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Title III Program Monitoring Tier I, Tier II, & Tier III and BAAS Documentation February 6, 2014 North Carolina Department of Public Instruction K-12 Programs Title III/ESL Office

Monitoring Focus Programmatic Success Compliance

Areas Assessed ELD Standards Assessment & Accountability Instructional Support Fiscal Compliance

Tiered Monitoring Build Capacity Tier ITier IITier III

Tiered Monitoring Build Capacity Tier I Feb. 1 – Mar. 31, 2014 Tier IITier III Title III Self-Evaluation Survey

Tiered Monitoring Build Capacity Tier I Tier II Ongoing Tier III Needs Based Monitoring Onsite One or Two day Monitoring

Tiered Monitoring Build Capacity Tier ITier II Tier III Feb – May On-Site Monitoring Two(2) Day

Exploring Monitoring Documents

Title III Monitoring Plan oordinators Title III Monitoring Plan 13-14

Monitoring Schedule Considerations Coordinators Monitoring Schedule Considerations 13-14

Monitoring FAQ Coordinators Monitoring FAQ

Classroom Observations Form Coordinators Classroom Observations Form

Guidelines for Observations Coordinators Guidelines for Observations

Fiscal Documents Coordinators Fiscal Documents

Title III Monitoring 16

Title III Monitoring: Accountability SBE Policy GCS-A-012 Subgrantees receiving Title III funds (LEAs, public charter schools, & consortia) must meet a series of Annual Measurable Achievement Objectives (AMAOs) AMAO 1 – Progress AMAO 2 – Proficiency AMAO 3 – AMOs for the LEP Subgroup 17

Title III, Sec. 3122(b)(2) and State Board Policy reference (4) ACCOUNTABILITY- If a State educational agency determines that an eligible entity has failed to meet the annual measurable achievement objectives described in subsection (a) for 4 consecutive years, the agency shall — (A) require such entity to modify the entity's curriculum, program, and method of instruction; Policy Identification Priority: Globally Competitive Students Category: Testing Policy ID Number: GCS-A-012 Sanctions for AMAOs Not Met If the Title III subgrantee has failed to meet the AMAOs for four (4) consecutive years, the State Board of Education shall require the Title III subgrantee to modify its curriculum, program, or method of instruction. 18

Risk Factors Risk factors include but are not limited to: size of subgrantee grant award, percentage of LEP students, program performance based on meeting AMAOs 1 and 2, student subgroup academic performance based on AMOs for LEP students, change in program or leadership, and the length of time since previous onsite monitoring. 19

Timeline 20 AMAO 3 Calculations Risk Factor Analysis Monitoring Schedule

Tying It All Together Application Improvement Plan Monitoring Implementation 21

Budgets Basic Supplement, Not Supplant 22 USDE, Student Achievement and School Accountability (SASA)

Title I, Part A & Title III, Part A Title I Funds must supplement, and not supplant State and local funds (Section 1120A of ESEA) Title III Funds must supplement, and not supplant other Federal, State, and local funds. (Section 3115 of ESEA) 23 USDE, Student Achievement and School Accountability (SASA)

Title III “A Supplemental Program to Serve English Learners” Cake – state and local funds used to provide the Core EL program Icing/Frosting – Other federal funds Sprinkles – Title III funds –High Quality Language Instruction Educational Program (LIEP) –High Quality Professional Development 24 USDE, Student Achievement and School Accountability (SASA)

Developing My LEA’s Supplemental Title III Program Do all of the items on my local plan and budget narrative meet the following criteria? Are they allowable? Are they allocable? Are they reasonable and necessary to carry out grant function? Determine whether they should be included in the 2% limit as administrative costs? 25 USDE, Student Achievement and School Accountability (SASA)

Supplement, Not Supplant Requirement – General The First Test of Supplanting: Required by Law The Department assumes supplanting exists if – An LEA uses Title III funds to provide services that the LEA is required to make available under State or local laws, or other Federal laws. 26 USDE, Student Achievement and School Accountability (SASA)

Supplement, Not Supplant Requirement – General The Second Test of Supplanting: Prior Year The Department assumes supplanting exists if – An LEA uses Title III funds to provide services that the LEA provided in the prior year with State, local or other federal funds. This assumption can be rebutted. 27 USDE, Student Achievement and School Accountability (SASA)

To refute the “prior year” test of supplanting, the LEA would need to have contemporaneous records to confirm….  Budget cuts were made in a number of areas, not just for LEP students; and  There was in fact a reduced amount of State or local funds to pay for this activity/position; and  The LEA made the decisions to eliminate the position/activity without taking into consideration of Federal funds. 28 USDE, Student Achievement and School Accountability (SASA)

Questions to Ask When Considering Whether Title III Funds Can be Used Without Violating the Supplement, not Supplant Requirement 1.What is the instructional program/service provided to all students? 2.What does the LEA do to meet Lau requirements? 3.What service is the LEA required by other Federal, State, and local laws or regulations to provide? 4.Was the program/service previously provided with State, local, and Federal funds? 29 USDE, Student Achievement and School Accountability (SASA)

Supplement, Not Supplant FAQ Document 30

Resources Office of Planning, Evaluation and Policy Development, Policy and Program Studies Service Office of Management & Budget (OMB) Circular a-87: EDGAR – (See parts 76 and 80 in particular) Office for Civil Rights, ELL Resources

All in one place! –System notification of budget/amendment submission –Changed Justification feature allows you to note reason for changes –Response from NCDPI within the system

BAAS Documentation Why is using the changed justification feature important? No additional is needed unless there is a change to the application which requires additional documentation i.e. new staff position and additional technology purchases.

Changed Justification: Not Acceptable

Changed Justification: Acceptable

Our Responses: Status

Our Responses: DPI Comments

More Documentation Needed Technology purchases – requires approval of supplement not supplant rationale New staff positions – require approval of job description

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NC DPI ESL Consultants Regions 1, 2, 3, 4 Charlotte “Nadja” Trez ESL/Title III Consultant NC DPI Regions 5, 6, 7, 8 Ivanna (Mann Thrower) Anderson ESL/Title III Consultant NC DPI Lindsey Fults ESL/Title III Consultant NC DPI