Recommendations from NASTID &
June 2011
Direct Questions or Suggestions to:
Rich Long, Executive Director
National Association of State Title I Directors (NASTID)
Bill East, Executive Director
National Association of State Directors of Special Education (NASDSE)
What is NASTID?
• Not-for-profit membership organization
• Membership is made up of state education
agency officials responsible for administering
Title I in their state
• The mission of the association is to:
“To enable disadvantaged children and youth to meet or exceed high academic
state standards, the National Title I Association builds the capacity of state and
local educators for leadership, support and advocacy in the design and effective
implementation of programs under Title I of the Elementary and Secondary
Education Act (ESEA).”
What is NASDSE?
• Not-for-profit membership organization
• Members are special education directors from
the 50 states and 11 federal jurisdictions
• Mission is to assist state education agencies
provide improved educational outcomes for
students with disabilities.
What is Title I?
• Part of ESEA that provides funds to school
districts with high numbers of children living
in poverty
• Provides needed supports to close the
achievement gap between low-income
children and their more affluent peers
• Provides services to approximately 17 million
students with a $14 billion federal
appropriation (FY 2010)
What is the IDEA?
• Entitlement program ensuring identification
and services for students with disabilities
• Specially designed individualized instruction in
the least restrictive environment
• Services for approximately 7 million students
ages birth through 21 with a $12 billion
Why is Better Coordination Needed?
• Approximately 2.5 million students are served
by Title I and IDEA
• Administrative requirements overlap and are
often duplicative, contradictory or lack clarity
NASTID/NASDSE Collaboration
• IDEA Partnership at NASDSE convened a
Community of Practice in 2008
• Presentations at NASDSE and Title I
• Title I/IDEA Workgroup
• Collaborative paper with recommendations
for improved coordination
What Areas Overlap?
Many areas of Title I and IDEA overlap, but this
initiative will focus on:
compliance/outcome requirements
program requirements
integrated instruction
Under Title I:
• Move every child toward academic proficiency
• Identify schools’ annual yearly progress
• Implement appropriate
Under IDEA:
• Ensure that students receive a free,
appropriate public education in the least
restrictive environment
• Ensure that rights of children and parents are
Accountability Areas of Focus
Adequate Yearly Progress
Universal Design for Learning
Graduation Rate
Data Collection
• Proposed Change:
To impact instruction, ensure that assessment results are shared with
teachers in a way that is both timely and useful.
• Issue:
In some states, assessment results are returned too late for teachers to
make adjustments in their teaching.
Adequate Yearly Progress
• Proposed Change:
Encourage organizations to work together to determine how best to
balance a focus on individual student growth (IDEA) with improvement
from year to year within a single grade (ESEA).
• Issue:
AYP does not measure individual student performance from year to year.
Rather it compares how well a school is making progress towards reaching
the goal of all students being proficient by school year 2013-14.
Universal Design for Learning (UDL)
• Proposed Change:
Principles of UDL should infuse both instruction and assessments across
all education programs.
• Issue:
Students do not always have curriculum and assessment materials in a
format that is accessible to them.
Graduation Rate
• Proposed Changes:
Provide a common definition of graduation rate and a single data
collection point. ESEA regulations should recognize that under IDEA, some
students may need additional time.
• Issue:
All students should have access to a quality education to help them
graduate college and/or career ready. Some students need individualized
instruction and time to complete their curriculum and transition services.
Data Collection (1)
• Proposed Change 1:
Identify 5-10 required data points that are most critical (e.g., graduation rate,
dropout rate, post-school outcomes) and focus on these for both Title I and
IDEA. Include stakeholders in determining which data points are most critical
to be reported at the federal level.
• Issue 1:
The US-ED lacks a coherent approach to data collection. Under IDEA,
similar data are collected at different times and some data are reported
under EDFacts, while Annual Performance Report (APR) data under the
State Performance Plan (SPP) are not. Under Title I, states report under a
Consolidated State Performance Report (CSPR) submitted through
EDFacts. The different reporting dates with different terms or different
definitions for similar data points is most confusing.
Data Collection (2)
• Proposed Change 2:
The Government Accountability Office (GAO) should conduct a study of
the overall cost of education data collection for states.
• Issue 2:
Data collection is burdensome for states. Many states report hiring
multiple staff exclusively for meeting Title I and/or IDEA data collection.
The exact cost is unclear.
Data Collection (3)
• Proposed Change 3:
EDFacts should be the basic reporting system and should serve as the
repository for all data (including Title I and IDEA) reported to the US-ED.
• Issue 3:
Because data are collected in a piecemeal fashion by individual programs,
the sharing of data across programs is a challenge.
Data Collection (4)
• Proposed Change 4:
All data need to be current (i.e. less than 12 months old) and data
collection systems should be constructed with the intent of reporting data
in a timely way.
• Issue 4:
Many policy decisions are based on outdated data. In IDEA, states are
often cited for violations that have already been corrected.
Data Collection (5)
• Proposed Change 5:
All data collected need to be linked to specific anticipated actions by the
US-ED or specific requirements for state action in the statutes.
• Issue 5:
Not all data collected are currently being used due to the immense
volume. For example, under IDEA, Indicator 8 (Part B) is not used at the
federal level except to monitor the response rate.
1. Maintenance of Effort
2. Supplement Not Supplant
Maintenance of Effort
• Proposed Change:
The US-ED should provide guidance for schools serving students enrolled
in both programs regarding how to comply with the two laws’ differing
maintenance of effort requirements.
• Issue:
Maintenance of effort is defined differently under the two laws, creating
confusion at the local level about how to administer programs in
compliance with two sets of requirements.
Supplement Not Supplant
• Proposed Change:
The US-ED guidance on supplement not supplant should clarify the
differences between each program’s requirements, and include
recommendations on how states can support the use of Response to
Intervention/Multi-tiered System of Support (RTI/MTSS) without violating
the supplement not supplant requirements.
• Issue:
The measurements of supplement not supplant are different for each
program. In Title I, there are differences between school-wide programs
and targeted assistance schools.
1. Working Across Programs
2. Definitions
3. Paraprofessionals
Working Across Programs
• Proposed Change:
The US-ED should development recommendations for schools on how
they can increase collaboration across programs.
• Issue:
The complexity of Title I and IDEA requirements sometimes creates
concern in schools and districts that collaboration across programs
will result in being cited in a compliance review. This can reduce the
likelihood of collaboration between the two programs.
• Proposed Change:
The US-ED should include in its materials, trainings and technical
assistance an acknowledgement of the different definitions within the two
laws, as well as guidance for reconciling the requirements of both.
• Issue:
Differing definitions for the same or similar concepts create confusion at
state and local levels. The lack of clarity makes it difficult for
administrators to apply the laws effectively.
• Proposed Change:
Schools should include paraprofessionals in professional development
activities that are the same or comparable to those received by teachers.
More flexibility regarding Title I aides would allow for more flexibility in their
use in school-wide programs.
• Issue:
The integration of paraprofessionals into Title I or IDEA programs varies
widely. Under Title I, parapros monitor instructional tasks and are required
to either pass a proficiency test or have an associate degree. Under IDEA,
parapros provide support in academics, health or behavior-related
activities, but there are no specific requirements for paraprofessionals in
the IDEA.
(MTSS/RTI) (1)
• Proposed Change 1:
Proposed changes: Schools and school districts should be allowed to use
their comprehensive early intervening funds (i.e., up to 15 percent of their
federal IDEA funds) to implement all tiers, including the basic tier, of a
Response to Intervention/Multi-tiered System of Supports, whether they
have elected voluntarily to develop such a system or have been ordered to
redirect 15 percent of their federal funds by the state education agency.
• Issue 1:
Schools using 15% of their IDEA funds for struggling learners are not able
to use those funds for Tier I services in a RTI/MTSS model. It remains
unclear what this means for schoolwide Title I programs.
• Proposed Change 2:
The US-ED should issue guidelines for states to develop a waiver
procedure that would allow states to issue Title I schools an exception
from supplement not supplant requirements if they can show that they
are implementing with fidelity a robust RTI/MTSS model.
• Issue 2:
If a state or district requires all schools to implement RTI/MTSS, Title I
funds are at risk of supplanting rather than supplementing federal, state
and local funds.
What Next? – Topics for Further
1. Flexibility
2. Defining the Effective Teacher
3. Formative Assessments and Progress
Where to go for more information
• National Title I Assocation –
• National Association of State Directors of
Special Education –