Rules and Regulations Meeting Office of Federal and State Accountability March 14, 2013

Welcome and Introductions 2 Roy Stehle Title I Director

Sequestration Roy Stehle Title I Director 3

Sequestration The President was required by the Budget Control Act of 2011 to order sequestration on March 1, 2013 to enforce automatic spending cuts to Federal Government Programs. There are two other budget related Congressional votes looming: FY13 Budget approval or continuing resolution and a debt ceiling vote.

Sequestration Most ESEA programs will be affected for the school year. The USED has released tables which indicate a 5% reduction in ESEA programs nationally. South Carolina FY 13 at FY 12 Level FY 13 less 5%5% Reduction Title I218,475,309206,607,75811,867,551 Title II ITQ7,610,1587,229,6501,872,595 Title III ELL4,468,5263,895,375573,151

Sequestration Title I allocations to SEA’s and LEA’s are, in part, based on census poverty ages The Title I reduction to LEA’s in S.C. could be from 1% to 15 % depending on the revised census poverty figures for counties and districts. In budgeting for Title I in , the recommendation would be to plan for a reduction in the 5-10% range and no new FTE’s.

Questions 7

Fiscal Moves Roy Stehle Title I Director 8

Fiscal Moves to Consider Carryover: LEA’s, upon approval of the SEA, may carryover more than 15% of their allocation. This SEA carryover waiver may be granted to LEA’s once every three years. The SCDE received approval from the USED for districts to carryover more than 15% from into due to residual ARRA funding.

Fiscal Moves to Consider The USED waiver permits the SCDE to grant all LEA’s a carryover waiver of more than 15% for going into if they need it. If LEA’s requested a carryover waiver, it would start the once every three year clock. The SCDE would not be able to grant the same district another carryover waiver for going into or for going into

Fiscal Moves to Consider The SCDE will be requesting another carryover waiver from the USED due to sequestration for going into If granted, it would push the “once every three years” prohibition to going into allowing for greater flexibility in the use of carryover to cushion sequestration. The SCDE will be requesting comment from stakeholders prior to submitting the waiver.

Fiscal Moves to Consider Supplement, not Supplant: Testing for Presumptions of Supplanting: Is it required by the state, district, or another federal source? Are the same services provided for in non-Title I schools or students with (non-supplemental) state/local funds? Were these activities paid for in prior years with state/local funds?

Fiscal Moves to Consider Exclusion Rule - Similar activity (Schoolwide, TA) is funded in a non-Title school with supplemental funding, such as: State At-Risk Funding Palmetto Priority School Discretionary Grant Possibly, other funds that all schools are not eligible for.

Fiscal Moves to Consider Consolidation of federal funds in a Title I schoolwide project school. Consolidation of administrative funds from federal funds. If interested in exploring these fiscal moves, please contact us for more details on the pros and cons and the “how to.”

Fiscal Moves to Consider Transferability: Allows LEAS to transfer federal funds from one program to another. Funds that may be transferred include: Teacher Quality Title II, Part A, Education Technology Title II, Part D – subpart 1, Safe and Drug Free Title IV, Part A – subpart 1, and Innovative Programs Title V, Part A LEA must notify the SEA (30 days) but the authority to transfer is in the law.

Fiscal Moves to Consider These funds may be transferred within this cluster of funds. Funds may be transferred into Title I, Part A but may not be transferred out. Once the funding is transferred it becomes part of that program allocation (for that year) and is spent/reported according to the program guidelines.

Fiscal Moves to Consider Before transferring funds, an LEA must conduct consultations according to the guidance, determine which programs from which funds will be transferred and which programs will receive the funds, determine the amount and fiscal year, establish date of the transfer, modify affected program plans as needed, and notify the SEA (30 days). It is important to read the USDE guidance for details as the transfer of funds may affect set asides (parenting, private school, choice, and SES, etc.).

Fiscal Moves to Consider The fiscal moves may offer some flexibility for LEA’s that have lost funding. Always study the law and guidance. Always consult with your program office. The OFSA is willing to work with your district if you wish to explore any of these fiscal possibilities.

Questions 19

Roy Stehle Contact Information 20

Title VI Evelyn Towns Education Associate 21

Questions 22

Contact Information Evelyn Towns

Title III Supplement, Not Supplant Crystal Fields Education Associate 24

Professional development for content teachers so that they may better serve ELLs in their classes Paraprofessionals to assist ELLs in mainstream content classes Additional hardware (listening stations, handheld translators, dictionary devices) Additional software Manipulatives Additional reading materials (novels, magazines, newspapers, leveled readers) Listening materials (Play aways, Books on CDs) Visual aids (posters, pictures, flash cards) Allowable Expenses

Salaries for teachers providing core instruction, or instruction in content areas for which students earn credit. Translation and interpretation services for general and required school functions, including lunch menus, report cards. handbooks, NCLB-related parent notices, routine parent conferences, and IEP meetings and determination letters. Prohibited Title III Expenditures Include:

Salaries for support staff providing transitional services for families, including registration and placement support. Payment for teachers to attend LEP student meetings. Purchase of computers for ESOL teachers; content teachers were provided computers with local funds. Purchase of primary reading curricula. Purchase of general office supplies and equipment, such as telephone installation. Prohibited Title III Expenditures Include:

Consultants testing incoming kindergarten students. Salary for an instructional coach who worked on schedules and helped content teachers arrange for test accommodations. Title III-funded tutors and teachers who have the same job description as local and state-funded ESL and bilingual teachers. A split-funded parent liaison whose job description does not differentiate between Title III and non-Title III activities Prohibited Title III Expenditures Include:

District personnel Community (be cautious about confidentiality) Local colleges and universities (stipend) Translation companies Translations

Using state funds for ESOL teacher salaries while travel costs from one school to another were paid with Title III funds Supplanting --Travel

Questions 32

Crystal Fields Contact Information 33

Title II-A Updates Deborah Larkin Karen Cook 34

South Carolina’s Progress 35 The State reports > 97 percent of core academic classes taught by HQ teachers.

Improving Teacher Quality State Grants SOUTH CAROLINA $29,687, percent retained for SEA and SAHE administration The remaining 99% percent set aside for SEA- administered State activities 2.5 percent set aside for SAHE partnership grants 95 percent reserved for LEA formula subgrants $28,673, % based on census data of ages % based on poverty

ESEA Flexibility and Title II - A Waived Requirements of § Improvement plans for Non-HQ Teachers 2.Employment of Title I Paraprofessionals 37

Not Waived Highly qualified requirements for teachers of core academic subjects Standards for Title I instructional paraprofessionals Private school participation Inclusion in planning before decisions are made Equitable services under the programs to which and from which the funds are transferred, based on the total available for each program after the transfer 38

Private Schools Calculations for “Hold Back” When Transferring Title II – A Funds Divide the LEA “Hold Harmless” amount by the total number of students in public and private schools to determine a per pupil amount. II/documents/holdharmless.pdf II/documents/holdharmless.pdf Multiply the per pupil amount by the private school enrollment for that school’s equitable funding. “Hold back” the amount that will provide private schools with equitable participation. There may be additional funding for private schools, depending on how monies are expended in the program to which Title II-A is transferred. 39

Title II – A Staff 40

Procedure for Claiming Title II Funds No carryover Two awards with partial simultaneous periods of availability, as 12TQ (7/01/11-6/30/13) and 13TQ (7/01/12-6/30/14) Claims from 12TQ until exhausted Claims from 13TQ if there are no funds in the appropriate accounting function in 12TQ Claims from 12TQ and 13TQ simultaneously if 12TQ has insufficient funds to cover claim 41

Audit Procedures Initial Contact Fiscal Year Those Involved in the Audit: Title II contact The person responsible for monitoring progress toward the goal of having 100 percent core academic classes taught by HQ teachers Someone with fiscal responsibility

Be Aware of the Following…. Travel for Non-Approved Employees Food Purchases CSR Teacher Consistency CSR Teacher Salaries must supplement, not supplant Consultant Services Rendered 43

After the District Visit Opportunity for Clarification Documentation Audit Closes with Letter to Superintendent 44

Questions Feel free to contact us. 45

Deborah Larkin Karen Cook Contact Information 46

Migrant Education NCLB Title I, Part C Jennifer Almeda Education Associate 47

An eligible migrant student : 49

50 Qualifying agricultural work can include activities related to: Preparing/planting/picking/ packing/weeding crops Nurseries Sod farms Livestock Fishing/Seafood

Areas of Concern for Migrant Students: “The Office of Migrant Education identified Seven Areas of Concern through a process that involved research on the literature on migrant education and the needs of migrant students, and the implementation of a pilot program on needs assessment conducted in four states. These Seven Areas of Concern were found to consistently arise across several pilot states. The root causes are apparent in the migratory lifestyle of migrant children. The root causes include: Mobility Possible moves from one country to another Low wages for work Feelings of isolation from the larger community due to cultural adjustment and linguistic differences The Seven Areas of Concern are: Educational continuity Instructional time School engagement English language development Educational support in the home Health Access to services We suggest that you use these identified Areas of Concern as a framework for identifying the needs of migrant children in your state.” 53

 Federal law requires that eligibility must meet the definition of a migrant child.  The COE is available from the Migrant Program Web page: Please print and use as a two sided document. The original must be provided for review. Please send to Jennifer Almeda. Certificate of Eligibility (COE) 54  59% of eligible SCMEP students for funding in SY were OSY  OME has stressed the need to serve OSY  New SCMEP COE reflects importance of OSY

Questions 55

56 Contact Information Jennifer Almeda, PhD, SCMEP State Coordinator Phone: Fax: Bruce Wright, SCMEP State Migrant Recruiter Phone: Fax:

McKinney-Vento Homeless Assistance Act Title VII, Subtitle B Linda Mirabal-Pace Education Associate 57

The Definition Individuals who lack a fixed, regular, and adequate nighttime residence, including Sharing the housing of other persons due to loss of housing, economic hardship, or a similar reason Living in motels, hotels, trailer parks, or camping grounds due to the lack of alternative adequate accommodations Living in emergency or transitional shelters Awaiting foster care placement Abandoned in hospitals 58

The Definition Individuals who lack a fixed, regular, and adequate nighttime residence, including Have a primary nighttime residence that is a public or private place not designed for or ordinarily used as a regular sleeping accommodation for human beings who are living in cars, parks, public places, abandoned buildings, substandard housing, bus or train stations, or similar settings; and migratory children who qualify as homeless because they are living in the circumstances described above. unaccompanied youth (not in the physical custody of a parent or guardian) 59

Homeless Education and Title I District Title I plans must demonstrate compliance with the McKinney-Vento Homeless Assistance Act and coordination with the district’s Homeless Education program. Title I, Part A – Sec. 1112(a)(1) Title I Application See question 1 on page 5 See question 6, bullet 2 60

Homeless Education and Title I Title I mandates that school districts set aside a portion of their Title I allocation to serve homeless students attending non-participating schools. Title I, Part A – Sec. 1113(c)(3)(A) An LEA may use funds reserved under this section to provide services to eligible homeless students in both Title I and non-Title I schools that are comparable to services provided to non-homeless students in Title I schools. (Non-Regulatory Guidance, p.28, M-4) 61

Homeless Education and Title I Homeless children and youth are automatically eligible for services under Title I, Part A, whether or not they live in a Title I school attendance area or meet the academic standards required of other children for eligibility. Homeless children and youth may receive Title I educational or support services from Schoolwide and Targeted Assistance school programs. Title VII-B of the McKinney-Vento Homeless Assistance Act as amended by the No Child Left Behind Act of 2001 (NCLB) Non-Regulatory Guidance, July 2004, p. 27, M-1 62

Calculating Title I Set-Aside Identify homeless student’s needs, and fund accordingly Obtain count of homeless students and multiply by Title I, Part A per-pupil allocation Reserve a specific percentage based on your district’s poverty level or total Title I, Part A allocation For an LEA with a McKinney-Vento sub-grant, reserve an amount of funds greater than or equal to the amount of your request 63

How can Title I, Part A Set-Aside be used? Examples of Services: Supporting the position of the homeless liaison Tutoring Enrichment activities/educational trips Summer school Clothing (school uniform or suitable clothing) Extended-day activities School supplies Testing fees (i.e. GED, ACT, SAT) Activity fees 64

What You Can Do? Be familiar with the McKinney-Vento Act requirements. Invite Homeless Liaisons to Title I trainings Work together to develop state and local plans for serving homeless students Share awareness and informational materials Encourage regular interactions between local homeless liaisons and district Title I coordinators. 65

Web Resources National Center for Homeless Education National Association for the Education of Homeless Children and Youth National Law Center on Homelessness & Poverty United States Department of Education’s Web site on Education for Homeless Children and Youth

Questions 67

N & D Updates CSPR Data Collection Linda Mirabal-Pace Education Associate 68

N&D Timeline of Events August - LEA will receive annual notice of eligibility. September - LEA will locate unserved N&D residential facilities/sites. October - LEA will provide data to the SEA from each identified facility/site for the October count on a TBA December date.

N&D Application Process March/April – N&D preliminary allocation is provided to LEA for each site. April/May – Consultation with facility/site to review N&D application components. July – N&D program application is submitted as part of the LEA Title I project application. Final allocation may require project revision.

N&D Program and Evaluation Programs must target achievement in ELA and Math. Transition activity is integral. Pre and post testing in both academic areas provides the data for the required Consolidated State Performance Report. On an annual basis, facilities/sites must summarize achievement data through narrative for the required third year evaluation report.

CSPR Proposed Changes Numbers of students in Part D programs who are IDEA and LEP status of students (new to Title I, Part D) Transition services Able to collect data on student outcomes after exit? Number of students receiving transition services that address further schooling and/or employment Academic and vocational outcomes tables will merged Disaggregation of outcome/transition data (same items) Expansion of transition period to 90 days Pre-post mathematics and reading tables condensed from five to four levels of change on pre ‑ post tests Webinar – after changes are finalized

Questions 73

Linda Mirabal-Pace Phone: Contact Information 74

ScholarshipLuncheon Scholarship Luncheon 75 11:00 AM – 1:00 PM

ESEA Waiver Latest Updates Roy Stehle Title I Director

ESEA Waiver The ESEA Flexibility Waiver was approved in July of The new ESEA accountability system results were announced in August of Title I schools were identified for the Reward, Priority, and Focus categories as required.

ESEA Waiver ESEA Priority Schools (Lowest 5% of Title I schools based on student achievement) set aside 20% of funds and offered Choice and SES. The Office of School Transformation has worked with ESEA Priority Schools during the school year. ESEA Priority Schools were required to complete a Challenge to Achieve Plan with funding from state TA funds.

ESEA Waiver ESEA Focus Schools (10% of Title I schools based on greatest achievement gaps) set aside 10% of funds and offered Choice and SES. The Office of School Transformation and the Office of Federal and State Accountability has worked with ESEA Focus Schools during the school year. ESEA Focus Schools were required to complete a Challenge to Achieve Plan with funding from federal 1003(a) funds.

ESEA Waiver ESEA Support Schools are Title I schools that received an ESEA grade of F, D, and C. Funding will be provided to F and D schools from 1003(a) funds. Schools will complete a plan for spending the funds using the online application.

ESEA Waiver The top three ESEA Reward Schools in each reward category received funding to attend SCAT and present. The top Reward School in each category received funding to attend the National Title I Conference.

ESEA Waiver The waiver is for two years and will be up for renewal in The reauthorization of ESEA would determine whether the waiver is renewed. One half of the districts in the state did not have a priority or focus school and did not have to set aside funds for Choice and SES or do Challenge to Achieve Plans. The USED is monitoring the implementation of the ESEA Waiver.

Questions 83

Contact Information Roy Stehle

Title I Support Schools (1003a) Teresa Dillard, PhD Education Associate 85

12 BJ Funds (1003a) 12 BJ funds must be spent by September 30, 2013 Amend and/ or spend 86

Title I Support Schools Title I Support schools are classified as C,D, and F schools and are NOT identified as Priority or Focus Schools Schools designated as D or F will receive funding under 1003a funds based upon recommendations from Title I District Coordinators and the Committee of Practitioners Allocations to these schools will be made within a few days. Please check your for your allocation information The plan is due within the online application by mid April 2013 Funds should be expended by September 30, (Budget Period: April 5, September 30, 2014) 87

Title I Support School Plans Plans for the expenditure of funds must be submitted using the online Title I application When expending funds make sure activities are supplemental to state and local funds and coordinate with activities in current plans which address low achievement in the school Make sure that the activities are allowable under Title I Make sure the activities have a focus on the at-risk subgroups who are not meeting the Annual Measureable Objectives (AMOs) 88

Support School Plan in the Online Application This group of activities will be grouped in one section (just as Title I, Focus Schools or any other fund activities). In the schoolwide plan for each school, go to the strategies link in the section and click on “New TI Support (1003a) Activities. A budget report will be created and you must complete a Needs Assessment. 89

90

Parent Notification Priority and Focus Schools 91

92

Focus and Priority Schools Parent Notifications Notification of Choice A statement that names the Accountability Indicator and meaning of the indicator An explanation of how the achievement levels at this school compare to those of other schools in the district and state in terms of academic achievement of its students The reason(s) for being identified as a Focus or Priority School Example: insufficient participation in assessments or one or more subgroups not meeting academic proficiency targets 93

Focus and Priority Schools Parent Notifications (Cont.) An explanation of how parents can become involved in addressing the academic issues that led to the school’s rating An explanation of what the LEA is doing to help the school address this problem An explanation of student eligibility to attend another school ( Choice) 94

Focus and Priority Schools Parent Notifications Notification of SES Explain how parents can obtain SES for their child in clear, concise language that parents can understand. The explanation must: Include who is eligible for services State why services are being offered to low income students at said school Be in a uniform format (including alternate formats upon request (Visual/Audio) Be communication that is clearly distinguishable from other information on school improvement that an LEA sends to parents 95

Focus and Priority Schools Parent Notifications (Cont.) Notification of SES Identify each approved SES provider within the LEA or in its general geographic location, including providers that are accessible through technology, such as distance learning Describe the procedures and timelines that parents must follow to select a provider to serve their child Include where and when to return a completed application Include when and how the LEA will notify parents about enrollment dates and start dates Include whom to contact in the LEA for more information If an LEA anticipates that it will not have sufficient funds to serve all eligible students, it should also include in the notice information on how it will set priorities in order to determine which eligible students receive services 96

Focus and Priority Schools Parent Notifications (Cont.) Notification of SES Describe briefly the services, qualifications and evidence of effectiveness for each SES provider. The description must also include: The grade levels each provider will serve The subjects in which services will be provided Where and when each provider will offer its program How many sessions each provider will offer and how long each session will last The pupil/tutor ratio for each provider The qualifications of a provider’s tutors, if available Whether a provider operating off-site will offer transportation for students and Whether a provider is able to serve students with disabilities and 504 Plans or LEP students 97

Focus and Priority Schools Parent Notifications (Cont.) Notification of SES Include an explanation of the benefits of receiving SES. Districts are encouraged to include the following as benefits: Free tutoring that can be tailored to the particular academic needs of each participating student, at no cost to parents Parents are allowed to select the approved SES provider of their choice that best meets their child’s academic needs and The student will be in a safe environment that makes productive use of their out-of-school time 98

Questions 99

Contact Information Teresa Dillard, PhD

SES Updates Basil Harris Education Associate 101

2013–14 SES Application Process NewReturning There are two types of applicants: New and Returning Returning Applicants SES providers that were selected by school districts and who served students during the 2012–13 school year and intend to submit an application for the 2013–14 application year. The on-line portion of the application as well as the financial soundness documentation for returning applicants must be submitted by 3:00 p.m., EST, June 7, Specific communication will be sent to applicants in this category. (State-approved providers chosen as one of the ten providers to serve in a district and provided tutoring services only) 102

2013–14 SES Application Process Returning Applicants Returning applicants will not have to respond to questions a, b, c, and d of the on-line portion of the application. Returning applicants will be required to use their pre and post assessment data as well as the district’s pre and post benchmark assessments to respond to the application’s abstract. 103

2013–14 SES Application Process New Applicants Applicants submitting an application for the first time; State-approved providers who did not serve students for the 2012–13 academic year; Applicants whose 2012–13 application score did not meet the minimum required approval score; or Applicants who served in previous years but did not submit an application for the 2012–13 application year. The on-line portion of the application as well as the financial soundness documentation for new applicants must be submitted by 3:00 p.m., EST, April 4,

2013–14 SES Application Process School Districts as Applicants School districts with a designated Grade of C or higher as defined by the ESEA Flexibility Waiver, are eligible to apply. These districts include districts consisting of:  Reward, Focus and Priority Schools  Focus Schools Only  Focus and Priority Schools School districts with a designated Grade lower than a C, as defined by the ESEA Flexibility Wavier, are not eligible to apply. School districts with Priority Schools only, are not eligible to apply. 105

2013–14 SES Application Process On-site Interview New returning New applicants with a preliminary composite score of 110 or greater as well as returning applicants who submitted updated applications, will be invited to the SCDE to interview with a panel of non-partisan educators to determine placement on the “conditional list” of applicants. The interviews are anticipated to take place in June and July. SES Provider and School District Combined Mandatory Meeting will take place the last week in July (Exact Date TBD) 106

Questions 107

Basil Harris Contact Information 108

Parent Involvement Jewell Stanley Education Associate 109

District Parent Involvement Policy  Develop a jointly agreed upon written policy which establishes the district’s expectations for parental involvement;  Include the following required elements explaining how the district will: a.Involve parents in the joint development of the LEA plan and school improvement, b.Provide coordination and technical assistance to schools in planning and implementing effective parent involvement activities; c.Build the schools and parents’ capacity for strong parent involvement d.Coordinate and integrate parental involvement strategies with other programs e.Conduct an annual evaluation of the content and effectiveness of the policy f.Involve parents in the activities of schools served under Title I Section 1118 (b) (3), NCLB], Parent Involvement Guidance C-3, C-4 D-1 110

School Parent Involvement Policy Each school must develop, jointly with parents, a written school-parental involvement policy that describes how the school will carry out the parental involvement requirements.  Schools may amend current policy to reflect Title I requirements  Any comment from parents not satisfied with this policy must be kept on record 111

School-Parent Compact Remember to include: 1.Parent-teacher conferences 2.Frequent reports to parents on their child’s progress 3.Reasonable access to staff 4.Opportunities to volunteer 112

Parent Notifications Parents’ Right to Know At the beginning of the school year, parents must be informed of their right to request information about qualifications of teachers and paraprofessionals. (District) If substitutes who are not highly qualified are used for four or more weeks, a letter must be sent to parents explaining the current classroom status. (Schools) 113

Parent Notifications Provide information to parents of students who have Limited English Proficient students about available programs, parent options, and program effectiveness. (District) Provide parents with information about schools identified as Focus or Priority (District) 114

Parent Notifications for Choice and SES A statement that names the Accountability Indicator and meaning of the indicator An explanation of how the achievement levels at this school compare to those of other schools in the district and state in terms of academic achievement of its students The reason(s) for being identified as a Focus or Priority School An explanation of how parents can become involved in addressing the academic issues that led to the school’s rating An explanation of what the LEA is doing to help the school address this problem An explanation of student eligibility to attend another school Explain how parents can obtain SES for their child Describe briefly the services, qualifications and evidence of effectiveness for each SES provider. 115

Parent Notifications Format A district must promptly notify parents directly: through regular mail or through the district or school and must also be disseminated through broader means of communication (i.e. Internet, news media, and public agencies serving students and their families) Basic Requirements: Uniform format Clear and non-technical language If feasible, convey info to LEP parents in either written or oral translations that they can understand 116

117 School Level Requirements Convene an annual meeting Conduct an annual evaluation of the parental involvement policy

Annual Parent Meeting  Title I program  School Choice  AYP  SES  Curriculum  Other information related  Assessment to academic program During the meeting, provide parents information about: Be sure to document with meeting notices, agendas, sign in sheets and minutes. [Section 1118 (c) (1)] Parent Involvement Guidance, D-5 118

Annual Evaluation of Parent Involvement Evaluating your plan should include LEA and school staff as well as parents All Title I parents be aware that the plan is being evaluated and understand the procedure for feedback Feedback may be gained by avenues such as: serving as a member of the committee conducting the evaluation completing a parental involvement survey participating in parent focus groups; etc. 119

Annual Evaluation of Parent Involvement Questions to consider: 1. What were our student achievement goals this year? 2. How did we work as partners with parents in meeting those goals? 3. How can we improve with actively involving parents in the activities of our schools? 4. Do we have any barriers to parent involvement that need to be addressed? 5. How are we doing with distributing our LEA and school parental involvement plans to all Title I parents? 6. How can we improve on training that is offered to parents: To help them work with their child at home? To help them to be active partners in LEA and school decision-making? 7. How can we improve on training that we offer school staff/teachers to help them to work more effectively with parents? 8. Based on these evaluation findings, what changes do we want to make to our parental involvement plan for next year? 120

121 Reservation of Funds for Parental Involvement Districts must ensure that Title I schools: Reserve at least one percent of the district’s total Title I, Part A, allocation to carry out parental involvement activities for divisions receiving $500,000 or more; and Set aside at least 95 percent of the reserved funds to be distributed to participating schools.

Questions 122

Contact Information Jewell Stanley

Monitoring Title I, Part A Findings and Updates Time and Effort Private Schools Garry Baxley David Boison Bobby Rykard 124

Monitoring Advice we have: Being organized is critical Use monitoring forms as basis for your files or binder Hold and document required Title I meetings If district does not have a required policy, develop and write out your procedure 125

Monitoring Areas needing attention Written policy or procedure for responding to parents suggestions or request for information Written policy or procedure for hiring highly qualified paraprofessionals and teachers Written policy or procedure for retaining documentation 126

Monitoring Areas needing attention Document school planning team meeting Document school parent involvement meeting Document first Title I meeting (at beginning of school year) Documentation = announcement, agenda, sign- in sheet and minutes 127

Monitoring Areas needing attention Private school letter (late, no Civil Rights requirement, 25 mile rule) School-home compact not complete (4 items at minimum) Choice option: letter, web and newspaper 128

Monitoring Areas needing attention Title I budget not balanced MOE miscalculated Equipment reconciliation not signed 129

Monitoring Areas needing attention External audit findings: Semi annual cert. forms or personnel activity reports not completed Districts not monitoring Excluded Parties List Inadequate segregation of duties Internal controls inadequate re: material misstatements Internal vs. external auditors 130

David Boison Garry Baxley Contact Information 131

Time & Effort Bobby Rykard Team Leader 132

Time & Effort Records Staff paid from and working on activities associated with a single federal award : Do not need to complete time sheets or maintain supporting documentation These positions must be documented by a semi-annual certification signed by employee or supervisor Need to be signed after the fact upon completion of job responsibilities at the end of the semi-annual period 133

134

Time & Effort Records Staff paid from multiple funds (multiple federal or combination of federal/state funds) and working on multiple activities: Example, district coordinators working on multiple programs, instructional staff working to serve different populations or program-specific activities Salaries/benefits for these types of activities must be supported by a monthly time sheet (or master schedule collected and signed monthly by the employee) and supporting documentation Time sheet activity must be compared to budgeted distributions at least quarterly If variance is greater than ten percent make adjustments quarterly If variance is within ten percent make adjustments annually 135

136

137

Time & Effort Records Staff paid from multiple funds (multiple federal or combination of federal/state funds) and working on the same activity in a schoolwide plan: Examples: teacher/paraprofessional providing the same type of instruction throughout the day or to reduce class size Parent coordinator/facilitator These positions may provide a semi-annual certification attesting to working on this single activity only in the schoolwide plan 138

139

Questions 140

Bobby Rykard Contact Information 141

David Boison Education Associate 142

Private Schools Read section 1120 of Title I, Part A law: “Participation of children enrolled in private schools.” 143

Private School Read: USDE Title I Services to Eligible Private School Children, Non-Regulatory Guidance, October 17,

Private Schools “25 Mile Rule” You must contact private schools within a 25 mile radius of each of your Title I schools These private schools may be in and/or outside of your district 145

Private Schools Private school letter Send letter in early March of each year, certified with return receipt Address letter to Principal, Headmaster, Headmistress etc. Solicit their participation in Title I per section 1120 Include requirement to comply with Civil Rights Act of 1964, Section 504 of the Rehabilitation Act of 1973, Title IX of the Education Amendments of 1972, and the Age Discrimination Act of Provide form for them to reply to you “Yes or No” 146

Private School Private School letter (cont.) Give them deadline to reply (at least 2 weeks) If they wish to participate in Title I let them know that you will meet with them to consult on the program you will both develop Give them date, time and place of consultation meeting 147

Private Schools If a private school does participate: 1. Read Section 1120 of Title I, Part A 2. Read Federal guidance 3. Contact me for help if needed: David Boison, , 148

Questions 149

David Boison Contact Information 150

District Set-Asides Bobby Rykard Team Leader 151

Required Title I Set-Asides Parent Involvement - 1% Homeless – no defined amount Choice/SES 20% for Priority 10% for Focus HQ Professional Development (as needed) 152

Title I Set-Asides Although some flexibility exists, generally, Title I, Part A funds may not be used to implement district-wide activities (Title I and Non-Title I schools). (B-7) The use of Title I, Part A funds to support district-wide activities will usually constitute an unallowable use of Title I, Part A funds or a violation of the supplement not supplant requirement. (B-7) 153

Non-Required Set-Aside Basis Title I legislation specifies that the only method to distribute funds to schools is based on per- pupil amounts (PPA) following the poverty ranking rules (ESEA Section 1113). However, guidance allows a few exceptions… 154

Allowable Non-Required District Set-Asides (PPA Consideration Not Required) Administration Allowable - District level staff, district level office supplies, district level equipment, travel, etc. Non-Allowable – Staff assigned to an individual school, instructional supplies/materials, school level software/technology (these should be included in school- wide plans or complete a PPA analysis demonstrating compliance with poverty ranking/PPA rules) Indirect Cost 155

Allowable Non-Required District Set-Asides (PPA Consideration Not Required) Parent involvement above 1% requirement Additional neglected/delinquent funds Support Services Supplemental health/nursing, guidance, or social services Must complete the “Support Services Activity Application ” 156

Allowable Non-Required District Set-Asides (PPA Consideration Not Required) Supplemental Pre-School Example – Expanding half-day to full-day Summer School for Title I Schools Housed at shared locations is allowable as district set-aside. Otherwise, should be included in the school-wide plans. Extended Learning Time Before/after school housed at shared locations is allowable as district set-aside. Otherwise, should be included in the school- wide plan * Must complete “District Set-Aside Instructional Program Application” for allowable district programs 157

Allowable Non-Required District Set-Asides (PPA Consideration Not Required)  Hiring of District Level Staff for Title I Schools Parent Coordinator of multiple schools SES Coordinator School Facilitators that oversee multiple Title I schools Instructional Coaches for multiple Title I schools School based staff assigned to an individual school should be included in schoolwide plans 158

When Must PPA be Considered? The following items would need to be included in schoolwide plans or consider PPA to schools if established as district level set-aside: Supplemental instructional supplies to Title I schools Technology or software unassociated with a specific allowable set-aside to Title I schools (Pre-K, summer school, intercession, etc.) Supplies/materials for media centers Other district level activities without apparent connection to previously mentioned district set-aside instructional programs 159

PPA Analysis Example 160

Questions 161

Bobby Rykard Contact Information 162

Title I Eligible School Attendance Areas Page 2-A Bobby Rykard Team Leader 163

Title I School Eligibility Basic eligibility is 35% poverty Schools must be served in rank order by highest poverty percentage Schools above 75% must be served (as funds are available) After serving schools above 75% poverty, the district may serve schools by grade span *Exception - Districts with less than 1,000 students or one school per grade span are not required to rank schools to be served 164

Skipping Schools Eligible schools may only be “skipped” when other supplemental state and local funds are allocated to that school and they are used in a “Title I – like” manner Lottery funds, Act 135 funds, any state funds for at-risk schools, other discretionary funds District needs to be specific about the source of funds or how the funds are supplemental These funds will be reviewed during monitoring, on-site reviews or desk reviews to ensure funds are budgeted and expended in these schools The school-wide plan must be completed and submitted to demonstrate these requirements School must maintain comparability 165

New Schools Estimate attendance and free and reduced lunch count Reexamine after the first week of school to see if a radical change has occurred that would result in ranking issues 166

Questions 167

Bobby Rykard Contact Information 168