Title: Office of Field Services
1Office 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(No Transcript)
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5Reference 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
6Reference Materials
- Technical Assistance Packets
- Title I, Part A
- Title I, Part C
- Title II, Part A
- Title III, Part A
7REQUIREMENTS
8Equitable 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)
9Equitable 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
10Equitable 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
11Equitable 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
12Equitable 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.
13Equitable 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
14Equitable Services Requirement Program
Responsibility
- The LEA is responsible for making program and
budgetary decisions based on timely and
meaningful consultation with the private school.
15Consultation
16Consultation 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
17Consultation 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
18Consultation Requirements
- What topics must be addressed during
consultation?
19Consultation 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
20Consultation 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
21Consultation 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
22Equitable 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
23Funding for Equitable Services
24Funding 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.
25Funding 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
26Funding 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.
27Funding for Equitable ServicesGenerating Funds
for Instruction
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
28Funding 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
29Funding 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.
30Title 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 -
31Funding 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
32Equitable Services for Children
33Equitable 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!
34Equitable 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
35Equitable Services for ChildrenTypes of Services
for Children
- Equitable services for children must be designed
as a Targeted Assistance Title program.
36Equitable Services for ChildrenTypes of Services
for Children
- Direct instruction outside the regular classroom
pull out model - Tutoring
- After- or before-school programs
- Saturday programs
37Equitable 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
38Equitable 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
39Equitable 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.
40Equitable 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.
41Equitable 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
42Equitable 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
43Equitable 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
44Equitable 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
45Equitable Services for Teachers and Families
46Equitable 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)
47Equitable 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
48Title 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 -
49Title 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 -
50Additional Programs
51Equitable 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
52Equitable 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
53Equitable 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
54Equitable 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.
55Equitable 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
56Equitable 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
57Equitable 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
58Evaluation
59Evaluation
- 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.
60EvaluationAnnual 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
61Other Considerations
62General 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
63General Requirements
- Reminder -
- Meetings and consultation must occur before
district makes decisions - Consultation continues throughout implementation
64Determining 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?
65Allowable 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
66What 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
67District 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!
68Other Resources
69Further 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
70Questions, 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