Allocations

1
No Child Left Behind
Title I, Part A Elementary and Secondary
Education Act (ESEA) Reauthorized by the No
Child Left Behind Act of 2001 - Public Law
107-110 (NCLB)
2
Fall Workshop-Agenda

• Introductions
• Overview of Title I, Part A and LAP
• Allocations
• Professional Development
• LAP
• Parent Involvement
• Private Schools
• Fiscal Requirements
• Time and Effort Reporting
• Revision Process/Monitoring
• Federal Monitoring/AYP
• Q and As/Network Meetings

3
Overview

• The purpose of the federally-funded Title I
  program is to provide supplemental educational
  services to children who are most at risk of
  failing to meet the states student academic
  achievement standards in reading, language arts
  and mathematics and science in 2005-2006.

4
Overview

• The services provided are in addition to the
  basic education services to which every child is
  entitled and may not supplant those services.
• Students Pre-K through grade 12 are eligible for
  Title I services

5
Overview

• Types of services
• Additional instruction either in class or in
  small groups
• Extended learning time (before and after school
  and in the summer)
• Family Literacy
• Pre-K readiness to learn
• Counseling
• Computer-assisted instruction
• Combination of services listed above

6
Overview

• Targeted Assistance Programs target Title I
  services to the students at greatest risk of not
  meeting the states student academic achievement
  standards
• Building staff decide what subject areas and
  grade levels are to be served with Title I funds,
  based on the greatest academic needs of the
  students

7
Overview

• Building staff should consider use of the state
  Learning Assistance Program (LAP), which also
  targets academically at risk students, when
  deciding how and where to use Title I, Part A
  funds.

8
Overview

• Students in the identified subject areas and
  grade levels are selected for Title I services
  based on multiple, educationally-related,
  objective criteria established by the local
  educational agency and supplemented by the
  school
• This usually means the use of results from
  standardized tests, classroom-based assessments,
  grade level academic performance, teacher
  recommendations, and parent input

9
Overview

• A selection matrix can be developed using the
  test results, classroom performance, teacher
  recommendations, and other indicators
• The district and/or building Title I staff
  determine how many students can be served based
  on the amount of Title I funds that have been
  allocated to the building and develop a
  rank-ordered list by subject and grade level

10
Overview

• Instructional programs are developed to meet
  academic needs of the most at-risk students
• Students automatically eligible for services
  include homeless, migrant, special education
  students, and former Head Start, Even Start and
  Early Reading First students
• Parents must be notified their students are
  eligible and give written permission to receive
  services

11
Overview

• Services may be provided through extended
  learning opportunities including before and after
  school and summer programs
• Title I regulations strongly discourage the
  removal of students from the regular classroom to
  provide Title I services
• State law requires all students receive basic
  education before supplemental services to avoid
  supplanting

12
Overview

• Instruction for Title I students
• Must incorporate effective methods and
  instructional strategies based on scientifically
  based research
• Must be aligned with state Essential Academic
  Learning Requirements and Grade Level
  Expectations
• Must be incorporated into existing school
  planning

13
Overview

• Targeted Assistance Programs
• NCLB Section 1115
• Students must be rank-ordered and services
  provided to the most academically at risk
• Students enter and exit the program based on
  assessment analysis and criteria defined in their
  school improvement building plan

14
Overview

• Schoolwide Programs
• NCLB Section 1114
• Designed for high poverty schools (40 or higher)
• Does not require rank order list but targets most
  academically at risk students
• Requires a year of planning

15
Overview

• A schoolwide plan describing 10 components is
  required
• The schoolwide plan must include the names and
  the dollar amounts of the federal, local, and
  state programs that have been combined into the
  schoolwide program
• All programs serving students should be addressed
  in the plan

16
Overview

• The schoolwide plan must address the intent and
  purpose of each of the federal programs that have
  been included in the program
• Schoolwide programs must meet all requirements
  relating to health, safety, civil rights, student
  and family participation and involvement,
  services to private school children, maintenance
  of effort, and comparability of services

17
Overview

• Although all students in the schoolwide program
  are eligible for Title I services, it is the
  students who are at greatest risk of not meeting
  the state academic achievement standards that are
  to be the main focus of the services
• Annual evaluation of the program/plan
  effectiveness is required

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19

• Allocations

Section 1120A
20
Allocations

• From USDOE to OSPI
• Basic Grants
• Concentration Grants
• Targeted Grants
• Education Finance Incentive Grants
• From OSPI to Districts
• Single allocation
• From District to Buildings

21
District Eligibility

• Basic Grants
• 10 formula children, and
• Number must exceed 2 of the districts 5-17
  population
• Concentration Grants
• More than 6,500 formula children, or
• 15 of districts 5-17 population

22
District Eligibility

• Targeted Grants
• At least 10 formula children and
• Number must be at least 5 of districts 5-17
  population
• Education Finance Incentive Grants
• Same as Targeted Grants

23
Basic Grants

• ED determines Basic Grant allocations for
  districts within states based primarily on the
  number of Census poor children ages 5-17 adjusted
  for each States per pupil expenditure for
  education. Each district is guaranteed at least
  85, 90 or 95 (depending on the districts
  formula rate) of its prior years allocation. To
  qualify, a district must have at least 10
  formula children counted for allocation
  purposes and the number must exceed 2 of its
  5-17 population.

24
Concentration Grants

• ED determines Concentration Grant allocations
  using the same factors in the Basic Grant formula
  for districts that have more than 6,500 formula
  children or the number of those children exceeds
  15 if the districts 5-17 population. Each
  district is guaranteed 85, 90, or 95 of its
  preceding years allocation.

25
Targeted Grants

• ED determines Targeted Grant allocations based
  on the same factors in Basic Grant formula,
  except the formula counts are adjusted to give
  greater weight to districts with higher numbers
  or percentages of formula children. Each district
  is guaranteed 85, 90 or 95 of its preceding
  years allocation. To qualify a district must
  have at least 10 formula children and the number
  must equal or exceed 5 of its 5-17 population.

26
Education Finance Incentive Grants

• ED bases state EFIG allocations on the number
  of formula children counted for Basic Grant
  purposes, each States per pupil expenditure, the
  degree to which a State spends money on education
  relative to its wealth (fiscal effort factor),
  and the degree to which education expenditures
  across the State are equalized (equity factor).
  Once ED determines State allocations, it
  calculates district suballocations using a
  weighted formula similar to Targeted Grants. To
  qualify, a district must meet the 10 formula
  children and 5 thresholds established for
  Targeted Grants.

27
State Per Pupil Expenditure Data (SPPE)

• Factor changes yearly and is a proxy for the cost
  of education in each state
• Formula adjusts each school districts formula
  number to account for the states PPE
• For SY 2004-2005 allocations, used 2001-2002 SPPE

28
Census Data

• Census poor children
• Changes yearly for 2004-2005 based on 2000 census
  data (2003-2004 based on 1999 census data, number
  of poor children decreased by 8 nationally
  between 1999 and 2000)
• Children in N or D institutions, foster homes,
  and families above poverty receiving TANF
  assistance. (About 5 of formula children)

29
Hold Harmless Guarantee

• All 4 formulas provide for a variable
  hold-harmless guarantee for each district of 85,
  90, and 955 of their previous years allocation
• Hold-harmless percentage depends on the formula
  child rate of each district
• For Basic, Targeted, and EFIG the district must
  meet the eligibility criteria in order for
  hold-harmless protection to apply
• For Concentration Grants the hold-harmless
  provision applies to a district for four years
  even if it no longer meets the eligibility
  criteria

30
SY 2004-2005 Allocations

• Based on
• Income year 2000 census data
• Updated SY 2001-2002 State per pupil expenditure
  (SPPE) data
• Data on N or D children, foster children and
  children in families above poverty receiving TANF
  assistance used last year to determine 2003-2004
  allocations

31
SY 2004-2005 Allocations

• Factors affecting allocations
• Census data
• State per-pupil expenditures
• Amount appropriated
• Hold-harmless guarantee
• Small State minimum

32
Allocations to Buildings

• Rank order all buildings according to poverty
  percent (usually based on free and reduced price
  lunch percentage)
• Must serve buildings over 75 poverty
• Then rank and serve by district wide or by grade
  span
• Can reach buildings down to 35
• If district average is lower than 35 can reach
  buildings down to district (or grade span)
  average but must allocate at least 125 of
  district per pupil amount to every building in
  the rank order
• Buildings with higher poverty must have a per
  pupil allocation of at least as much as one with
  lower poverty
• Districts with enrollment of less than 1000
  students or districts with only one building per
  grade span are not required to rank order their
  buildings

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34

• Professional Development

Section 1119
35
High Quality Professional Development

• 5 of the districts allocation set aside to
  ensure teachers and paraprofessionals meet the
  highly qualified standards under NCLB unless a
  lesser amount is needed.
• Research staff personnel files to determine
  status
• Determine staff who meet the standard
• Create a plan for those who do not currently meet
  the standard
• Estimate the cost to carry out the plan
• Set Aside the amount necessary
• Keep documentation on file
• 34 CFR 200.60
• .58 paras .56 certs
• On the igrant application this set aside is found
  on part 2 A1.

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37
Remember

• Coordinate with Title II report

38
School Improvement Professional Development

• Once a school is identified for school
  improvement Step 1
• The building needs to set aside 10 of its Title
  I Part A funds to provide the staff with high
  quality professional development.
• Required each fiscal year the school is
  identified
• Must address the academic achievement problems
• On the iGrants this type of professional
  development is under the building allocation
  section, part 3.

39
District Improvement

• Once a school district is identified for
  improvement the district must set aside 10 of
  the districts Title I allocation to address the
  professional development needs of the
  instructional staff
• This 10 mandate applies each fiscal year that
  the district is identified for improvement.

40
District ImprovementCont.

• This mandate may include any amount of funds
  reserved for professional development from the
  schools that have been identified.
• District 10 minimum commitment for professional
  development is in addition to the set aside for
  highly qualified.

41
Ongoing Professional Development

• Funds can be set aside to increase the knowledge
  and skills of teachers, principals,
  administrators and paraprofessionals
• Title I professional development opportunities
  need to be aligned with EALRs and the grade level
  expectations for both math and reading
• This set aside in the igrant is located under
  part 2 (D4).

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43

• Learning Assistance Program
• (LAP)

44
What is the Learning Assistance Program?

• A state-funded program to serve students with the
  greatest deficits in academic basic skills as
  identified by statewide assessments.
• Basic skills include reading, writing,
  mathematics and readiness associated with those
  skills.

45
Who benefits from LAP?

• Students in kindergarten through grade 11 (moving
  through grade 12 in 2007)
• Who score below standard at grade level on
  statewide assessments
• Identified in an OSPI-approved plan to receive
  services as those with greatest academic deficits
  in basic skills

46
Which School Districts Receive Funds? (Section 5)

• Each school district with an approved plan is
  eligible
• Districts failing to make AYP must receive
  technical assistance in development of their
  plans
• Schools in any of the AYP Steps must have plans
  and activities reviewed and approved in
  conjunction with state and federal school
  improvement requirements

47
How do Districts Receive Funds? (Section 6)

• Through a distribution formula, in accordance
  with the biennial appropriations act, based on
• a) projected or reported enrollment
• b) student assessmenta five year average of
  ITBS test scores from grades 3, 6, and 9
• c) family income factors measuring economic
  need- usually free/reduced lunch

48
Districts Receive Funds

• Beginning with the 2005-2006 school year, 50 of
  the formula is based on assessment and 50 on the
  poverty factor
• This is a change from the current 92
  assessment/8 poverty factor

49
When is the funding cycle for LAP?

• From September to August
• An allocation, not a grant, monthly amounts
  change during the year, based on reported
  enrollment to OSPI

• Formula figured on F203 form
• This is the same form on which basic ed funding
  is figured, usually with the district business
  manager

50
Program Decisions

• LAP funds may enhance programs in Title I schools
• LAP may be distributed to non-Title I schools
  with low performing students
• Unlike Title I funds, which are distributed to
  schools on a rank order poverty formula, LAP
  funds may go to any schools with significant
  numbers of low performing students

51
Program Plan

• By July 1, 2004, participating districts must
  submit to OSPI for approval a district plan which
  
• a) identifies program activities from Section 4
• b) is encouraged to include the 8 elements from
  Section 3 as they will be developed to be
  included in 2005-2006 school year plan

52
LAP Program Plan and Activities

• The LAP application will be the approved district
  plan, much like the required district plan for
  Title I, and requires districts to select or more
  of the following uses of funds
• Extended learning time
• Professional development
• Consultant teachers
• Tutoring
• Parent Outreach

53
Learning Assistance Program-Summary Changes

• Expands program
• Up to Grade 11 immediately
• Through Grade 12 with class of 2008
• Formula changed in 2005-2006
• 50 assessment/50 family income factors
• Changed from 92 assessment/8 poverty

54
Learning Assistance Program-Summary Changes

• Requires Accelerated Learning Plans
• Required to be in place in 2005-2006 school year
• May be developed as part of existing student
  achievement plan processes for either individual
  students or groups of students

55
Learning Assistance Program-Summary Changes

• Accelerated Learning Plans must include 4
  elements
• Achievement goals for students
• Student, teacher and parent roles
• Communication of student progress
• Review and adjustment of the plan

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57

• Parent Involvement

Section 1118
58
Title I Parent Involvement

• Each school district receiving Title I funds must
  develop a
• District Parent Involvement Policy
• And
• Building Parent Involvement Policies

59
Title I Parent Involvement

• District Parent Involvement Policy
• must be a written document
• must be developed jointly with parents
• if district already has a parent policy, it can
  be amended to meet Title I requirements
• the policy must be distributed to all parents of
  participating students

60
Title I Parent Involvement

• District Parent Involvement Policy (cont.)
• Components of the district policy
• (1) developed with participation of parents of
  Title I students
• (2) provide assistance to buildings in carrying
  out their parent involvement activities
• (3) build the schools and parents capacity for
  strong parental involvement

61
Title I Parent Involvement

• District Parent Involvement Policy (cont.)
• -Components of the district policy
• (4) coordinate Title I parent involvement
  policies with other programs such as Head Start,
  Reading First, Even Start, ECEAP and other
  pre-school programs
• (5) conduct an annual evaluation of the content
  and effectiveness of the district Title I parent
  involvement policy

62
Title I Parent Involvement

• District Parent Involvement Policy (cont.)
• (6) identify barriers that prevent greater
  participation in Title I parental activities by
  parents of economically disadvantaged, disabled,
  limited English proficient, or racial or ethnic
  minority students

63
Title I Parent Involvement

• Districts with Title I allocations of 500,000 or
  more must set aside not less than 1 of the
  districts Title I allocation for parent
  involvement purposes (including promotion of
  parent literacy and developing parenting skills)

64
Title I Parent Involvement

• Parents of children receiving Title I services
  shall be involved in decisions regarding how the
  district Title I parent involvement funds shall
  be allocated for parent involvement activities

65
Title I Parent Involvement

• School Parent Involvement Policy
• Each school that receives Title I funds shall
  jointly develop and distribute to parents of
  Title I students a written school parent
  involvement policy
• If the school already has a parent policy it can
  be amended to meet the requirements of the Title
  I law

66
Title I Parent Involvement

• School Parent Involvement Policy
• (1) Annually convene a meeting for parents of
  Title I students to explain the Title I program
  requirements
• (2) Title I funds may be used to provide
  transportation, child care, or home visits as
  such services relate to parent involvement

67
Title I Parent Involvement

• School Parent Involvement Policy
• (3) Must involve Title I parents in the planning,
  review and improvement of the schools Title I
  program
• (4) Must provide Title I parents
• timely information about their Title I programs

68
Title I Parent Involvement

• School Parent Involvement Policy (cont.)
• -a description and explanation of the curriculum
  in use at the school, the forms of academic
  assessment used to measure student progress and
  the proficiency levels students are expected to
  meet

69
Title I Parent Involvement

• Teacher/Parent/Student Compact
• Each school receiving Title I funds shall jointly
  develop with Title I parents, the school staff,
  and Title I students, a school/teacher/student
  compact
• The compact shall
• (1) outline each partys responsibilities for
  improving the academic achievement of Title I
  students

70
Title I Parent Involvement

• Teacher/Parent/Student Compacts (cont.)
• (2) describe the schools responsibility for
  providing high quality curriculum and
  instruction, and an effective and supportive
  learning environment
• (3) describe the ways in which each parent and
  student will be responsible for attendance,
  homework completion, television watching and
  positive use of extra-curricular time

71
Title I Parent Involvement

• Teacher/Parent/Student Compacts (cont.)
• (4) address the importance of communication
  between teachers and parents through
  parent-teacher conferences (during which the
  compact is discussed) frequent reports to
  parents on their childs academic progress and
  opportunities for volunteering

72
Title I Parent Involvement

• Building Capacity for Parent Involvement
• Each district and school receiving Title I funds
  shall
• (1) assist parents in understanding such topics
  as EALRs, GLEs, WASL content and results, AYP
  criteria, and other relevant issues
• (2) provide materials and training to help
  parents work with their children to improve their
  academic performance

73
Title I Parent Involvement

• Building Capacity for Parental Involvement
• (3) educate teachers, pupil services personnel,
  principals, and other staff in how to reach out
  and work with parents to build ties between
  parents and the school

74
Title I Parent Involvement

• Building Capacity for Parental Involvement
• (4) coordinate and integrate, when possible, with
  Head Start, Reading First, Early Reading First,
  Even Start, ECEAP, and other public preschool
  programs, and Family Resource Centers

75
Title I Parent Involvement

• Building Capacity for Parent Involvement
• (5) inform parents of Title I students, about
  parent programs, meetings and other activities in
  a format, and to the extent possible, in a
  language the parents can understand

76
Title I Parent Involvement

• Building Capacity for Parent Involvement
• (6)To the extent practicable, provide full
  opportunities for participation of parents with
  limited English proficiency, parents with
  disabilities, parents of migrant children

77
Title I Parent Involvement

• Building Capacity for Parent Involvement
• (7) Provide such other reasonable support for
  Title I parental involvement activities parents
  may request

78
Title I Parent Involvement

• Other Considerations
• Title I funds may be used to pay reasonable and
  necessary expenses associated with local parental
  involvement activities, including transportation
  and child care costs to enable parents to
  participate in school-related meetings and
  training sessions

79
Title I Parent Involvement

• Other Considerations
• -the state education agency shall review district
  and school parental involvement policies and
  practices to determine if they meet Title I
  requirements

80

• Providing Equitable Services to Private School
  Students

Section 1120
81
Ensuring Equitable Participation

• To ensure equitable participation, the LEA or
  other entity receiving federal financial
  assistance must
• assess, address, and evaluate the needs of
  private school students and teachers through
  consultation
• determine amount of funds per student to provide
  services
• provide private school students and teachers with
  an opportunity to participate in activities
  equivalent to the opportunity provided public
  school students and teachers and
• offer services that are secular, neutral and
  non-ideological.

82
Title I, Part A-Equitable Services

• Services are equitable if the LEA
• Addresses and assesses the specific needs and
  educational progress of eligible private school
  children on a comparable basis as public school
  children.
• Meets the equal expenditure requirements for
  instructional programs, and professional
  development and parental involvement activities.
• Provides private school children with an
  opportunity to participate that
• Is equitable to the opportunity provided to
  public school children and
• Provides promise of private school children
  reaching high levels of academic achievement.

83
Title I, Part A Determining Poverty of
Private School Students

• Same measure of poverty as public schools.
• Results of a survey, and allowing extrapolation
  from a representative sample of actual data.
• Proportionality, applying the low-income
  percentage of each participating public school
  attendance area to the number of private school
  children who reside in that school attendance
  area.
• Comparable data, using an equated measure of
  low-income that can be correlated with the
  measure of low-income used to count public
  school students.
• sec.1119(c)(1)

84
Title I, Part AGenerating Funds

• Per-pupil allocation X number of poor private
  school students residing in Title I attendance
  areas Funds available for private school Title
  I program.
• Private school funds may be pooled.
• Funds generated by private school
• students must be used for instructional
  services.

85
Title I, Part AIdentifying Children To Be Served

• Must reside in participating public school Title
  I attendance area AND are failing or most at risk
  of failing to meet high standards.
• Selected on the basis of multiple,
  educationally-related, developmentally-appropriate
  criteria.
• Homeless, 2 preceding years in Head Start, Even
  Start, Early Reading First, Title I Preschool or
  Title I, Part C (Migrant Education).
• Poverty is NOT a criterion.
• District chooses children to be served from the
  list that the private school provides of eligible
  students.

86
Title I, Part A-Equitable Services for Teachers
and Families

• From funds reserved for parent involvement
  (Section 200.65) and professional development
  (Section 200.77), an LEA shall ensure that
  teachers and families of participating private
  school children participate on an equitable basis
  in professional development and parent
  involvement activities.

87
Timely and Meaningful Consultation

• To ensure timely and meaningful consultation the
  LEA must consult with private school officials
  prior to the LEA making any decision that affects
  the opportunities of any private school children
  to participate in programs.
• Requirements in NCLB Section 1120(b)
• and 200.63 regulations

88
What is consultation?

• It involves discussions between public and
  private school officials.
• Provides a genuine opportunity for all parties to
  express their views and to have those views
  considered.
• Successful consultation establishes positive and
  productive working relationships.

89
How do LEAs begin the consultation process?

• Intent to Participate Form
• LEA must contact private school officials with
  children who reside in the LEA boundaries
  regardless of private school location
• LEA convenes a meeting to discuss needs and
  service options

90
When does an LEA consult with private school
officials?

• Must occur before the LEA makes any decision that
  affects Title I services provided to private
  school students, their teachers, and their
  families.

91
Who participates in the consultation process?

• Public School Officials
• Representatives of Private Schools

92
How long does consultation continue?

• Throughout the implementation and assessment of
  services.
• Must include early discussions to prepare for the
  next school year.

93
What are the regulatory requirements for
consultation?

• How the LEA will identify the needs of eligible
  private school children.
• What services the LEA will offer to eligible
  private school children.
• How and when the LEA will make decisions about
  the delivery of services.
• How, where and by whom the LEA will provide
  services to eligible private school children.
• How the LEA will assess academically the services
  provided and how the LEA will use the results of
  that assessment to improve services.
• The size and scope of the equitable services that
  the LEA will provide to eligible private school
  children and the proportion of its Title I funds
  that the LEA will allocate and reserve.
• The method, or sources of data, the LEA will use
  to determine private school children from
  low-income families residing in participating
  public school attendance areas.
• sec.1120(b)(1)

94
Consultation must also include

• The services that will be provided to teachers
  and families.
• Discussion of service delivery mechanisms the LEA
  will use to provide services.
• Thorough consideration and analysis of the views
  of the private school officials on whether the
  LEA should contract with a third-party provider.

95
LEA Authority and Responsibility

• Where the LEA disagrees with the views of the
  private school officials on the provision of
  services through a contract, the LEA must provide
  a written explanation of the reasons why the
  local educational agency has chosen not to use a
  contractor.

96
When should private school officials sign the
required affirmation that appropriate
consultation has taken place?

• The affirmation should be signed when
  consultation on the planning and design of the
  next years program has been completed.
• The exact timing for signing should be part of
  the consultation discussion.

97
Do private school officials have the right to
complain?

• Yes, if they believe that the LEA did not engage
  in a timely and meaningful consultation process
  or did not consider their views.
• The complaint goes to the State Education Agency.

98
Determining Equitable Services

• Under NCLB Section 1113(a) and 200.78
  regulations, an LEA must allocate Title I funds
  to public school attendance areas, identified as
  eligible and selected to participate, in rank
  order on the basis of the total number of
  children from low-income families residing in
  each area.

99
How does an LEA determine participating public
school attendance areas?

• Eligible to participate in Title I if the
  percentage of students from low-income families
  is at least as high as the percentage of children
  from low-income families in the LEA.
• Or it has a 35 poverty rate.
• An LEA first ranks its public school attendance
  areas by poverty and then selects, in rank order,
  those areas that the LEA will serve.
• All schools above 75 poverty must be served.

100
What data does an LEA use when determining
eligible attendance areas?

• An LEA must use one or more of the following
  sources of poverty data
• Census
• Free and Reduced Price Lunch
• Temporary Assistance for Needy Families
• Medicaid Assistance

101
How does an LEA allocate funds for services?
102
How does an LEA collect poverty data on private
school children?

• NCLB 1120(c)(1) and 200.78(2) regulations allow
  an LEA to calculate the number of private school
  children who are from low-income families and
  attend private schools in
• Using the same measure of poverty.
• Using comparable poverty data from a survey and
  allowing the survey results to be extrapolated if
  complete actual data are unavailable.
• Geographic information verifying residence
• Grade level of each child
• Income level of parents

103
If an LEA does not collect the names of
low-income families, how do LEAs determine that
the poverty numbers are accurate?

• Private school officials should maintain the
  poverty data in their files.
• If the LEA or an auditor wish to review the data,
  they may review the data at the private school.

104
May an LEA reserve funds off the top of its Title
I allocation before it allocates funded services
to participating public school attendance areas?

• Yes
• An LEA must reserve funds, as needed, for
• Neglected Students
• Homeless Students
• Parental Involvement Activities
• Professional Development Activities
• Public School Choice
• Supplemental Education Services
• Administration of Title I

105
Title I, Part A-Off-the-top Costs

• Non-Instructional
• Administration
• Insurance
• Maintenance
• Electricity
• Transportation
• Non-instructional technicians
• Mobile instructional vans/units

• Instructional
• Professional Development
• Parental Involvement
• Summer School
• Homeless
• Services for Neglected and Delinquent Children
• Early Childhood
• Supplemental Services
• Equitable services apply

106
What are the requirements if an LEA reserves
Title I funds off the top for district-wide
instructional programs?

• The equitable services requirement applies.
• LEA receives 500,000
• Title I Attendance Area 25,000
• Private school attendance 5
• 5 of 500,000 25,000 of services for private
  schools
• LEA must consult with the private schools to
  determine how these funds will be used to benefit
  private school participants.

107
What are the options available for using funds
for instructional services to private school
participants?

• In consultation with the LEA and private school
  officials one or both of the options may be
  selected
• 1) On a School-By-School Basis or
• 2) Pooling Option
• Creates a pool of funds to provide services to
  eligible private school students who are in
  greatest educational need of those services

108
Eligible Children

• A private school child must reside in a
  participating public school attendance area and
  must meet the criteria in Section NCLB
  1115(b),which require the LEA to use multiple,
  educationally-related, objective criteria in
  selecting children to participate.

109
Are private school children from low-income
families automatically eligible for Title I
services?

• No.
• The LEA must work with the private school to
  select private school students who are failing,
  or most at-risk of failing, to meet high student
  academic achievement standards.

110
What are some of the educationally-related
criteria that an LEA may use to identify the
at-risk private school student for Title I
services?

• The criteria may include
• Achievement tests
• Teacher referrals and recommendations based on
  objective, educationally- related criteria
• Grades

111
May Title I funds be used to identify eligible
private school students?

• No.
• May be used to select participants from among
  those who are eligible for services and to
  determine specific educational needs of those
  students.

112
Once participants are selected, how does an LEA
determine what Title I services are to be
provided?

• In consultation with the private school
  officials, determine the appropriate Title I
  services based on the needs of the private school
  students.
• Grade span must be the same as public school
  service in that residential area specific
  grades may differ.

113
Who is responsible for planning and designing the
Title I program?

• Through the consultation process, the LEA must
  design a program that meets the needs of the
  private school.
• LEA is responsible for planning, designing and
  implementing the Title I program may not
  delegate that responsibility to the private
  school.

114
How does an LEA design a Title I program?

• Employs methods that meet the needs of private
  school students.
• Employs scientifically-based researched methods
  and instructional strategies.
• Gives primary consideration to providing extended
  learning time and high-quality curriculum.
• Provides supplemental services tied to the
  private schools instructional programs.

115
What types of services are available for private
school participants?

• Services for participating private school
  students may include
• Instructional services provided by LEA employees
  or third-party contractors
• Extended day services
• Family literacy programs
• Counseling programs
• Extended day programs
• Home tutoring

116
For Title I services, may an LEA just provide a
private school with instructional materials and
supplies?

• Simply providing a private school with
  instructional materials and supplies is NOT an
  option.
• It does not meet the equitability requirement.

117
May private schools purchase materials and be
reimbursed by an LEA?

• No, private school officials have no authority to
  obligate or receive Title I funds.

118
May Title I services be provided in religiously
affiliated schools?

• Yes, defined in 1997 in a U.S. Supreme Court
  Case Agostini v. Felton.

119
Parental Involvement

• Section 1118 requires the LEA to reserve funds
  off the top of its Title I allocation.
• Allocation 6,000,000
• Reserve is 60,000
• 25,000 LEA students x 5 3000 for services
  for private school parent participation.

120
Professional Development

• Section 1119 requires the LEA to reserve funds
  off the top of its Title I allocation for
  professional development activities private
  schools are to receive equitable services
• 5 of the reserve for private school services

121
Professional Development

• May Title I funds be used to pay for substitutes
  who replace Title I instructors?
• No

• May the private school arrange for professional
  development?
• No
• May stipends to private school teachers of Title
  I participants be paid?
• Yes

122
Standards, Assessment, and Program Modifications

• Private school students must be held to high
  standards but the States standards may not be
  appropriate.
• In that case alternative standards must be
  used.
• An LEA must annually assess the progress on
  agreed upon standards.

123
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124
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125

• Fiscal Requirements

Section 1120A
126
Maintenance of Effort

• District Requirement
• Section 1120A(a) and 9521 of NCLB
• 34 CFR 299.5

127
Maintenance of Effort

• The district has maintained fiscal effort if
  either
• The combined fiscal effort per student or
• The aggregate (total of included) expenditures of
  the district were at least 90 of that of the
  preceding year. This shows the district
  maintained its non-federal funding within 90.

128
Maintenance of Effort

• Preceding fiscal year the federal fiscal year
  or the 12 month fiscal period used for reporting
  purposes prior to the beginning of the federal
  fiscal year in which funds become available.
• Example For funds available July 1, 2004
• Preceding fiscal year is 2003 (SY 2002-2003)
• Second preceding fiscal year is 2002 (SY
  2001-2002)
• Third preceding fiscal year is 2001 (SY 2000-2001)

129
Maintenance of Effort

• Expenditures included for MOE
• Administration
• Instruction
• Attendance and health service personnel
• Pupil transportation services
• Operation and maintenance of building
• Fixed charges
• Net expenditures to cover deficits for food
  services and student body activities

130
Maintenance of Effort

• Expenditures excluded for MOE
• Community services
• Capital outlay
• Debt service
• Supplemental expenses made pursuant to a disaster
  declared by the President of the USA
• Any expenditures made for funds provided by the
  federal government

131
Maintenance of Effort

• When a district does not meet the maintenance of
  effort test its allocation is reduced in the
  exact proportion by which it fell below 90
  (combined fiscal effort per student and aggregate
  expenditures).
• The measure most favorable to the district is
  used.

132
Maintenance of Effort

• In determining maintenance of effort for the year
  following a failure to maintain effort, OSPI
  considers the districts expenditures in the year
  the failure occurred to be 90 of the
  expenditures for the third preceding year.
• OSPI does not use the expenditures for the year
  in which the failure occurred.

133
Maintenance of Effort

• District may apply to the US Department of
  Education for a waiver for
• Exceptional or uncontrollable circumstances, such
  as a natural disaster,
• or
• Precipitous decline in the financial resources of
  the district

134
Supplement Not Supplant

• Considers services
• Section 1120A(b) and (d) of NCLB
• 34 CFR 200.79

135
Supplement Not Supplant

• Targeted Assistance Schools
• Title I funds must be used only to supplement the
  level of funds that would, in the absence of
  Title I, be available from non federal (state and
  local) sources for Title I students
• The district is not required to provide Title I
  services using a particular instructional method
  (i.e. pull out programs, in class, etc.).
• Based on services

136
Supplement Not Supplant

• Schoolwide Program Schools
• Must use Title I funds only to supplement the
  amount of funds that would, in the absence of
  Title I funds, be made available for that
  schoolwide program (including funds needed to
  provide services required by law for disabled
  children and LEP children)
• Similar to MOE

137
Supplement Not Supplant

• Presumption of supplanting
• The district has used the Title I funds to
  provide services that the district was required
  to make available under federal, state or local
  law
• The district used Title I funds to provide
  services it provided with non-federal funds in
  the prior year(s)
• The district has used Title I funds to provide
  services for participating children that it
  provided with non-federal funds for
  non-participating children
• Rebuttals are possible, see OSPI website

138
Supplement Not Supplant

• Exclusions
• The district may exclude supplemental state or
  local funds expended in any school for programs
  that meet the intent and purposes of Title I,
  Part A

139
Supplement Not Supplant

• Program meets the intent and purposes of Title I
  in a schoolwide program if
• It is implemented in a school with 40 or more
  poverty
• It is designed to promote schoolwide reform and
  upgrade the entire educational operation of the
  school
• It is particularly designed to meet the
  educational needs of at-risk students
• It uses the states assessment system to review
  the effectiveness of the program

140
Supplement Not Supplant

• Program meets the intent and purposes of a Title
  I program in a targeted assistance program if
• It serves only children who are failing or most
  at risk of failing to meet the states
  performance standards
• It provides supplementary services designed to
  meet the educational needs of the children who
  are participating in the program
• It uses the states assessment system to review
  the effectiveness of the program

141
Comparability

• Building level
• Section 1120A(c) and (d)
• 34 CFR 200.79
• OSPI Bulletin 011-04

142
Comparability

• A district may receive Title I, Part A funds
  only if it uses state and local funds to provide
  services in Title I schools that, taken as a
  whole, are at least comparable to services
  provided in non-Title I schools.

143
Comparability

• If all schools in the district are Title I
  schools, the district must use state and local
  funds to provide services that, taken as a whole,
  are substantially comparable in each school.

144
Comparability

• Comparability is met if the district provides
  written assurance it has established and
  implemented
• A district wide salary schedule,
• A policy to ensure equivalence among schools in
  teachers, administrators, and other staff, and
• A policy to ensure equivalence among schools in
  the provision of curriculum materials and
  instructional supplies

145
Comparability

• Alternative criteria
• The district may meet the comparability
  requirement if it establishes and implements
  other measures for determining compliance such as
  student/teacher rations, student/instructional
  staff salary ratios or total expenditures per
  school.
• Staff salary differentials for years of
  employment may not be included in comparability
  determinations
• The district need not include unpredictable
  changes in student enrollment or personnel
  assignments that occur after the beginning of a
  school year.

146
Comparability

• Documentation
• The district must develop procedures/policies
  for meeting the comparability requirement and
  maintain records that are updated at least
  biennially.

147
Comparability

• Exclusions
• Bilingual education for children of limited
  English proficiency
• Excess costs of providing services to children
  with disabilities
• Supplemental state and local funds spent for
  programs that meet the intent and purposes of
  Title I, Part A (LAP).

148
Time and Effort Reporting

• Why Does it Take So Much Time and Require So Much
  Effort?

149
Where is the Requirement?

• Time and effort reporting is required under the
  Federal Office of Management and Budgets
  Circular A-87, Cost Principles for State, Local,
  and Indian Tribal Governments
• Attachment B, Selected Items of Cost, Item 11,
  Compensation for personnel services

150
When is Time and Effort Required?

• Time and effort reporting is required when any
  part of an individuals salary is charged to a
  federal program.
• Charge may be direct or indirect.

151
What type of reporting is needed?

• Single cost objective ?Semi annual certification
• Multiple cost objectives ?Monthly time reports or
  Personnel Activity Reports (PARs)

152
What is a cost objective?

• Work activities allowable under the terms and
  conditions of a funding source

153
What are some examples of a single cost objective?

• 100 charged to a single federal program activity
• Exceptions
• Title I, Part A and LAP
• Federal Special Education and State Special
  Education
• Schoolwide programs
• Multiple activities in a single federal program

154
What are some examples of multiple cost
objectives?

• Salary charged to more than one activity in a
  single federal program
• Salary charged partially to federal program and
  partially to state and/or local sources
• Salary charged partially to sources combined into
  a schoolwide program and partially to those not
  included

155
What is a semi annual certification?

• Statement individual(s) worked solely on
  activities related to single cost objective
• Completed at least every six months
• Signed by employee or supervisor with first-hand
  knowledge of work performed

156
What is a monthly time report?(PAR)

• Accounts for total activity
• Prepared at least monthly
• Signed by employee
• Reflects actual work performed (not budget)
• Agrees to supporting documentation

157
When are adjustments to actual made?

• If payroll is initially based on budgeted or
  estimated time/amounts, payroll and time and
  effort reports must be compared at least
  quarterly.
• If the difference is 10 or more and any needed
  adjustments made.
• Payroll records must be adjusted to actual.
• Following quarters estimates must be adjusted.

158
Who should sign the reports?

• Monthly reports (PARs) should be signed by the
  employee
• Semi annual certifications should be signed by
  employee or supervisor having first-hand
  knowledge of work performed
• For internal control purposes, districts may
  require both the employee and supervisor to sign

159
What type of supporting documentation is needed?

• Examples include, but are not limited to
• Class schedules
• Number of students
• Number of minutes

160
Supplemental Contracts, Stipends, Extra Hours

• Primary contract and additional contracts may be
  considered separately
• Based upon whether or not charged to federal
  program
• Time and effort may be required for primary
  contract but not supplemental (or vice versa)

161
Administrators

• Superintendent, assistant superintendent,
  principal, assistant principal usually not
  allowable charge to federal program
• Requires good documentation to support
• Could be a supplant issue

162
What is a substitute system?

• Other method for determining time and effort
  report based on sample of work performed
• Must be approved by OSPI prior to use
• Must be statistically sound
• Should be periodically reviewed to determine if
  still appropriate

163
Schoolwide Programs

• Schoolwide plan must specify programs to be
  included
• A schoolwide program is a single cost objective
• If employee works 100 on programs combined ?
  Semi annual certification
• If employee works partially on programs combined
  and partly on those not combined, ? Monthly time
  report (PAR)

164
For Additional Information

• See OSPI Bulletin 006-04
• Examples
• Sample forms
• OMB Circular A-87, Cost Principles for State,
  Local, and Tribal Governments

165
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166

• Accountability
• Auditing, Monitoring and Review

167
State Audit Report

• Exit Item

• Lowest level,
• least formal communication between the
  district and the auditor
• Fixable

168
State Audit Report

• Management Letter Item

• Mid Level
• On official letterhead
• Public document
• May be an item not yet attended to or of a more
  significant than an exit item

169
State Audit Report

• Finding
• Some items such as fraud, or federal questioned
  costs above 10,000 must be findings

• Strongest level
• Goes to the press
• Costs may be recovered
• Must be fixed

170
State Audit Report

• Exit items, management letter items, and findings
  are presented to the district at their exit
  conference.
• The district may respond in writing-which will be
  included in the audit report.
• Auditors express their concluding remarks.
• Findings must be addressed in the next years
  audit.

171
Remember

• When questioned by the auditor it is appropriate
  for the district to call Title I or the audit
  resolution office at OSPI
• OSPI may contact the State Auditors Office
• It is important to try to resolve the problem
  before the report is made public
• Jennifer Carrougher 360-725-6288

172

• In 2003 there were 23 audit findings related to
  time and effort reporting and 14 audit findings
  regarding Title I set asides.

173
Audit Issues

• Adequately demonstrate less set aside is needed
• Have a process, i.e. spreadsheet or list to
  identify who have met the NCLB requirements
• Demonstrate you have monitored the expenditures
• Develop a sub-code in your ledger so you have a
  way to identify expenditures

174
Parent Notification

• Audits will review annual report card and verify
• Information on schools in school improvement
• Results of districts annual process review
• Notification of school choice, supplemental
  education services

175
Data Quality

• A-133 Compliance Supplement
• Review the process used by the LEA to ensure the
  accuracy of information included to determine
  schools in need of school improvement
• Trace the data about the LEA to source records
• Review the process the LEA uses to inform schools
  and parents using widely available means such as
  the Internet and media.

176
Data QualityWASL test scores

• Audit of continuously enrolled students
• Review schoolhouse edit reports
• Districts will need to describe their system for
  determining whether unexcused absences data and
  or graduation rates reported appear accurate
• Remember that alternative schools must also
  submit data

177
Private School Participation

• District must be able to document whether all
  approved private schools chose to participate in
  federal programs
• OSPIs bulletin outlines how to document
  participation of private schools who do not
  respond. (Bulletin No.

178
Consolidated Program Review

• OSPI monitoring of most federal and some state
  programs
• Conducted every four years
• Districts in ESD 101 and 114 will be reviewed
  this year
• Examines program documentation
• Interviews administrative, instructional and
  fiscal staff
• Visits schools and classrooms

179
Consolidated Program Review

• Building plans
• Not approved by OSPI but reviewed during CPR
• If AYP not met OSPI req