1. Title I Equitable Services to Non-public Schools

2. Jonathan Bolding McKinney-Vento & Non-public Programs Coordinator Office of Consolidated Planning & Monitoring Jonathan.Bolding@tn.gov (615) 770-1793

3.  Review of Title I Equitable Services  Review Consultation  Review process for delivering Intent to Participate (ITP) Form  Navigate ePlan to access the Private School Survey –Uploading the Private School Survey  The importance of collecting the information for the private school survey Agenda 3

4. Provision of Equitable Services

5. Under Title I 1, local educational agencies (LEAs) are required to provide services for eligible children 2 attending private elementary and secondary schools, their teachers, and their families with Title I services or other benefits that are equitable to those provided to eligible public school children, their teachers, and their families. 1 Title I, Part A § 1120 of the Elementary and Secondary Education Act (ESEA), as amended by the No Child Left Behind Act (NCLB) 2 Eligible students are those students that reside in Title I school zones and are failing or at risk for failure. Why LEA’s Provide Services to Private Schools 5

6.  All private schools (non-profit and for-profit) must provide enrollment data.  All non-profit private schools must be offered the opportunity to participate in federal programs.  Only non-profit private schools may participate in federal programs. Private School Participation in Federal Programs 6

7.  To qualify for Title I assistance, a student must reside within the attendance area of a participating public school located in a low-income area and be failing, or at risk of failing, to meet student academic achievement standards.  Poverty is not a requirement eligibility. Who is Eligible? 7

8.  Criteria for eligibility is determined during consultation through multiple measures such as: –Achievement test scores –Report card grades –Teacher referral Who is Eligible? 8

9.  Assess, address, and evaluate the needs of non-public school students, teachers, and parents.  Provide non-public school students and teachers with an opportunity to participate in activities equivalent to the opportunity provided to public school students and teachers.  Begin services with non-public school students at the same time as public school students. Services are Equitable When LEAs…

10.  The total amount expended by the LEA for services to eligible private school children must be proportionate to the amount of funds generated by private school students.  Private school students generally must receive an equitable amount from any reservations of funds made by the LEA before sending funds to public schools and deriving the nonpublic allocation. Equitable Funding for Students

11.  LEAs are required to reserve funds off the top of their Title I allocation to carry out required parental involvement activities. 1  LEAs are also required to calculate the amount of funds available for parental involvement activities from the reserved funds proportionally for private school children from low-income families residing in participating public school attendance areas. 2 1 Title I § 1118 2 Title I § 200.65 Equitable Services for Families

12.  LEAs must set aside funds from the Title I allocation for Title I professional development activities. 1 –LEAs must provide equitable services to teachers of private school participants from this set-aside. –LEA calculate these equitable services in proportion to the number of private school children from low-income families residing in participating public school attendance areas. 2  Activities must be planned during consultation and implemented with participating private school officials and teachers. 1 Title I § 1119 2 Title I § 200.65 Equitable Services for Teachers

13. Consultation

14.  Title I requires timely and meaningful consultation between the LEA and private school officials prior to any decision that affects the opportunities of eligible private school children, families, and teachers to participate in Title I programs, and shall continue throughout the implementation and assessment of activities. –Title I § 1120(b) and § 200.63 Regulatory Requirements of Consultation 14

15.  Consultations must address the following for eligible private school children: –How LEAs will identify needs –What services LEAs will offer –How and when LEAs make decisions about the delivery of services –How, where, and by whom LEAs will provide services –How LEAs assess the academic services to private school children, and how LEAs use the results to improve Title I services Regulatory Requirements of Consultation 15

16.  The consultation process between public and private school officials regarding the Title I program services should result in a Title I program designed to meet the educational needs of eligible private school children. Goal of the Consultation Process 16

17. Example Timeline for LEA Consultation with Private Schools 17 MonthLEA ActivityLegal Basis November/December in preparation for the next school year Obtain complete list of all private schools who are residents of the LEA LEA uses list to ask all private school officials if they want their eligible students to participate in Title I the next school year December/March in preparation for the next school year Obtain from principals or a central office serving a group of private schools poverty data (as appropriate) Private school students from low-income families who live in Title I participating public school attendance areas generate funds for instructional purposes

18.  Well-constructed meeting agendas provide road maps for well-run and focused consultation meetings.  To the extent possible, envisioning the consultation needs for the school year prior to the first consultation meeting will determine what subjects should be covered in order to effectively pace the consultation process.  The agenda items and timing of the meetings should follow the decisions made and the timeline established, respectively, at the first consultation meeting. Meeting Agendas for the Consultation Process 18

19.  Title I § 200.63 requires that each LEA must obtain a written affirmation signed by the official of each participating private school, or a representative of those schools, that the required consultation process has occurred.  A signature on an affirmation form signifies that the private school official is satisfied that an equitable program has been designed to meet student needs and has a reasonable promise of being effectively implemented. Statement of Affirmation 19

20. Intent to Participate

21.  Collects enrollment data from all private schools; both non-profit and for-profit  Indicates which non-profit private schools will be participating in federal programs during the following year  Independent home schools do not complete an Intent to Participate form. Intent to Participate Form 21

22.  Distribute to all private schools in your district –Use the Tennessee non-public schools list –Use registered mail to document contact with each private school –Attempt more than one form of communication: email (return receipt) Non-registered mail Fax  Refer to forms on ePlan for current deadlines Intent to Participate Form: Distribution

23. Intent to Participate Information on ePlan 23

24. Intent to Participate Information on ePlan 24

25. Intent to Participate Form 25

26. Intent to Participate Form 26

27. Intent to Participate Form 27 *if box is checked, fill out number of LEP students.

28. Private School Surveys

29.  LEAs should submit the enrollment and participation data collected from private schools using the Private School Survey.  The Private School Survey is located on ePlan in the district LEA Document Library.  Surveys should be uploaded to ePlan in late January of each year. –Refer to the survey for actual deadline Reporting Intent to Participate Data 29

30. Locating the Survey on ePlan 30

31. Private School Survey 31 The Private School Survey

32.  Click on “Edit Documents” to the right of “Private Schools Participation Form (completed).” Upload the Completed Document 32 If “Edit Documents” does not appear, contact the ePlan Help-Line at (615) 253-5209.

33.  The name of the document will appear under “Documents/Links” section.  The trash can icon can be used to remove an unwanted upload to replace with a corrected upload. Once the Completed Document is Uploaded 33

34.  The name of the document and the upload history will appear on the main page of the LEA Document Library. Checking the Document Upload 34

35. Complaint Process

36.  Private school officials have recourse through the complaint process if they do not believe their eligible children, teachers, or families are receiving equitable services. Complaint Process 36

37.  A private school official has a right to complain to the state educational agency (SEA) if the LEA did not: –engage in a timely and meaningful consultation process –give due consideration to the views of the private school officials.  Any dispute regarding the accuracy of low-income data for private school students also can be the subject of a complaint.  The SEA must have complaint procedures in place which include a reasonable time by which the SEA must respond in writing to the complaint as required by § 34 CFR 299-12. Complaint Process Components 37

38.  Within 30 days of the SEA’s written response or failure to resolve the complaint, the private school official may appeal the decision of the SEA to the secretary of the U.S. Department of Education.  Appeals must include a copy of the SEA’s written response, if available, and a complete statement of the reasons supporting the appeal.  The secretary must complete an investigation of the complaint and resolve the appeal within 120 days after the receipt of the appeal. Complaint Process Components 38

39.  Consult with non-public schools to determine delivery of services  Complete the intent to participate  Complete the private school survey  Calculate funding for Title I services and set-asides It All Ties Together... 39

40.  Jan. 5 –LEA’s Send Intent to Participate to all Private schools in their area  Jan. 30 –Deadline for private schools to submit completed Intent to Participate forms  Jan. 30 – Feb. 15 –LEA’s populate Private School Surveys  Feb. 15 –LEA’s upload surveys into ePlan Reminders 40

41. Resources

42.  Title I Non-public Schools guidance –https://www2.ed.gov/programs/titleiparta/ps/titleitoolkit.pdfhttps://www2.ed.gov/programs/titleiparta/ps/titleitoolkit.pdf –http://www2.ed.gov/policy/elsec/guid/equitableserguidance.dochttp://www2.ed.gov/policy/elsec/guid/equitableserguidance.doc –http://www2.ed.gov/programs/titleiparta/psguidance.dochttp://www2.ed.gov/programs/titleiparta/psguidance.doc  Title II-A guidance –https://www2.ed.gov/programs/teacherqual/guidance.pdfhttps://www2.ed.gov/programs/teacherqual/guidance.pdf  Title III guidance –http://www2.ed.gov/about/offices/list/oii/nonpublic/title3- factsheet.htmlhttp://www2.ed.gov/about/offices/list/oii/nonpublic/title3- factsheet.html Resources 42

43. Questions 43

44. Jonathan Bolding McKinney-Vento & Non-public Programs Coordinator Jonathan.Bolding@tn.gov (615) 770-1793 (office) (615) 580- 2036 (cell) (615) 253-5705 (fax) 44 Contact Information

45. Districts and schools in Tennessee will exemplify excellence and equity such that all students are equipped with the knowledge and skills to successfully embark on their chosen path in life. Excellence | Optimism | Judgment | Courage | Teamwork

46. Citizens and agencies are encouraged to report fraud, waste, or abuse in State and Local government. NOTICE: This agency is a recipient of taxpayer funding. If you observe an agency director or employee engaging in any activity which you consider to be illegal, improper or wasteful, please call the state Comptroller’s toll-free Hotline: 1-800-232-5454 Notifications can also be submitted electronically at: http://www.comptroller.tn.gov/hotline FRAUD, WASTE, or ABUSE 46