Title IA Fiscal Issues Jackie Godbout Title IA Program Consultant 624-6705 jackie.godbout@maine.gov

Title I Part A – Basic Program for Disadvantaged Part B – Reading First, Early Reading First, & Even Start Part C – Migrant Education Part D – Neglected & Delinquent Part F – Comprehensive School Reform Part G – Advanced Placement

Title I-Sec. 1003 & Title IA-Sec. 1115(a) Even though the general purpose statement for Title I, Parts A-H is to ensure that all students have a fair, equal, and significant opportunity to obtain a high-quality education and reach, at a minimum, proficiency on challenging State academic achievement standards and assessments,

Title I, Part A resources are to be used only for programs and services to support all eligible children served under this part as defined under Section 1115(b) or a schoolwide program as defined under Section 1114.

Section 1120A Title IA Fiscal Requirements Maintenance of Effort = LEA Comparability = School Supplement, not supplant = Student

Sec. 1120A(a) Maintenance of Effort Requires districts to maintain fiscal effort by at least 90% from year to year. If not, federal funds are reduced. The expenditures on the EF-M-45 are used for this comparison. Determination is made in June using the preceding two completed years’ data. We compare total expenditures and a per pupil expenditure. The LEA must reach 90% in at least one of these categories. Expenditures not considered: Debt service and Capital Outlay A waiver may be requested through USDE

Section 1120A(c) Comparability of Services …is a precondition to receiving Title I Funds …is about fairness …looks only at state and local resources …compares each Title I school to the average of non-Title I schools or, if all schools are Title I, to each other.

Comparability [cont’d] Comparability is flexible. May exclude schools with less than 100 students. Has a variety of measures. May be measured by school size—large vs. small. May be measured school by school or grade span by grade span. May be measured differently for schoolwides vs. targeted assistance schools.

SEAs responsibilities regarding comparability Establish procedures for LEAs to use to determine comparability. Definition: Maine has adopted the teacher/student ratio and the per pupil instructional staff salary expenditure. Timeframe for making comparability determinations and adjustments: October 1-November 1. Recordkeeping Requirements: Documentation to support staff counts and student enrollment numbers reported. Monitoring for compliance.

LEAs responsibilities regarding comparability Determine what measure to use—either state adopted form or other as noted in the Consolidated NCLB Application. Develop written procedures if using other than state adopted form. Calculate annually. Document and submit to the state that Title I schools are comparable. Maintain records for three years.

Supplement, Not Supplant Section 1120A(b) A SEA or LEA shall use these Title IA funds to supplement the funds that would, in the absence of such federal funds, be made available from non-Federal sources for the education of students participating in programs under this part, and not to supplant such funds. “As hard as I try, I just don’t know if I’m using Title I funds to supplant state or local funds. Can you help??” Desparate in Detroit

Supplement, not supplant Testing To test for supplanting apply these assumptions: Is the activity required by federal, state or local law? Year to Year (Were the services/person supported with local funds in the prior year?) Title I vs. Non-Title I—Are these services provided to non-Title I students or in non-Title I schools? If you answered YES to any one of these, then supplanting is assumed and rebuttal can occur.

Supplement, Not Supplant Exclusion You may exclude supplemental state and local funds used in unserved Title I eligible schools so that Federal funds may be used in the higher-poverty schools. However, an LEA may no longer use supplemental state and local funds in an ineligible Title I school without also providing Title I eligible schools their fair share of those funds.

Carryover Funds An LEA has considerable discretion in using carryover funds: Allow each school to retain its carryover funds for use in the subsequent year. Add carryover funds to the LEAs subsequent year’s program. Designate carryover funds for a particular district/school activity.

Carryover for Setasides For those setasides required by law I.e. parent involvement, 10% AYP staff development, the LEA must carry over the unspent funds and spend them for the specific purpose in addition to the full reservation for the following year.

Schoolwide Fiscal Accountability The law requires the SEA to remove financial barriers for consolidating funds in a schoolwide program to support and upgrade the school’s entire program. So, may a schoolwide program use Federal funds on any activity?

Schoolwide [cont’d] Yes, ONLY IF… The school’s comprehensive needs assessment demonstrates that such activity is needed to raise the achievement of students in the school, particularly the lowest-achieving students. The schoolwide plan reflects the need. The school’s annual evaluation demonstrates that the program is effective in raising student achievement.

Title I Rules of Thumb for In-Class Delivery Models Responsibility: The Title IA staff is responsible to provide assistance to identified Title I participants when in the class. Duties: The Title IA staff may not assume any of the duties the classroom teacher would be required to perform as part of the regular instructional program. Team Teaching: The sharing of delivery of the regular instructional program in the classroom is not allowed.

Title IA Demonstration Lessons These lessons, for the specific benefit of Title I children, would be intermittent and presented on an irregular basis as a particular need of the Title I children in the class becomes apparent. No regularly scheduled whole group instruction by the Title I teacher may occur.

Cooperative Learning Groups Having the Title I staff scheduled to work regularly with pre-established, fixed cooperative learning groups containing Title I and non-Title I students I not allowed. The Title I staff may facilitate cooperative learning groups with Title I and non-Title I students only until the Title I students have mastered the specific objective for which the group was formed.

Heterogenous Groups Similar to the Cooperative Learning Groups, this arrangement lasts only until the Title I children have mastered the specific objective for which the group was formed.

Small Group Work The Title I staff may not work with small groups within the classroom that have no Title I students in them.

Rules of Thumb for Pull-Out Delivery Model Section 1115(c)(1)(C)(iii): Minimize removing students from the regular classroom during regular school hours. Ensure that the regular program of instruction in the content is delivered by the classroom teacher.

Notice: The following examples apply to a Targeted Assistance School (TAS) program. Schoolwide programs will be discussed in a future meeting.

Supplement or Supplant Examples Local and Title IA funds are used to provide a classroom math workbook for all students. Supplement or Supplant

Answer Supplant Title IA funds may not be used to purchase materials for the general education program.

Supplement or Supplant Example Local, Title IA and Special Ed funds are used to purchase an assessment to be administered to all students for a variety of reasons, of which one reason is for Title I identification and selection. Supplement or Supplant

Answer: Supplant. An LEA may not provide an assessment  for non-Title I students with State and local funds while using Title I funds to provide the same assessment for Title I participating students. (This principle applies within a single Title I school, or across the district among Title I and non-Title I schools.) This would violate the supplanting prohibition because an LEA may not use Title I funds to provide services to Title I students that it provides with non-Title I funds for non-Title I students.In addition, for targeted assistance schools, it is the responsibility of the LEA to identify at-risk students from State or local sources. Once eligible children are identified, Part A funds may be used to identify those most in need or to identify their specific educational needs. (Nola Cromer, USDE)

Supplement or Supplant Example The LEA hires a K-12 Director of Curriculum. All the Title I schools in the LEA are K-8 targeted assistance schools. Thirty percent of the students in the LEA receive Title I services. Title I pays for 30% of the Curriculum Director’s salary. Supplement or Supplant

Answer: Supplant. This is a K-12 position and this employee is responsible for the curriculum for all students, not just Title IA students and Title IA schools. No supplemental services are being provided by the Curriculum Director.

Supplement or Supplant Example The district offers a Title I summer school and accepts non-Title I identified students because local funds also support the summer school. Supplement or Supplant

Answer: Supplant. By adding local funds to the Summer School program and opening it to all students, the Title IA students are not receiving additional services.

Supplement or Supplant Example Title I funds pay for an extended day K program and/or a pre-K for identified low-achieving students. Supplement or Supplant

Answer: Supplemental. As long as only Title IA identified students participate in the programs, then they are receiving additional services.

Supplement or Supplant Example Title I funds are used for a high school summer program where students who have failed a class receive this instruction and receive a new grade and credits, if passed. Supplement or Supplant

Answer: Supplant. Title IA can provide supplemental tutoring services in the summer but may not be used to provide core instruction on which a grade or credit will be issued.

Supplement or Supplant Example Title I purchased materials for a Title I Demonstration Lesson that involved the whole group. These materials are then going to be used by the regular classroom teacher and the whole class during future instructional activities. Supplement or Supplant

Answer: Supplant. The purchase is to support the whole class to be used by the classroom teacher and will not be under the control of the Title I program.

Supplement or Supplant Example The district has chosen a new K-8 math curriculum. The district uses Title I funds to provide additional Staff Development after the core program staff development has been provided by the district. Supplement or Supplant

Answer: Supplement. As long as the district has already provided the core staff development required to implement the new program and offers Title IA services in the content area, then Title IA funds may pay for additional staff development to enhance instructional strategies directed at the needs of Title IA students.

Play “Bureaucrat for a Day” Write Your Own Example/Answer E-mail to jackie.godbout@maine.gov by June 16. We will review, modify, and post to the workshop overheads. Result: A wonderful resource for all of you to use as you plan your projects and expend your Title IA funds. Prize: The satisfaction that you have contributed to the successful implementation of the program and use of Title IA funds.

QUESTIONS or CONCERNS????