Private School Participation in Federal Programs

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Private School Participation in Federal Programs

• Barbara Quick/Christine Finkle/Anne Renschler
• Office of Superintendent of Public Instruction
• barbara.quick_at_k12.wa.us
• christine.finkle_at_k12.wa.us
• anne.renschler_at_k12.wa.us

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Private School Participation in Federal Programs

• NCLB requires equitable services be provided to
  private school students, teachers, and other
  educational personnel. (Under some programs, to
  parents.)

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Why ?

• Because federal programs are supported from tax
  dollars, so all children and teachers are
  eligible to access these programs.

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Equitable Participation

• What does this mean?
• Services should be equitable (the same in public
  school as in private school) and should begin at
  the same time as the public school services to
  the qualified students.
• For example
• If a Title I program is available to the public
  school student, then the private school student,
  who would have attended that qualifying public
  school, would be eligible to participate in the
  program if they meet the same requirements for
  eligibility for services.

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Key word is services

• No public funds are distributed to private
• schools, only services and materials.
• Must be secular, neutral and non-ideological
• Must be supplemental

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Covered Programs

• Title I, Part AImproving Basic Programs
• Title I, Part BReading First (Competitive)
• Title I, Part BEven Start Family Literacy
  (Competitive)
• Title I, Part CEducation of Migratory Children
• Title II, Part ATeacher and Principal Quality
• Title II, Part BMathematics and Science
  Partnership (Competitive)
• Title II, Part DEnhancing Education through
  Technology
• Title III, Part AELL/Emergency Immigrant
• Title IV, Part ASafe and Drug-Free Schools
• Title IV, Part B21st Century Learning Centers
  (Competitive)
• Title V, Part AInnovative Programs
• Carl Perkins/Career Technical Education
• Programs covered with own equitable provision
  requirements.
• Programs covered by Uniform Provisions.
• - Websites for guidance on last slide -

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Participation/Qualifications

• Private schools must submit all required forms
  in a timely manner in order to qualify for
  services the following school year. Private
  Schools must be a non-profit, state-approved
  elementary or secondary schools.

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Private School Form Cycle
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Process to Participate

• PRIVATE SCHOOLS MUST
• Complete Annual Approval Form Must be a State
  Board approved, not-profit elementary or
  secondary private school to qualify for federal
  program services.
• Complete P105 Enrollment Data Form (October
  headcount) Essential to participate
  allocations for services are based on this
  headcount.
• Complete the Private School Participation in
  Federal Programs (Intent to Participate) Form

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District Consultation Cycle
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Process to Participate

• SCHOOL DISTRICTS MUST
• Review Intent to Participate forms See private
  schools that wish to participate, do not wish to
  participate, or did not apply.
• Contact private schools that did not apply Make
  notations on the contact log (electronic form).
  District must make multiple attempts to contact
  the private school.
• Contact private schools that did apply and begin
  consultation process (JanuaryMarch) must
  consult prior to submitting their annual federal
  grant application.

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Consultation

• Consultation between the public school and
  private schools during the design and development
  of the programs
• Must be timely and meaningful, must happen prior
  to district decisions being made to ensure the
  needs of the private school are considered when
  professional development, teacher assignments,
  and other decisions are being made.
• Must take place on an annual basis, and be
  documented by the district. Public school
  district must complete and submit to OSPI a
  written affirmation form (required for Title I)
  indicating the date the consultation took place
  between the public and private school. The
  affirmation of consultation must be signed by
  both the public and private school officials.

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Consultation continued

• Must continue throughout the year, to ensure the
  needs of private school students are being met.
  Consultation is an on-going process and can occur
  in many ways. It can be via phone calls,
  e-mails, or a site visit.

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Consultation continued

• Consultation must cover issues such as
• How the childrens needs will be identified.
• What services will be offered.
• How and where the services will be provided
• The district maintains administrative
  control over services
• District recruits, interviews and selects
  teachers who will provide services.
• Regularly supervise and monitor teachers who
  provide services.
• Communicate effectively with private school
  officials.
• Must be clear about the services to be provided.
• Must begin at the same time that services begin
  in the public school.

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Consultation continued

• How the services will be assessed and how the
  results of the assessment will be used to improve
  those services.
• Service delivery mechanisms used to provide
  equitable services.
• Who will provide the services.

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Consultation continued

• The amount of funds available to serve private
  school students. Public schools should discuss
  with the private school the amount of services
  available to them in each of the federal
  programs. This will allow the private schools to
  better plan appropriately and make careful
  decisions with the public school district to
  serve their students.
• The size and scope of the services to be
  provided.Public and private school should have a
  written plan of services to be provided.
• Consideration of the views of the private
  school officials re use of third-party providers
  
• When the LEA disagrees with the views of the
  private school officials on the provision of
  services, the LEA must provide a written
  explanation of the reasons why the LEA has chosen
  not to use a contractor.

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Consultation continued

• During the consultation process, the public
  school district must review the complaint
  procedures (WAC 392-168) with the private school.

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Complaint Process

• If private school officials believe that timely
  and meaningful consultation has not occurred or
  that the district did not give due consideration
  to their views, they should first contact the
  Federal Programs representative or superintendent
  at the school district to discuss their concerns.
  
• If the concern is not satisfactorily resolved,
  the private school has the right to contact the
  Federal Programs office at OSPI for resolution.
  In the event the concern is not resolved, the
  private school has the right to file a formal
  written complaint with OSPI.
• See OSPI Bulletin 007-07

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Complaint Process Steps

• The formal written complaint should include
• A statement that the district, other educational
  agency, or in some cases OSPI, has violated a
  requirement of a federal statue or regulation
  that applies to a program requiring equitable
  participation.
• The specific requirement alleged to have been
  violated.
• The facts on which the complaint is based.
• The name and address of the complainant.
• The expected resolution of the alleged violation.
  
• The signature of the complainant.
• A complaint should be sent directly to
• Office of Superintendent of Public Instruction
• Attn Federal Programs Office
• P. O. Box 47200
• Olympia, WA 98504-7200

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Title I, Part A Improving Basic Programs

• Purpose
• Provides supplemental educational services for
  eligible public and private school students to
  ensure that all children have a fair, equal, and
  significant opportunity to obtain a high-quality
  education and reach, at a minimum, proficiency on
  challenging state academic achievement standards
  and state academic assessments (should the
  private school choose to do so).
• Governed under Title I, Part A Guidance

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Title I, Part A continued

• Examples of Services
• Instructional services outside the regular
  classroom
• Extended learning time (before/after school and
  in the summer)
• Family literacy programs
• Counseling programs
• Early childhood
• Home tutoring
• Computer-assisted instruction

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What additional services may be provided to
private school students, parents, and educators?

• In addition, the law requires equitable
  participation of private school teachers and
  other educational personnel of Title I students
  in professional development activities and of
  parents of Title I students in parent involvement.

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Title I, Part A continued

• Who is served?
• Must reside in participating public school Title
  I attendance area AND be failing or most at risk
  of failing to meet high standards
• Selected on the basis of multiple,
  educationally-related, developmentally-appropriate
  criteria
• Poverty is NOT a criterion for services
• District chooses children to be served from the
  list that the private school provides of eligible
  students

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How are Title I funds for private school students
determined?

• Funds NCLB Section 1120 specifies that funds
  are generated on the basis of the number of
  students from low-income families who reside in
  participating public school attendance areas and
  attend private schools whether the private
  schools are located within or outside district
  boundaries.
• Services Private school students who reside
  within a Title I attendance area and who are
  failing or most at risk of failing to meet high
  academic standards are eligible for service.

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Where may Title I services be provided to
private school students?

• Services may be provided at the private school,
  including religiously affiliated schools, and/or
  at other locations.

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What is the applicability of state academic
assessment to private schools?

• Private schools, including private schools with
  Title I students, are not required to participate
  in a states academic assessments.

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Title I, Part C Migrant Education

• Purpose To improve the education for
  migrant children.
• Eligible children must meet the statutory and
  regulatory definition of a migrant child, meet
  the priority for services criteria, and have
  special educational needs identified.
• Equitable participation for private school
  migrant students in schools located in targeted
  areas (only schools that receive Migrant funds).
• Governed under Uniform Provisions

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Which Children who attend private schools are
eligible to receive MEP services?

• Children who attend private schools are eligible
  to receive MEP services if they
• (1) meet the statutory and regulatory definition
  of a migrant child
• (2) meet the priority for services criteria in
  NCLB Section 1304 (d), and
• (3) have special educational needs identified
  through the states comprehensive needs
  assessment and service delivery plan.

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Title II, Part AProfessional Development

• Purpose Opportunity for private school
  teachers and other educational professionals to
  participate in professional development.
• Services can be provided several different ways
  
• participation in scheduled professional
  development at the school district,
• qualified school district staff providing
  services to private school staff, and
• third party services (registration to
  conference, or a contracted trainer).
• Governed under Uniform Provisions

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How does the district determine the amount of
funds required for equitable services?

• To determine the per pupil allocation the
  district takes the total amount allocated for
  professional development in the district and
  divides this amount by the total number of public
  and privates students.
• This per pupil amount should then be multiplied
  by the total number of students enrolled in
  private schools to arrive at a total amount of
  funds to be designated for professional
  development for private school educators
  participating in the program.

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Does the professional development program for
private school teachers have to be the same as
the professional development program for public
school teachers?

• No. Consultation and coordination are essential
  to ensuring high quality, sustained, intensive,
  and classroom-focused professional development
  activities.
• If the professional development needs of the
  private school teachers are different from those
  of the public school teachers, the district with
  the private school representative should develop
  a separate program.

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May funds be used to support the acquisition of
advance degrees by private school teachers?

• Yes. Title IIA funds can support a teachers
  acquisition of an advance degree. Contact the
  Title II, A office at OSPI for more information.
  

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May funds be used to pay stipends to private
school teachers for professional development
activities?

• Yes. Funds may be used to pay for stipends for
  private school educators. The use of the funds
  for stipends must be reasonable and necessary.
• For example, if the professional development
  activity is conducted during after-school hours
  or in the summer, stipends may be needed to
  compensate educators for their participation
  outside their regular employment hours.
• Again, funds are never paid to the private school.

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Title II, Part DEnhancing Education through
Technology

• Purpose
• This program provides funds for innovative
  initiatives to support the integration of
  educational technology into classrooms to improve
  teaching and learning.

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What is equitable participation under Title II,
Part D?

• Professional development in technology
  integration and use of the internet.
• Distance learning initiatives.
• Acquiring educational technology.
• Using technology to enhance parental involvement.

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Title III, Part AEnglish Language Acquisition

• Purpose Provides assistance for helping limited
  English proficient (LEP) children attain English
  proficiency.
• Services can be used for increasing the English
  proficiency of LEP children by assistance
  (professional development/materials) for teachers
  of English to limited English proficient
  children.
• Services for students and teachers in schools
  that are located within an LEA that receives
  Title III funds.
• Governed under Uniform Provisions.

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Title IV, Part ASafe and Drug-Free

• Purpose Supports programs that foster a safe
  and drug-free learning environment.
• Authorized activities include prevention
  materials and training, including bullying,
  harassment, peer mediation, conflict resolution,
  and other activities/programs.
• Governed under Uniform Provisions

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Must the same Title IV program design be the same
for both the public and private schools?

• No. The required consultation must take place
  before the district makes any decision that
  affects the opportunities of eligible private
  school students.

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Title V, Part A Innovative Education

• Purpose Innovative Programs support education
  reform and innovative school improvement programs
  to improve school, student, and teacher
  performance
• Provides support in 27 different areas.
• Examples include library materials/media, at risk
  programs, and professional development.
• Generally the amount of services/materials is
  limited, but it is the most flexible of all the
  Title programs.
• (Most private schools use these funds to
  
• support their library materials.)
• Governed under Title V, Guidance

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What administrative requirements apply regarding
service to private school students and teachers?

• The control of the Title V, Part A funds and the
  title to any equipment and materials purchased
  remain in the district.
• Services must be supplemental and not supplant
  services that would be available to participating
  students and teachers in the private school in
  the absence of the Title V, Part A funds.
• The district must implement safeguards that any
  equipment and materials placed in private schools
  will be secular, neutral, and non-ideological.

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Carl Perkins

• Purpose allows, upon written request, for the
  participation of private school personnel in
  in-service and pre-service CTE professional
  development programs and for the participation of
  students in CTE programs, supported by this act.
• Contact the CTE office at OSPI for further
  information

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Competitive Grant Programs

• What are competitive grants
• Different than flow-through funding
• Application required by public schools to
  participate in programs and are for a three-year
  grant only, and only open to participate each
  grant cycle.

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Competitive Grant Programs continued

• During the competitive grant application process,
  the district must contact the private school and
  provide the opportunity to participate in the
  development of the grant and implementation of
  competitive programs for which they may qualify.

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Title I, Part BReading First

• Purpose Reading First provides funding to
  implement comprehensive reading instruction for
  students in kindergarten through third grade.
• Program services include reading programs,
  instructional materials, professional
  development, and screening and evaluation. This
  program is available to private school students
  in the areas served by public schools receiving
  Reading First.

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Title I, Part B, Subpart 3 Even Start Family
Literacy

• Purpose Supports family literacy programs that
  integrate early childhood education, adult
  education, parenting education, and literacy
  activities for low-income families and their
  children from birth through age seven.
• This program is available to private school
  students in the areas served by districts
  receiving Even Start.

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Title II, Part BMathematics and Science
Partnership

• Purpose Provides funding to improve
  mathematics and science teaching through a
  variety of activities through partnerships with
  institutions of higher education and high-needs
  districts.
• Activities include professional development,
  stipends and scholarships for advanced coursework
  in math, science or engineering , and programs to
  bring math and science teacher into contact with
  working scientists, mathematicians and
  engineers.

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Title IV, Part B21st Century Learning Centers

• Purpose Provides before/after school
  programs, including enrichment programs to
  support childrens academic needs. (Equitable
  participation for private school students,
  teachers and other education personnel who are
  part of the target population.)

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Are private school students, teachers, and others
eligible to participate in 21st Century
Activities?

• Yes. Students, teachers, and others are eligible
  to participate in 21st Century programs on an
  equitable basis.
• A public school or private organization that is
  awarded a grant must provide equitable services
  to private school students, their families, and
  educators if those students are part of the
  population identified for assistance.

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Title VI Flexibility AccountabilityFor
Districts Only

• If a district uses the Title VI Flexibility
  Accountability option, they must conduct
  consultations with private school officials prior
  to making any decision that could affect their
  ability to benefit from programs for which they
  are eligible.
• Private school students and teachers will receive
  equitable services from the district under the
  programs to which the funds are used.

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Resources

• Title I Services to Eligible Private School
  Students Guidance http//www.ed.gov/programs/titl
  eiparta/psguidance.doc
• Ensuring Equitable Services to Private School
  Children A Title I Resource Tool Kit
• http//www.ed.gov/programs/titleiparta/ps/titleito
  olkit.pdf
• Title V, Part A, State Grants for Innovative
  Programs Guidance http//www.ed.gov/programs/inn
  ovative/titlevguidance2002.pdf
• Uniform Provisions Equitable Services to
  Eligible Private School Students, Teachers, and
  Other Educational Personnel, Non-Regulatory
  Guidance
• http//www.ed.gov/policy/elsec/guid/equitableserg
  uidance.doc
• OSPI ESEA Private School Website
  http//www.k12.wa.us/ESEA/PrivateSchools.aspx

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Questions?

• Thank you for your participation!