Some slides in this presentation were excerpted from US Eds February 2009 PowerPoint presentation titled: Help! Im a New Title I Director. What Do I Need.

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Some slides in this presentation were excerpted from US Ed’s February 2009 PowerPoint presentation titled: Help! I’m a New Title I Director. What Do I Need to Know?

Ensuring Equitable Services to Private School Children Under NCLB, Title I, Part A

Regional Title I Technical Assistance Sessions

May, 2009

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Private School Monitoring Findings

Process Findings:• The DDOE has not ensured LEAs document

that all required consultation topics have been discussed

• The DDOE has not ensured LEAs maintain control of the program delivered in private schools

• The DDOE has not ensured LEAs met requirements for selection of private school students eligible for Title I services

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Private School Monitoring Findings

Financial Findings• The DDOE has not ensured LEAs correctly calculate

equitable services for parents and teachers of private school children

• The DDOE has not ensured LEAs correctly calculate equitable services for all applicable central reservations

• The DDOE has not ensured the LEAs exercised proper oversight in awarding contracts for Title I service provision

• The DDOE has not ensured the LEAs exercised proper oversight in reimbursing third party providers

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Process Finding 1: Consultation topics not discussed

What 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 must:• occur during the design, development,

and implementation of Title I programs;• include meetings; and• occur prior to the LEA making any

decisions.

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At a minimum, consultation must address:1. How the LEA will identify the needs of eligible

children;2. What services the LEA will offer; 3. How and when the LEA will make decisions;4. How, where, and by whom the LEA will provide

services;5. How the LEA will assess the Title I program

and use the results to improve Title I services;6. The size and scope of the equitable services

and the proportion of funds the LEA will allocate for services;

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7. Method or sources of data the LEA will use to determine the number of low-income students;

8. Services the LEA will provide to teachers and families of participating children;

9. Discussion of service delivery mechanism the LEA can use;

10.A thorough consideration and analysis of the views of private school officials services through a contract with third-party provider.

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Monitoring Resolution 1:

The DDOE will• Provide ongoing technical assistance and

guidance

and• Monitor LEA documentation of private school

consultation during October site verification audits by reviewing– Signed LEA Affirmations of Consultation with

Private School Officials • See sample documents Tools 1.1A and 1.1B

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Process Finding 2:LEA control of the program

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.

This theory was developed to comply with the Constitutional prohibition against Federal funding to private schools.

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• Private school officials have no authority to make any decision.

– LEAs decide which children are

eligible to participate in the Title I program

– No funds go to private schools– LEAs develop program plans

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• The LEA is responsible for designing and implementing Title I programs for its resident children who attend private schools, even those attending private schools located in other LEAs.

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• The LEA is required to develop and implement Title I programs that meet the needs of the Title I participants and the LEA cannot delegate this responsibility to private school officials.

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The DDOE will• Provide ongoing technical assistance and guidance

and• Monitor LEA compliance during the Desk Audit

and/or October site verification audits by reviewing– Documentation of how eligible private school students

were selected (spreadsheets okay) and – Documentation of LEA financial management of private

school programs– Third party provider RFPs and contracts

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Process Finding 3:Selection of eligible students

An LEA must only use Title I funds to meet the needs of the Title I participants.

Consequently ….• An LEA cannot use any Title I funds to meet the

needs of the private school or the general needs of the private school children.

• Private schools cannot have schoolwide programs.

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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.

• 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.

See Section 2 of the Title I Resource Toolkit

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• 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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guidance


and/or October site verification audits by reviewing– Documentation of how eligible private school students

were selected (spreadsheets okay) and – Poverty data for students receiving services

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Financial Findings 1&2:Equitable service calculations

• LEAs must provide equitable participation from funds reserved under §200.77 of the regulations for the purpose of district wide instructional activities and/or programs* for elementary and secondary public school children.

*This requirement does not apply to reservations for program improvement required under section 1116 of ESEA, homeless, pre-k, neglected or delinquent programs.

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In order to meet Equitable Services requirements 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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Types of services• Direct instruction outside the regular

classroom = pull out model• Tutoring• After or before school programs• Saturday programs• Summer school• Counseling• Computer assisted instruction (CAI)

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Types of central reservations

• Professional development

• Parent activities

• ELL services

• What else???

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In participating public school attendance areas:

# of Private school Total # of all Proportion

children from ÷ public and private = of

low-income school children reservation

families from low-income

families

Proportion Amount Amount of

of x of = funds for

Reservation Reservation equitable services**

** May be added to the instructional funds generated by low-income private school children

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guidance


and/or October site verification audits by reviewing– Documentation of eligible private school equitable

service calculations (spreadsheets okay)

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Financial Findings 3 & 4:Contract Oversight

• LEA must follow State procedures for procurement when contracting with a third party.

• Contract must be detailed enough so LEA knows that the third party will comply with all Title I requirements.

• Invoices from the third party must list administrative and instructional costs as would be required by an audit.

• LEA must monitor third party’s performance.

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guidanceand• Monitor LEA compliance during the Desk Audit

and/or October site verification audits by reviewing– Documentation of LEA financial management of

private school programs– Third party provider RFPs, contracts, and invoices – LEA financial coding of third party payments

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Questions

Some slides in this presentation were excerpted from US Eds February 2009 PowerPoint presentation titled: Help! Im a New Title I Director. What Do I Need.

Documents

powerpoint presentation

new title

us eds

regional title

implementation of title

private schools leas

lea control

equitable services