)

•Timeframe for consultation and delivery of services

•Who will determine eligibility of students

•Who will assess the students and assessment tools to be used

•Where services will be provided

•How student performance will be measured

•Method of termination of agreement and disposal of property

•Other agreed upon items

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Let’s

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Group Activity: Building a Timeline

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Let’s take a 10 minute break

Timely and Meaningful ConsultationAt a minimum, consultation must address:• The method or source of poverty data used to

determine the amount of funds generated;

• The amount of funds available for services;• How students’ needs will be identified;

• What services will be offered;• How and when the LEA will make decisions about

the delivery of services;

• How, where and by whom the LEA will provide services;

• The size and scope of services;

• The services provided to teachers and families;• How the LEA will assess the Title I program and use the results to improve Title I

services. Collection of signed affirmation of consultation forms

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Student Eligibility for Title I Services

To be eligible for Title I services, a child must:• reside in a participating public school attendance area. (LEA must

verify)• be failing or at risk of failing based on multiple, educationally-related

objective criteria determined by LEA, in consultation with private school officials

The following children may be considered automatically eligible:

• Homeless children and children who participated in Head Start, Even Start, or Early Reading First, a Title I preschool program, or a Title I, Part C (Migrant Education) program within the past two years

POVERTY IS NOT A CRITERION FOR ELIGIBILITY

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Setting reasonable academic eligibility criteria• LEA must use multiple, educationally-related objective

criteria to determine which children are eligible, and within the eligible group, which children will be served.

• Criteria may include:– Achievement tests

– Teacher referrals and recommendations based on objective, educationally related criteria

– Grades

• Children Preschool – Grade 2 are eligible based on the following– Selected on teacher judgment, interviews with parents and other

developmentally appropriate measures.

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Selecting eligible children to be served

• Determine which children are most at risk using multiple selection criteriaExamples include:

– Test cut points

– Ask private school classroom teachers for specific recommendations on which students could benefit from the Title I program

– Provide private school principals and teachers with ranking sheets that rate the skills and abilities of potential students.

• Apply criteria selection objectively and uniformly across the district.

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Planning for Equitable Services

Services to eligible students in private schools should resemble the structure of a targeted assistance program, where services are provided to a specific set of eligible students and teachers, not the entire school.

Consequently…• An LEA cannot use any Title I funds to meet the needs of the

private school or the general needs of the private school children

• Private schools cannot have schoolwide programs

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Program Design

• The LEA and private school officials must work together to design programs to meet the education needs of the private school participants

• The LEA makes the final decision on the program design

Types of services:• Direct instruction outside the regular classroom (pull out model)• Tutoring• After or before school programs• Saturday programs• Summer school• Counseling• Computer Assisted Instruction (CAI)

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Parent Involvement

• LEA must consult with private school officials and parents before implementing activities

• Activities should provide parents of participating children the tools they need to support their child’s learning activities.– Examples include:

• Establishing a parent center or resource library for parents of participating students

• Inviting parents to attend parent involvement activities hosted by the LEA or public school

• Providing resources for parents to use at home with their children

• Parent education sessions

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Professional Development

• LEA must consult with private school officials and teachers before implementing PD activities

• Activities may only serve teachers of private school participants

• Activities must be geared toward serving students who are failing or at risk of failing

– Examples include:• Providing information on research based strategies in reading

and mathematics for at-risk children.

• Inviting teachers of private school participant to join an LEAs PD so long as the PD is geared toward meeting the specific needs of at-risk children

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Working with a Third Party to Provide Services

If an LEA enters into a contract with a third party provider for the delivery of Title I services to the private school participants, their teachers, or families such contracts must provide technical descriptions of the Title I services with detail sufficient to enable LEAs to determine that all Title I statutory and regulatory requirements will be met. [ESEA Section 9306(a)(1) and (2)]

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Contract Elements

• Describe service(s) in enough detail to assure that the LEA can show that the third party is in compliance with all Title I requirements

• Assure that administrative services are identified in the contract and budgeted by the third party provider in the provision of services. Administrative costs must be paid out of the funds reserved by the LEA for administrative costs

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Contract Elements Continued

• Outline an invoicing procedure which includes a description as to how the contractor will list administrative and instructional costs separately

• Describe the monitoring process that will be used to monitor the contractor’s performance and a list of steps the LEA will take if the contractor is not in compliance

• Provide a timeline for the delivery of services• Provide a list of required deliverables with due

dates

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Contract Elements Continued

• Include or assurance that all equipment purchased with Title I funds are the property of the LEA and not the contractor

• Include a statement or assurance that the contractor will comply with all Title I statutory and regulatory requirements

• Include a statement or assurance that the LEA has the right to withhold payment if any requirements are not met

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Contract Elements Continued

• Include a statement or assurance that the contract may be modified if there is a reauthorization of ESEA during the performance of the contract

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Additional Resources Private School Participation Website

http://www.doe.k12.de.us/infosuites/staff/fedstprog/TitleIPartA/PrivateSchoolParticipation/Private-School-Participation.shtml

US ED Non-Regulatory Guidance on Equitable Services

http://www.doe.k12.de.us/infosuites/staff/fedstprog/TitleIPartA/TitleIFILES/FederalGuidanceFILES/psguidance.doc

Section 1120 of the ESEA

http://www2.ed.gov/policy/elsec/leg/esea02/pg2.html#sec1120

DEDOE’s Title I Technical Assistance Session Materials

www.doe.k12.de.us/infosuites/staff/fedstprog/default.shtml

Ensuring Equitable Services to Private School Children: Title I Resource Toolkit

http://www.doe.k12.de.us/infosuites/staff/fedstprog/TitleIPartA/TitleIFILES/FederalGuidanceFILES/titleitoolkit.pdf

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Best Practices

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Presented by:

Christine Miller

Red Clay Consolidated School

District