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TITLE I PROGRAM DIRECTORS TRAINING

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1 TITLE I PROGRAM DIRECTORS TRAINING
Welcome Thank you for coming today and most of all…(point to the screen)…thank you for your anticipated attention! We will discuss components related to Title I administration in the context of what you need to know. Some things may be familiar, but some things are also very new. Let’s begin with introductions… I am (state your name and office) and my colleagues are (state their names). Let’s begin. . . Developed by the Office of Title I

2 Workshop Goals and Objectives
To provide an overview of Title I requirements that must be implemented in schools and districts. To enable the program director to implement Title I policies at the school and district level. To provide technical assistance and support to the Title I program director(others) responsible for Title I program design and implementation. Workshop Goals and Objectives Good Morning. Introductions and Logistics. The purpose of today’s session is to provide you with technical assistance in implementing the Title I Program in your Title I district. The primary audience for the training is Title I directors and central office personnel involved in school improvement in the district. The module provides the following for Program Directors: A fundamental overview of Title I policies under the federal Elementary and Secondary Act (ESEA). A fundamental understanding of how Title I policies are implemented at the district and school levels Technical assistance and support in developing an effective local school program design and providing you with resources that are available to assist you in meeting your achievement goals.

3 Agenda Overview of Elementary and Secondary Education Act
Intents and Purpose of Title I Eligibility Comprehensive Needs Assessment Program Requirements Supplement vs. Supplant Serving Nonpublic School Students Professional Development Paraprofessionals Family and Community Enagagement ESEA Flexibility Agenda Today’s agenda is outlined in the following eleven sections. The sections are critical to the articulation of Title I policies and programs at the district and school level. The first segment relates to programmatic responsibilities associated with Title I policies and the second segment relates to the specific components associated with the legislation. An Overview of the Elementary and Secondary Act A Single Accountability System Determining Title I Eligibility for Public Schools and Private Schools Scientifically Based Research Programs Targeted Assistance and Schoolwide Programs Professional Development in Title I Schools Paraprofessionals Parental Involvement School Choice and Supplemental Educational Services Web Site Information

4 The Early Years – In the Classroom

5 Signing of the Elementary and Secondary Education Act (ESEA) of 1965

6 Title I, Part A: Intent and Purpose
Public Law Section : Improving the Academic Achievement of the Disadvantaged Improving Basic Programs Operated by Local Education Agencies (LEA) provides supplemental funding to state and LEAs for resources to help schools with high concentrations of students from low-income families provide a high quality education that will enable all children to meet the state’s student performance standards.

7 Title I - A Brief History
Elementary and Secondary Education Act Educational Consolidation and Improvement Act (Chapter 1) Reauthorized – focus on accountability Improving America’s Schools Act (Title I) No Child Left Behind New Rules – CFR 200 Secretary’s Blueprint for Reform 2011- ESEA Flexibility Waivers 2014- Renewal of ESEA Flexibility Waivers

8 Scope of Title I-Nationwide
School Year* Federal allocation of over $14 billion Title I represents the largest federal elementary and secondary education program Over 66,000 schools Over 23 million students served *US Department of Ed-Data Express (http://eddataexpress.ed.gov/index.cfm

9 Scope of Title I in New Jersey
School Year Allocation of $302,805,798 388, 681 students served (over 7,000 nonpublic) Supplemented instructional programs in English Language Arts, Mathematics, Science, Social Studies and CTE Provided support services: guidance, medical, dental, eye care (Title I Schoolwide and Homeless)

10 DETERMINING TITLE I ELIGIBILITY Determining Title I Eligibility
The next section that will be addressed refers to Title I Eligibility for public and private schools.

11 Eligibility Eligible School Attendance Area (§1113)
The proportion of economically disadvantaged students in a school determines the amount of funds that may go to a school. Any student enrolled in an eligible school may receive Title I services if they are low achieving. All Title I funds must be distributed and accounted for. Low-income nonpublic school students in served school attendance areas must receive an equitable share. Eligible School Attendance Areas − Definition The term “school attendance area” means, in relation to a particular school, the geographical area in which the children who are normally served by that school reside. The term “eligible school attendance area” means a school attendance area in which the percentage of children from low-income families is at least as high as the percentage of children from low-income families served by the LEA as a whole.

12 Poverty Criteria or Measures
Eligibility Select poverty criteria: Free/reduced lunch, TANF, Medicaid, Composite, Feeder Method Rank Schools: Based on the percentage (not number) of children from low-income families. Serve Schools 75% rule Poverty rate at/above district poverty rate Grade-span grouping Poverty rate below 35% Per pupil expenditure calculated at 125% or 1.25 times the district per pupil amount Poverty rate ≥ 35% Poverty Criteria or Measures The district is required to use the same measure of poverty to determine the eligibility of educationally and economically disadvantaged students. The following measures individually or in composite are used to determine Title I eligibility with respect to all school attendance areas in the district: 1. The number of children ages 5 through 17 in poverty counted in the most recent census data approved by the USDOE. 2. The number of children eligible for free and reduced-price lunches under the Richard B. Russell National School Lunch Act. 3. The number of children in families receiving assistance under the state program funded under Title IV, Part A of the Social Security Act. 4. The number of children eligible to receive medical assistance under the Medicaid program. Exception: This does not apply to an LEA with a total enrollment of less than 1,000 children. Definition: TANF – Temporary Aid to Needy Families

13 COMPREHENSIVE NEEDS ASSESSMENT
Definition: A comprehensive needs assessment is required for planning Title I programs; a needs assessment must be completed for the district and each school identified as in need of improvement. Essentially, the needs assessment enables the school to identify its strengths and weaknesses for specific population categories, including student subgroups and other stakeholders. Using the needs assessment, the school/district can assess how well the school is closing the achievement gap, identify priority problems, and select program activities that address the priority problems to help improve student academic achievement. Conducting a comprehensive needs assessment helps school planners focus on schoolwide issues and link goals with data. An excellent resource to follow is the U.S. Department of Education’s, Implementing Schoolwide Programs: An Idea Book on Planning.

14 Comprehensive Needs Assessment
Includes the input of all stakeholder groups Teachers, administrators, families, community members, students (if appropriate) and technical assistance providers Ongoing process that is summarized in the district’s Consolidated Application Foundation for the use of Title I funds Expenditures not supported by comprehensive needs assessment are not “necessary and reasonable.”

15 Data-Driven Decision Making
Purpose: Enable schools to identify their strengths and weaknesses, so they can specify priority problems and plan activities to help improve student achievement and meet state academic standards. The following can be used: State assessments District commercial tests and other data Teacher tests and observations Surveys and stakeholder input Comprehensive Needs Assessment Definition: A comprehensive needs assessment is required for planning Title I programs; a needs assessment must be completed for the district and each school identified as in need of improvement. Essentially, the needs assessment enables the school to identify its strengths and weaknesses for specific population categories, including student subgroups and other stakeholders. Using the needs assessment, the school/district can assess how well the school is closing the achievement gap, identify priority problems, and select program activities that address the priority problems to help improve student academic achievement. Conducting a comprehensive needs assessment helps school planners focus on schoolwide issues and link goals with data. An excellent resource to follow is the U.S. Department of Education’s, Implementing Schoolwide Programs: An Idea Book on Planning. Sources: Section 1116 Implementing Schoolwide Programs: An Ideal Book on Planning; U.S. Department of Education; p. 42

16 Priority Problems The problems selected by the district require an adequate description that identifies the following: The target population The causes of the problem The identification of the data source The analysis of the data, areas to be measured The measurement tool The specific school targets Comprehensive Needs Assessment The purpose of the comprehensive needs assessment is to show the strengths and weaknesses through the use of data. The LEA is required to identify the problems and the target population associated with a problem area. In addition, the LEA must provide the causes of the problems, the identification of the data source, the analysis of the data, the measurement tools used, and the specific school targets. Sources: Titles I-A, I-D, II-A, II-D, III-A, IV-A, V-A, VI-B NCLB sections 1112, 1116, 2122, 2414, 3115, 4114, 5133, and 6223

17 TITLE I PROGRAM DESIGN Targeted Assistance and Schoolwide Programs
The following slides will discuss the schoolwide programs and targeted assistance schools and their implementation according to the federal guidelines proposed in section 1114 (schoolwide programs) and section 1115 (targeted assistance schools). It will also provide guidance in assessing the needs of the school to identify which program option works best within a particular school.

18 Targeted Assistance and Schoolwide Programs
Title I supports schools in implementing either a school-wide program or a targeted assistance program. These programs must use effective methods and instructional strategies that are grounded in scientifically based research. Schoolwide Poverty Threshold 40% Targeted Assistance Assessing the Needs of the District/School: Targeted Assistance vs. Schoolwide Programs A schoolwide program permits a school to use funds from Title I, Part A and other federal education program funds and resources to upgrade the entire educational program of the school in order to raise academic achievement for all the students. This contrasts with a Title I targeted assistance program through which Title I, Part A funds are used only for supplementary educational services for eligible children who are failing or at risk of failing to meet state standards. The new poverty threshold is forty percent. The LEA determines if a school’s poverty level makes it eligible to become a schoolwide program. In addition, the school, in consultation with its district, decides that it wants to become a schoolwide program, and if high-quality assistance and support is available to the school. This can be demonstrated in one of two ways: 1. The state has provided written information to the LEA that demonstrates the SEA has established a statewide system of support and improvement. 2. The school demonstrates to its LEA that it will receive high-quality technical assistance and support from other assistance providers. Sources: Schoolwide Policy (section 1114): Targeted Assistance Policy (section 1115): School wide Programs (federal guidance): Targeted Assistance Schools (federal guidance):

19 Targeted Assistance Programs (TAS)
Title I funds are used only for services for eligible children who are failing or at risk of failing to meet state standards. Eight required program components Must identify student eligibility for services.

20 Targeted Assistance Programs (TAS)
Establish entrance and exit criteria based on multiple, objective, and uniform criteria such as: Assessment results, teacher recommendations, and parent recommendations Children who have the greatest academic need receive Title I services Districts may need to prioritize the student selection to provide a meaningful program Title I Targeted Assistance Schools – Section 1115 A targeted assistance school generally identifies eligible children within the school on the basis of multiple, educationally related, objective criteria established by the LEA and supplemented by the school. Children from preschool through grade two must be selected solely on the basis of such criteria as teacher judgment, interviews with parents, and developmentally appropriate measures that determine which children are failing, or most at risk of failing, to meet the State's challenging content and student performance standards. From the universe of eligible children in a targeted assistance school, the school selects those children who have the greatest need for special assistance to receive Part A services. Because it is likely that a school will not have sufficient Part A resources to provide services to all eligible children, the school must make some informed choices concerning which children to serve. These choices are difficult because they inevitably result in some children being selected before other children who may also have significant needs. School staff, in consultation with the LEA and based on a review of all the information available about the performance of eligible children, must use their best professional judgment in making these choices. It is not so simple as merely selecting a cut-off score on an assessment measure. School staff will necessarily need to balance the needs of different populations. For example, most schools will likely need to concentrate Part A resources in certain grades or in certain subjects to the exclusion of children in the grades or subjects not being served. Similarly, a school may decide that some children who are homeless have greater needs because, for instance, homeless children may likely face problems of attendance and homework completion due to recurrent moves and, therefore, may be at greater risk of failure than some other children who are not faced with the disruption associated with homelessness. Furthermore, schools and LEAs that focus strongly on family literacy, for example, may add the additional educationally-related criterion of the educational level of parents when selecting those children who are most in need of Part A assistance from the eligible pool of students to be served. Sources: Targeted Assistance Policy (section 1115): Targeted Assistance Schools (federal guidance):

21 Targeted Assistance Programs (TAS)
Eight Essential Components (§1115) Assist students in reaching state standards Are based on effective means for improving student achievement Ensure appropriate planning Use instructional strategies effectively by minimizing pull-out and offering in-class support or extended day and summer programs Coordinate with and support regular education programs such as pupil services (counseling, mentoring) and transition programs Offer instruction by highly qualified staff Provide professional development Use strategies to increase parental involvement Targeted Assistance Schools Title I, Part A provides a clear goal―to enable participating children to achieve challenging state content and performance standards. To meet this goal, section 1115(c) requires that each targeted assistance program include eight components that research suggests are essential to any high-functioning program, including: Use Title I, Part A resources to help participating children meet the state’s student performance standards expected for all children. 2. Be based on effective means for improving achievement of children. 3. Ensure that planning for participating students is incorporated into existing school planning. 4. Use effective instructional strategies that give primary consideration to providing extended learning time such as an extended school year, before- and after-school, and summer programs and opportunities. Help provide an accelerated, high-quality curriculum. Minimize removing children from the regular classroom during regular school hours for Title I, Part A instruction. 5. Coordinate with and support the regular education program, which may include counseling, mentoring, and other pupil services; integrating college and career awareness and preparation; services to prepare students for the transition from school to work; and services to assist preschool children’s transition to elementary school. 6. Provide instruction by highly qualified staff. 7. Provide professional development opportunities with Title I, Part A resources, and other resources, to the extent feasible, for administrators, teachers, and other school staff who work with participating children. 8. Provide strategies to increase parental involvement, such as family literacy services. Sources: Targeted Assistance Policy (section 1115): Targeted Assistance Schools (federal guidance):

22 Targeted Assistance Programs (TAS)
Instructional and Programmatic Strategies In- class support Extended year programs Summer programs Transition programs Coaches Test prep classes Specified professional development

23 Schoolwide Programs 34 CFR 200.25
“[t]he purpose of a schoolwide program is to improve academic achievement throughout a school so that all students, particularly the lowest-achieving students, demonstrate proficiency related to the State's academic standards . . .” Schoolwide Programs – Section 1114 An LEA may consolidate and use Title I, Part A funds blended with other federal, state, and local funds in order to upgrade the entire educational program of a school that serves an eligible school attendance area in which not less than 40 percent of the children are from low-income families, or not less than 40 percent of the children enrolled in the school are from such families. In regards to the identification of students, when a school opts to implement a schoolwide program, identification of students is not required. NCLB section 1114 further explains the identification of children within a schoolwide program and states that, “No school participating in a schoolwide program shall be required to do the following: 1. To identify particular children under this part as eligible to participate in a schoolwide program. 2. To provide services to such children that are supplementary, as otherwise required by section A(b).” Sources: Schoolwide Policy (section 1114): Schoolwide Programs (federal guidance):

24 Schoolwide Programs (SW)
Criteria (§1114) Title I funds are used to upgrade the educational program of the entire school to meet the state’s academic standards. 40 percent or more of the students enrolled in the school, or residing in the school attendance areas, must be from low-income families. A comprehensive needs assessment must be conducted. The district must meet with stakeholder group when developing the schoolwide plan Schoolwide Programs – Section 1114 An LEA may consolidate and use Title I, Part A funds blended with other federal, state, and local funds in order to upgrade the entire educational program of a school that serves an eligible school attendance area in which not less than 40 percent of the children are from low-income families, or not less than 40 percent of the children enrolled in the school are from such families. In regards to the identification of students, when a school opts to implement a schoolwide program, identification of students is not required. NCLB section 1114 further explains the identification of children within a schoolwide program and states that, “No school participating in a schoolwide program shall be required to do the following: 1. To identify particular children under this part as eligible to participate in a schoolwide program. 2. To provide services to such children that are supplementary, as otherwise required by section A(b).” Sources: Schoolwide Policy (section 1114): Schoolwide Programs (federal guidance):

25 Ten (10) Components of a Schoolwide Program
COMPREHENSIVE NEEDS ASSESSMENT INCREASE PARENTAL INVOLVEMENT SCHOOLWIDE REFORM STRATEGIES TRANSITION OF PRESCHOOL CHILDREN HIGHLY QUALIFIED TEACHERS TEACHER DECISIONS REGARDING ASSESSMENT PROFESSIONAL DEVELOPMENT ASSISTANCE TO AT-RISK STUDENTS RECRUITMENT AND RETENTION OF COORDINATION & INTEGRATION OF SERVICES & PROGRAMS

26 Title I Schoolwide Plan
Reflects 10 components of a schoolwide programs Annual requirement Submitted with district’s Consolidated Application

27 Title I Schoolwide Plan
The schoolwide plan must include the following three elements: A description of how the school will implement the mandatory schoolwide program components described below; A description of how the school will use resources from Title I and other resources to implement those components; and A list of federal, state, and local programs that will be consolidated in the schoolwide program.

28 Stakeholder Engagement ESEA §1114(b)(2)(B)(ii)
The schoolwide plan should be developed with the involvement of parents and other members; Provide all students in the school the opportunity to meet the state’s proficient and advanced levels of student academic achievement; Use effective methods and instructional strategies that are grounded in scientifically based research; and Strengthen the core academic program in the school.

29 A school operating a schoolwide program must—
Evaluation 34 CFR § (c) A school operating a schoolwide program must— Annually evaluate the implementation of, and results achieved by, the schoolwide program, using data from the State's annual assessments and other indicators of academic achievement; Determine whether the schoolwide program has been effective in increasing the achievement of students in meeting the State's academic standards, particularly for those students who had been furthest from achieving the standards; and Revise the plan, as necessary, based on the results of the evaluation, to ensure continuous improvement of students in the schoolwide program.

30 Needs Assessment ESEA §1114(b)(1)(A)
Schools must perform a comprehensive needs assessment of the entire school. The assessment must be based upon information that includes the achievement of children in relation to the State academic content standards and the State student academic achievement standards.

31 Reform Strategies ESEA§1114(b)(I)(B)
Provide all students in the school the opportunity to meet the state’s proficient and advanced levels of student academic achievement Use effective methods and instructional strategies that are grounded in scientifically based research Strengthen the core academic program in the school

32 Reform Strategies ESEA§1114(b)(I)(B)
Increase the amount and quality of learning time (i.e., extended school year , before and after school programs, and summer programs) Provide an enriched and accelerated curriculum Meet the educational needs of historically underserved populations Include strategies to address the needs of ALL children in the school (particularly, the needs of low-achieving students)

33 Family and Community Engagement ESEA§1114(b)(1)(F)
Schoolwide plans must contain strategies to involve families and the community in assisting children to do well in school Families and communities must be involved in the planning, implementation, and evaluation of the schoolwide program

34 SUPPLEMENT NOT SUPPLANT

35 Supplement Not Supplant
Schoolwide Programs Schoolwide Programs: Programs and services do not have to be supplemental; Title I funds used to support the program must be supplemental. District cannot reduce schools’ state/local funding based on an increased Title I allocation. The amount of state/local funding to schools must be sufficient to support the school’s basic educational program. Documentation that schools have enough state/local funds to fully operate without federal funds. District must be able isolate the state/local funds needed for schools in current year and prior years.

36 Supplement Not Supplant
Targeted Assistant Programs and District-Level Expenditures Presumption of supplanting The district has used the Title I funds to provide services that the district was required to make available under federal, state or local law. The district used Title I funds to provide services it provided with non-federal funds in the prior year(s). The district has used Title I funds to provide services for participating children that it provided with non-federal funds for non-participating children.

37 Supplement Not Supplant
Targeted Assistance Program Scenarios District has 3 elementary schools. School A and B are Title I-funded schools with a Targeted Assistance Program. School C is not a Title I school. The district wants to pay the salaries of its basic skills teachers in School A and B with Title I funds and will pay the salaries of its basic skills teachers in School C with local funds. Is this allowable? NO! This is supplanting.

38 Supplement Not Supplant
Targeted Assistance Program Scenarios A district with a Targeted Assistance Program has an afterschool program for its Title I students. With Title I funds, it wants to pay the salary of the Title I teacher, instructional materials for the students in this afterschool program, and iPads for the students to use as part of the program. Are all of these things allowable? YES! All of these costs are supplemental and used for Title I teachers/students only.

39 Supplement Not Supplant
Targeted Assistance Program Scenarios The school would like to send all of its Math teachers to a Math Recovery professional development program that provides a powerful mathematics intervention framework that gives teachers the unique techniques and assessment tools they need to help elementary children achieve lifetime results. Is this allowable? NO! In a Targeted Assistance program, Title I funds for professional development may benefit Title I staff only.

40 Supplement Not Supplant
Targeted Assistance Program Scenarios The school wants to contract with reading expert to provide onsite professional development on techniques and assessment tools to help low-achieving students achieve lifetime results. The school would like every teacher to participate in the professional development. Is this allowable? YES! The district may pay for a consultant/expert to come to school district to provide professional development that primarily benefits Title I staff. The other teachers may attend as "incidental benefit."

41 Supplement Not Supplant
Targeted Assistance Program Scenarios A Title I school with a Targeted Assistance Program would like to put in three SmartBoards in English language arts classes where the majority of students (about 70%) are Title I. Is this allowed? NO! Title I instructional equipment may benefit Title I students only.

42 Supplement Not Supplant
Targeted Assistance Program Scenarios A Title I school with a Targeted Assistance Program would like to use Title I funds to hire a data analyst, a Math Coach and a Literacy Coach. Is this allowed? Possibly, but not advisable! The services of these staff would have to be limited to Title I students only. This is a high bar to meet in a targeted assistance program, so it is advisable for the district to use it state/local funds for these positions.

43 SERVING ELIGIBLE NONPUBLIC STUDENTS

44 Equitable Service Provision ESEA §1120
Requires districts receiving Title I, Part A funds to provide services to: Eligible nonpublic students Teachers of eligible nonpublic school students Families of eligible nonpublic school students

45 Equitable Services Why?
Census poverty data includes low-income families with nonpublic school children Census poverty data used to determine districts’ Title I allocations Child Benefit Theory: Funds benefit child ONLY

46 Child Benefit Theory 34 CFR § 200.66
Title I services benefits the “individual” child, NOT the entire school. Services are provided by the district, not the nonpublic school Child Benefit Theory complies with the Constitutional Prohibition against Federal funding- No funds are to EVER go to the nonpublic school!

47 Equitable Service Provision ESEA §1120
Step 1: Locating Nonpublic Students Step 2: Counting Nonpublic Students Enrollment data, Income data Step 3: Generating Nonpublic Allocation

48 Equitable Service Provision ESEA §1120
Step 1: Locating Resident Nonpublic Students Resident nonpublic schools Bordering nonpublic schools Transportation Documents (Busing routes, Aid-in-Lieu)

49 Equitable Service Provision ESEA §1120
Step 2: Counting Resident Nonpublic Students Enrollment data: match resident nonpublic students to their public school attendance area Low-income data: Contact schools enrolling resident nonpublic students Various methods: survey, extrapolation, proportionality, equated m

50 Equitable Service Provision ESEA §1120
Step 3: Generating Nonpublic Allocations Who: Nonpublic students who 1) live in the attendance area of a Title I public school and 2) come from low-income families How: District enters enrollment and low-income numbers into its annual Title I, Part A application How much: The same per-pupil amount as public schools students residing in the Title I attendance area

51 Participation of Students Enrolled in Private Schools (ESEA § 1120 )
An eligible private school student resides in the participating attendance area of the school district and is selected on the same basis as targeted assistance students. The district in consultation with non-public school official(s) MUST establish clearly defined entrance and exit criteria to meet the needs of eligible nonpublic school children using multiple, educationally related, objective criteria (i.e. Achievement tests, teacher referral/recommendations based upon objective, and educationally related criteria; and grades)

52 Allocating Funds District reserves off the top –
If a district reserves funds for instructional related activities for public school students at the district level, the district must also provide from these funds equitable services to eligible nonpublic school children. Amount of funds must be proportional to the number of nonpublic school children from low-income families residing in public school attendance areas.

53 Allocating Funds Not eligible for equitable services
N&D/ Homeless Eligible for equitable services Parental Involvement Professional Development Districtwide Instructional Programs 1% of 500,000 Title I monies – private school is eligible for equitable services 5% of allocation for professional development – “ “ $ must be proportional to the # of private school children from low-income families residing in participating public school attendance areas.

54 Consultation Consultation between the public school and private schools, during the design and development of the programs: Must be timely and meaningful. Must take place on an annual basis, and be documented by the district: sign in sheets, agenda, written affirmation. Must continue throughout the year, to ensure the needs of private school students are being met. Shall occur before the school district makes any decision that affects the opportunities of eligible private school children, teachers, and other educational personnel to participate.

55 Delivery of Services Under control and supervision of the public school. The public school maintains control of all materials, supplies, equipment, and property acquired with Title I funds for the benefit of eligible private school students. Services for private school children must begin at the same time as services for public school children.

56 Delivery of Services Key word is services. No public funds are distributed to private schools, only services and materials..

57 Delivery of Services Examples
Instructional services outside the regular classroom. Extended learning time (before/after school and in the summer). Family literacy programs. Counseling programs. Early childhood. Home tutoring. Computer-assisted instruction.

58 Delivery of Services Materials and supplies purchased with Title I funds may ONLY be used by the “identified” Title I students in the Title I program. Must be supplemental and may not replace or supplant services that would, in the absence of Title I, be provided by nonpublic school to participating nonpublic school children. Services must be provided in a separate space that is under the LEAs control If services are being provided in a library or private school classroom, the space must be separated and partitioned off Computer equipment and other supplies purchased with Title I monies may be used only by Title I students in the Title I program

59 Evaluation The district in conjunction with nonpublic officials MUST define ‘annual progress’ for nonpublic school Title I participants. If annual progress is not met, the district in conjunction with nonpublic officials must modify the Title I program.

60 PROFESSIONAL DEVELOPMENT
Professional Development in Title I Schools The next series of slides will focus on professional development in Title I schools.

61 Professional Development
Must be sustained, high-quality, classroom-focused training in core content areas and strategies that work Use of Title I funds for PD will vary depending upon Title I program Title I teachers, principals, paraprofessionals, and other staff may participate.

62 Allowable Uses Strategies tied to the state’s academic standards, state student performance standards and consistent with the district’s needs assessment Activities involving parents in the education of their children Activities addressing the needs of teachers in Title I schools and students most “academically” at-risk Activities incorporating teaching strategies in the CCSS/CCCS areas for meeting the needs of “academically” at-risk students Professional Development Plans Professional development plans for both targeted assistance schools and schoolwide programs must provide highly qualified instructional staff to address the needs of disadvantaged children and youth. Professional development plans must be developed that improve the teaching of the academic subjects and be consistent with state content standards, in order to enable all children to meet the state’s student performance standards. The plans must also include activities that address parents, and address the specific needs of the teacher. The plans should also coordinate with the existing professional development programs in the district.

63 PARAPROFESSIONALS The next series of slides will provide information related to paraprofessionals according to the NCLB Act of 2001.

64 Requirements Instructional paraprofessionals in targeted assistance and schoolwide programs MUST meet one of the following criteria: Have an Associate’s Degree or higher Completed two years of college coursework Passed a rigorous test showing the ability to assist with the teaching of reading, writing, and mathematics Title I Paraprofessionals Requirements NCLB introduced several requirements for paraprofessionals. By January 8, 2002, all newly hired paraprofessionals must meet stringent requirements. The paraprofessionals are required to meet at least one of the following options: Possess an Associate’s Degree with approximately 60 credits in a single discipline (e.g., Language Arts Literacy or a discipline in a non-educational field such as business) 2. Two years of college, or 48 credits (not including remedial/development courses) 3. An assessment/test (e.g., ETS Parapro Assessment) Previously hired paraprofessionals had until January 8, 2006, to meet these requirements. Sources: Section 1119 107 Congress

65 Duties Provide one-on-one tutoring when a student is not being instructed by a teacher. Assist with classroom management. Provide instructional assistance in a computer lab. Conduct parental involvement activities. Provide support in a library/media center. Act as a translator. Provide instructional support under the direct supervision of a teacher. Paraprofessionals who perform any of these duties on a full-time basis are exempt: Conduct parental involvement activities Act as a translator Provide personal care services Assist in a library/clerical role

66 FAMILY AND COMMUNITY ENGAGEMENT
Parental Involvement The next section includes policy regulations concerning how parental involvement activities should be conducted, taken from NCLB sections 1111, 1112, 1116, and The sections may be briefly described as follows: The Purpose of State Plans Section 1111 “State Plans” describes how states are required to develop a plan that will support LEAs and schools with effective parental involvement practices, annual school report cards, Parents Right-to-Know, parental notification, and language education programs. The Process of Notification Section 1116 “Notification” describes how the LEA is required to promptly notify parents of each student enrolled in an elementary or secondary school identified for school improvement or restructuring, in an understandable and uniform format and in a language that parents can understand, of the school’s status. The LEA and School Roles to Parents They Serve Section 1118 describes how the LEA and school are required to establish a written parent involvement policy, school-parent compacts, and build capacity for parental involvement.

67 Why Family and Community Engagement?
It is required by law. It helps raise student achievement.

68 Family and Community Engagement
Parent involvement is one form of family and community engagement The Title I statute defines the term “parental involvement” as the participation of parents in regular, two-way, and meaningful communication involving student academic learning and other school activities.

69 Family and Community Engagement
Applies to all Title I districts & schools. Comprehensive and based upon families’ needs. Benefit the greatest number Title I families who have children being served in Title I programs. One-percent reserve of Title I allocations over $500,000. Parental Involvement Funds If an LEA receives over $500,000 in Title I funds, it is required to allocate 1 percent of Title I funds for parental involvement activities. Districts are required to allocate not less than 1 percent of their Title I allocation for parent involvement programs, including promoting family literacy and parenting skills (section 1118). Exception: If the school’s allocation is $500,000 or less, this reservation does not apply. However, the requirements to involve parents still apply. Districts must allocate 95% of the parent involvement funds to school level activities. Sources: Section 1118

70 Family and Community Engagement
District Set-Asides Districts receiving $500,000 or more in Title I, Part A funds must set aside, at minimum, 1% for family & community engagement purposes, including promotion of family literacy and developing parenting skills. 95% of the district set-sides must be allocated to Title I buildings for building-level family and community engagement activities. Districts < $500,000 must also provide family and community engagement opportunities at the district and building levels.

71 Parents’ Right-to-Know (§1111)
At the beginning of the school year Title I district must notify parents of their right to request the following information regarding their child’s teachers: Whether the teacher has met state qualifications and licensing criteria. Whether the teacher is under emergency or provisional status. Whether the teacher has a baccalaureate degree, certification in the discipline field and other pertinent education. Whether the child is provided services by paraprofessionals, and, if so, their qualifications. Schools must notify parent when their child has been taught for four consecutive weeks by a teacher not highly qualified. Parents Right-to-Know – Section 1111 District and School Level Responsibility According to section 1111, Parents Right-to-Know, it is the responsibility of districts and schools to notify parents of each student that certain information may be requested and provided by the district (LEA) in a timely manner. The Parents Right-to-Know section requires the local school to provide each individual parent with information related to the qualifications and skills of teachers. The information should be presented in a manner that is practical and understandable for parents. It should also include the following: Information on the level of achievement of the parent’s child in each of the state academic assessments. Timely notification that the parent’s child has been assigned, or has been taught for 4 or more consecutive weeks by, a teacher who is not highly qualified. Sources: No Child Left Behind Act of 2001 107 Congress 1st Session – Title I

72 Language Instruction Education Program (§1111)
Not later than 30 days after the beginning of the school year, the district is required to inform the parent (s) of a limited English proficient child identified for participation in a language instruction educational program of the following: The reasons for the identification of their child as limited English proficient and in need of placement in a language instruction educational program. The child’s level of English proficiency, how such level was assessed, and the status of the child’s academic achievement. Language Instruction Program − Section 1111 School-Level Responsibilities The LEA is also required to implement an effective means of outreach to parents of limited English proficient students to inform the parents how they can be involved in assisting their children in attaining English proficiency, achieve at high levels in the core academic subjects, and meet challenging state academic achievement standards. Parents of children in a language instruction educational program must receive information about the following: The methods of instruction used in the program and the methods of instruction used in other available programs, including how such programs differ in content, instructional goals, and the use of English and a native language in instruction. How the program will meet the educational strengths and needs of their child. How the program will specifically help their child learn English and meet age-appropriate academic achievement standards for grade promotion and graduation. The specific exit requirements for the program, including the expected rate of transition form such program into classrooms that are not tailored for limited English proficient children, and the expected rate of graduation from secondary school for such program if funds under this part of NCLB are used for children in secondary schools. In the case of a child with a disability, how such program meets the objectives of the individualized education program of the child. Information pertaining to parental rights that includes written guidance detailing the right of parents to have their child immediately removed from such a program upon their request; and assisting parents in selecting among various programs and methods of instruction, if more than one program or method is offered by the eligible entity. Sources: No Child Left Behind Act of 2001 107th Congress

73 The Written Parental Involvement Policy (§1118)
Describes how the district will: Involve parents in developing the district’s plan for school review and improvement Provide coordination, assistance and support to assist in planning and implementing effective parental involvement activities to improve student performance Build schools’ and parents’ capacity for strong parental involvement Coordinate and integrate parental involvement strategies with other programs (e.g., Head Start, Reading First etc.) Conduct an annual evaluation of the content and effectiveness of the parental involvement policy Involve parents in the activities of schools served under Title I The Written Parent Involvement Policy – Section 1118 Local District Parent Involvement Policy Incorporated into the district’s plan developed under NCLB section 1112 Establish district’s expectations for parent involvement, and describe how the LEA will do the following: Involve parents in the joint development of the plan, and the process of school review and improvement. Provide coordination, technical assistance, and other supports to assist participating schools in planning and implementing effective parent involvement activities to improve student academic achievement and school performance. Build the schools’ and parents’ capacity for strong parental involvement. Coordinate and integrate parental involvement strategies under Title I, Part A with parental involvement strategies under other programs (e.g., Head Start, Reading First, Early Reading First, Even Start). Conduct, with parents, an annual evaluation of the content and effectiveness of the parental involvement policy in improving the academic quality of the schools served under Title I, Part A, including identifying barriers to greater participation by parents in activities authorized by this section (with particular attention to parents who are economically disadvantaged, are disabled, have limited English proficiency, have limited literacy, or are of any racial or ethnic minority background), and use the findings of such evaluation to design strategies for more effective parental involvement, and to revise, if necessary, the parental involvement policies described in this section. Involve parents in the activities of the schools served under this part. Written School Parent Involvement Policy Developed with, and distributed to parents of participating children; agreed on by parents Describes how the district will implement the requirements of this parental involvement section. Parents must be notified of the policy in an understandable and uniform format and, to the extent practicable, provided in a language the parents can understand. Policy must be made available to the community and updated periodically to meet the changing needs of parents and the school

74 The Written Parental Involvement Policy (§1118)
School Policy Requirements Each school must develop, jointly with parents of children participating in Title I services, a written school parental involvement policy that describes how the school will carry out the parental involvement requirements in §1118(c)-(f), including the development of a parent compact

75 The School-Parent Compact: Shared Responsibility for High Student Achievement (§1118 )
Each school must develop a school-parent compact jointly with parents, student and teachers of students receiving Title I services that outlines: How parents, the entire school staff, and students will share the responsibility for improved student academic achievement. How the school and parents will build and develop a partnership to help children achieve the state’s high standards. The School-Parent Compact − Section 1118 Shared Responsibility for High Student Achievement Outlines how parents, the entire school staff, and students will share the responsibility for improved student academic achievement and the means by which the school and parents will build and develop a partnership to help children achieve the state’s high standards. Describes the school’s responsibility to provide high-quality curriculum and instruction in a supportive and effective learning environment and address the importance of communication between teachers and parents on an on-going basis through, at a minimum, the following: Parent-teacher conferences in elementary schools, at least annually. Frequent reports to parents on their children’s progress. Reasonable access to staff, opportunities to volunteer and participate in their child’s class, and observation of classroom activities.

76 Annual Parent Meeting §1118(c)(1)(2)
All Title I funded schools invite parents to attend a meeting to inform parents of Title I program Meeting must be documented (invitational flyer/letter, agenda, sign-in-sheets, and minutes)

77 Title I Parental Involvement Notification Requirements for Districts
* Includes sample templates

78 ESEA FLEXIBILITY

79 10 Areas Subject to Waiver
District improvement requirements School improvement requirements 100% Proficiency by Rural districts Schoolwide Programs Rewards schools Supports for schools in need of improvement Highly-qualified teacher plans Transferability Use of School Improvement Grant (SIG) funds

80 Waiver Implementation 2012-2014
Schools no longer identified as schools in need of improvement. Identify priority schools (lowest 5% of Title I participating and/or eligible schools) Identify focus schools (10% of Title I schools that contribute to the achievement gap)

81 Waiver Implementation 2012-2014
Progress Targets: The NJDOE will calculate Progress Targets for schools and districts based on the goal of closing the achievement gap by half within six years. The Progress Targets are set in annual equal increments toward a goal of reducing by half the percentage of students in the “all students” group and in each subgroup who are not proficient within six years.

82 Progress Targets The ‘all students’ group has a proficiency rate of 40%, so there is a 60% point gap between 100% proficiency and the current rate. (100 – 40 = 60) Divide the gap in half to determine the target for the sixth year – a gain of 30 percentage points. ( 60 / 2 = 30) Divide the 30-percentage point gain into six equal increments to set annual targets. (30/6 = 5) The school in begins with 40% proficiency rate, and obtain proficiency rates of 45%, 50%, 55%, 60%, 65%, and finally 70% in each of the following years of the six-year period.

83 Waiver Implementation 2012-2014
Requirement for the NJDOE’s district and school report cards to identify a school in need of improvement and a district in need of improvement. Under the waiver, the Report Card will not identify schools as a School in Need of Improvement based solely on narrow AYP achievement targets.

84 Waiver Implementation 2012-2014
Requirement for a school to have a poverty rate of 40% or higher to operate a Title I schoolwide program. The waiver allows districts to apply to operate a Title I schoolwide program in a Priority or Focus School with a poverty rate below 40%.

85 Waiver Implementation 2012-2014
The requirement for districts reporting less than 100% of their teachers as meeting the definition of “Highly Qualified” to develop and implement an improvement plan. The waiver provides increased focus on the development of more meaningful evaluation systems for teachers.

86 Web Site Resources NJ Department of Education Title I Parental Involvement Notification: US Department of Education Guidance NCLB Consolidated Subgrant Reference Manual President’s Blueprint for Reform Web Site Resources The following Web site resources have been included for you to find research and updated policies related to Title I. NJ Department of Education US Department of Education Guidance Local Education Agency Consolidated Guidelines New Jersey Professional Education Port (NJPEP) In addition the New Jersey Professional Education Port (NJPEP) will also provide information related to Title I at

87 US Department of Education
Non-Regulatory Guidance Targeted Assistance Schoolwide Programs Parental Involvement Paraprofessionals Private School Children Web site: USDOE Non-regulatory Guidance Information related to non-regulatory guidance for specific questions related to Title I, Part A programs is provided on the Title I Web site at Targeted Assistance Programs Consolidated Grants Private School Children Public School Choice Supplemental Educational Services Report Cards Paraprofessionals Title I Funding Standards and Assessment Comprehensive School Reform LEA and School Improvement Summary and Analysis of the U.S. Department of Education’s Regulation on Alternative Achievement Standards and Alternative Assessments under NCLB of 2001

88 TITLE I FISCAL RESPONSIBILITIES

89 What Happens When Federal $$$ Are Misspent??????

90 US Dept of Education- Office of Inspector General
Accountability. Efficiency. Effectiveness. Oversight

91 OIG Fraud News According to court documents, on June 20, 2007, BROOKS-SIMMS pled guilty to conspiracy to commit federal program fraud. She admitted she secretly conspired with a local businessman, to approve the purchase of an educational software program for the Orleans Parish School System. Jefferson received over $900,000 of Orleans Parish School Board money as his sales commission for selling the software program to the school board. In exchange for her assistance in promoting and approving the software program, BROOKS-SIMMS received approximately $140,000 as a bribe/reward from the Jefferson. Both BROOKS-SIMMS and the Jefferson funneled these payoffs through several bank accounts to disguise their illegality. On August 21, 2009, Jefferson was convicted by a federal jury after a two week trial and has been sentenced to serve ten (10) years in federal prison.

92 OIG Fraud News THOMPSON was employed at Langston Hughes Academy Charter School as the Business and Human Resources Manager/Financial Manager beginning approximately July 1, 2008 until approximately November 6, THOMPSON admitted that in her position at Langston Hughes Academy Charter School, she would make cash withdrawals while acting in her capacity as Business and Human Resources Manager/Financial Manager and then manipulated the school’s record in order to conceal the thefts. The amount of loss to Langston Hughes Academy Charter School is approximately $660,000.

93 OIG Fraud News PHILADELPHIA—Rosemary DiLacqua, 51, of Philadelphia, was sentenced today to a year and a day in prison for honest services mail fraud committed while she was board president for the Philadelphia Academy Charter School (“PACS”), announced United States Attorney Michael L. Levy. DiLacqua accepted a total of approximately $34,000 in payments from codefendant Kevin O’Shea, the former CEO of PACS, and another former school official that she did not disclose on her mandatory statement of financial interest form or to the other board members. After receiving these undisclosed payments, DiLacqua approved a series of salary increases for O’Shea and also a 20-year consulting contract for the other former school official that would have paid him in excess of $100,000 annually for no more than 90 days of consulting each year. When O’Shea left PACS the following Spring (May 2008), he was earning in excess of $200,000 in salary from PACS.

94 OIG Fraud News FORMER CEO OF CHARTER SCHOOL SENTENCED TO 37 MONTHS ON FRAUD, THEFT AND TAX CHARGES In July 2009, O'Shea entered a guilty plea admitting that he stole between $400,000 and $1 million from PACS by: (1) using approximately $710,000 in PACS' funds to purchase a building in the name of his purported non-profit business; (2) demanding kickbacks from PACS vendors; (3) submitting for reimbursement at least $40,000 in fraudulent invoices for personal meals, entertainment, home improvements, and gas and telephone bills; (4) having approximately $50,000 worth of home repairs improperly billed to PACS; (5) collecting approximately $34,000 in rent from entities using PACS facilities; and (6) hiring a computer firm in an attempt to destroy computer evidence to obstruct this investigation. O'Shea also admitted to filing a false tax return for 2006.

95 Board Minutes What should be in my Board minutes?
Resolutions to: Apply for Funds (copy of budget statement)

96 What should be in my Board minutes? EDGAR Part 80, Section 20
Appointment of Teachers Name Salary School Funding Percentage for Each Program Appointment of Secretaries, Aides, Program Directors, etc. Work Location

97 Final Expenditure Reports
Must be consistent with budget (amendments filed through County Office) – EWEG Monitors CANNOT: Move more than 10% of total funds, whichever is less, without State approval (filed through County Office) Add a budget category without State approval (filed through County Office) Carryover more than 15% of total amount received more than once every three years without State approval (Must have good reason) – NJDOE has a Waiver in Place

98 Carryover of Funds (Set Asides)
Some Carryover Funds are Restricted to the Original Intent and Purpose of the Funding **** Accounting Tracking Required **** Parental Involvement If these funds carried over, then can only be spent for original intent and purpose or must be refund to SEA

99 Select Expenditures and Support Needed
Fully-funded Salaries Periodic certification signed at least semi-annually Signed by employee and supervisor ** New Model – October 2012 - Click on “Sample Time and Activity Reports”

100 Select Expenditures and Support Needed
Split-funded Salaries Personnel activity reports Signed by employee and supervisor Must be an after-the-fact distribution of actual activity Prepared at least monthly and must coincide with pay periods

101 Select Expenditures and Support Needed
General Purchases Must have purchase orders Must have account number on P.O. Should indicate Title I purchases Signed by Business Administrator If split P.O., Title I should be easily identifiable REMEMBER – Money spent in Individual Schools should EQUAL amount in Step 4 of Eligibility

102 Select Expenditures and Support Needed
Equipment Maintain master inventory listing (Date, Serial Number, Model, Cost, Location) Each school should maintain subsidiary listing All equipment should be labeled with “Title I” or equivalent tracking system Need to keep records for FIVE years past disposition (date needs to be on master list) Even if not equipment for GRANT purposes, if district has a lower threshold, then tracking of equipment is required If less expensive to inventory than to replace, it should be inventoried

103 Select Expenditures and Support Needed
Employee Benefits TPAF/FICA reimbursement applies only to teachers’ contracted salaries, supervisors and program directors TPAF/FICA reimbursement report does not apply to aides, secretaries or clerical, stipends, substitute teachers or summer teachers All other benefits based on actual cost, not budgeted percentages

104 Select Expenditures and Support Needed
Employee Benefits – TPAF/FICA Reimbursement Report

105 Selected Items of Cost Special rules for specific expenses
Still subject to basic guidelines Examples: Alcohol: Never allowable Salaries and Wages: Allowable if time distribution Meetings and conferences: Allowable if dissemination of technical information

106 Selected Items of Cost – Student Incentives
The US Dept. of Education(ED) has indicated that an LEA may use Title I funds to provide “non-monetary” rewards of “nominal” value (e.g., Plaque, gift certificate, or book, etc.) in an effort recognize Title I students for good performance. Title I funds may NOT be used to pay students a stipend or provide some other type of award as an incentive for student participation in a Title I program

107 Selected Items of Cost – Parent Incentives
To encourage parents of Title I students to participate in school activities in the evening, an LEA may use Title I funds to provide light refreshments. Note, ESEA § 1118(e)(8) authorizes LEAs to use Title I funds for “parent-related” activities that are reasonable and necessary for expenses associated with parental involvement activities, including child care and transportation to enable parents to attend “school-related” meetings and training sessions

108 Helpful Questions to Ask When Analyzing Costs
Is the proposed cost consistent with federal cost principles? OMB A-87, Attachment B Is the proposed cost allowable under the relevant program? (Title I, IDEA, etc) Is the proposed cost consistent with an approved program plan and budget? (EWEG) Is the proposed cost consistent with program specific fiscal rules? (Supplement not Supplant) Is the proposed cost consistent with EDGAR?

109 Expending Funds Documentation required for both school-level and district-level expenditures Documentation must explain: How is the expenditure reasonable and necessary to carry out the intent and purpose of the program? What need, as identified in the comprehensive needs assessment, does the expenditure address? How would the program, activity, or strategy be funded if the Title I, Part A funds are not available?

110 Expending Funds Documentation must explain:
If for a schoolwide campus, how will the expenditure upgrade the entire educational program on the campus? How is the expenditure supplemental to other nonfederal programs? How will the expenditure be evaluated to measure a positive impact on student achievement?

111 Allowable Costs All Costs must be: Necessary Reasonable Allocable
Legal under state and local law

112 Nonpublic Expenditures
Same Fiscal Rules Apply Only your districts students Students that need extra services NO longer just supplies/computer – SERVICES ARE REQUIRED Carryover Funds not Spent in Prior Year (Discretion) Automatic flow of district carryover in EWEG

113 Nonpublic Expenditures
Third Party Provider Contracts When bid, the specifications should have the Stephens Amendment wording Vendor Complaint Policy Details on who provides parental involvement activities Renting/Ownership of Supplies, Trailers, etc. Breakout of Invoices to Include: Instructional Salaries and Benefits Instructional Supplies Rental of books, supplies, trailers Administrative Charges/Profit

114 Nonpublic Expenditures
Third Party Provide Contracts Administrative Costs of Third Party Providers counts against the District’s Five Percent (5%) Total Administrative Costs Who pays the Administrative Costs? Off the top allocation of the District of Other Title I Funds (USDOE Non Regulatory Guidance)

115 Fiscal Policy District Policies on: Maintenance of Effort
Comparability Supplement vs. Supplant

116 *** Must Be Done Annually ***
Fiscal Policy Maintenance of Effort Current Expenditures (Not Including Capital Outlay) Less: Community Services Divided by: Average Daily Enrollment Compare to prior year (current year/prior year) and must be at least 90% *** Must Be Done Annually ***

117 Maintenance of Effort Example
Fiscal Policy Maintenance of Effort Example Line Description Aggregate Expenses Average Daily Enrollment Amount Per Student 1 Amount from $ ,098,944 377.50 13,507.14 2 Amount LEA had to Spend in (90% of Line 1) $ ,589,050 12,156.42 3 Actual Amount Spent in $ ,095,897 398.00 12,803.76 4 Amount District Failed to Maintain 5 Percent of Reduction in EXCESS $ ,847 $

118 (Elementary, Middle or High – Only 3 Groupings)
Fiscal Policy Comparability Compare Like-Kind Grade Span Groupings (Elementary, Middle or High – Only 3 Groupings) Monitoring Coming Soon – Verify staffing

119 Schoolwide Programs MUST have approved plan that addresses all schoolwide issues Time sheets are required (except in a blended resource fund, e.g., Fund 15 for former Abbott districts)

120 Frequently Asked Questions
Time Sheets and Salaries Q: Multiple Federal Grants – If someone works on multiple federal grants, must their salary be allocated to all the grants since it is one large federal pot of money? A: Yes, since each is a separately funded program.

121 Fiscal News from Washington
New Haven Audit Report from Office of Inspector General Supplanting in a Schoolwide Program

122 Fiscal News from Washington
William Floyd Audit Report from Office of Inspector General Unsupported Expenses Unsupported Adjusting Journal Entries Supplanting of Textbooks Weak Internal Controls

123 Fiscal News from Washington
City of Detroit and Parent Involvement Fund 2005 Disallowed Charges for Entertainment, Promotional Items and Public Relations Need to be necessary, reasonable, allocable and documented Disallowed items include advertising for an event and live musical entertainment at parent volunteer function

124 Fiscal News from Washington
City of Detroit -Revisit in 2008 Over $131 Million in 2005 and $126 Million in 2006 No Time Sheets – Almost $50 Million Teaching non-Title I students – even though most of Detroit is schoolwide some schools are not (no plan submitted) and OIG looked to these schools and found staff being funded that were teaching non-Title I identified students. Detroit argued they could have been schoolwide if they did a plan and the OIG rejected this argument Over $21 M for adjusting entries for employees that were charged to other programs and then charged to Title I Gift cards they could not show got to students $150,000 for martial arts training

125 Fiscal News from Washington
OIG Audit-St. Louis Lost 125 Computers Serving Ineligible Schools

126 Fiscal News from Washington
OIG Audit Kiryas Joel Union Free School District Supplanted funds by charging rent to lease building for public school Couldn’t Support Salaries for After School Program

127 Fiscal News from Washington
Philadelphia Findings totaling $138,376,068 Unsupported salaries (some direct and some through adjusting entries) School police paid from Title I Funds Supplanting (moving company, etc) No backup for school choice charges of $1.3M Weak internal controls

128 Fiscal News from Washington
Maryland – Title I ARRA Funds Findings totaling $540,013 $8,736 in gifts to staff $4,352 in Dinner Cruises in Baltimore Harbor Lack of Receipts for Expenses $200,323 in Unsupported Title I and IDEA Salaries $3,922 for tablets with no controls over them or applications that are downloaded (Items against policy – 22%)

129 Fiscal News from Washington
Former Charles County Public Schools Title I Coordinator Sentenced (Maryland). The former Title I coordinator was sentenced to serve 27 months in prison and 36 months of supervised release. She was also ordered to pay more than $115,300 in restitution for theft. The former official used Title I grant funds to purchase technology items for herself, family, and friends, including computers, video games consoles, portable media players, tablet computers, and televisions.

130 Fiscal News from Washington
Sandra Campbell, 57 a former Detroit Public Schools contract accountant and school board candidate, and her daughter, Domonique Campbell, 38, a Detroit Public Schools teacher, were convicted today by a federal jury in Detroit on charges of program fraud conspiracy, money laundering conspiracy, and tax charges following a five-week jury trial, United States Attorney Barbara L. McQuade announced today. The jury returned its verdict after only one-and-a-half hours of deliberations. McQuade was joined in the announcement by FBI Special Agent in Charge Robert D. Foley, III and Special Agent in Charge, Erick Martinez, Internal Revenue Service, Criminal Investigation. The evidence presented at trial established that between 2004 and 2008, Sandra Campbell and Domonique Campbell obtained in excess of $530,000 from the Detroit Public Schools through a fraudulent scheme in which orders were placed with the Campbells’ sham company for books and educational materials never provided to the schools. Sandra Campbell and Domonique Campbell conspired to launder the fraud proceeds and to defraud the Internal Revenue Service and failed to report the money they fraudulently obtained from the Detroit Public Schools as income on their tax returns. United States Attorney Barbara L. McQuade said, “Anyone who considers stealing from our school children should take note that we are scrutinizing records and conduct, and will prosecute wrongdoers.”

131 Common Audit Findings Lack of time sheets (or signature of employees/supervisors) Improper payroll distribution (not pro-rated) Purchase orders not indicating Title I (and adjusting entries to reclassify amounts)

132 Common Audit Findings Policies not being updated for current law
Supplanting on purchases of non-salaried items Not spending at the schools approved in the application Not liquidating within timelines (now less than prior year)

133 Conclusion Remember: “If you take the money, you are responsible for knowing the rules and regulations concerning the grant.” If you need further help contact Anthony Hearn (609)

134 609-943-4283 titleone@doe.state.nj.us
When in Doubt, Reach Out!!


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