Title I Coordinator Training
Equitable Services
January 2013
1
Essential Questions
 Why Equitable Services?
 Who is responsible for what?
 What are the most common mistakes?
 What constitutes meaningful consultation?
 How do I calculate equitable services and
utilize the funds?
 How do I select students to participate and
how do I design a program for them, their
teachers and their parents?
 How do I evaluate the program?
 How do I maintain control of the program?
2
Title I Equitable Services
Section 1120 of Elementary and
Secondary Education Act (ESEA)
requires participating Local
Education Agencies (LEAs)
to provide eligible private school
students, their teachers and families with Title I
services or other benefits that are equitable to
those provided to eligible public school children,
their teachers, and their families.
Title I Equitable Services - WHY?
 Low-income parents with private
school children are included in the
census poverty counts that generate
funds the LEA’s use for Title I
services.
 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.
4
Defining Roles
 SEA - Monitor LEA implementation of private
school program and provide TA
 LEA – Design, deliver and maintain control of the
program/services provided to private school
children, their teachers and families
 Private School Officials - Participate in design of
program
 Vendors (if applicable) - Provide services in
accordance with contract terms
5
Top 10 Findings
1.
2.
3.
4.
5.
6.
Failure to conduct timely and meaningful consultation
Miscalculating equitable share
Lack of written selection criteria
Using paraprofessionals without direct supervision
Providing services that benefit the private school
Inadequate supervisions and control of contracts with
vendors
7. Failure to evaluate the program
8. Failure to maintain control of the program
9. Failure of states to establish complaint procedure
10. Failure of states to monitor, provider oversight and offer TA
6
Equitable Services
 LEAs must annually invite
non-profit private schools to
participate in Title I
 LEAs must regularly consult
with interested private schools
• Consultation involves discussions between public
and private school officials on key issues that affect
the ability of eligible private school students to
participate equitably in Title I programs.
• Consultation must occur in a timely and meaningful
manner during the design, development, and
implementation of the program.
• Consultation is considered meaningful when there is a
genuine opportunity for all parties to express their
views and to have those views heard.
7
Timely and Meaningful Consultation
At a minimum, consultation must address:
•
The method or source of poverty data
used to determine the amount of funds
generated;
•
The amount of funds available for services;
•
How students’ needs will be identified;
•
What services will be offered;
•
How and when the LEA will make
decisions about the delivery of services;
•
How, where and by whom the LEA will provide services;
•
The size and scope of services;
•
The services provided to teachers and families;
•
How the LEA will evaluate the Title I program and use the
results to improve Title I services.
How the private school has the right to complain
Collection of signed affirmation of consultation forms
•
•
8
Collecting Poverty Data
 LEA must collect poverty data from private
schools at least every two years. Schedule can
vary by school.
 LEAs must discuss frequency and feasibility of
data collection with private school officials in
consultation
9
Calculating Equitable Services
LEAs must provide an equitable
share of funds reserved at the LEA level:
 Applies to:
– Reservation for Parent involvement
– LEA-wide professional development reservation unless all funds are
targeted to a specific subset of low-performing schools only
– LEA-wide instructional activities reservation unless all funds are targeted to
a specific LEA identified subset of low-performing schools only
 Does not apply to:
– Reservations from which an LEA provides services to an identified
subgroup of students – e.g., Homeless, Pre-k, Focus or Priority — because
public Title I school students as a whole do not benefit from those services
either.
– Professional development or instruction reservations where all funds are
targeted to a specific LEA identified subset of low-performing schools only
– Reservations for administering the Title I program – because private
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schools do not administer the program.
Activity (5 minutes)
 Review each of the three scenarios.
 For each scenario, indicate which of the LEA set
aside funds are subject to equitable share.
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Determining Which Private Schools
Generate Title I Funds
 The LEA, in consultation with private school
officials, must obtain the best available poverty
data on private school children in participating
private schools residing in participating public
school attendance areas.
 There are several allowable ways to calculate
poverty
1.
2.
3.
4.
5.
Use the same measure of poverty LEA uses
Use comparable poverty data from a survey
Use comparable poverty data from another source
Use proportionality
Use an equated measure
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Calculating Equitable Services on
LEA Level Set-Asides
In participating public school attendance areas:
# of Private school
children from
low-income
families
Proportion
of LEA
Set -Aside
÷
x
Total # of all
public and private
school children
from low-income
families
Amount
of
LEA Set-Aside
=
=
Proportion
of LEA
Set Aside
Amount of
funds for
equitable
services
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Calculating Equitable Services on
School level Allocations
LEAs must provide an equitable share of funds
generated for students at the school level:
•
Low income private school students in participating private
schools from a participating public school’s feeder generate the
same PPA as public school students from that participating public
school.
Below is an example of how equitable share is
calculated at the school level:
School
Public
Enroll
Public Pov Private Pov
(DOE
(DOE
(LEA
Provided) Provided) Provided) Total
Rate
Eligible
School Category
Title I
Service
Status
PPA
Actual
Allocation
(Public and Public
Private)
Allocation
Private
Allocation
School 1
500
378
35
413 82.60%
Yes
1
Schoolwide $425.00 $175,525.00 $160,650.00 $14,875.00
School 2
500
408
0
408 81.60%
Yes
1
Schoolwide $425.00 $173,400.00 $173,400.00
14
$0.00
Options for Providing Equitable
Services
In consultation, the LEA and private school officials
may choose one or both of the following options for
using the funds reserved for instructional services
for eligible private school children:
•
On a School-by-School Basis: Provide equitable services to
eligible children in each participating private school with the
funds allocated for the children who reside in participating
public school attendance areas and attend that participating
private school.
•
Pooling Option: Combine funds allocated for private school
children in all participating areas to create a pool of funds
from which the LEA provides equitable services to eligible
private school children who are in the greatest educational
need of those services and reside in participating public
school attendance areas.
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More on Pooling
 The LEA, in consultation with officials from the
private schools, must establish criteria to
determine the eligible private school students in
greatest educational need who should receive
services.
 The services provided to eligible children
attending a particular private school do not
depend on the amount of funds allocated for
children in that school.
 The possibility exists that students with a
demonstrated educational need in a private
school that does not generate funds may receive
services.
16
Budgeted Items for Private School
Funds
 You should have at least one budgeted item for
each Funding Description for which funds were
generated.
– Parent Involvement
– Professional Development
– Instruction (LEA and School Level)
 LEA and School Level Instruction can be
combined in a single item or in two separate
items.
17
Budgeted Items for Private School
Funds (cont’d)
 Budgeted item description can be general (see
examples below).
– “LEA equitable share set aside for Parent Involvement
for Private schools”
– “LEA equitable share set aside for Professional
Development for Private schools”
– “Combined LEA and School Level equitable share set
aside for Instruction for Private schools”
 Target for funds should be “Private Schools”.
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Let’s take a 10
minute break
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Planning for Equitable Services
Services to eligible students in private schools
should resemble the structure of a targeted
assistance program, where services are provided
to a specific set of eligible students and teachers,
not the entire school.
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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Student Eligibility for Title I Services
To be eligible for Title I services, a child must:
•
•
reside in a participating public school attendance area. (LEA
must verify)
be failing or at risk of failing based on multiple, educationallyrelated objective criteria determined by LEA, in consultation with
private school officials
The following children may be considered
automatically eligible:
•
Homeless children and children who participated in Head Start,
Even Start, or Early Reading First, a Title I preschool program,
or a Title I, Part C (Migrant Education) program within the past
two years
POVERTY IS NOT A CRITERION FOR ELIGIBILITY
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Setting reasonable academic eligibility
criteria
 LEA must use multiple, educationally-related
objective criteria to determine which children
are eligible, and within the eligible group, which
children will be served.
 Criteria may include:
– Achievement tests
– Teacher referrals and recommendations based on objective,
educationally related criteria
– Grades
 Children Preschool – Grade 2 are eligible based
on the following
– Selected on teacher judgment, interviews with parents and
other developmentally appropriate measures.
22
Selecting eligible students to be served
 Determine which students are most at risk using
multiple selection criteria
Examples include:
– Test cut points
– Ask private school classroom teachers for specific
recommendations on which students could benefit from the
Title I program
– Provide private school principals and teachers with ranking
sheets that rate the skills and abilities of potential students.
 Apply criteria selection objectively and uniformly
across the district.
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Preschool Children
 Preschool children in a participating private
schools are not entitled to receive equitable
services
 If, after meaningful consultation with private
school officials, and after considering the needs
of other private school children, the LEA
determines that sufficient Title I funds are
available to provide services to preschool
children determined to have educational need,
the LEA may provide services to the preschool
children.
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Program Design
 The LEA and private school officials must work together to
design programs to meet the education needs of the private
school participants
 The LEA makes the final decision on the program design
 Services must be delivered in a space used (at the time)
exclusively for Title I instructional services.
 Services must be provided outside the regular private
school classroom
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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Parent Involvement
 LEA must consult with private school officials
and parents before implementing activities
 Activities should provide parents of participating
children the tools they need to support their
child’s learning activities.
– Examples include:
• Establishing a parent center or resource library for
parents of participating students
• Inviting parents to attend parent involvement activities
hosted by the LEA or public school
• Providing resources for parents to use at home with their
children
• Parent education sessions
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Professional Development
 LEA must consult with private school officials
and teachers before implementing PD activities
 Activities may only serve teachers of private
school participants
 Activities must be geared toward serving
students who are failing or at risk of failing
– Examples include:
• Providing information on research based strategies in
reading and mathematics for at-risk children.
• Inviting teachers of private school participant to join an
LEAs PD so long as the PD is geared toward meeting
the specific needs of at-risk children
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Evaluating the Title I Program
 LEA’s must academically assess Title I services
annually and use the results of that assessment to
improve services. 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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Evaluating the Title I Program
 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.
 It’s not enough to just assess participants -- LEA
must determine the effectiveness of the total
program in raising academic achievement.
 If the expected annual progress is not met, the LEA,
after consultation, must review its program and
determine modifications it should make in order to
improve the effectiveness of the Title I program29
Maintaining Control
LEA must maintain control of the Title I funds,
materials, equipment and property. LEAs should:
•
Ensure materials purchased with Title I funds are clearly
marked as the property of the LEA and are being used
only by Title I students and their teachers
•
Monitor the delivery of services to:
– Ensure services are delivered in a accordance with LEA’s
plan as determined after meaningful consultation
– Ensure the services are provided strictly to Title I students or
their teachers of Title I students
– Make general observations of the quality and effectiveness
of the services being delivered
– Check materials against your inventory records
– Note any changes you would suggest in consultation as you
prepare for the next school year.
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Record Keeping
LEAs should maintain the following records:
•
•
•
•
•
•
•
•
•
•
•
Signed MOU (if participating in a consortium)
Records of consultation (invitations, minutes, affirmations,
etc.)
Written criteria used to determine educational need
Ranked listing of students by private school or in pool
Amt of funding per private school and associated services
Vendor contracts (if applicable)
Invoices (if applicable)
Inventory records
Records of monitoring (schedule, notes, etc.)
Standards that will be used to measure effectiveness of the
program
Results of the program evaluation
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Availability of Funds
 Services should begin at the same time as the
Title I program for public school participants.
 Funds are available as soon as consolidated
grant is processed (July –Sept)
 Expenditures can be re-coded to initial grant
submission date (if grant was considered
substantially approvable)
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Unobligated/Unexpended Funds
Scenario 1: Equitable services are fully delivered
during the school year
– LEA can reallocate funds for public school Title I program to be
used prior to the end date of the grant*
Scenario 2: Equitable services are delayed and/or
not fully delivered during the school year
– Funds must be carried over and added to the next year’s pool
that private school students generate. First in, first out rule
applies.
– The funds must be used to make up for the lack of equitable
services during the previous year and cannot be used by the
public school Title I program.
*Equitable services apply, if applicable
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Interlocal agreements
LEAs operating as consortia should develop MOUs
outlining:
•
The obligations of each participating LEA including which LEA will
serve as fiscal agent
•
How and when charges and reimbursements will
be made (Ex. Through an IV, based on cost of service
divided proportionally by the number of students or
parents of students served)
•
Timeframe for consultation and delivery of services
•
Who will determine eligibility of students
•
Who will assess the students and assessment tools to be used
•
Where services will be provided
•
How student performance will be measured
•
Method of termination of agreement and disposal of property
•
Other agreed upon items
34
Working with a Third Party to
Provide Services
If an LEA enters into a contract with a third party
provider for the delivery of Title I services to the
private school participants, their teachers, or
families such contracts must provide technical
descriptions of the Title I services with detail
sufficient to enable LEAs to determine that all
Title I statutory and regulatory requirements will
be met. [ESEA Section 9306(a)(1) and (2)]
35
Contract Elements
 Describe service(s) in detail to assure the third
party services are in compliance with all Title I
statutory and regulatory requirements. Include
an assurance that the contractor will comply.
 Assure that administrative costs are
identified in the contract separately.
Administrative costs must be paid out of the
funds reserved by the LEA for administrative
costs
 Outline an invoicing procedure which ensures
the contractor will list administrative and
instructional costs separately on invoices
 Describe the process that will be used to
monitoring vendor performance.
36
Contract Elements Continued
 Provide a timeline for the delivery of services
 Provide a list of required deliverables with due
dates
 Include an assurance that all equipment
purchased with Title I funds are the property of
the LEA and not the contractor
 List the steps the LEA will take if the contractor
is not in compliance including an assurance that
the LEA has the right to withhold payment if any
requirements are not met
 Include a statement or assurance that the
contract may be modified if there is a
reauthorization of ESEA during the performance
of the contract
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Budgeted Item for Contractor
Administration Costs
Funding description should be
“Administration Cost” as funds must
come from LEA Administration set aside
not the Private School equitable share
funds.
Budgeted item description should
provide detail to justify the cost.
• Example: “Administrative costs for contract
with ABC Instructional Services to administer
Private School equitable share services (40
hours @ $20 per hour)”
Target should be “LEA-wide”
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Additional Resources
 DDOE Private School Participation Website
http://www.doe.k12.de.us/infosuites/staff/fedstprog/TitleIPartA/PrivateSchoolParticipatio
n/Private-School-Participation.shtml
 US ED Non-Regulatory Guidance on Equitable Services
http://www.doe.k12.de.us/infosuites/staff/fedstprog/TitleIPartA/TitleIFILES/FederalGuid
anceFILES/psguidance.doc
 Section 1120 of the ESEA
http://www2.ed.gov/policy/elsec/leg/esea02/pg2.html#sec1120
 DEDOE’s Title I Technical Assistance Session Materials
www.doe.k12.de.us/infosuites/staff/fedstprog/default.shtml
 Ensuring Equitable Services to Private School Children: Title I
Resource Toolkit
http://www.doe.k12.de.us/infosuites/staff/fedstprog/TitleIPartA/TitleIFILES/FederalGuid
anceFILES/titleitoolkit.pdf
 State’s Official Complaint Procedure
http://regulations.delaware.gov/AdminCode/title14/200/258.shtml#TopOfPage
 Private School Registration Website
http://www.doe.k12.de.us/infosuites/schools/Nonpublicwebpages/default.shtml
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