The Role a Charter School Plays in its Charter Authorizer’s Submission of the Consolidated Federal Programs Application Joey Willett, Unit of Federal Programs Administration, Colorado Department of Education

What is the Consolidated Application for Federal Funds? On December 10, 2015, the Every Student Succeeds Act (ESSA), which reauthorizes the Elementary and Secondary Education Act (ESEA), was signed into law. The passage of ESSA provides a much anticipated opportunity to improve achievement outcomes for all students by providing effective programs supported with Titles I, II, III, and IV funding. The new law broadens the allowable uses of title funds and our goal is to help ensure that you understand all of the opportunities this funding affords your LEA.

What is the Consolidated Application? Under the ESSA, state educational agencies (SEAs) are required to collect local education agency (LEA) plans that address the requirements of the law, as well as descriptions of the activities the LEA will implement with its Title I, II, III, and IV allocations. To meet this requirement, the Colorado Department of Education (CDE) has developed, with stakeholder input, a new consolidated application, which includes a set of five cross-program questions, organized around five core elements: A comprehensive needs assessment; Meaningful, ongoing consultation with parents, teachers and other community members; The identification of students in need of additional support; Delivery and progress monitoring of evidenced-based student supports; and Evaluation of programs and activities funded by the ESSA.

What funding sources are included as part of the Consolidated Application? The Consolidated Application for Federal Funds allows LEAs to apply for Titles I, II, III, and IV using a single application. Title I, Part A The purpose of Title I, Part A is to provide resources to schools and districts to ensure that all children have a fair, equitable, and significant opportunity to obtain a high-quality education and close educational achievement gaps. Title II, Part A Title II, Part A of the Every Student Succeeds Act (ESSA) of 2015 is intended to increase student academic achievement consistent with challenging State academic standards, improve the quality and effectiveness of educators, increase the number of educators who are effective in improving student academic achievement in schools, and provide low- income and minority students greater access to effective educators.

What funding sources are included as part of the Consolidated Application? (continued) Title III, Part A Title III is a supplemental grant under the ESEA that is designed to improve and enhance the education of English learners (ELs) in becoming proficient in English, as well as meeting the Colorado Academic Content standards. The Title III Immigrant Set-Aside grant resides within this program and provides opportunities for LEAs to enhance the instructional opportunities for immigrant students and their families Title IV, Part A Title IV, Part A of the Every Student Succeeds Act of 2015 is intended to improve students’ academic achievement by increasing the capacity of States, local educational agencies (LEAs), schools, and local communities to provide all students with access to a well- rounded education, improve school conditions for student learning, and improve the use of technology in order to improve the academic achievement and digital literacy of all students.

Who completes the Consolidated Application for Federal Funds? The LEA (Charter Authorizer) will complete Consolidated Application. LEAs use a district-level needs assessment to inform Title II and IV programming LEAs will work with school administration to plan for Titles I and III programming, informed by a school level needs assessment

Eligibility for Accessing Title I, Part A Title I, Part A targets resources to districts and schools in greatest need. The program is the largest ESEA program supporting both elementary and secondary education. The USDE allocates funds based on census poverty rates from ages 5 through 17. Eligibility is based on statutory formulas. Although the amount of Title I, Part A funds a school and district may receive is based on poverty rates, the children that benefit from the program(s) are not, necessarily, students in poverty. Rather, Colorado’s Title I, Part A programs work to address the needs of a school's lowest performing students and those students most at risk for not meeting the Colorado English Language Proficiency (CELP) and Colorado Academic Standards (CAS).

Eligibility for Accessing Title I, Part A (continued) Rank Order Title I schools must be served in rank order by poverty percentage unless they reside in a district with less than 1,000 students enrolled or with only one school per grade span. There are different measures of poverty that can be used when determining rank order. The selected poverty measure is what will be used to determine the number of low-income students at district schools and the proportionate share for eligible non- public schools. LEAs are not required to allocate the same per-child amount to each area or school. However, the LEA must allocate a higher per-child amount (based on the number of low-income students at each Title I, Part A school) to areas or schools with higher poverty rates than it allocates to areas or schools with lower poverty rates.

Participation in Titles II and IV Title II, Part A Activities supported with Title II, Part A funds must be planned through consultation with teachers, school leaders, paraprofessionals, special service providers, charter school leaders, parents, and community partners. The LEA must also engage in continued consultation with these stakeholders to improve supported activities. Descriptions of funded activities in the Consolidated Application must address alignment with the Colorado Academic Standards. Title IV, Part A Activities supported with Title IV, Part A funds must be planned through consultation with parents, teachers, principals, other school leaders, special service providers, students, community-based organizations, local government representatives, Indian tribes or tribal organizations that may be located in the region served by the LEA, and charter school teachers and principals; teachers, principals and other relevant stakeholders. The LEA must also engage in continued consultation with these stakeholders to improve supported activities. Descriptions of funded activities in the Consolidated Application must address program objectives and intended outcomes.

Title II, Part A & Title IV,Part A – Supplement Not Supplant Title II, Part A & Title IV, Part A funds must only be used to provide additional services, staff, programs, or materials that are not provided with State or local resources absent federal funds; federal funds cannot pay for resources that would otherwise be purchased with State and/or local funds. The list of questions on the following slide should be used to determine if current or proposed uses of Title II, Part A funds may be supplanting non- Federal funds that would otherwise be used for such activities. If the answer to any numbered question is ‘yes’, the sub-question listed below should be used to continue the supplanting test. If the answers to all lettered sub-questions are also ‘yes’, then the use of Title II, Part A funds to support the activity is determined to be supplanting non-Federal funds and cannot be funded with Title II, Part a funds.

Title II, Part A & Title IV, Part A - Test Questions Has a non-Federal funding source been previously used to support this activity? Is the previously utilized funding source still available and sufficient to fully support this activity? Is this activity mandated by any State law or local policy? If yes, does the applicable law or policy mandate the use of a particular funding source to implement the activity? If yes, is the applicable funding source still available and sufficient to fully support the activity?

Participation in Title III Title III grantees must submit a plan to CDE that describes: proposed activities and programs that will expand, enhance, or modify core English Language Development (ELD) and academic programs, how proposed activities are supplemental to core ELD and academic programs, the intended outcomes of the proposed activities and programs, how the proposed activity will be utilized to increase language proficiency and provide equitable access to grade-level content, how the LEA or consortium lead will provide professional development for increasing the capacity of principals and other school leaders, administrators, and instructional staff working with ELs, and how the grantee will promote parent and community engagement.

Title III, Part A - Supplement, Not Supplant Title III, Part A is a supplemental that is designed to improve and enhance the education of English learners (ELs) in becoming proficient in English, as well as meeting the Colorado Academic Content standards. The Title III Immigrant Set-Aside grant resides within this program and provides opportunities for local educational agencies (LEAs) to enhance the instructional opportunities for immigrant students and their families. Title III, Part A funds must only be used to provide additional services, staff, programs, or materials that are not provided with federal, state, or local resources.

Title III, Part A - Supplement, Not Supplant Test Supplanting occurs when Title III, Part A funds are used to provide services that, absent the funds, would have otherwise been provided with federal, state, or local funds. Under Title III, Part A, the U.S. Department of Education presumes that supplanting has occurred if the LEA uses the funds to provide services that: are required under other federal, state, or local laws, or were provided with non-federal funds in the prior year.

Title III, Part A - Supplement, Not Supplant and the Civil Rights Act of 1964 and the Equal Educational Opportunities Act of 1974 Under Title VI of the Civil Rights Act of 1964 (Title VI) and the Equal Educational Opportunities Act of 1974 (EEOA), all States and LEAs must ensure that ELs can participate meaningfully and equally in educational programs and services. Title III, Part A funds may not be used to satisfy the LEA’s obligations outlined under Title VI or the EEOA.

Timeline and Planning Considerations for Charter Schools LEAs must submit the Consolidated Application for Federal Funds by June 30, 2018. The online platform will open in the Spring. LEAs have likely already begun the necessary planning. In order to access federal funds, it is important that charter schools consult with their authorizers and share a mutual understanding of the needs identified at both the district and school level. Finding areas where the needs of the charter school intersect with the needs of the district will facilitate participation in district-managed, federally-funded activities.

Questions

Joey Willett Senior Consultant Contact Information Joey Willett Senior Consultant Office of ESEA Programs willett_j@cde.state.co.us 303-866-6700