1. 1 MARIA GARCIA-MORALES REGIONAL COORDINATOR DIVISION OF FEDERAL PROGRAM mgarcia-mo@state.pa.us Title I Schoolwide Programs

2. 2 Presentation Overview Brief Overview of Title I Program Requirements Program Components Fiscal Requirements Benefits of Schoolwide Programs Guiding Principles and Practices of Effective Schoolwide Programs New Roles/personnel changes Next Step...

3. 3 Title I. Part A

4. 4 Title I Largest federally funded education program. Largest federally funded education program. Purpose: To help low achieving students achieve high academic standards. Purpose: To help low achieving students achieve high academic standards. Supplemental Educational Assistance Supplemental Educational Assistance  Mainly in Reading & Math Two main models for servicing students: Two main models for servicing students:  Targeted Assistance Program  Schoolwide Programs 4

5. 5 Title I Uses of Funds Instructional Programs Instructional Programs  In Class  Pull Out  Extended Day  Extended Year  Pre-Kindergarten  Summer Programs  Online Learning  Take Home Resources  Tutoring Supporting Programs Supporting Programs  Professional Development  Parent Involvement  Materials/Supplies  Technology  School Choice  Supplemental Educational Services 5

6. 6 Two - Title I Program Models Schoolwide -vs- Targeted Assistance

7. 7 Any building with less than 40% low income Eligible students include :  Children identified as “failing”, or most at risk of failing  Students served in the previous two years under the Migrant Program  Any child who participated in Head Start, Even Start, The Early Reading First, within the previous two years.  Any child in a community day program or living in a neglected or delinquent institution  Any child who is homeless

8. 8 Targeted Assistance Program Selection for services is based entirely in low achieving, not low income Title I may be used to coordinate and supplement services Maintain documentation showing program expenditures to verify funds were used to meet statutory requirements for such programs & not to supplant non-federal resources

9. 9 Students Selected Based on LEA Criteria Pre K-2 Teacher Recommendation Developmentally Appropriate Assessment Parent Recommendation Grades 3-12 Students Performing Below Proficient on local assessments (formative) Students Performing Below Proficient on previous year’s PSSA Attendance/Suspension Retention Report Card Grades Other: Anecdotal Records, Teacher Recommendations

10. 10 Supplement not Supplant Targeted Assistance Program Requires that federal funds be used to augment the regular education program, not to substitute for funds or services that otherwise would be provided during the time period in question. It prohibits the use of federal funds to perform a service that would normally be paid for with state or local funds. Additional programmatic services must be provided to identified Title I students.

11. 11 Schoolwide Program

12. 12 What is a Schoolwide Program?  A Schoolwide Program (SWP) is a comprehensive reform strategy designed to upgrade the entire educational program in a Title I school; its primary goal is to ensure that all students, particularly those that are low achieving, demonstrate proficient and advanced levels of achievement on state academic standards.

13. 13 SCHOOLWIDE Identification of Students Schoolwide programs are not required to specifically identify eligible Title I students for targeted Title I services. All students are eligible to participate in all aspects of the schoolwide program. The statute requires the program to particularly address the needs of low achieving children and those at risk of not meeting the state student academic achievement standards.

14. 14 SWP has Three Core Elements: Comprehensive Needs Assessment Comprehensive Plan Annual Review of Effectiveness

15. 15 Program Requirements 40% poverty threshold (unless waived by PDE) One year of planning prior to implementation (unless waived by PDE) Annual evaluation of the program effectiveness 10 implementation components

16. 16 Ten Required Components of the Schoolwide Plan Component 1 - Needs Assessment (5 Step Process) 1) Establishing SW planning team Organizes and oversees the needs assessment Leads staff in developing the SWP Oversees and conducts annual evaluation 2) Clarifying the vision for reform Discusses how their reformed school will look

17. 17 Ten Required Components of the Schoolwide Plan (cont.) Component 1 - Needs Assessment (5 Step Process) (continued) 3) Creating the school profile Serves as the starting point Will provide a picture of data driven description of the school’s students, staff, community demographics, programs, and mission 4) Identifying data sources Quantitative Qualitative Dropout rate Graduation rate 5) Analyzing data The team analyzes the data and the gaps between the current operating state and the established vision.

18. 18 Ten Required Components of the Schoolwide Plan (cont.) Component 2 - Schoolwide reform strategies that:  Increase the amount & quality of learning time (extended year, before- and after-school)  Address needs of all, but particularly low-achieving Component 3 - Instruction by “highly qualified” teachers  HQ teachers in all core content areas  All instructional paraprofessionals meeting NCLB requirements

19. 19 Ten Required Components of the Schoolwide Plan (cont.) Component 4 - High Quality & Ongoing Professional Development  PD must be aligned to achieving the goals of the SW program.  PD must be extended to those who partner with teachers to support student achievement. Ten Required Components of the Schoolwide Plan (cont.)

20. 20 Component 5 - Strategies to attract high quality teachers  The SW plan must describe what strategies it will use to attract and retain HQ teachers.  A statement that your district/charter only hires HQ is not sufficient in a SW plan. Ten Required Components of the Schoolwide Plan (cont.)

21. 21 Ten Required Components of the Schoolwide Plan (cont.) Component 6 - Parental Involvement  SW Plans must contain strategies to involve parents, especially in helping their children do well in school.  Must have at least 1 parent in the planning team. Component 7 - Transition from pre-school SW programs are required to implement effective pre- school transitional programs in order to better prepare students for the kindergarten curriculum.

22. 22 Ten Required Components of the Schoolwide Plan (cont.) Component 8 - Include teachers in assessment decisions  Provide Professional Development to teachers about multiple assessments  Teachers should know, understand, and be able to use assessments on a regular basis to inform instruction. Component 9 - Timely, effective additional assistance  Plans must include regular assessments of all students and specific plans for what happens when a student is not achieving.

23. 23 Component 10 - Coordination and Integration Coordination and Integration of Federal, state and local funds, programs and services Ten Required Components of the Schoolwide Plan (cont.)

24. 24 Annual Review  Regulations require that SW schools conduct an annual review of the SWP  Annual Review should answer two main questions:  Was the program implemented as the planning team intended?  Was there improvement in student achievement, particularly for the lowest-achieving students?

25. 25 Documentation  A school operating a SWP must retain the following documentation for five years:  Documentation related to the three core components:  Comprehensive Needs Assessment  Comprehensive Plan  Annual Review

26. 26 Benefits of a Schoolwide Programs

27. 27 Benefits of Schoolwide Programs  Flexibility  Must meet “intent and purpose” of program  Not required to identify particular children: all children  Coordination and Integration  Not required to provide supplemental services: can use all resources of the school  Accountability  Unified Goals

28. 28 Guiding Principals and Practices of Effective Schoolwide Programs Numbers in parenthesis correlate with the Nine characteristics of High Performing Schools 1) Redesign of organizational Infrastructure 2) Use of meaningful planning process subject to continual review and monitoring of teaching and learning (6) 3) Reform goals that are based on clear focus and shared vision by stakeholders (1) 4) Reform strategies to accommodate a variety of approaches which reflect high standards and expectations (2) 5) Effective school leadership which nurtures an instructional program conductive to student and teacher growth (3)

29. 29 Guiding Principals and Practices of Effective Schoolwide Programs (cont.) 6) Collaboration and communication across grade level that accommodates all students populations and community needs (4) 7) Ongoing, focus professional development, based on the share vision and identified student needs (7) 8) Investment of resources to support the emerging system that is supportive of a stimulating learning environment, aligned curriculum, instruction and assessment with standards (5 & 8) 9) Sustainable high levels of communication with, and feedback from families and community members (9)

30. 30 Going from Targeted Assistance to Schoolwide Personnel Reorganization  The school will do the needs assessment to determine the goals…  The team should analyze how the Title I teachers can take a new role at the school to help you reach your schoolwide goals

31. 31 Ideas for new roles Parent Involvement Coordinator Before and after school program teacher Summer school teacher Regular classroom teacher (reducing class size for all subjects or specifically to reduce a specific subject’s class size) Math/Reading coaches Assessment and/or Curriculum coordinator Instructional facilitator Family literacy coordinator Technology teacher Any position that will result in the school’s progress towards achieving the schoolwide goals.

32. 32 Interested in Becoming a Schoolwide School? First Steps:  Send an intent form to your regional coordinator to lock the start date for planning (Found in DFP’s website)  Is your building less than 40% poverty level?  Submit a waiver request and have it approved by PDE before starting the planning process. (Found in DFP’s website)  Required Application as of 2010-2011  Getting Results or  SWP Template found in DFP’s website

33. 33 Title I funding will support the implementation of your Schoolwide Plan.

34. 34 U.S. DEPARTMENT OF EDUCATION www.ed.gov AN IDEA BOOK OF PLANNING: IMPLEMENTING SCHOOLWIDE PROGRAMS-VOLUME 1, AND PROFILES SUCCESSFUL PROGRAMS: IMPLEMENTING SCHOOLWIDE PROGRAMS VOLUME www.ed.gov/pubs/idea_planning www.ed.gov/pubs/idea_planning WHAT WORKS CLEARINGHOUSE http://ies.ed.gov/ncee/wwc/ Resources

35. 35 Note: If additional copies of packet or PowerPoint Presentation are needed, please phone or email Reba at 717-783-6903 or rkansiewic@state.pa.us

36. 36 Schoolwide: Legal Resources Statute: Section 1114 Regulations: 34 CFR 200.25-200.29 Federal Register Notice, July 2, 2004 www.ed.gov/legislation/FedRegister/other/2004- 3/070204a.html www.ed.gov/legislation/FedRegister/other/2004- 3/070204a.html

37. 37 Consolidation NEW: Non-Regulatory Guidance: “Title I Fiscal Issues,” February 2008 (replacing May 2006) www.ed.gov/programs/titleiparta/fiscalguid.doc  Consolidating funds in schoolwide programs, MOE, SNS, Comparability, Grantbacks, and Carryover

38. 38 Designing Schoolwide Programs Guidance: March 2006 www.ed.gov/policy/elsec/guid/designingswpgui d.doc

39. 39 What does it mean to consolidate funds? Treat funds like a “single pool of funds” Lose individual program identity School has one flexible pool of funds “Use to support any activity of the schoolwide program without regard to which program contributed the specific funds used for a particular activity”

40. 40 What does it mean to consolidate funds? (cont.) LEA does not literally need to combine funds in a single account or pool with its own accounting code “Pool” is used “conceptually” IMPT: Identify in SWP PLAN: “consolidated” programs and the amounts consolidated from each!

41. 41 What does it mean to consolidate funds? (cont.) EXAMPLE 1:literal consolidation (across district for all SWP schools) Consolidated schoolwide pool with its own accounting code The expenditures attributed to that code are charged on a proportional basis  If Title I contributed 8%, then 8% of SWP expenses charged to Title I

42. 42 What does it mean to consolidate funds? (cont.) EXAMPLE 2: (Single school model) No single accounting code for SWP For accounting purposes, LEA attributes expenditures back to specific program REGARDLESS of what services those funds support

43. 43 What does it mean to consolidate funds? (cont.) EXAMPLE 2, cont. “Expenditures are allowable without regard to whether they support the program that generated the funds so long as they are incurred to support the schoolwide program plan”

44. 44 What does it mean to consolidate funds? (cont.) EXAMPLE 2: Two options for distributing expenditures:  1. Proportion of revenues  2. Sequence charging  Charge 100% of all employee and non-employee SWP expenditures first to state and local sources and then to Title I and other federal until these funds are spent in their entirety or until the maximum carryover amount is all that remains unexpended  Problems with carryover

45. 45 Proportional Reporting: LEA Programs Contributing Funds to the Consolidated Schoolwide Pool Federal Funds School Building Title I - A Disadvantaged Title II-A Improving Teacher Quality Title IV-A Safe and Drug Free SchoolsIDEA- B State and Local Funds Total for Each Building A$182,535$25,000$10,685$94,462$2,048,115$2,360,797 B115,45525,00020,07127,7091,380,8841,569,119 C181,78025,00023,68669,2721,940,1612,239,899 D141,900110,43722,35193,2021,999,9022,367,792 E229,460110,43727,54661,7151,936,2912,365,449 F169,860110,43723,79654,1581,525,3071,883,558 Total Funds LEA Distributes to Individual Schools 1,020,990406,311128,135400,51810,830,66012,786,614 Percent of Total8%3%1%3%85%100% 45

46. 46 Sequential Reporting Source of FundsRevenues Total Expenditures ($950,000) Charged to Federal, State, and Local Programs Amount Remaining Total Included in Schoolwide Consolidated Pool$1,000,000 State and Local Sources520,000$520,000 Title I, Part A240,000 Title II, Part A -- Improving Teacher Quality40,000 IDEA Part B (Special Education) *50,000 Title V, Part A70,000 Carl D. Perkins Career and Technical Education Act 80,000 30,000 50,000

47. 47 What about state accounting requirements? States require LEAs to identify expenditures by functional categories like salaries, travel, supplies, etc. “However, an LEA would not be required to track how much it spends on salaries back to a specific program included in the consolidated SW pool”

48. 48 What programs CAN be consolidated? Federal, State, and Local BUT, the reality.... Only federal (if anything!)

49. 49 What federal programs can be consolidated? Federal Register, July 2, 2004 All formula (non-competitive)  Except Reading First  Includes IDEA, up to cap (but not exempt from programmatic requirements) Total LEA allocation divided by LEA IEP enrollment multiplied by IEP enrollment in SWP  Migrant; Indian Ed restrictions All discretionary (competitive)  Still must comply with application  Need not account separately for specific expenditures ED only (no School Lunch, Head Start)

50. 50 “Intents and Purposes” A school that consolidates federal funds is not required to meet most of the statutory and regulatory requirements of the specific federal programs  Not required to ID particular children or provide supplemental services Must meet “intents and purposes” of program

51. 51 Recordkeeping in SWP School operating SWP that consolidates is not required to maintain separate fiscal accounting records, by Federal program, that ID the specific activities supported by each program’s funds

52. 52 Can the LEA consolidate only federal in a SWP? Yes (E-4) Single Federal consolidated pool “From an accounting perspective, the funds from the contributing Federal programs lose their individual identity when they become part of a consolidated schoolwide pool and would be accounted for as part of that pool rather than by the individual programs that contribute to the consolidated schoolwide pool”

53. 53 On what activities can consolidated Federal funds be used? NEW!!!!! Activities to address the “educational needs” of the school  Identified by needs assessment  Articulated in SW Plan  E-5, etc.

54. 54 On what activities can consolidated Federal funds be used? NEW!!!!! OMB Circular A-87 applies “Cost Principles for State, Local and Tribal Governments” Applies to all federal funds – not education specific General: “necessary and reasonable” Specific: Allowability of salaries/wages (time and effort records), equipment, and alcohol

55. 55 If Title I is not consolidated with other federal, state, and local, then how must the LEA use Title I funds? E-7 On the “educational needs” of school  Identified in needs assessment  Articulated in SW Plan OMB Circular A-87 applies

56. 56 If Title I not consolidated (cont.) All kids may participate Need not be supplemental ** “Must account for and track the Title I funds separately, identifying the activities the Part A funds support”

57. 57 If Title I not consolidated (cont.) What is the impact on other federal programs (not Title I)? Still have to meet all the requirements of those programs – not just “intents and purposes”

58. 58 What if the LEA consolidates federal, state, and local?? “When Title I Part A funds are consolidated with State and local funds.... they lose their identity” E-8

59. 59 REMINDER: The Plan! The SWP Plan tells the auditor:  What programs have been consolidated  How much from each program

60. 60 Supplement not Supplant Statute 1114(a)(2)(B): Title I must supplement the amount of funds that would, in the absence of Title I, be made available from non-federal sources  E-18 The actual service need not be supplemental

61. 61 Supplement not Supplant Guidance: School must receive all the state and local funds it would otherwise need to operate in the absence of Federal funds  Includes routine operating expenses such as building maintenance and repairs, landscaping and custodial services

62. 62 Can Title I $ be used for basic operational expenses? If only federal combined –  No, must be for educational needs If federal and non-federal combined –  No, but impossible to determine which is federal  Be sure sufficient state and local funds allocated to school to meet basic operational needs

63. 63 What is “educational need”? Not addressed in guidance  Instruction – yes  Instructional support – probably yes  Administration – possibly yes  Operational – no

64. 64 Reporting Expenditures Proportional basis  Example: If 25% of combined funds are from Title I, then report 25% of expenditures as Title I expenditures Use for identifying:  Reporting expenditures back to State or USDE  Carryover of Title I Part A  Amount unused non-federal funding  MOE

65. 65 Fiscal Requirements in SWP Set-Asides  10% for School Improvement  Portion of 1% for parent involvement – follow all requirements  “An amount equal to”; Need not be Title I $ Carryover  15% cap still applies on LEA level, regardless of whether allocation from SWP or TAS

66. 66 Time and Effort Records OMB Circular A-87: Compensation for Personnel Services:  If federal funds used for salaries, then “time distribution records” are required  Must demonstrate= If employee paid with federal funds, then employee worked on that specific federal program/ cost objective

67. 67 If employee works... 100% on single cost objective... Semi-Annual Certification  Signed every six months by supervisor or employee “From January 1, 2010, until June 30, 2010, Don McCrone spent 100% of his time on Title I administration”

68. 68 If employee works... On multiple cost objectives Personnel Activity Reports (PAR)  Signed every month by employee “For the month of September 2005, I spent my time 50% on Title I program services and 50% on non-federal programs”

69. 69 If federal, state, and local funds consolidated... Employees paid with consolidated funds are not required to file T&E records “There is no distinction between staff paid with Federal funds and staff paid with State or local funds”

70. 70 If federal funds kept separate from state and local... Employee who works on single cost objective (i.e., a single Federal program whose funds have not been consolidated or Federal programs who funds have been consolidated but not with State and local funds) must furnish a semi-annual certification

71. 71 If federal funds kept separate from state and local... Employee who works on multiple cost objectives (i.e., in part on a Federal program whose funds have not been consolidated in a consolidated SW pool and in part on Federal programs supported with funds that have been consolidated in a pool or on activities funded from other revenue sources) must maintain monthly PARs

72. 72 “Blanket” Semi-Annual Certification Single cost objective (semi-annual cert) Multiple employees Signed by supervisor with first-hand knowledge (principal)

73. 73 Closing thoughts The SWP is VERY important! Targeted versus SWP which is better?