Office of Field Services

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Office of Field Services Ensuring Equitable
Services for School Children Attending Private
Non-Profit Schools
Office of Field Services
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Katie Doerr Parker Gayle Green Yvonne W.
Mayfield Field Services Consultants Office of
Field Services www.michigan.gov/ofs
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(No Transcript)
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(No Transcript)
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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

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Reference Materials

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

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REQUIREMENTS
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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)

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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

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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

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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

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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.

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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

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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.

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Consultation
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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
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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

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Consultation Requirements

• What topics must be addressed during
  consultation?

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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

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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

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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

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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

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Funding for Equitable Services
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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.

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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

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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.

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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
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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

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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.

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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
•  

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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

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Equitable Services for Children
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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!

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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

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Equitable Services for ChildrenTypes of Services
for Children

• Equitable services for children must be designed
  as a Targeted Assistance Title program.

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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

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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

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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

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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.

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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.

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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

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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

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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

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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

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Equitable Services for Teachers and Families
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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)

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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

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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
•  

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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
•  

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Additional Programs
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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

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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

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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
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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.

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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

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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

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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
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Evaluation
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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.

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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

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Other Considerations
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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

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General Requirements

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

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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?
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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
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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

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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!

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Other Resources
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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

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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