1. Providing Effective Equitable Title I Services to Non-Public School Students ESEA Directors InstituteESEA Directors Institute October 2014October 2014

2. Title I Non-Public Quache Bowles Spencer Division of Consolidated Planning & Monitoring Strategic Projects Manager Quache.Spencer@tn.gov

3. Why do LEA’s provide services to non-public schools? Under Title I, local educational agencies (LEAs) are required to provide services for eligible non-public school students, as well as eligible public school students. In particular, §1120 of Title I, Part A of the Elementary and Secondary Education Act (ESEA), as amended by the No Child Left Behind Act (NCLB), requires a participating LEA to provide eligible children attending non-public 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. Eligible students are those students that reside in Title I school zones and are failing or at risk for failure.

4. Services to Non-Public Students  The Title I services provided by the LEA for non-public school participants are designed to meet their educational needs and supplement the educational services provided by the non-public school.  These services may be provided by the LEA, or by a contractor who is independent of the non-public school.  Title I services or benefits must be secular, neutral, and non- ideological.

5. Best Practices For Providing Effective Services  The three main components to effective services are: Consultation – single most important piece to providing effective equitable services Communication – timely and transparent Collaboration – developing a partnership with non-public school officials can prove beneficial

6. Consultation  Consultation is a requirement in the implementation of an effective Title I program  Effective Consultation must be: Timely and meaningful Before decisions are made about services and before services begin Involves discussions between public and non-public school officials Provides a genuine opportunity for all parties to express their points of view Annual Ongoing

7. Annual Consultation Meeting  The annual consultation meeting should be a face-to-face meeting LEAs send invitations in advance and reminders leading up to the meeting date Require an RSVP prior to the meeting date LEAs invite key players from public and non-public schools: – Central office staff – Non-public school building administrators – Specialty areas » Family/Community Engagement » IDEA/SPED » Title III  The annual consultation should contain the regulatory requirements

8. Regulatory Requirements for Consultation Under §200.63 of the Title I regulations consultation must, at a minimum, address the following issues:  How the LEA will identify the needs of eligible non-public school children.  What services the LEA will offer to eligible non-public school children.  How and when the LEA will make decisions about the delivery of services.  How, where, and by whom the LEA will provide services to eligible non- public school children.  How the LEA will assess academically the services to non-public school children in accordance with §200.10 of the Title I regulations, and how the LEA will use the results of that assessment to improve Title I services.

9. Regulatory Requirements for Consultation  The size and scope of the equitable services that the LEA will provide to eligible non-public school children and, consistent with §200.64 of the Title I regulations, the proportion of its Title I funds that the LEA will allocate for these services and the amount of funds that the LEA reserves from its Title I allocation for the purposes listed in §200.77 of the Title I regulations.  The method, or the sources of data, that the LEA will use (under §200.78 of the Title I regulations) to determine the number of non-public school children from low-income families residing in participating public school attendance areas, including whether the LEA will extrapolate data if a survey is used.  The services the LEA will provide to teachers and families of participating non-public school children.  Discussion of service delivery mechanisms the LEA will use to provide services

10. When Communicating with Non-public Officials  Be timely Set up meetings far in advance Set due dates far in advance  Be deliberate Send RSVP’s with meeting notifications Have more than one contact for each school Communicate in writing – E-mail – Fax  Be mindful Different calendars Different start times (school openings, school days) Religious holidays

11. Collaboration  Collaboration between public and non-public schools creates a sense of trust Creates a feeling of partnership in the decision-making process Breaks down barriers Decreases complaints Makes public school officials the first point of contact

12. When Collaborating with Non-Public School Officials  Be transparent Share pertinent information with them – Allocations – Changes coming to the district that may affect them Allow time for questions and answers during collaborative events  Be genuine Read surveys and questionnaires Respond to questionnaires Give due consideration to requests

13. Delivery of Services  Services may be provided by the LEA, or by a contractor who is independent of the non-public school. Determining who will deliver the services is discussed and agreed upon during annual consultation – If public and non-public school officials disagree on provision of services through a contract, the LEA will provide in writing to such public school officials an analysis of the reasons why the LEA has chosen not to use a contractor Ultimately the LEA has the final decision as to the provision of services NOTE: Tasks related to the administering services and programs are the responsibility of the LEA (purchasing, contracting, etc.)

14. Comparison of Delivery of Services- Services Provided By the LEA Pros  LEAs have a direct link to non- public schools and their administration  LEA hires its own tutors (upholding licensure standards)  Decreases administration fees  Creates autonomy for non-public school students  Creates increased collaboration between non-public school teachers and LEA tutors Cons  Creates the need for more staff Coordinator to head the program Supervisor to visit and monitor program Technology person to maintain technology purchased for non- public schools’ students

15. Comparison of Delivery of Services- Contracted Services  Can be managed by minimal LEA staff  Creates a feel of the LEA being outsiders  Tutors are hired by the contractor  Administrative cost comes into play  Contractors may use a curricular program  Decreases the need for collaboration between the non-public school teachers and contracted tutors

16. Title I Non-public in ePlan  Non-public schools participating in Title I should appear in ePlan in the following 4 pages: District Set Asides and Overview Page (parent involvement, districtwide instructional initiatives subject to non-public, etc) PPA Page (column H – Services to Students in Non-Public Schools for the school-level instructional PPA) Non-public Schools Page (from Sections Page) indicating participation and student information of non-public schools in LEA attendance areas Budget narratives

17. Questions

18. FRAUD, WASTE or ABUSE 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