1. Equitable Services
For Private Schools

2. According to ESSA Part F Uniform Provisions, Subpart 1—Private Schools Section 8501(a)(1)(A) IN GENERAL.—Educational services and other benefits provided under this section for private school children, teachers, and other educational personnel shall be equitable in comparison to services and other benefits for public school children, teachers, and other educational personnel participating in the program and shall be provided in a timely manner.

3. Basic Rules of Service Delivery to Private Schools
Any employee must be under the control and supervision of the LEA
Any contractor must be under the control and supervision of the LEA
The LEA must maintain control of all federal funds
Regulations require the LEA to keep title to and exercise continuing administrative control of all materials, supplies, equipment and property that the LEA acquires with Title I funds for the benefit of eligible private school students. (See 34 CFR )

4. Basic Rules of Service Delivery to Private Schools
Although the LEA maintains title and control, it may place equipment and supplies in a private school for the period of time needed for the program. Certain safeguards must be maintained to ensure that the equipment and supplies placed in a private school are only used for Title I purposes and can be removed from the private school without remodeling the private school facility. (See CFR )
LEAs must maintain a current inventory of Title I-funded equipment located in the private schools.

5. Basic Rules of Service Delivery to Private Schools
Federal funds may not be used for the needs of the private school itself, or for the general needs of children in the private school. (See 34 CFR )
Title I funds must be used in a targeted fashion to supplement NOT SUPPLANT services that would, in the absence of the Title I services, be made available to participating private school students.
The LEA is considered the fiduciary and is legally responsible for operating a program in compliance with the law.

6. Timeline Intent to Participate LEA Sends to Private Schools
February – March
Private Schools Return to LEA
February - April
LEA Collects Data from Private Schools (April)
Private Schools Complete Needs Assessment and Planning (April)
Private Schools and LEAs Collaboratively Write Service Agreements (July – August)
Implement Service Agreements
(August- May)
LEA Should Evaluate Program Throughout School Year
Evaluate Effectiveness of Services Provided (May)

7. Intent to Participate

8. Data Needed From the Private School Title I-A
The number of low income students enrolled in the private school who live in the LEA attendance zone and the students’ addresses.
The LEA can require the private school to use the same method as the LEA to determine poverty students. ESSA 1117(c)(1)(A)

9. Data Needed From the Private School Title II-A
The number of students enrolled in the participating private school that is located within the LEA attendance area. Title II funds is for professional development for teachers.

10. Data Needed From the Private School Title III-A
The number of EL students enrolled in the participating private school that is located within the LEA attendance area. Only as determined through screening.

11. Data Needed From the Private School Title IV, Part B
Competitive Grant: The 21st Century Community Learning Centers (21st CCLC) program provides before-and after-school services to children and their families that include academic enrichment activities, particularly for students who attend low-performing schools, to help them meet State and local student performance standards in core academic subjects. Eligibility is based on coordination with grantees.

12. Private School Needs Assessment and Planning
Private schools should plan with their faculty, staff, and parents to create a needs assessment that includes what the school will need for the school year. Data to consider when creating a needs assessment:
Academic Data
Attendance Data
Teacher Data
Surveys (Teacher/Student/Parent)
Other Pertinent Data Sources
Material and Supplies the Private School will need for the year
The Private School Calendar

13. Allocation Worksheets
FOCUS
Title I
Allocation Worksheets
And Service Agreements.

14. Service Agreements—Title I
Enter Name of Private School Here
Enter Number of Low Income Students who reside in the LEA attendance zone.
Calculation—An LEA shall have the final authority to calculate the number of children, ages 5-17 who are from low-income families
ESSA Section 1117 (c) (1) (A –D)

15. Service Agreements—Title I
DO NOT LEAVE ANY QUESTION BLANK ON THIS PAGE
The questions on page 2 should be answered in great detail. For #5 use the Targeted Assistance section of the monitoring document as a guide (pages in the most recent monitoring document).
#12—Administrators should note “one-day” or short-term workshops or conferences” are expressly disallowed in the Title VIII definition of professional development. Professional development activities must be “sustained, intensive, collaborative, job-embedded, and data-driven.”

16. Service Agreements—Title I
Total Allocation for the Private School
Private School Parent Involvement Funds
Remainder of Allocation After Parental Involvement Funds are Subtracted
DETAILS! DETAILS! DETAILS!

17. Service Agreements—Title I
TYPED/ELECTRONIC SIGNATURES WILL NOT BE ACCEPTED ON SERVICE AGREEMENTS!
#18 Private School Officials should enter comments regarding the collaboration process.
ESSA requires Private School Officials to confirm if the consultation was timely and meaningful or not (If “no” is marked, there is no fault or repercussion to the private school.)

18. ESSA REMINDERS
§1117(b)(3) Letters of intent to participate must be sent to each private school in attendance zone. For each private school that elects to participate, LEAs must submit documentation in the form of a service agreement for each funding source of meaningful and timely collaboration that includes the private schools comments and affirmation that consultation was timely and meaningful.
§1117(b)(2) If an LEA disagrees with the private school as to how students will be served the LEA shall provide in writing to such private school officials the reasons why the LEA disagrees.
§1117(b)(6)(A) A private school official shall have the right to file a complaint to the State educational agency. It is the responsibility of the LEA to ensure the private school understands how to file a formal complaint to the state ombudsman. This is on the compliance monitoring document.
§1117(c)(1)Calculation—An LEA agency shall have the final authority to calculate the number of children ages 5-17 who are from low-income families and attend private schools by using the same measures of low income used to count public school children.
§1117(d)(A)(B)Public Control of Funds—The control of funds, materials, equipment, and property purchased with funds shall be the property and shall be administered by the LEA. All employees funded shall be employees of the LEA OR be contracted by the LEA with an individual association, agency, or organization. In the provision of such services such employee, individual association, agency or organization shall be independent of such private school and of any religious organization, and such employment or contract shall be under the control and supervision of the LEA.
§1117(a)(2) Educational services or other benefits, including materials and equipment, shall be secular, neutral, and nonideological.

19. ESSA TIPS LEAs send letters of intent to participate.
Private Schools return letters of intent to participate.
Plan meetings to begin to write service plans. Service plans cannot be written in one meeting in order for consultation to be meaningful. Keep sign in sheets, detailed meeting notes, and any materials used during the meetings.
The law states the LEA and Private School should both have the goal of reaching agreement on how to provide equitable and effective programs for eligible private school children.
Private Schools should bring their needs assessment and all previous planning tools to the meeting.
If personnel will be hired, the LEA should bring personnel hiring policies, handbooks, procedures, etc. to the meeting. Remember personnel will actually be employees of the LEA.
The LEA should bring procurement procedures to the meeting to avoid confusion. Private schools often work with different LEAs and procurement procedures differ between LEAs.
LEAs should bring a copy of the complaint procedure to the final meeting. Explain the complaint procedure to the private school. Then private school officials should sign the assurance the complaint procedure was explained by the LEA.
Plans should be as detailed as possible. Planning is essential.
Preliminary allocations will be posted by the Equitable Services Ombudsman before the first day of school and made public via

20. Evaluation of the Program
Title I
An LEA is required to annually evaluate the progress of the Title I program toward enabling private school Title I participants to improve academically. ESSA states that an LEA must decide, through timely consultation with private school officials, how services to eligible private school students will be academically assessed and how the results of that assessment will be used to improve those services. (ESSA Section 1117 (b)(1)(D) The LEA is expected to make annual changes in its private school program if the students in that program fail to make the expected annual progress.

21. Allocation Worksheets
FOCUS
Title II
Allocation Worksheets
And Service Agreements.

22. “
The term “professional development” means activities that are sustained (not stand-alone, 1-day, or short term workshops), intensive, collaborative, job-embedded, data driven and classroom-focused… ’’
ESSA §8502(42)(B)

23. Service Agreements—Title II
Enter Private School Information
Enter Total Number of Students Enrolled in All Participating Private Schools that is in the LEAs Attendance Zone
Enter Name of Private School and Total Enrollment
Multiply Private School Total Enrollment by PPA
This is the Title II Allocation for the Private School

24. Service Agreements—Title II
Type an overview of all professional activities planned.
Check the appropriate box(es) that addresses the professional development, and type the title of the professional development.
This will come from the private school’s needs assessment.
Tell how the effectiveness of the professional development will be measured.

25. Service Agreements—Title II
#8 Private School Officials should enter comments regarding the collaboration process.
TYPED/ELECTRONIC SIGNATURES WILL NOT BE ACCEPTED ON SERVICE AGREEMENTS!

26. Allocation Worksheets
FOCUS
Title III
Allocation Worksheets
And Service Agreements.

27. It should be noted that the provision for Title III includes services and benefits, not funds, designed and implemented by the district in consultation with private school officials, to meet the needs of teachers and private school students.
The Title III, A program (Title III) is subject to the equitable services requirements in the Title VIII Uniform Provisions of the ESEA. These requirements apply to districts awarded subgrants under the Title III English Learner State Grants.
Title III funds may not be used to finance the existing level of instruction in a private school. Services must supplement, not supplant, the federal, state, or local funds the private school would otherwise offer absent the Title III program.

28. Examples of Eligible Title III Activities
participation in professional development organized specifically to meet the needs of the private school teachers;
Participation in district sponsored professional development;
tutoring for students before, during, or after school hours;
participation of private school ELs in summer school; and
purchase of supplemental instructional materials and supplies.
REMEMBER ANY TITLE III ACTIVITIES MUST BE IN ADDITION TO THE CORE PROGRAM THE PRIVATE SCHOOL ALREADY HAS IN ITS SCHOOL.

29. Service Agreements—Title III
Enter Private School Information
EL services must be supplemental to what a private school already provides to its EL students. Tutoring should support the educational program already taught in the classroom.
LEAs must pay for screening potential EL students based on home language survey.

30. Service Agreements—Title III
Check the appropriate box(es) that addresses the activities to serve eligible EL students, and type a description and estimated cost of the activity.
TYPED/ELECTRONIC SIGNATURES WILL NOT BE ACCEPTED ON SERVICE AGREEMENTS!

31. Formal Complaints TO THE OMBUDSMAN
Each LEA is responsible for reviewing the formal complaint to the ombudsman procedure with each private school. After the procedure is reviewed, each private school should sign the complaint procedure assurance.

32. NOTE: ELECTRONIC SIGNATURES WILL NOT BE ACCEPTED
The Alabama Equitable Services Complaint to the Ombudsman Procedures Assurance
LEAS MUST SUBMIT A SIGNED “EQUITABLE SERVICES COMPLAINT TO THE OMBUDSMAN PROCEDURES ASSURANCE” FORM FOR EACH PARTICIPATING PRIVATE SCHOOL
FORMS SHOULD BE UPLOADED TO THE DOCUMENT LIBRARY
NOTE: ELECTRONIC SIGNATURES WILL NOT BE ACCEPTED

33. The Alabama Equitable Services Complaint to the Ombudsman Procedures Assurance

34. LEA Monitoring Responsibilities
Service Agreement is Followed
Evaluation of Program
Targeted Assistance Program (Title I)

35. Most Common Issues No Inventory List
Personnel Not Under Control and Supervision of LEA
No Academic Multi Criteria to Identify Students to be Served
Professional Development Receipts that are not itemized
LEA Reimbursed Private School
Professional Development and/or Materials not Secular and/or Non-Ideological
Using Federal Funds to Fund a Program (No EL Program without Title III Funds)
Unclear VAGUE Service Agreements
Service Agreements with Incomplete Budgets

36. Ombudsman Equitable Services Resources
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37. Ombudsman Equitable Services Resources
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38. Ombudsman Equitable Services Resources
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39. Ombudsman Equitable Services Resources
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40. Ombudsman Equitable Services Resources
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41. Ombudsman Equitable Services Resources
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42. Ombudsman Equitable Services Resources

43. Questions Ombudsman Equitable Services Julie Turner, Ed.D.
Alabama State Department of Education
Federal Programs