1. Office of Field Services
Ensuring Equitable Services for School Children Attending Private Non-Profit Schools
The purpose of this PowerPoint is to provide you with an overview of the requirement that Local Educational Agencies (LEAs) provide equitable services to students, teachers and other education personnel and parents of students attending private non profit schools. The equitable services provision is as old as the Elementary and Secondary Education Act (ESEA), and is authorized by the No Child Left Behind Act of This overview will focus on the essential elements of equitable services requirements as they relate to “Funding,” “Services for Children, Teachers and Families,” “Program Evaluation ” and “the Consultation process.” The topic of “Third Party Contracts” is provided as PowerPoint slides as a handout.
Office of Field Services

2. Field Services Consultants Office of Field Services
Katie Doerr Parker
Gayle Green
Yvonne W. Mayfield
Field Services Consultants
Office of Field Services
Contact information and resources for this PowerPoint are located on the OFS website,

3. Our focus is on the improvement of student academic achievement
Our focus is on the improvement of student academic achievement. We value the many partners that support our efforts towards the success of this mission.

4. These are the principles that guide our daily work and were derived with input from focus groups throughout the State.

5. Ensuring Equitable Services for Private Non-Profit School Children -
Reference Materials
The following handouts are available on MDE’s website,
Ensuring Equitable Services for Private Non-Profit School Children -
Power Point
Overview Technical Assistance Packet – Working with Private Schools
Allocation Worksheets
Non-Regulatory Guidance
Private School Questions and Answers
Equitable Worksheet
You are encouraged to review the materials that are available on the Michigan Department of Education website, In addition to the PowerPoint, an Overview Technical Assistance (TA) Packet, as well as stand alone TA packets for each categorical program that is subject to equitable services for private, non-profit school students, is available for downloads. TA packets include general information on how to implement PNP programs that meet statutory and regulatory requirements, a suggested consultation timeline, sample letters, documentation forms for each funding source, a chart of allowable uses of funds, and certifications for equipment and instructional materials. Additionally allocation worksheets, guidance and a Q & A are available.

6. Reference Materials Technical Assistance Packets – Title I, Part A
Title I, Part C
Title II, Part A
Title III, Part A
A Technical Assistance Packet includes each of these funding sources requiring equitable shares for participating private schools.

7. REQUIREMENTS
The next several slides will further review and clarify details relevant to equitable services for children.

8. Equitable Services Requirement- District Responsibility
Equitable Participation in:
Title I, Part A Improving the Academic Achievement of the Disadvantaged
Title I, Part C Migrant Education
Title II, Part A Teacher & Principal Training & Recruiting
Title III, Part A Language Acquisition Program
(English Learners and Immigrant Students)
The equitable services provision requirement applies to districts that receive the following federal funding: Title I, Part A for improving the Academic Achievement of the Disadvantaged; Title I, Part C for Migrant Education; Title II, Part A for Teacher & Principal Training and Recruitment; Title III, Part A, which must be used to increase the English proficiency of English Learners and Immigrant Students.
The focus of this presentation will be on Title I requirements. For a further explanation of Title I and other funding sources, refer to the Overview Technical Assistance Packet on Working with Private Schools and the stand alone Technical Assistance packets for each categorical program that was highlighted in slide 6.

9. Equitable Services Requirement
In order to meet Equitable Services requirements, a Local Educational Entity (LEA) must annually notify all private, non-profit schools within its boundaries and outside of district if resident students attend, of eligibility for equitable participation with Title programs
Under the equitable services requirement, the LEA must annually notify private school officials that have students who reside in the LEAs attendance area of eligibility for equitable participation in Title programs. Scheduling a consultation meeting is critical to ensuring that funded programs meet the needs of all students. Subsequent slides in this presentation will address the consultation in more detail.

10. Equitable Services Requirement
Low-income parents with private school children are included in census poverty counts that generate funds the Local Educational Agencies (LEAs) use for Title I services
The law requires that local LEAs receiving these funds provide eligible private school children with Title I benefits that address their needs because low income parents with private school children are included in the census poverty counts that generate funds that local educational agencies (LEAs) use for Title I services. These benefits must be provided on an equitable basis.

11. Equitable Services Requirement Child Benefit Theory
This theory was developed to comply with the Constitutional prohibition against Federal funding to private schools. No funds go directly to private schools.
Under the Child Benefit Theory, Title I services –
Benefit the individual child, not the private school
Are provided by the LEA, not the private school
There is a constitutional prohibition against federal funding to private schools. The Child Benefit Theory was developed to ensure 1), that Title I funding provided to PNPs under the equitable services provisions, benefits the individual child and not the private school, and 2) that Title I services are provided by the LEA and not the private school.

12. Equitable Services Requirements
In order to meet equitable services requirement, an LEA must:
Provide eligible private school children with an opportunity to participate;
Meet the equal expenditure requirements for instruction, professional development, and parent involvement;
Assess student needs and the effectiveness of the Title I program; and
Begin Title I programs at the same time as the Title I programs for public school children.
If an LEA applies for and accepts the federal funding, it is required to:
Provide private school children with an opportunity to participate;
Meet equal expenditure requirements for instruction, professional development, and parent involvement;
Assess the needs of students and the effectiveness of the Title I program; and
Begin Title I programs for private school students at the same time it begins the programs for public school children.
Please note that Equitable Services participation is not required of Public School Academies

13. Equitable Services Requirement Program Responsibility
The LEA is responsible for designing and implementing Title I programs for its resident children who attend private schools, even those attending private schools located in other LEAs
ESEA has legislated responsibilities for developing and implementing private school Title I programs and for making budgetary decisions to the LEA only. A district may not delegate these responsibilities to the private school.

14. Equitable Services Requirement Program Responsibility
The LEA is responsible for making program and budgetary decisions based on timely and meaningful consultation with the private school.
Program designs and budgetary decisions are to made by the LEA based on timely and meaning consultation with the private school.

15. Consultation
This section of the PowerPoint provides information regarding consultation requirements between LEAs and participating private schools.

16. Consultation Requirements What is Consultation?
Consultation involves discussions between public and private school officials on key issues that affect the ability of eligible private school children to participate equitably in Title I programs
What is consultation? Consultation is the discussion between both the public and eligible participating private schools. Discussions must involve open and honest dialogue about eligible private school children and their opportunities for equitable participation in Title I programs. It is important to have agendas for consultation meetings throughout the school year of planning and implementation. A sample agenda is provided in the overview technical assistance packet.

17. Consultation Requirements
Must occur during the design, development, and implementation of the Title I programs
Must include meetings
Must occur prior to the LEA making any decisions
Must continue throughout implementation of programs
Must be documented (Reference the Private School Consultation Checklist)
Complete the process by May 1st
Consultation must occur in a timely and meaningful manner, prior to the LEA making any decisions. The consultation must include meeting with PNPs to design, develop and discuss how the services will be implemented. May I reiterate the consultation with private school officials must occur prior to LEA making any decisions of private school programming. Consultation meetings must continue throughout the implementation of programs.

18. Consultation Requirements
What topics must be addressed during consultation?
Consultation:
If you do not remember anything else from the resources previewed today, remember this word – CONSULTATION! It is required by law and is discussed in the guidelines. It is essential to the successful implementation of Federal education programs.
Don’t wait for the PNPs to initiate consultation. Resolve to make a phone call to your private non-public schools today.

19. Consultation Requirements
At a minimum, consultation must address:
How the LEA will identify the needs of eligible children
What services the LEA will offer
How and when the LEA will make decisions
How, where, and by whom the LEA will provide services
How the LEA will assess the Title I program and use the results to improve Title I services
Consultation meetings must include discussions of equitable services and programs a LEA can provide to the PNPs. As set forth in Federal regulations, the consultation must focus on issues including, but not limited to the following: 1) How the LEA will identify the needs of eligible private school students. 2) What services will the LEA offer to eligible students? 3) How and when the LEA will make decisions about the delivery of these services. 4) How, where, and by whom the LEA will provide services to eligible private school students. 5) How the LEA will academically assess services to eligible private school students and how the LEA will use the results of that assessment to improve Title I services. Remember it is critical that student eligibility be clearly outlined and discussed during the consultation. There must be a written student selection criteria and it must include the factors that will determine which students with greatest need will be served.

20. Consultation Requirements
At a minimum, consultation must address:
The size and scope of the equitable services and the proportion of funds the LEA will allocate for services
Method or sources of data the LEA will use to determine the number of low-income students
Services the LEA will provide to teachers and families of participating children
Discussion of service delivery mechanism the LEA can use
A thorough consideration and analysis of the views of private school officials services through a contract with third-party provider
6) It is also imperative that the size and scope of the services and the proportion of funds that will be allocated for services are discussed in detail. These services are based on eligible private non-public participants. 7) Method or sources of data the LEA will use to determine the number of low-income students. 8) The services the LEA will provide to teachers and families of participating students must be clearly outlined. 9) The service delivery mechanism the LEA can use for programming. 10) A thorough consideration and analysis of the views of private school officials services through a contract with a third-party provider.

21. Consultation Requirements
Private school officials have the right to complain to the SEA for the following reasons:
The LEA did not engage in timely and meaningful consultation
The LEA did not give consideration to the views of private school officials
The LEA disputes the low-income data provided by private school officials
The SEA resolves the complaint
To add real teeth to the consultation provisions, Federal law requires LEAs to obtain written documentation for each funding source from private school officials stating that timely and meaningful consultation has occurred. (MDE’s Overview Technical Assistance Packets contain sample documentation forms.) These documentation forms must be signed by officials of each private school with participating children or appropriate private school representatives. The documentation forms must be maintained by the LEA. The guidance states that SEAs have the discretion to ask LEAs to submit the documentation as part of the annual Title I application process or at another time. Finally, the statute explicitly states that private school officials may appeal to the SEA if they feel appropriate consultation was not provided. The SEA must resolve complaints after thorough investigations of the complaints.

22. Equitable Services for Teachers & Families Professional Development
REQUIRED CONSULTATION TOPIC: LEA must consult with private school officials prior to the LEA designing and implementing professional development activities that increase the private school teachers’ skills and knowledge on how to better instruct their students
Regulations further explain that the use of the reservation for private school teachers must be determined through timely and meaningful consultation with private school officials. As determined through consultation, the LEA may either conduct these activities in conjunction with the LEA’s professional development activities for the public school teachers of participating students, or independently. In any case, the services must meet the needs of the private school teachers on how to better instruct and meet the needs of their students.

23. Funding for Equitable Services
The next several slides will further review and clarify details relevant to equitable services for children.

24. Funding for Equitable Services Collecting Poverty Data
An LEA may calculate the number of private school children* who are from low-income families and live in participating public school attendance areas in several ways:
Use same measure of poverty as for public school children. The majority of districts in Michigan use free and reduced price meals eligibility as its source of data
Use comparable poverty data from a survey and must extrapolate results if actual data are unavailable
Use comparable data from a different source
Use an equated measure
* LEA must collect poverty data on their resident low-income children attending private schools in other LEAs.
Guidance provided by the USED says LEAs “must obtain the best available poverty data on private school children residing in participating public school attendance areas.” In addition the guidance asserts that if available, LEAs should use the same measure of poverty used to count public school children. Only if these data are not available should they resort to one of the other methods of determining poverty. To obtain the count of private school children from low income families, the law and regulations provide several allowable measures of poverty. Districts may use the same measure it uses for public school children if available, such as free and reduced lunch eligibility;
Comparable poverty data from a survey;
Comparable data from a different source, such as scholarship applications; or
An equated measure.
The majority of LEAs in Michigan use the free and reduced price meal eligibility of private school students as its data source for the poverty measure.

25. Funding for Equitable Services Generating Funds for Instruction
Low-income public and private school children residing in the same Title I attendance areas generate the same per-pupil amount (PPA)
PPA x the number of low-income private school children residing in participating public school attendance areas = instructional funds for the Title I programs for eligible private school children
After the poverty data has been reviewed, a per-pupil amount, or PPA, is calculated and is the same for low income public and private children within the Title I attendance area. That PPA is multiplied by the number of low income private school children residing in the attendance area to determine total funding available to provide supplementary instructional support for eligible private school children.

26. Funding for Equitable Services Generating Funds for Instruction
Funds may be generated from multiple LEAs with students attending a private school or from multiple attendance areas within a district.
Funding and program services for students attending a particular private school may be provided by multiple public school districts whose students live in various attendance areas but attend the same private school. Also, students attending the private school may reside in various attendance areas within a single-district. In both scenarios, per pupil formulas will vary based on per pupil amounts determined for each public school representative of private school student attendance areas.

27. Funding for Equitable Services Generating Funds for Instruction
e complaint
Eligible Public School Attendance Area
(1)
Grade Span Group
(2)
Percent Low- -Income
(3)
Amt. Per Low-Income Child
(4)
Public Low Income Count
(5a)
Section 31a Funding Per Child
(5b)
Public Amount
(5c)
Carryover and Parent Involvement Reservations
(5d+5e+5f)
Total Public Amount
(5g)
Private Low Income Count
(5h)
Private Amount
(5i)
School A
K – 8
85%
$780
460
$358,800
$23,000
$381,800 29
$22,620
School B
79%
516
$402,480
$36,500
$438,980
School C
65%
375
$492,500
$13,000
$305,500 15
$11,700
This chart illustrates the allocations for private schools based on multiple attendance areas within a LEA district. Private schools would receive program services from multiple districts according to multiple residing areas of eligible students attending their schools if private schools agree to participate in Title I programs.

28. Funding for Equitable Services Generating Funds for Instruction
Funds generated by low-income private school children who reside in Title I attendance areas must be used only for instructional services
Funds that are generated by the low-income private school children may only be used for instructional support.

29. Funding for Equitable Services Reservation of Funds
If an LEA elects to reserve funds for district level instructional activities, such as summer school, for public school students, the LEA must also provide from those reserved funds equitable services to eligible private school children. These funds are in addition to per pupil funds designated for instructional services.
Equitable funds for all district initiatives set-asides for instructional programs, additional professional development and parent engagement activities, must be reserved for private schools to be used in the same areas that generated the funds. Set-asides for Priority and Focus School reservations are not included in this requirement.

30. Title I Funds for Equitable Services District-Wide Instructional Activities
Districtwide Instructional Program(s) Reservation (does not apply to preschool programs) in participating public school attendance areas: No. of private school children from low-income families divided by total no. of children, public and private, from low-income families equals proportion of reservation _______5,000____ ÷ ______10,000_______ = _____5%___ (Proportion of Reservation)__5% x _$50,000__Reservation = $___2,500 for Equitable Services
The next several slides will further review and clarify details relevant to equitable services for children.

31. Funding for Equitable Services Carryover
LEAs must consider the equitable services requirements when making any decision about the use of district reservations and carryover funds:
Instructional Programs
Professional Development
Parent Involvement
Carryover funds are also subject to equitable services requirements. If carryover results from circumstances under the control of the district, then the carryover funds must be reserved for services to eligible private school students. On the other hand, if the carryover results from lack of full participation by the PNP, then carryover fund use may be determined by the district.

32. Equitable Services for Children
The next several slides will further review and clarify details relevant to equitable services for children.

33. Equitable Services for Children Selection of Students
Private school children who reside in Title I participating public school attendance areas AND are failing or most at risk of failing to meet student academic achievement standards
Homeless; 2 preceding years in Head Start; Great Start Preschool Program; Title I Preschool; Title I, Part C (Migrant Education)
Grades pre-K-2: selected solely on the basis of teacher judgment, interviews with parents, developmentally-appropriate criteria and local assessments
Grades 3 and above: selected using multiple written selection criteria
Poverty is NOT a criterion!
ESEA clarifies who is eligible to receive services under the equitable services provision. In order to receive equitable services, a student:
Must attend a private school within or outside of the district’s attendance boundaries;
Reside in a Title I participating public school attendance area of the LEA, AND
Be failing or most at risk of failing to meet student academic achievement standards.
Students who are homeless or who participated in any of the programs listed in bullet 3 at any time within the previous two years are also eligible.
If in grades pre-K-2, develop selection criteria, which may include teacher judgment, interviews with parents and local assessments.
Selection of students in Grades 3 and above must be based on multiple, educationally related objective criteria.
Poverty is not a selection criterion. Selection is based entirely on place of residence and low achievement, not on income.
Please note - Private schools may use alternate written selection criteria other than the criteria used by the LEA, as long as the criteria is discussed and accepted by the LEA.

34. Equitable Services for Children Standards
The LEA should use:
Standards that are aligned with the curriculum of the private school
Depending on the number of private schools, there may be more than one standard
The State Educational Agency cannot impose standards, achievement levels, or assessments
The instructional support provided by the LEA must align with curriculum standards of the private school. If there is more than one private school, there may be more than one standard. The state cannot impose its standards, achievement levels or assessments on private schools.

35. Equitable Services for Children Types of Services for Children
Equitable services for children must be designed as a Targeted Assistance Title program.
Equitable services are provided in the same manner as a Title I Targeted Assistance Program in an LEA.

36. Equitable Services for Children Types of Services for Children
Direct instruction outside the regular classroom = pull out model
Tutoring
After- or before-school programs
Saturday programs
The types of services that an LEA may provide to eligible private school students include: a pull out model that provides direct instruction outside the regular classroom, tutoring, before and after school programs, Saturday programs, summer school, counseling and computer assisted instruction. The equitable services instructional program must be well coordinated with the instruction the private school children are receiving in their regular classrooms. It should complement classroom instruction rather than be a separate instructional program.

37. Equitable Services for Children Assessments
After consultation, LEA establishes the assessment it will use to measure the effectiveness against the agreed-upon standards
May use the State assessment or another assessment that is aligned to the agreed-upon standards, such as the assessment used in the private school
All participants are assessed annually, including children receiving nonacademic services
The LEA must annually assess the progress of the Title I program toward enabling private school Title I participants to meet the state’s standards or identified alternate standards. All PNP students who have participated in Title I programs must be assessed with an assessment instrument established in consultation with the PNP. The assessment instrument must align with the agreed upon standards. Examples of appropriate assessment tools could be the state assessment or an assessment used by the PNP.

38. Equitable Services for Children Supplement, Not Supplant
The supplement, not supplant provision applies
Title I services must be in addition to, and cannot replace or supplant, services that would be provided by private schools to their private school participants
The supplement not supplant provision requires that federal funds be used to augment the regular educational program, and not to substitute for funds or services that would otherwise be provided by the private school.

39. Equitable Services for Children Subject Areas and Grade Spans
Title I services for private school children DO NOT need to be in the same subject areas or the same grade levels as Title I services for public school children. Needs of private school participants determine what Title I services are appropriate.
According to the Title I guidance, services may be provided in subjects areas or at grade levels that are different from those provided to public school students, as long as those services are provided in the same grade span as the services provided to public school students.

40. Equitable Services for Children Subject Areas and Grade Spans
The providing LEA has the option of providing services for the private school within any grade of the public school’s grade span. Private school services do not have to be for the same grade levels as services at the public school, but they must be within the same grade span.
Services are provided in any grades within the same grade span as services provided to public school students.

41. Equitable Services for Children Service Providers – LEA Employees
Provider of Title I services must be either an employee of the LEA or an employee of a third party under contract with the LEA
Private school teachers may be employed by both the private school and the LEA; however, they must be independent of the private school during the time they are employed by the LEA to provide Title I services
Service providers for the Title I funded support to PNP students must be LEA employees or an employee of a third party under contract with the LEA. Private school teachers may be employed by both the private school and the LEA but must be independent of the private school during the time they provide Title I services. LEA teachers and paraprofessionals providing instructional support under the equitable services requirement must meet HQ requirements. Paraprofessionals must work under the direct supervision of and in close and frequent proximity to a HQ public school teacher. Time and effort records may not be signed by PNP officials, nor may PNP officials establish requirements for LEA employed teachers.

42. Equitable Services for Children Service Providers – LEA Employees
Paraprofessionals must meet the paraprofessional qualification requirements, provide instructional support, and be under the direct supervision of and in close and frequent proximity to a highly qualified public school teacher
Private school officials may not sign time and effort records
Private school officials cannot establish requirements for LEA-employed teachers
This slide highlights specific requirements for employees hired to service eligible students participating in Title programs in private schools. No paraprofessionals can be sent to work in private schools alone. They must work under direct supervision of the public school teacher.

43. Equitable Services for Children Materials and Equipment
Title I funds may only be used to meet the needs of participating children
Non-Title I private school children, nor non-Title I teachers and parents non-Title students may not use materials purchased with Title I funds
LEA must retain title to all materials purchased with Title I funds
Legislation mandates that LEAs implement safeguards to ensure that the following requirements are met:
Title I funds may only be used to meet the needs of participating PNP children;
Non Title I PNP children may not use materials purchased with Title I funds;
The LEA must retain title to all materials purchased; and
They must be labeled as property of the LEA and placed in a secured location when not in use.
Lastly, PNP officials have no authority to obligate federal funds.

44. Equitable Services for Children Materials and Equipment
All materials, etc., purchased with Title I funds must be labeled “Property of… School District” and placed in a secured location when not in use
Private school officials have no authority to obligate Federal funds
There must be an instructional program before the purchase of supplemental materials
The exception to the requirement that instructional program materials can only be purchased if there is a designated Title I program, is for the purchase of backpacks or take-home programs during the summer.

45. Equitable Services for Teachers and Families
There is an explicit mandate that ensures equitable services for families and teachers relevant to Title I parent involvement and professional development. Following is a review of those requirements.

46. Equitable Services for Teachers & Families Requirements
An LEA must provide equitable services to private school teachers and families of participating private school children from funds reserved for professional development (§1119) and parental involvement (§1118)
Similar to the rule on determining equitability for students, the federal regulations require that an LEA ensure that teachers and families of participating private school students receive an equitable benefit from funds reserved or set aside by the LEA for parental involvement and professional development activities. As with equitability for student services, the amount of funds provided for equitable services must be proportionate to the number of private school children from low-income families residing in participating public school attendance areas.
The LEA may invite parents and teachers of identified eligible Title I students to participate in parent involvement activities or professional development activities offered by the LEA.

47. Equitable Services for Teachers & Families Use of Funds
The LEA must use these funds to provide equitable services to teachers and families of participants
There is no authority under Title I for an LEA to transfer these funds to instruction
If teachers or families of participating private school students do not have a need for equitable services, those funds are available to the LEA for other allowable uses
To reiterate, funds must be used to provide equitable services to teachers and families of the participating Title I PNP students. These funds may not be used for instruction. If teachers and families do not have a need for equitable services, those funds become available to the LEA for other allowable uses.

48. Title I Funds for Equitable Services District Professional Development Reservation
Professional Development Reservation under Sec of ESEA in participating public school attendance areas: No. of private school children from low-income families divided by total no. of children, public and private, from low-income families equals proportion of reservation ___5,000 ÷ _____100,000_______ = _____5%___ (Proportion of Reservation)__5 % x $360,000__Reservation = $__18,000 for Equitable Services
This slide illustrates how to calculate funding for Equitable Services based on District Professional Development Reservations.

49. Title I Funds for Equitable Services District Parental Involvement Reservation
Parental Involvement Reservation under Sec of ESEA in participating public school attendance areas: No. of private school children from low-income families divided by total no. of children, public and private, from low-income families equals proportion of reservation ________5,000____ ÷ _____100,000_______ = _____5%___ (Proportion of Reservation)__5% x $60,000__Reservation = $__3,000__ for Equitable Services
The next several slides will further review and clarify details relevant to equitable services for children.

50. Additional Programs
The next several slides will further review and clarify details relevant to equitable services for children.

51. Equitable Services Title I, Part C
Allocation
Use the Title I, Part C Calculation of Private Schools’ Equitable Share screen to determine the appropriate per pupil amount for students eligible for Title I, Part C services. This is located on the OFS website under Consolidated Application Important Information. Services require consultation. Contact the Title I, C Consultant.
It is important to communicate with the Title I, C consultant in the Office of Field Services regarding Equitable Services for Title I, Part C Migrant students if further assistance is needed in determining the appropriate per pupil amount for students eligible for Title I, Part C services.

52. Equitable Services Title II, Part A
Under Title II, Part A, LEAs are required to provide equitable services for private school teachers and other educational personnel only to the extent that they use the funds for professional development
LEAs may utilize Title II, Part A for multiple purposes, including class size reduction, retention bonuses, merit pay and transferring of funds to Title I, Part A. The equitable share for private schools is based on the amount allocated for professional development activities.

53. Equitable Services Title II, Part A
LEA Enrollment
17,814 (Box A)
Current Title II , Part A Allocation
Box B
$715,604
Amount of Title II, Part A Budgeted for PD
Box C
FY 2001 Eisenhower Funds
Box D
$96,822
Base Amount
Box E
Amount of Title II Budgeted for PD
Box C
$715,604 Divided by Total Pupil Count of 18,691 = Current Per Pupil Amounts = $38.29
List of Private Schools within the LEA Boundary
Private School Enrollments
Private School Title II, Part A Allocations
School A
230
$8,806.70
School B
159
$6,088.11
School C
271
$10,376.59
School D
217
$8,308.93
Title II, Part A allocations for private schools is determined by the following:
Indicate the total number of students in the LEA district. (Box A)
Determine the posted allocation for the LEA. (Box B)
Determine the amount of funds budgeted just for professional development. Exclude funding for retention bonuses, merit pay and class size reduction. Funds transferred into Title I, A are included in the private school allocation for participating private schools. (Box C)
Review the Eisenhower Grant found under Program Allocations at the bottom of the screen in (Box D)
Select the greater amount of Box C and D and place in Box E. (Box E)
Determine the number of students per participating private school.
Total the number of students including the LEA and all private schools.
Divide the base amount (Box E) for professional development by the total number of students to determine the per pupil amount.
Multiple the number of students per private school by the current pupil amount to determine the allocation per private school.
This information is found in the Appendix of the Title II, Part A Technical Assistance Packet for Working with Private Schools on the website.

54. Equitable Services Title II, Part A Transfer of Funds/Other Uses
The amount of Title II, Part A that the district would use to calculate what is due to the private school would be the amount of the Eisenhower Grant:
If an LEA was putting all of it’s Title II, Part A funds into class size reduction, merit pay or bonuses
Transferring all of Title II, Part A into Title I, Part A. The amount of Title II, Part A that the district would use to calculate what is due to the private school would be the amount of the Eisenhower Grant. 
This calculation would have to be done for the private school before budgeting other LEA uses of the funds.
The equitable share that is due to a private school is calculated against the amount of Title II, A that the district is dedicating for PD and not the entire allocation (unless the entire amount is budgeted under FC 221 and/or FC 283).  The ‘amount’ of Title II, Part A to be shared must at least be equal to what the district’s Eisenhower Grant was back in  However, if the amount of Title II, Part A that the district is using for PD is greater than the old Eisenhower Grant, then the LEAs PD amount would be the amount used for calculating the private school equitable share.
However, if an LEA was putting all of its Title II, Part A into class size reduction or was transferring all of its Title II, Part A into Title I, Part A, the amount of Title II, Part A that the district would use to calculate what is due to the private school would be the amount of the Eisenhower Grant.  This calculation would have to be done before transferring funds or

55. Equitable Services Title III, Part A- Language Acquisition Program
Participation is considered equitable if the LEA:
Assesses, addresses and evaluates the needs and progress of public and private school students and educational personnel on a comparable basis
Provides, in the aggregate, approximately the same amount of services to students and educational personnel with similar needs
Characteristics of Language Acquisition Programs providing equitable services for English Learners and Immigrant students.

56. Equitable Services Title III, Part A- Language Acquisition Programs
Spends an equal amount of funds to serve similar public and private school students and educational personnel
Provides both groups of students and educational personnel equal opportunities to participate in program activities
Resource – Private School Participation Fact Sheet
Characteristics of Language Acquisition Programs providing equitable services for English Learners and Immigrant students.

57. Equitable Services Title III, Part A
LEA (LEP) Enrollment
151
Current Title III, LEP Allocation Base = $15,100
Total enrollment for LEA & Private Schools (263) divided by the base amount =
Total enrollment for LEA & Private Schools (263) divided by the base amount =
$57.42
List of Private Schools within the LEA Boundary
Private School Enrollments
Private School Title III,
Part A (LEP) Allocations
School A 16
$918.72
School B 25
$1,435.50
School C 40
$2,296.80
School D 31
$1,780.02
Title III, Part A allocations for private schools are established through the following steps:
Indicate the total number of LEP or Immigrant students in the LEA district.
Determine the posted allocation for the LEA.
Determine the number of LEP or Immigrant students per participating private school.
Total the number of students including the LEA and all private schools.
Divide the base amount (allocation) by the total number of students to determine the per pupil amount.
Multiple the number of students per private school by the current pupil amount to determine the allocation per private school.
This information is found in the Appendix of the Title III, Part A Technical Assistance Packet for Working with Private Schools on the website.

58. Evaluation
The next few slides will give you some general information on evaluation of Title programs and services for PNPs.

59. Evaluation
After consulting with private school officials, the LEA must establish standards it will use to measure the effectiveness of the Title I program as indicated by the academic achievement of its participants The MDE Program Evaluation Tool is a viable option for evaluating Title programs and services.
It is absolutely necessary that you establish guidelines for measuring the effectiveness of the Title I programs. The guiding yardstick is naturally the academic achievement of students as measured by the standards developed in consultation with the PNPs and the LEA.

60. Evaluation Annual Progress
Every year, the LEA, after consulting with private school officials, must determine what constitutes acceptable annual progress for the Title I program
This decision must be made before Title I services begin
It’s not enough to just assess participants – the LEA must determine the effectiveness of the total program in raising academic achievement
Prior to the beginning of the Title I services, it is important to remember, you must establish acceptable annual progress measures for the entire Title I program. The decision about program evaluation must be collaboratively designed and implemented that include academic achievement of students, and the delivery of instruction. (A sample evaluation is provided in the overview technical assistant packets for LEA procedures for using Title I Assessment information to develop a program evaluation plan and subsequent program modifications). MDE has developed the Program Evaluation Tool found on the OFS website, under “Current Topics”.
The critical piece to remember is that there must be an evaluation component to measure progress in the areas of instruction that were the focus of the program. An evaluation plan must be included in the consultation with the PNP schools and a timeline for when the evaluation is implemented. Please remember, the evaluation of programs and services for private non-public participants must be reviewed to measure impact of the program.

61. Other Considerations
The next several slides will further review and clarify details relevant to equitable services for children.

62. General Requirements Suggested Timeline
January/February
Mail letter (see sample of letter)
March
Conduct initial meeting (see sample of documentation)
Review demographics
Plan program
April - July
Await allocations
Meet to confirm
Submit application
Provide consultation throughout the year
This is a suggested timeline for the inclusion of planning and submitting the budget for the equitable share of funds for private schools.

63. General Requirements Reminder -
Meetings and consultation must occur before district makes decisions
Consultation continues throughout implementation
Please remember that the LEA staff must meet and consult with the PNPs before the LEA makes any program and budget decisions.

64. Determining Private School Participation—Student Numbers
Private School Students Residing Within District Boundaries (who attend a private school within or outside of district boundaries)
Students Attending Private School Within District Boundaries (regardless of their residency)
Title I, Part A
Funding Generated By:
Low-income students who reside in a Title I school attendance area
Students Eligible to be Served:
Identified by a Needs Assessment for achievement below standard and reside in a Title I school attendance area*
Title I, Part C
Meet criteria for migrant?
Meet priority for services?
Title II, Part A
Title III, Part A
Meet criteria for ELs/Immigrant?
Completes Home Language Survey?
Please note that Title I, Part A funds can be used for private school students residing within district boundaries and who attend a private school within or outside of district boundaries. Students attending private school within district boundaries regardless of their residency are only eligible for Title I, Part C; Title II, Part A; Title II and Title III, Part A

65. Allowable Uses of Funds for Private Non-Profit (PNP) Schools
LEA for PNP Schools
Title I, Part A
Title I, Part C
Title II, Part A
Title III, Part A
Salaries for PNP personnel No
Salaries of LEA staff who service PNP
Yes
Yes, if providing PD
Substitutes for ANY reason
Stipends
Professional Development in core academic areas – secular content only
Reasonable & necessary
Outside of school day
Paid directly to teacher by LEA
Purchase of Computers
Yes for Eligible students
Supplies
Yes, for Title I students
Yes, for Migrant students
Yes for Professional Development
Class Size Reduction
Support for PNP staff to become HQ
Yes for ESL/Bilingual Endorsement
Professional Development
Yes, for helping Title I students
This screen is a sample of allowable uses of funds for private non-profit (PNP) schools. If you have any additional questions and or concerns about allowable expenditures please contact your field service consultant for guidance.

66. What Happens When a PNP Closes or the Program Ends?
If a program is terminated or if the private school closes, the non-consumable materials and equipment must be returned to the district
What happens when a PNP closes or the program ends? The answer is very clear – If a program is terminated or the private school closes, all non-consumable materials and equipment must be returned to the LEA.

67. District Fiscal Responsibilities
Write a check?
NO!
Generate a purchase order
Pay for professional development registrations
Pay wages of district employees who serve the private school
Pay for services of third-party employees who serve the private schools (“purchased services”)
YES!
The LEA has the fiscal responsibilities and must adhere to all established fiscal regulations. The district can not, may I repeat can not, write a private non-public school checks for any programs or services. The district is responsible for processing purchase orders, paying for professional development registration, paying the wages for district employees providing services to the eligible Title I students and paying purchased services of third-party employees.

68. Other Resources
This section of the PowerPoint provides information regarding consultation requirements between LEAs and participating private schools.

69. Further Assistance U.S. Department of Education Guidance Documents
Office of Nonpublic Education
Michigan Department of Education
Office of School Improvement, Field Services Unit
Technical Assistance packets on each grant source
Call your Field Services Consultant
1) The United States Department of Education and the Office of Nonpublic Education have two links available for your perusal if needed. 2) Also, The Michigan Department of Education (MDE) has created several documents for additional review and overview technical assistance packets on each grant sources are available for additional assistance. You may also contact your MDE Field Services consultant for questions.

70. Questions, Comments and Concerns
Contact your Field Services Consultant:
Regions
Special Populations…… Homeless, Migrant, Section 31a,
Section 41, Title I, D and Title III
Finance…………………
Listed on this screen are your Field Services Unit Consultants’ phone numbers for any questions, comments and concerns.