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Title: Office of Field Services


1
Office of Field Services Ensuring Equitable
Services for School Children Attending Private
Non-Profit Schools
Office of Field Services
2

Katie Doerr Parker Gayle Green Yvonne W.
Mayfield Field Services Consultants Office of
Field Services www.michigan.gov/ofs
3
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5
Reference Materials
  • The following handouts are available on MDEs
    website, www.michigan.gov/ofs
  • Ensuring Equitable Services for Private
    Non-Profit School Children -
  • Power Point
  • Overview Technical Assistance Packet
    Working with Private Schools
  • Allocation Worksheets
  • Non-Regulatory Guidance
  • Private School Questions and Answers
  • Equitable Worksheet

6
Reference Materials
  • Technical Assistance Packets
  • Title I, Part A
  • Title I, Part C
  • Title II, Part A
  • Title III, Part A

7
REQUIREMENTS
8
Equitable Services Requirement-District
Responsibility
  • Equitable Participation in
  • Title I, Part A Improving the Academic
    Achievement of the Disadvantaged
  • Title I, Part C Migrant Education
  • Title II, Part A Teacher Principal Training
    Recruiting
  • Title III, Part A Language Acquisition Program
  • (English Learners and Immigrant
    Students)

9
Equitable Services Requirement
  • In order to meet Equitable Services requirements,
    a Local Educational Entity (LEA) must annually
    notify all private, non-profit schools within its
    boundaries and outside of district if resident
    students attend, of eligibility for equitable
    participation with Title programs

10
Equitable Services Requirement
  • Low-income parents with private school children
    are included in census poverty counts that
    generate funds the Local Educational Agencies
    (LEAs) use forTitle I services

11
Equitable Services RequirementChild Benefit
Theory
  • This theory was developed to comply with the
    Constitutional prohibition against Federal
    funding to private schools. No funds go directly
    to private schools.
  • Under the Child Benefit Theory, Title I services
  • Benefit the individual child, not the private
    school
  • Are provided by the LEA, not the private school

12
Equitable Services Requirements
  • In order to meet equitable services requirement,
    an LEA must
  • Provide eligible private school children with an
    opportunity to participate
  • Meet the equal expenditure requirements for
    instruction, professional development, and parent
    involvement
  • Assess student needs and the effectiveness of the
    Title I program and
  • Begin Title I programs at the same time as the
    Title I programs for public school children.

13
Equitable Services Requirement Program
Responsibility
  • The LEA is responsible for designing and
    implementingTitle I programs for its resident
    children who attend private schools, even those
    attending private schools located in other LEAs

14
Equitable Services Requirement Program
Responsibility
  • The LEA is responsible for making program and
    budgetary decisions based on timely and
    meaningful consultation with the private school.

15
Consultation
16
Consultation RequirementsWhat is Consultation?
Consultation involves discussions between public
and private school officials on key issues that
affect the ability of eligible private school
children to participate equitably in Title I
programs
17
Consultation Requirements
  • Consultation
  • Must occur during the design, development, and
    implementation of the Title I programs
  • Must include meetings
  • Must occur prior to the LEA making any decisions
  • Must continue throughout implementation of
    programs
  • Must be documented (Reference the Private School
    Consultation Checklist)
  • Complete the process by May 1st

18
Consultation Requirements
  • What topics must be addressed during
    consultation?

19
Consultation Requirements
  • At a minimum, consultation must address
  • How the LEA will identify the needs of eligible
    children
  • What services the LEA will offer
  • How and when the LEA will make decisions
  • How, where, and by whom the LEA will provide
    services
  • How the LEA will assess the Title I program and
    use the results to improve Title I services

20
Consultation Requirements
  • At a minimum, consultation must address
  • The size and scope of the equitable services and
    the proportion of funds the LEA will allocate for
    services
  • Method or sources of data the LEA will use to
    determine the number of low-income students
  • Services the LEA will provide to teachers and
    families of participating children
  • Discussion of service delivery mechanism the LEA
    can use
  • A thorough consideration and analysis of the
    views of private school officials services
    through a contract with third-party provider

21
Consultation Requirements
  • Private school officials have the right to
    complain to the SEA for the following reasons
  • The LEA did not engage in timely and meaningful
    consultation
  • The LEA did not give consideration to the views
    of private school officials
  • The LEA disputes the low-income data provided by
    private school officials
  • The SEA resolves the complaint

22
Equitable Services for Teachers Families
Professional Development
  • REQUIRED CONSULTATION TOPIC
  • LEA must consult with private school officials
    prior to the LEA designing and implementing
    professional development activities that increase
    the private school teachers skills and knowledge
    on how to better instruct their students

23
Funding for Equitable Services
24
Funding for Equitable ServicesCollecting Poverty
Data
  • An LEA may calculate the number of private school
    children who are from low-income families and
    live in participating public school attendance
    areas in several ways
  • Use same measure of poverty as for public school
    children. The majority of districts in Michigan
    use free and reduced price meals eligibility as
    its source of data
  • Use comparable poverty data from a survey and
    must extrapolate results if actual data are
    unavailable
  • Use comparable data from a different source
  • Use an equated measure
  • LEA must collect poverty data on their resident
    low-income children attending private schools in
    other LEAs.

25
Funding for Equitable ServicesGenerating Funds
for Instruction
  • Low-income public and private school children
    residing in the same Title I attendance areas
    generate the same per-pupil amount (PPA)
  • PPA x the number of low-income private school
    children residing in participating public school
    attendance areas instructional funds for the
    Title I programs for eligible private school
    children

26
Funding for Equitable ServicesGenerating Funds
for Instruction
  • Funds may be generated from multiple LEAs with
    students attending a private school or from
    multiple attendance areas within a district.

27
Funding for Equitable ServicesGenerating Funds
for Instruction
  • e complaint

Eligible Public School Attendance Area (1) Grade Span Group (2) Percent Low- -Income (3) Amt. Per Low-Income Child (4) Public Low Income Count (5a) Section 31a Funding Per Child (5b) Public Amount (5c) Carryover and Parent Involvement Reservations (5d5e5f) Total Public Amount (5g) Private Low Income Count (5h) Private Amount (5i)
School A K 8 85 780 460 0 358,800 23,000 381,800 29 22,620
School B K 8 79 780 516 0 402,480 36,500 438,980 0 0
School C K 8 65 780 375 0 492,500 13,000 305,500 15 11,700
28
Funding for Equitable ServicesGenerating Funds
for Instruction
  • Funds generated by low-income private school
    children who reside in Title I attendance areas
    must be used only for instructional services

29
Funding for Equitable ServicesReservation of
Funds
  • If an LEA elects to reserve funds for district
    level instructional activities, such as summer
    school, for public school students, the LEA must
    also provide from those reserved funds equitable
    services to eligible private school children.
    These funds are in addition to per pupil funds
    designated for instructional services.

30
Title I Funds for Equitable ServicesDistrict-Wide
Instructional Activities
  • Districtwide Instructional Program(s) Reservation
    (does not apply to preschool programs) in
    participating public school attendance areas
  •  No. of private school children from low-income
    families divided by total no. of children, public
    and private, from low-income families equals
    proportion of reservation
  • _______5,000____ ______10,000_______
    _____5___
  • (Proportion of Reservation)__5 x
    _50,000__Reservation ___2,500 for
    Equitable Services
  •  

31
Funding for Equitable Services Carryover
  • LEAs must consider the equitable services
    requirements when making any decision about the
    use of district reservations and carryover funds
  • Instructional Programs
  • Professional Development
  • Parent Involvement

32
Equitable Services for Children
33
Equitable Services for ChildrenSelection of
Students
  • Private school children who reside in Title I
    participating public school attendance areas AND
    are failing or most at risk of failing to meet
    student academic achievement standards
  • Homeless 2 preceding years in Head Start Great
    Start Preschool Program Title I Preschool Title
    I, Part C (Migrant Education)
  • Grades pre-K-2 selected solely on the basis of
    teacher judgment, interviews with parents,
    developmentally-appropriate criteria and local
    assessments
  • Grades 3 and above selected using multiple
    written selection criteria
  • Poverty is NOT a criterion!

34
Equitable Services for ChildrenStandards
  • The LEA should use
  • Standards that are aligned with the curriculum of
    the private school
  • Depending on the number of private schools, there
    may be more than one standard
  • The State Educational Agency cannot impose
    standards, achievement levels, or assessments

35
Equitable Services for ChildrenTypes of Services
for Children
  • Equitable services for children must be designed
    as a Targeted Assistance Title program.

36
Equitable Services for ChildrenTypes of Services
for Children
  • Direct instruction outside the regular classroom
    pull out model
  • Tutoring
  • After- or before-school programs
  • Saturday programs

37
Equitable Services for ChildrenAssessments
  • After consultation, LEA establishes the
    assessment it will use to measure the
    effectiveness against the agreed-upon standards
  • May use the State assessment or another
    assessment that is aligned to the agreed-upon
    standards, such as the assessment used in the
    private school
  • All participants are assessed annually, including
    children receiving nonacademic services

38
Equitable Services for ChildrenSupplement, Not
Supplant
  • The supplement, not supplant provision applies
  • Title I services must be in addition to, and
    cannot replace or supplant, services that would
    be provided by private schools to their private
    school participants

39
Equitable Services for ChildrenSubject Areas and
Grade Spans
  • Title I services for private school childrenDO
    NOT need to be in the same subject areas or the
    same grade levels as Title I services for public
    school children. Needs of private school
    participants determine what Title I services are
    appropriate.

40
Equitable Services for ChildrenSubject Areas and
Grade Spans
  • The providing LEA has the option of providing
    services for the private school within any grade
    of the public schools grade span. Private
    school services do not have to be for the same
    grade levels as services at the public school,
    but they must be within the same grade span.

41
Equitable Services for ChildrenService Providers
LEA Employees
  • Provider of Title I services must be either an
    employee of the LEA or an employee of a third
    party under contract with the LEA
  • Private school teachers may be employed by both
    the private school and the LEA however, they
    must be independent of the private school during
    the time they are employed by the LEA to provide
    Title I services

42
Equitable Services for ChildrenService Providers
LEA Employees
  • Paraprofessionals must meet the paraprofessional
    qualification requirements, provide instructional
    support, and be under the direct supervision of
    and in close and frequent proximity to a highly
    qualified public school teacher
  • Private school officials may not sign time and
    effort records
  • Private school officials cannot establish
    requirements for LEA-employed teachers

43
Equitable Services for ChildrenMaterials and
Equipment
  • Title I funds may only be used to meet the needs
    of participating children
  • Non-Title I private school children, nor
    non-Title I teachers and parents non-Title
    students may not use materials purchased with
    Title I funds
  • LEA must retain title to all materials purchased
    with Title I funds

44
Equitable Services for ChildrenMaterials and
Equipment
  • All materials, etc., purchased with Title I funds
    must be labeled Property of School District
    and placed in a secured location when not in use
  • Private school officials have no authority to
    obligate Federal funds
  • There must be an instructional program before the
    purchase of supplemental materials

45
Equitable Services for Teachers and Families
46
Equitable Services for Teachers Families
Requirements
  • An LEA must provide equitable services to private
    school teachers and families of participating
    private school children from funds reserved for
    professional development (1119) and parental
    involvement (1118)

47
Equitable Services for Teachers FamiliesUse of
Funds
  • The LEA must use these funds to provide
    equitable services to teachers and families of
    participants
  • There is no authority under Title I for an LEA to
    transfer these funds to instruction
  • If teachers or families of participating private
    school students do not have a need for equitable
    services, those funds are available to the LEA
    for other allowable uses

48
Title I Funds for Equitable ServicesDistrict
Professional Development Reservation
  • Professional Development Reservation under Sec.
    1119 of ESEA in participating public school
    attendance areas
  • No. of private school children from low-income
    families divided by total no. of children, public
    and private, from low-income families equals
    proportion of reservation
  • ___5,000 _____100,000_______
    _____5___
  • (Proportion of Reservation)__5 x
    360,000__Reservation __18,000 for
    Equitable Services
  •  

49
Title I Funds for Equitable ServicesDistrict
Parental Involvement Reservation
  • Parental Involvement Reservation under Sec. 1118
    of ESEA in participating public school attendance
    areas
  •  No. of private school children from low-income
    families divided by total no. of children, public
    and private, from low-income families equals
    proportion of reservation
  • ________5,000____ _____100,000_______
    _____5___
  • (Proportion of Reservation)__5 x
    60,000__Reservation __3,000__ for Equitable
    Services
  •  

50
Additional Programs
51
Equitable ServicesTitle I, Part C
  • Allocation
  • Use the Title I, Part C Calculation of Private
    Schools Equitable Share screen to determine the
    appropriate per pupil amount for students
    eligible for Title I, Part C services. This is
    located on the OFS website under 2014-15
    Consolidated Application Important Information.
    Services require consultation. Contact the
    Title I, C Consultant.
  • www.michigan.gov/ofs

52
Equitable ServicesTitle II, Part A
  • Under Title II, Part A, LEAs are required to
    provide equitable services for private school
    teachers and other educational personnel only to
    the extent that they use the funds for
    professional development

53
Equitable ServicesTitle II, Part A
LEA Enrollment 17,814 (Box A)
Current Title II , Part A Allocation Box B 715,604
Amount of Title II, Part A Budgeted for PD Box C 715,604
FY 2001 Eisenhower Funds Box D 96,822
Base Amount Box E 715,604
  • Amount of Title II Budgeted for PD
  • Box C

715,604 Divided by Total Pupil Count of 18,691 Current Per Pupil Amounts 38.29
List of Private Schools within the LEA Boundary Private School Enrollments Private School Title II, Part A Allocations
School A 230 8,806.70
School B 159 6,088.11
School C 271 10,376.59
School D 217 8,308.93
54
Equitable Services Title II, Part ATransfer of
Funds/Other Uses
  • The amount of Title II, Part A that the district
    would use to calculate what is due to the private
    school would be the amount of the Eisenhower
    Grant
  • If an LEA was putting all of its Title II, Part
    A funds into class size reduction, merit pay or
    bonuses
  • Transferring all of Title II, Part A into Title
    I, Part A. The amount of Title II, Part A that
    the district would use to calculate what is due
    to the private school would be the amount of the
    2000 - 2001 Eisenhower Grant. 
  • This calculation would have to be done for the
    private school before budgeting other LEA uses of
    the funds.

55
Equitable ServicesTitle III, Part A- Language
Acquisition Program
  • Participation is considered equitable if the LEA
  • Assesses, addresses and evaluates the needs and
    progress of public and private school students
    and educational personnel on a comparable basis
  • Provides, in the aggregate, approximately the
    same amount of services to students and
    educational personnel with similar needs

56
Equitable ServicesTitle III, Part A- Language
Acquisition Programs
  • Spends an equal amount of funds to serve similar
    public and private school students and
    educational personnel
  • Provides both groups of students and educational
    personnel equal opportunities to participate in
    program activities
  • Resource Private School Participation Fact Sheet

57
Equitable ServicesTitle III, Part A
LEA (LEP) Enrollment 151
Current Title III, LEP Allocation Base 15,100
Total enrollment for LEA Private Schools (263)
divided by the base amount
Total enrollment for LEA Private Schools (263) divided by the base amount 57.42
List of Private Schools within the LEA Boundary Private School Enrollments Private School Title III, Part A (LEP) Allocations
School A 16 918.72
School B 25 1,435.50
School C 40 2,296.80
School D 31 1,780.02
58
Evaluation
59
Evaluation
  • After consulting with private school officials,
    the LEA must establish standards it will use to
    measure the effectiveness of the Title I program
    as indicated by the academic achievement of its
    participants
  • The MDE Program Evaluation Tool is a viable
    option for evaluating Title programs and
    services.

60
EvaluationAnnual Progress
  • Every year, the LEA, after consulting with
    private school officials, must determine what
    constitutes acceptable annual progress for the
    Title I program
  • This decision must be made before Title I
    services begin
  • Its not enough to just assess participants the
    LEA must determine the effectiveness of the total
    program in raising academic achievement

61
Other Considerations
62
General RequirementsSuggested Timeline
  • January/February
  • Mail letter (see sample of letter)
  • March
  • Conduct initial meeting (see sample of
    documentation)
  • Review demographics
  • Plan program
  • April - July
  • Await allocations
  • Meet to confirm
  • Submit application
  • Provide consultation throughout the year

63
General Requirements
  • Reminder -
  • Meetings and consultation must occur before
    district makes decisions
  • Consultation continues throughout implementation

64
Determining Private School ParticipationStudent
Numbers
Private School Students Residing Within District Boundaries(who attend a private school within or outside of district boundaries) Students Attending Private School Within District Boundaries (regardless of their residency)
Title I, Part A Funding Generated By Low-income students who reside in a Title I school attendance area Students Eligible to be Served Identified by a Needs Assessment for achievement below standard and reside in a Title I school attendance area Title I, Part C Meet criteria for migrant? Meet priority for services? Title II, Part A Title III, Part A Meet criteria for ELs/Immigrant? Completes Home Language Survey?
65
Allowable Uses of Funds for Private Non-Profit
(PNP) Schools
LEA for PNP Schools Title I, Part A Title I, Part C Title II, Part A Title III, Part A
Salaries for PNP personnel No No No No
Salaries of LEA staff who service PNP Yes Yes Yes, if providing PD Yes
Substitutes for ANY reason No No No No
Stipends Professional Development in core academic areas secular content only Reasonable necessary Outside of school day Paid directly to teacher by LEA Yes Yes Yes Yes
Purchase of Computers Yes for Eligible students Yes for Eligible students No Yes for Eligible students
Supplies Yes, for Title I students Yes, for Migrant students Yes for Professional Development Yes for Eligible students
Class Size Reduction No No No No
Support for PNP staff to become HQ No No No No Yes for ESL/Bilingual Endorsement
Professional Development Yes, for helping Title I students Yes Yes Yes
66
What Happens When a PNP Closes or the Program
Ends?
  • If a program is terminated or if the private
    school closes, the non-consumable materials and
    equipment must be returned to the district

67
District Fiscal Responsibilities
  • Write a check?
  • NO!
  • Generate a purchase order
  • Pay for professional development registrations
  • Pay wages of district employees who serve the
    private school
  • Pay for services of third-party employees who
    serve the private schools (purchased services)
  • YES!

68
Other Resources
69
Further Assistance
  • U.S. Department of Education
  • Guidance Documents
  • www.ed.gov/policy/elsec/guid/list.jhtml
  • Office of Nonpublic Education
  • www.ed.gov/about/offices/list/oii/nonpublic/index.
    html
  • Michigan Department of Education
  • Office of School Improvement, Field Services Unit
  • Technical Assistance packets on each grant source
  • Call your Field Services Consultant

70
Questions, Comments and Concerns
  • Contact your Field Services Consultant
  • Regions 1 - 5 . . . . . . . . .517-373-4004
  • Special Populations.517-373-6066
    Homeless, Migrant, Section 31a,
  • Section 41, Title I, D and Title III
  • Finance.517-373-2519
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