1. Private School Participation in Federal Programs
Equitable Participation Designed to Meet the Needs of Private School Students and Teachers
OFFICE OF SUPERINTENDENT OF PUBLIC INSTRUCTION
Special Programs and Federal Accountability
March 21, 2019

2. Agenda ESEA General Program Requirements
Basics
Intent to Participate Process
Consultation Process and Requirements
Complaint Resolution Process
Individual ESEA Programs and Carl Perkins
Consolidated Program Review (CPR)

3. Private School Participation in Federal Programs
Equitable Services for Eligible
Private School Students, Teachers, and Parents
ESEA | Elementary and Secondary Education Act as amended by the
ESSA | Every Student Succeeds Act
Required by Federal Law

4. …Why? Private School Participation in Federal Programs
Public tax dollars support federal programs. Children and teachers in approved, non-profit private schools are eligible to access the services these programs provide.

5. Law, Regulation, Guidance, Resources
ESEA Equitable Services Guidance–ESSA Section 8501
Uniform Provisions (2009): Title IX, Part E Equitable Services to Eligible Private School Students, Teachers, and Other Educational Personnel, is the non-regulatory guidance that covers:
Education of Migrant Children–Title I, Part C
Teacher and Principal Quality–Title II, Part A
ELL/Emergency Immigrants–Title III, Part A
Student Support & Academic Enrichment–Title IV, Part A
21st Century Community Learning Centers–Title IV, Part B
ESEA Title I, Part A Equitable Services Guidance–ESSA Section 1117
Non-regulatory Guidance (2003)
Updated guidance to arrive soon!
Title I, Part A Resource Toolkit
Ensuring Equitable Services to Private School Children
Law, Regulation, Guidance, Resources
Private School Participation in Federal Programs

6. Law, Regulation, Guidance, Resources
ESSA Updates for Federal Programs
Non-Regulatory Guidance: Fiscal Changes & Equitable Services (2016)
Carl D. Perkins Career and Technical Education Act Non-regulatory Guidance │ Carl D. Perkins CTE Act (U.S. Dept. of Education)
ESEA Private Schools Webpage
Private School Participation in Federal Programs
State Board of Education Website
Private School Initial Application/Renewal
Law, Regulation, Guidance, Resources
Private School Participation in Federal Programs

7. Private School Participation in Federal Programs
Equitable Participation—The Basics
Equitable Services
Services should be equitable to the public school—not necessarily identical—designed to meet the needs of private school students and teachers.
Equal Expenditures on a Per-pupil Basis
Expenditures must be equal to the amount of funds expended for participating public school children. iGrants calculates this amount.
Same Start Date
Services for private school students should begin at the same time as services begin in public schools.

8. Private School Participation in Federal Programs
Key Word Is Services
Services and materials only.
District monitors teachers and providers who deliver services.
District maintains administrative control over services.
Districts do not distribute public funds to private schools.
No reimbursement to private schools.

9. Private School Participation in Federal Programs
Private School Requirements
Private schools may participate in federal program equitable services in 2019–20 if they:  
Are a state approved, non-profit, elementary or secondary school certified through the State Board of Education.
Have completed the Private School October Enrollment Report P105B form in 2018.
Complete the Intent to Participate portion of the Private Participation in Federal Programs application in EDS in the Spring of 2019–due April 15.

10. Private School Approval Washington State Board of Education
To become an approved private school in Washington–
Private schools must initiate approval through the Washington State Board of Education.
The approval process will open mid- to late February, and run through the end of March—we will be sending out more information on the approval process soon.

11. Private School Approval Washington State Board of Education
State Board of Education—Initial Approval
Complete the Application for Private School Initial Approval
Renew approval annually
State Board of Education—Annual Approval (Renewal)
Annually—apply for approval from the State Board
The initial approval application will be sent out in electronic format this year.
Complete the P105B Enrollment Data Report

12. State Board of Education Approval
Private School Approval
Washington State Board of Education
State Board of Education Approval
Questions? Contact the State Board of Education |
Law & Regulation
Minimum Standards for Private School Approval
Chapter 28A.195 RCW | Chapter WAC

13. Intent to Participate Process

14. Private School Participation in Federal Programs
Private Schools must notify the school district and OSPI of intent to participate through the Private Participation in Federal Programs Application in EDS.
1. Enter your Federal Tax ID number
2. Choose Participation or Nonparticipation
3. Check federal program boxes to indicate participation
4. Enter enrollment data
5. Select all the public school districts where your students reside–necessary for Title I, Part A and Title IV, Part B

15. Helpful Tips for Completing the EDS Application
For school name changes, a change in address or school district, contact OSPI’s customer support– or
State Board of Education|
Submit the application even if the private school decides NOT to participate.
Once submitted, the application goes to OSPI and the school district in which the private school is located.
Private School Participation in Federal Programs
Important! Make sure the information entered is correct. Once entered, you cannot modify.

16. 2 1 Private School Participation in Federal Programs
District Process: Ensure Equitable Participation 1
Review the Intent to Participate form in EDS.
Contact the private schools that completed the form and begin the consultation process.
Contact private schools that have not filled out the form. 2
Required: document each contact attempt in the Contact Log. Mandatory: Two attempts by the district. Use multiple strategies to make contact.

17. Consultation Process

18. Consultation
The goal of all parties should be to reach an agreement on how to provide equitable and effective programs for eligible private school children and teachers.
District must provide “timely and meaningful” consultation with appropriate private school officials.
ESSA Section 1117(a)(1)(A) and (b)
ESSA Section 8501(c)(1)

19. What is Timely? ESSA Section 1117(b)(3)/8501(c)(3)–
Before the district makes any decisions about opportunities for private school students’ and teachers’ participation.
Includes the district decision to transfer eligible federal program funds to another federal program.
Consultation should continue throughout the implementation and assessment of services.
Observation
A letter on the intent of program is not enough.
ED suggests invitation to meet to explain.
Document that you attempted contact and held meetings. Logging these attempts in the contact log is a district requirement.

20. What is Meaningful? EDGAR 76.652–
Genuine opportunity for parties to express their views–the district may initiate consultation with a proposal for services.
Final decisions made by the district after consultation.

21. Private School Participation in Federal Programs
Initial Consultation: Required Topics for Discussion
-Identification of student’s need
-What services will be offered
-How, where, and by whom the services will be provided
-How the district will academically assess these services
-How the results of this assessment will improve future services

22. Private School Participation in Federal Programs
Initial Consultation: Required Topics for Discussion
-Size and scope of the equitable services that the district will provide
-How much funding is available to serve private school students, teachers, educational personnel, and in some cases, parents and if the funds will be pooled

23. Private School Participation in Federal Programs
Initial Consultation: Required Topics for Discussion
Transferability and REAP Flexibility
Consult with private schools before any decisions are made that could affect the ability of private schools to benefit from programs for which they are eligible.
Private school students and teachers must receive equitable services under the programs that the funds are transferred to.
Eligible programs to transfer or REAP into other federal programs include:
Title II, Part A
Title IV, Part A

24. Affirmation of Consultation includes all required areas of discussion for the consultation process. Districts must review the complaint procedures with private school officials.
Upload one signed Affirmation of Consultation, in the Private Participation in Federal Programs application for each participating private school.
Consultation
Private School Participation in Federal Programs

25. Private School Participation in Federal Programs
…must continue throughout the implementation and assessment of services
January
March
July
August
June
February
October
November
December
May
September
April
Timely, Meaningful Consultation…
April

26. Complaint Resolution Process

27. OR Private School Participation in Federal Programs
Complaints: Try Local Resolution First
If the private school officials believe timely and meaningful consultation has not occurred… OR
…the district did not give due consideration to their views
The private school should contact the federal programs representative or superintendent at the school district to discuss these concerns.

28. Private School Participation in Federal Programs
Complaints: OSPI and the Formal Complaint
If the concern is not resolved satisfactorily, the private school should contact the OSPI Federal Program Ombudsman for resolution.
If the concern is not resolved, the private school has the right to file a formal written complaint with OSPI.
| WAC

29. Formal, Written Complaint
1. Statement that the district, or other educational agency, or in some cases OSPI, has violated a requirement of a federal statute or regulation that applies to a program requiring equitable participation.
2. Specific requirement alleged to have been violated.
3. Facts on which the complaint is based.
4. Name and address of the complainant.
5. Expected resolution of the alleged violation.
6. Signature of the complainant.
Complaints
Private School Participation in Federal Programs
Mail to Office of the Superintendent of Public Instruction
Private Schools Unit
P.O. Box 47200
Olympia, WA

30. Federal Programs Title I, Part C Migrant Education Title II, Part A
Title I, Part A
Title I, Part C Migrant Education
Title II, Part A
Title III
Title IV, Part A
Title IV, Part B
Carl Perkins
See Attachment A of Bulletin B Private School Participation in Federal Programs for more information about each program.

31. Title I, Part A
Improving Basic Programs

32. Private School Participation
Title I, Part A
Private School Participation
Purpose
Supplemental educational services to provide all children significant opportunity to receive a fair, equitable and high-quality education, and to close educational achievement gaps.

33. Who And Title I, Part A Private School Participation
Level of Funding for Services
Funds are generated based on the number of private school students from low-income families…
Who
Reside in the participating Title I, Part A public school attendance areas
Attend private schools, whether the private schools are located within or outside the district’s boundaries
And

34. Who And Title I, Part A Private School Participation
Eligible Students for Services
Private school students…
Reside in the participating Title I, Part A public school attendance areas
Who
Are failing or most at risk of failing—rank order—to meet state academic standards
And

35. Private School Participation
Title I, Part A
Private School Participation
Selection & Process
Poverty Is Not a Criterion for Services
Students are selected on the basis of multiple, educationally-related, developmentally-appropriate criteria.
District chooses children from the list of eligible students the private school provides.
District has a process to meet the needs of eligible students who attend a private school outside the district.

36. Private School Participation
Title I, Part A
Private School Participation
Supplemental Services
Methods and instructional strategies proven to increase academic achievement.
Instructional program that not only supplements, but is well coordinated with the instruction private school children receive in their regular classrooms.

37. Title I, Part A Service Options for Students There are many more…
― Instructional services outside the regular classroom
― Extended learning time before/after school and through the summer
― Family literacy
― Academic counseling
― Early childhood learning support
― Home tutoring
― Computer-assisted instruction
Title I, Part A
Private School Participation in Federal Programs
There are many more…

38. Title I, Part A Options for Teachers & Families
By law, equitable services may extend to the teachers and parents of Title I-served students. Districts make decisions about these services through the consultation process.
Professional Development
― Should address how teachers can support academic achievement of students served in Title I.
Parent Involvement
― Conducted independently, or in conjunction with the district’s regular parent involvement program.
Private School Participation in Federal Programs

39. Private School Participation
Title I, Part A
Private School Participation
Who Provides Services?
District Employee or Third-Party Contractor
Individual | Association | Agency | Organization
Private school teachers are allowed to provide services outside the time they are employed by the private school.
Paraeducators and teachers must meet Title I, Part A requirements if an “employee” of the district.

40. Title I, Part A Record of Agreed Upon Services
The Title I, Part A Record of Agreed Upon Services serves as documentation of the services agreed to during consultation, and only applies to Title I, Part A.
Upload one Title I, Part A Record of Agreed Upon Services in the Private Participation in Federal Programs application, for each private school participating in Title I, Part A.
Title I, Part A
Record of
Agreed Upon Services
Private School Participation in Federal Programs

41. Title I, Part A
Out-of-District Services

42. Private School Participation
Title I, Part A
Private School Participation
Out-of-District Services: Communication Process
Eligible students who attend a private school outside the local school district can receive services.
Districts must develop a process to communicate with their neighboring districts and private schools.

43. Out-of-District Services
Title I, Part A
Out-of-District Services
The Intent to Participate portion of the Private Participation in Federal Programs application includes information about the resident districts of private school students.
Federal program directors should use this data to communicate with private schools who have students from their districts.
Private School Participation in Federal Programs

44. Interlocal Agreements

45. Private School Participation
Title I, Part A
Private School Participation
Interlocal Agreements: Definition
Agreements between public school districts in which the districts agree to provide services for eligible students in private schools.

46. Interlocal Agreements
Law & Regulation
State Law | Interlocal agreement should address “powers, rights, objectives, and responsibilities of contracting parties” in RCW Include duration and purpose.
Sample interlocal agreements are posted on the OSPI ESEA Private School website: ols.aspx.
Interlocal Agreements
Private School Participation in Federal Programs

47. Interlocal Agreements
Key Questions to Answer in an Interlocal Agreement
Funds, Fund Codes, & Accounting
Interlocal Agreements
How will you finance services for private school students?
How will you develop and maintain the budget?
Which district will be the fiscal agent?
How will you charge for services?
How will code services for federal/state reporting?
How will the accounting work?
Which district(s) does the accounting?
Services, Timeframe, &Termination
When will services begin?
What timeframe is in place for consultation and service delivery?
How will you terminate this interlocal agreement and dispose of any property associated with it?
Private School Participation in Federal Programs

48. Private School Participation
Title I, Part A
Private School Participation
Interlocal Agreements: Important Issues
Who determines student eligibility?
Who assesses the students? Which assessments?
Who provides the services?
Where will the services be provided?
How will student performance be measured?

49. Ask Questions. Get Help.
Title I Office

50. Title I, Part C
Migrant Education

51. Private School Participation
Title I, Part C
Private School Participation
Purpose
Support high-quality and comprehensive educational programs.
Provide services during the school year, and, as applicable, during summer or intersession periods, that address the unique educational needs of migratory children.

52. Private School Participation
Title I, Part C
Private School Participation
Equitable Participation
Applies only to migrant students in schools located in targeted areas that receive Title I, Part C funds.

53. And And Title I, Part C Private School Participation Eligible Students
Meet the statutory and regulatory definition of a migrant child.
Section 1115(c)(1)(A) of the ESEA and 34 C.F.R. §
And
Meet the priority for service definition criteria. Section 1304(d)
And
MEP Non-regulatory Guidance March 2017, page 72, H4.
Have educational needs identified through the state needs assessment and Service Delivery Plan.

54. Ask Questions. Get Help. Title I, Part C, Migrant Education
Sylvia Reyna, Program Supervisor

55. Title II, Part A
Professional Development

56. Private School Participation
Title II, Part A
Private School Participation
Purpose
Provide PD opportunities for private school teachers and other educational personnel.
Services must be based on the needs of private school staff.

57. Private School Participation
Title II, Part A
Private School Participation
Allowable Activities
Participation in scheduled professional development at the school district.
Professional development provided by qualified school district staff.
Third party services―attend conferences or PD led by a contracted trainer.

58. Private School Participation
Title II, Part A
Private School Participation
Allowable Activities
― Improve the knowledge and skills of teachers and staff in core academic subjects
― Effective instructional strategies, methods, and skills
― Integrate technology into curricula
― Teaching students with different needs
― Methods to improve student behavior/classroom management
― Principal training
― Training in the use of data and assessments to improve instruction
There are many more!

59. Professional Development
Important! Take Note.
Do not use Title II, Part A funds for student materials―professional development for teachers and staff only.
Professional development around core academic subjects can include participation in faith-based conferences.
Professional development must align to the needs of the private school educators.
Title II, Part A
Professional Development
Private School Participation in Federal Programs

60. Title II, Part A Summer Conference for Private School Teachers
State-level Activity Funds
Professional development activities for private school teachers
Based on private school needs and in consultation with private school representatives.
Notification Channels
WIFIS, ACIS, CIS, PNAIS, Diocese websites, PSAC and through OSPI bulletins to private schools.

61. Title II, Part A Summer Conference for Private School Teachers Differentiation: Practical Strategies for Implementation
FREE to private school educators employed by State Board of Education approved private schools!
Seattle Pacific University – Seattle
June 24-25, 9 am – 4 pm
August 20-21, 9 am – 4 pm
Each session will contain the same content and materials.
Gonzaga University - Spokane June 27–28, 9 am – 4 pm
Registration for the conferences opens on May 1. Registration for all conferences will be posted on the Title II, Part A Private Schools website. The last day to register for all conference dates is May 31.  For questions, contact Pat Smithson, Program Supervisor, at or

62. Ask Questions. Get Help. Title II, Part A title2quality@k12.wa.us

63. Title III, Part A
English Language Acquisition

64. Private School Participation
Title III, Part A
Private School Participation
English Language Acquisition: Purpose
Support for children as they develop language proficiency that enables meaningful access to grade level curricula and instruction.

65. Private School Participation
Title III, Part A
Private School Participation
English Language Acquisition: Services
Professional development and materials for teachers working with children who need language acquisition support.
Services for students and teachers in schools that are located within the district that receives Title III funds.

66. Ask Questions. Get Help.
Title III
Jolynn Engellant

67. Title IV, Part A
Student Support and Academic Enrichment Grants

68. Private School Participation
Title IV, Part A
Private School Participation
Purpose
Improve students’ academic achievement by increasing the capacity of states, school districts, schools, and local communities to:
Provide all students with access to a well-rounded education.
Improve school conditions for student learning.
Improve the use of technology in order to improve the academic achievement and digital literacy of all students.

69. Private School Participation
Title IV, Part A
Private School Participation
Examples of Allowable Activities Under Title IV, Part A

70. Title IV, Part A Private School Participation
Examples of Allowable Activities
STUDENTS
TEACHERS
Reimbursement for the cost of AP/IB exams for low-income students
Participation in afterschool or summer enrichment activities
Access to counseling
Participation in professional development opportunities connected to the three Title IV-A purposes:
Well-rounded education
Safe and healthy students
Effective use of technology
Participating private schools are not required to select the same type of activities as the district, but may consider the range of allowable Title IV-A activities.

71. Ask Questions. Get Help.
Title IV, Part A Student Support and Academic Enrichment

72. Title IV, Part B
21st Century Learning Centers (21 CCLC)

73. Private School Participation
Title IV, Part B
Private School Participation
Definition & Purpose
Competitive federal grant program that assists students to meet the challenging state academic standards by providing academic enrichment opportunities during non-school hours, such as before and afterschool.
Provides opportunities for academic enrichment, particularly for students who attend low-performing schools, to meet the challenging state academic standards. Provides related educational opportunities to families.

74. Private School Participation
Title IV, Part B
Private School Participation
Eligibility
Served by schools eligible for schoolwide programs under ESEA section 1114.
Eligible Students & Families
‘‘Eligible children’’ means children who are in the targeted population of the CCLC program, and children who reside in the attendance area of the CCLC program.
Eligible Grant Applicants: Local Education agency/School district, community-based organization, Indian tribe or tribal organization, public or private entity, or a consortium of two or more agencies, organizations, or entities.

75. Private School Participation
Title IV, Part B
Private School Participation
Allowable Activities
tutoring, academic enrichment, arts and music education, expanded library service hours, programs that promote parental involvement and family literacy
drug and alcohol prevention programs, counseling programs and character education programs

76. Ask Questions. Get Help.
Title IV, Part B 21st CCLC

77. Carl Perkins
Career and Technical Education (CTE)

78. Allowable Activities CTE/Perkins Private School Participation
Private school secondary students may participate in CTE programs funded with Perkins.
Professional development may be eligible for private school staff who teach CTE classes.

79. Ask Questions. Get Help.
Career and Technical Education Office

80. Consolidated Program Review
CPR

81. CPR & Private School Equitable Services
OSPI staff monitor district activities for reasonable assurance that state and federal funds and equitable services are administered in compliance with the requirements of law.

82. CPR & Private School Equitable Services
OSPI staff conducting CPR look for equitable participation in districts that serve private school students and teachers.
CPR monitoring can include private school visits and interviews.

83. Ask Questions. Get Help.
Private School Ombudsman

84. Federal Programs & Private School Services Not Covered in Webinar
Private School Participation in Federal Programs
Federal Programs & Private School Services Not Covered in Webinar
Program & Contact
Contact
Child Nutrition
Subsidies for eligible students for breakfast, lunch, snack, and milk programs. Private Schools included.
Wendy Barkley
Special Education IDEA, Part B includes equitable services provisions.
Scott Raub

85. Ask Questions. Get Help. Special Programs and Federal Accountability