1. Equitable Services to Private Schools Russ Sweet Oregon Department of Education Summer 2013

2. Objectives This workshop will provide information on:  Private school participation under ESEA in Oregon  Titles I-A, II-A & III requirements and use of funds  Tips for working with private schools  Regulatory & Non-Regulatory Guidance  State contact information

3. Private School Participation Under ESEA The Elementary and Secondary Education Act (ESEA), requires districts to provide equitable opportunities for participation to private school students, teachers and other education personnel, including those in religiously-affiliated schools. In Oregon, public school districts are encouraged to become partners with private schools, in the best educational interest of all children and youth.

4. In Plain Language... Private schools are eligible to receive services. Private schools are not eligible to receive funds directly. No funds are to be channeled directly through the private school. Any payment (i.e., stipend) to private school personnel must be paid directly to the individual by the district.

5. Title I Improving Academic Achievement for Educationally-Disadvantaged Students ◦ Part A - Improving Basic Programs

6. Title II Preparing, Training and Recruiting High Quality Teachers and Principals  Part A -Teacher and Principal Training and Recruiting Fund Equitable participation is required to the extent that the district uses the funds to provide professional development.

7. Title III Language Instruction for Limited English Proficient and Immigrant Students Timely and meaningful consultation Equitable and timely services Secular, neutral and non-ideological Serve private school LEP children and education personnel directly or through third party contracts Funds are not co-mingled with non-federal funds

8. The First Step is Consultation  Timely and meaningful consultation during the design and development of the programs  Occurs before any decisions are made that could affect the private school students and teachers from accessing services  Continues throughout the implementation and assessment of services

9. Title I-A Services to Private Schools  Provides supplementary instruction by public school teachers, or through a third- party contractor, to students who are educationally disadvantaged and failing or at risk of failing to meet high academic standards, and who live in Title I attendance areas.

10. Funding  Generated on basis of number of students from low-income families who reside in participating public school attendance area and who attend private schools.  See worksheet on pg. 36 of Title I Services to Eligible Private School Children Located at: “Private School Participation in ESEA”: http://www.ode.state.or.us/search/page/?id=3345 http://www.ode.state.or.us/search/page/?id=3345  Budget Narrative contains a worksheet that automates these calculations.  In some cases, the private school may be in an adjacent school district – the funding is still generated by student’s resident district.

11. Title I-A Instructional Program  During the school day, before or after school, during the summer  Onsite at the private school (even religiously affiliated schools), or at other locations  Targeted assisted pullout model, supplementary instruction, direct instruction, computer-assisted instruction, tutoring, family literacy, and early childhood programs

12. Title I-A Professional Development  Professional development activities for private school teachers should address how these teachers can serve Title I students better by providing information on research- based reading and mathematics instruction.  Funding is an equitable portion of LEA Title I-A funds being used to support professional development for district staff.  Do not confuse Title I professional development funds with those in Title II-A.  There are allowable and non-allowable uses of these funds.

13. Title I-A Parent Involvement  After consultation with private school officials, the district may conduct these activities independently or in conjunction with the district’s regular parent involvement activities.  Parent involvement activities can vary from simple parent meetings about the Title I Program to more sophisticated activities, such as strategies to use at home to build academic success.  Needs to be an equitable portion of the district’s parent involvement set-aside.

14. Documentation: Consultation & Participation  Document the Process  Initial communication  Consultation  Instructional program  Professional development  Parent involvement  Complaint process  Evaluation  Sample documents available at: http://www.ode.state.or.us/search/page/?id=3345 http://www.ode.state.or.us/search/page/?id=3345

15. Title II-A Private School Participation  References for requirements can be found in Improving Teacher Quality State Grants ESEA Title II, Part A: Non-Regulatory Guidance (revised October 5, 2006).

16. Title II-A Eligible Activities  Improving the knowledge of teachers, principals, and other educational personnel in one or more of the core academic subjects and in effective instructional teaching strategies, methods, and skills  Training in effectively integrating technology into curricula and instruction  Training in how to teach students with different needs, including students with disabilities or limited English proficiency, and gifted and talented students

17. Title II-A Eligible Activities (cont.)  Training in methods of improving student behavior, identifying early and appropriate interventions, and involving parents more effectively in their children’s education  Leadership development and management training to improve the quality of principals and superintendents  Training in the use of data and assessments to improve instruction and student outcomes.

18. Ensuring Equitable Services for Title II-A  Assess, address and evaluate the needs and progress of both public and private school teachers  Spend an equal amount of funds per student to serve the needs of public and private school teachers and their students  Provide private school teachers with an opportunity to participate in Title II-A activities equivalent to the opportunity provided public school teachers  Offer educational services to private school teachers that are secular, neutral, and non- ideological.

19. How to Ensure Equitable Services for Title II-A Based on the needs assessment of the private school teachers, it may be that a private school professional development plan is different from the one developed for the district’s teachers.

20. Title II-A Allowable Activities  Professional development conferences put on by faith-based organizations that are sustained, comprehensive and secular  Stipends for private school teachers to attend professional development outside the teacher’s regular work day, paid directly to the teacher

21. Non-allowable Expenditures Under Title II-A for Private Schools (examples)  Teacher, administrator or other staff salaries  Substitute teacher pay  Teacher or administrative certification courses  Items or costs that would otherwise be provided to teachers by the private school* *Supplement/Not Supplant: Title II-A funds supplement non-federal funds. Professional development provided with federal funds needs to be in addition to, and not replace, what the private school would otherwise provide.

22. Avoiding Problems If problems arise between districts and private schools, it can often be attributed to any one or all of the following:  Lack of Communication

23. Avoiding Problems Timely and meaningful consultation does not mean:  Notifying private schools of a meeting happening without sufficient lead time.  A meeting where the district has already pre- determined available services, so “take it or leave it.”  A one-time meeting, as it may take more than one meeting to set up the program.

24. Avoiding Problems Timely and meaningful consultation does mean:  Coming away with a very clear plan that both parties agree on and understand  Continuous monitoring of the implementation of the plan

25. Common Monitoring Findings  Lack of district documentation on process of consultation and program agreements  Perceived or real barriers to private school participation as evidenced by: ◦ short timelines imposed on private schools by the LEA for meetings, consultations, etc. ◦ Inconsistent responses from the district to questions by private schools ◦ Consultation that is one-sided, not really consultation  Private school programs that do not begin until well after public school begins

26. Due Diligence of Efforts “I’ve tried to consult with the private schools, but they never respond.” Document due diligence efforts:  Send a registered letter with receipt required  Follow-up with a phone call  Try to make an in-person visit (optional)  Attempt to acquire documentation from the private school acknowledging the waiver of participation

27. Resources ESEA Title IX, Part E Uniform Provisions Subpart I-Private Schools: Equitable Services for Eligible Private School Students, Teachers and Other Educational Personnel Non- Regulatory Guidance (Revised March 2009)

28. Resources Title I Services to Eligible Private School Children: Non-Regulatory Guidance (Revised October 17, 2003)

29. Web-based Resources  Oregon Department of Education http://www.ode.state.or.us/search/page/?id= 3345  US Department of Education -- Office of Non-Public Education http://www2.ed.gov/about/offices/list/oii/non public/index.html

30. Contacts: ODE Office of Educational Improvement & Innovation  Russ Sweet, Education Specialist russ.sweet@state.or.us (503) 947-5638  Dona Bolt, Education Specialist dona.bolt@state.or.us (503) 947-5781  Tanya Frisendahl, Education Specialist tanya.frisendahl@state.or.us (503) 947-5754