2. ARKANSAS STATE DEPARTMENT OF EDUCATION MEETING Title I Equitable Services

3. We’re #1! Title I Equitable Services

4. A Little Background

5. Section 1120 of Elementary and Secondary Education Act (ESEA) requires participating Local Education Agencies (LEAs) to provide eligible private school students, their teachers and families with Title I services or other benefits that are equitable to those provided to eligible public school children, their teachers, and their families. Title I Equitable Services

6. 5 Low-income parents with private school children are included in the census poverty counts that generate funds the LEA’s use for Title I services. Low-income parents with private school children are included in the census poverty counts that generate funds the LEA’s use for Title I services. Child Benefit Theory.Child Benefit Theory. WHY?

7. 6 Title I Equitable Services Under the Child Benefit Theory Title I services: Benefit the individual child, not the private school.Benefit the individual child, not the private school. Are provided by the LEA, not the private school. Are provided by the LEA, not the private school. This theory was developed to comply with the Constitutional prohibition against Federal funding to private schools. This theory was developed to comply with the Constitutional prohibition against Federal funding to private schools.

8. Title I Equitable Services An LEA must only use Title I funds to meet the needs of the Title I participants. Consequently …. An LEA cannot use any Title I funds to meet the needs of the private school or the general needs of the private school children.An LEA cannot use any Title I funds to meet the needs of the private school or the general needs of the private school children. Private schools may not operate schoolwide programs.Private schools may not operate schoolwide programs.

9. Private schools are NOT Title I schools. Title I Equitable Services Note

10. In order to meet Equitable Services requirements an LEA must – Provide eligible private school children with an opportunity to participate;Provide eligible private school children with an opportunity to participate; Meet the equal expenditure requirements for instruction, professional development, and parent involvement;Meet the equal expenditure requirements for instruction, professional development, and parent involvement; Assess student needs and the effectiveness of the Title I program; andAssess 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.Begin Title I programs at the same time as the Title I programs for public school children. Title I Equitable Services

11. ALL applicable requirements in the ESEA, the Title I regulations, other applicable laws and regulations, and OMB Circulars A-87 and A- 133 apply to the use of Title I funds, including those requiring equitable services for eligible private school children, their teachers and families. Note: ED may not waive the statutory and regulatory requirements relating to equitable services. Questions D-1 and D-6 April 2009 Guidance Questions D-1 and D-6 April 2009 Guidance

12. 11 Title I Equitable Services The LEA is responsible for designing and implementing Title I programs for its resident children who attend private schools.

13. 12 Title I Equitable Services The LEA is required to develop and implement the Title I program that meets the needs of the Title I participants and the LEA cannot delegate its responsibility to private school officials. Note: Private school officials do not develop plans or make budget decisions. This is an LEA responsibility.

14. Title I Equitable Services Ultimately, the LEA is responsible for ensuring that the Title I program is compliant.

15. Title I Equitable Services What steps must an LEA take to design the Title I program to be provided to eligible private school children, their teachers and families?

16. 15Consultation

17. 16Consultation Section 200.63 of the Title I regulations requires LEAs to consult with private school officials.

18. 17Consultation Consultation involves discussions between public and private school officials on key issues that affect the ability of eligible private school students to participate equitably in Title I programs.

19. 18Consultation Consultation must occur in a timely and meaningful manner during the: Design Design Development, and Development, and Implementation of the program. Implementation of the program.

20. 19 An LEA cannot make any decision on any aspect of the Title I program without first consulting with the appropriate private school officials and providing them opportunities to comment and make suggestions.* An LEA cannot make any decision on any aspect of the Title I program without first consulting with the appropriate private school officials and providing them opportunities to comment and make suggestions.* * This includes such topics as rank ordering, per pupil allocation (PPA) determinations, program decisions, grade levels served, etc. * This includes such topics as rank ordering, per pupil allocation (PPA) determinations, program decisions, grade levels served, etc.Consultation

21. When is consultation timely? When is consultation meaningful? It depends …… Timely and Meaningful Consultation

22. LEA staff told private school officials that, in order to be considered eligible for Title I services, children must take a special test. Meaningful Consultation FINDING

23. A LL REQUIRED TOPICS DISCUSSED W HAT IS M EANINGFUL C ONSULTATION ?

24. A LL REQUIRED TOPICS DISCUSSED WHAT IS MEANINGFUL CONSULTATION?

25. A LL REQUIRED TOPICS DISCUSSED WHAT IS MEANINGFUL CONSULTATION?

26. Genuine opportunity for all parties to express their views and to have those views heard. W HAT IS M EANINGFUL C ONSULTATION ?

27. At the time of the monitoring review (November), LEA staff indicated that they had just begun to meet with private school officials to design the Title I program for that school year. W HAT IS T IMELY C ONSULTATION ? FINDING

28. LEA staff must allow enough time to both discuss all required topics with private school officials and allow sufficient time for the LEA to be able to begin services when they begin for public school students. W HAT IS T IMELY C ONSULTATION ?

29. T IMELY AND M EANINGFUL C ONSULTATION T ITLE I P ROGRAM THAT MEETS THE NEEDS OF ELIGIBLE S TUDENTS P OSITIVE AND PRODUCTIVE WORKING RELATIONSHIPS B UY - IN FROM PRIVATE SCHOOL STAFF

30. C ONSULTATION LEA must maintain written affirmation signed by each private school official or their appropriaterepresentative that consultation has occurred.

31. C ONSULTATION Roles for Private School Officials in Consultation Participate in consultation Participate in consultation Provide poverty data Provide poverty data Provide lists of eligible children Provide lists of eligible children Suggest program designs and modifications Suggest program designs and modifications Provide a dedicated space for Title I services, if possible Provide a dedicated space for Title I services, if possible

32. C ONSULTATION Private school officials have the right to complain to the SEA if the LEA didn’t engage in timely and meaningful consultation or give adequate consideration to the views of private school officials.

33. C ONSULTATION At the end of the consultation process, LEA staff and private school officials should have identified: Grade(s) to be served.Grade(s) to be served. Subject area(s).Subject area(s). Evaluation.Evaluation. Selection criteria.Selection criteria. Method and source of data.Method and source of data. Professional development activities. *Professional development activities. * Parent involvement activities.Parent involvement activities.

34. Title I Instructional Services

35. Generating Funds for Title I Services Step 1

36. Title I Instructional Services The amount of Title I funding that is available for equitable services is determined by the number of low-income private school children who live in Title I participating attendance areas.

37. Title I Instructional Services Public School# of Low- Income Students Per PupilAmount Generated Lincoln6$500$3,000 Adams2$450$900 Bentley7$300$2100 Charles1$0 TOTAL$6000 Name of Private School: St. John’s School

38. Title I Instructional Services Generating Funds for Title I Services Step 2

39. Title I Instructional Services If the LEA has reserved funds for districtwide instructional activities, equitable services may apply.

40. Title I Instructional Services This requirement does not apply to reservations for: Homeless, Homeless, Pre-k, or Pre-k, or Neglected or delinquent programs.Neglected or delinquent programs.

41. LEA D ECISIONS C AN H AVE A D OMINO E FFECT ON T ITLE I E QUITABLE S ERVICES

42. Title I Instructional Services Example The LEA has reserved funds for a summer school program for all Title I schools or for all Title I elementary schools. Equitable services’ requirement applies.

43. Title I Instructional Services Example The LEA has reserved funds for a summer school program for all its Title I schools identified for improvement, corrective action, or restructuring. Equitable services’ requirement does not apply.

44. Title I Instructional Services Calculating the proportionate share

45. TITLE I EQUITABLE SERVICES The LEA has reserved $25,000 for summer school activities for all of its Title I schools.  # of Low-Income Children from St. John’s residing within the boundaries of a Title I public school. 15  # of Low-Income Public School Children who attend Title I public schools. 2,385  15 + 2,385 = 2,400  15 / 2,400 =.63% .63% of $25,000 = $157.50

46. Title I Instructional Services The LEA must add the $157.50 to the funds already generated for instruction for children from St. John’s School. $6,000 + $157.50 = $6,157.50 $6,000 + $157.50 = $6,157.50 There is now $6,157.50 available to provide the Title I instructional program for eligible children attending St. John’s School.

47. 46 Title I Instructional Services Types of services Direct instruction outside the regular classroom.Direct instruction outside the regular classroom. Tutoring.Tutoring. Counseling.Counseling. Computer assisted instruction.Computer assisted instruction. After or before school programs.After or before school programs. Saturday programs.Saturday programs. Summer school.Summer school.

48. Title I Instructional Services 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.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. Title I paraprofessionals must be in close proximity and under the direct supervision of an HQ public school teacher.Title I paraprofessionals must be in close proximity and under the direct supervision of an HQ public school teacher. 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.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. LEA teachers providing Title I services must meet HQT requirements.LEA teachers providing Title I services must meet HQT requirements. Important

49. Title I Instructional Services Instructional costs include: Salaries and benefits for Title I staff who are providing the Title I services; Instructional materials, including such items as books, computers and software for student use, workbooks, and supplies that are needed to implement the Title I program. 48

50. E XAMPLES OF A LLOWABLE I NSTRUCTIONAL S ERVICES Extended day programs, Saturday classes or summer school;Extended day programs, Saturday classes or summer school; Providing Title I services to four-year old children who are enrolled in a preschool program offered by the private school;Providing Title I services to four-year old children who are enrolled in a preschool program offered by the private school; Providing on-line learning for middle and high school Title I students that is closely monitored by the LEA.Providing on-line learning for middle and high school Title I students that is closely monitored by the LEA.

51. E LIGIBILITY ► Private school children who reside in Title I participating public school attendance areas AND are failing or most at risk of failing to meet high standards. ► Homeless, 2 preceding years in Head Start, Even Start, Early Reading First, Title I Preschool, Title I, Part C (Migrant Education). ► Grades prek – 2 – selected solely on the basis of teacher judgment, interviews with parents, developmentally-appropriate criteria. ► Grades 3 and above - selected using multiple selection criteria. ► Poverty is NOT a criterion. 50

52. Section 200.62(b)(1)(i) of the Title I regulations defines Title I eligible private school children as those who reside in participating public school attendance areas of the LEA, regardless of whether the private school they attend is located in the LEA. Thus, the LEA in which the child resides is responsible for providing services to the child, but it may arrange to have services provided by another LEA and reimburse that LEA for costs. E LIGIBILITY

53. Findings – Instructional Costs Title I funds used for: Whiteboards for private school classrooms.Whiteboards for private school classrooms. Computers for the private school classrooms.Computers for the private school classrooms. Library books located in the library of the private school.Library books located in the library of the private school. LEA to hire a CAI paraprofessional who does not provide instructional services.LEA to hire a CAI paraprofessional who does not provide instructional services. Unallowable Costs – Instruction

54. Findings – Instructional Costs Title I funds used for: Software loaded on computers owned by the private school.Software loaded on computers owned by the private school. Materials and supplies for the Title I program that are used by classroom teachers when not in use by Title I.Materials and supplies for the Title I program that are used by classroom teachers when not in use by Title I. Paraprofessional who is not in close proximity and under the direct supervision of an HQ public school teacher.Paraprofessional who is not in close proximity and under the direct supervision of an HQ public school teacher. Unallowable Costs – Instruction

55. WHY? Section 200.66(b)(2) of the Title I regulations prohibit LEAs from using Title I funds for the needs of the private school or the general needs of children in the private school. Section 200.67(c)(1) of the Title I regulations requires that any Title I funded equipment or supplies placed in the private school are used for Title I purposes only. Unallowable Costs – Instruction

56. WHY? Section 1120(d)(1) of the ESEA requires that the LEA maintain control of the Title I funds, materials, equipment and property. Section 1120(d)(1) of the ESEA requires that the LEA maintain control of the Title I funds, materials, equipment and property. Unallowable Costs – Instruction

57. Unallowable Costs – Instruction WHY? Unallowable Costs – Instruction WHY? Section 1120(d)(1) requires that the LEA maintain control of the Title I funds, materials and property Title I funds may only be used to meet the needs of participating children.Title I funds may only be used to meet the needs of participating children. Non-Title I private school children may not use materials purchased with Title I funds.Non-Title I private school children may not use materials purchased with Title I funds. LEA must retain title to all materials purchased with Title I funds.LEA must retain title to all materials purchased with Title I funds. 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.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.Private school officials have no authority to obligate Federal funds.

58. Title I Instruction WHY? 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.

59. OMB Circular A-87 Test: OMB Circular A-87 Test: Reasonable and Necessary Reasonable and Necessary AllocableAllocable AuthorizedAuthorized Title I Instruction

60. Note: Title I funds may not be used to correct a violation of Title I statute or regulation. Title I Instruction

61. Yes or No? Allowable Instructional Costs

62. Title I Instructional Costs Questions Answers

63. T ITLE I P ROFESSIONAL D EVELOPMENT A CTIVITIES

64. TITLE I PROFESSIONAL DEVELOPMENT Section 200.65 of the Title I regulations requires that, if an LEA reserves funds for professional development under section 200.77, an LEA must ensure that classroom teachers of participating private school students receive on an equitable basis professional development.

65. TITLE I PROFESSIONAL DEVELOPMENT RequiredVersusAllowedReservations

66. If an LEA reserves Title I funds for professional development activities, equitable services may apply.

67. TITLE I PROFESSIONAL DEVELOPMENT Example The LEA has reserved Title I funds to provide professional development activities because it has been identified for improvement. NO

68. TITLE I PROFESSIONAL DEVELOPMENT Example The LEA has reserves Title I funds for professional development activities for all its Title I middle schools. YES

69. TITLE I PROFESSIONAL DEVELOPMENT Example The LEA has reserved Title I funds to provide professional development activities for its Title I schools identified for improvement. NO

70. T ITLE I P ROFESSIONAL D EVELOPMENT Calculating the proportionate share

71. T ITLE I P ROFESSIONAL D EVELOPMENT The LEA reserves $10,000 in Title I funds to provide professional development for all its Title I teachers to train them in providing assistance to students in math who are performing below grade level. The LEA reserves $10,000 in Title I funds to provide professional development for all its Title I teachers to train them in providing assistance to students in math who are performing below grade level.

72. T ITLE I P ROFESSIONAL D EVELOPMENT Calculating the Proportionate Share # of Low-Income Children from St. John’s residing within the boundaries of a Title I public school. 15 # of Low-Income Children from St. John’s residing within the boundaries of a Title I public school. 15 # of Low-Income Public School Children who attend Title I public schools. 2,385 # of Low-Income Public School Children who attend Title I public schools. 2,385 15 + 2,385 = 2,40015 + 2,385 = 2,400 15 / 2,400 =.63%15 / 2,400 =.63%.63% of $10,000 = $63.00.63% of $10,000 = $63.00

73. T ITLE I P ROFESSIONAL D EVELOPMENT The LEA has also reserved $5,000 in Title I funds to provide professional development in differentiated learning strategies for the teachers from all its Title I schools.

74. T ITLE I P ROFESSIONAL D EVELOPMENT Calculating the Proportionate Share # of Low-Income Children from St. John’s residing within the boundaries of a Title I public school. 15 # of Low-Income Children from St. John’s residing within the boundaries of a Title I public school. 15 # of Low-Income Public School Children who attend Title I public schools. 2,385 # of Low-Income Public School Children who attend Title I public schools. 2,385 15 + 2,385 = 2,40015 + 2,385 = 2,400 15 / 2,400 =.63%15 / 2,400 =.63%.63% of $5,000 = $31.50.63% of $5,000 = $31.50

75. T ITLE I P ROFESSIONAL D EVELOPMENT The LEA must add the amounts generated for professional development activities for the classroom teachers of Title I participants from St. John’s School. $31.50 + $ 63.00 = $94.50 $31.50 + $ 63.00 = $94.50 There is now $94.50 available to provide the Title I professional development activities for the classroom teachers of Title I participants at St. John’s School. $ 94.50 $ 94.50

76. T ITLE I P ROFESSIONAL D EVELOPMENT There is no authority under Title I for an LEA to transfer these funds to instruction.There is no authority under Title I for an LEA to transfer these funds to instruction. If teachers of participating private school students do not have a need for equitable services, those funds are available to the LEA for other allowable uses.If teachers of participating private school students do not have a need for equitable services, those funds are available to the LEA for other allowable uses.

77. 76 Professional development costs include: Professional development costs include: Those costs the LEA incurs to provide professional development activities to private school teachers of participating private school children. Those costs the LEA incurs to provide professional development activities to private school teachers of participating private school children. T ITLE I P ROFESSIONAL D EVELOPMENT

78. The LEA must consult with private school officials prior to the LEA designing and implementing professional development activities for the private school teachers of Title I children. The LEA must consult with private school officials prior to the LEA designing and implementing professional development activities for the private school teachers of Title I children.

79. T ITLE I P ROFESSIONAL D EVELOPMENT The LEA must design professional development activities for the private school teachers of Title I participants. These activities must increase the private school teachers’ knowledge and skills on how to better meet the needs of their Title I children.

80. E XAMPLES OF A LLOWABLE P ROFESSIONAL D EVELOPMENT A CTIVITIES Example Establishing a summer teaching academy for private school teachers of Title I participants to be held at the same time as a Title I summer school so that teachers can observe models of quality instruction for at-risk children.Establishing a summer teaching academy for private school teachers of Title I participants to be held at the same time as a Title I summer school so that teachers can observe models of quality instruction for at-risk children. Strategies for children performing below grade level in math or reading. Strategies for children performing below grade level in math or reading.

81. Findings – Professional Development Title I funds used for: Conferences sponsored by organizations that are not specific to Title I participants such as IRA, ASCD, NCTM, etc.Conferences sponsored by organizations that are not specific to Title I participants such as IRA, ASCD, NCTM, etc. Substitute teachers for private school classroom teachers attending professional development activities.Substitute teachers for private school classroom teachers attending professional development activities. Workshops on ADHD, IEPs, etc.Workshops on ADHD, IEPs, etc. Reimbursing the private school for professional development activities that it had arranged.Reimbursing the private school for professional development activities that it had arranged. Unallowable Costs – Professional Development

82. WHY? Section 200.66(b)(2) of the Title I regulations prohibit LEAs from using Title I funds for the needs of the private school or the general needs of children in the private school. Section 1120(d)(1) of the ESEA requires that the LEA maintain control of the Title I funds, materials, equipment and property. Unallowable Costs – Professional Development

83. TITLE I PROFESSIONAL DEVELOPMENT Questions Answers

84. Mid-PointCheck TITLE I EQUITABLE SERVICES

85. LEA staff have met with private school officials. Together they have designed this Title I program: A Title I teacher will be hired by the private school. The teacher will provide instruction in reading and math to any child that needs extra help.A Title I teacher will be hired by the private school. The teacher will provide instruction in reading and math to any child that needs extra help. Title I services will occur during the school day. If there is not sufficient time during the school day for the Title I teacher to pull children, the Title I teacher will provide the children their reading instruction.Title I services will occur during the school day. If there is not sufficient time during the school day for the Title I teacher to pull children, the Title I teacher will provide the children their reading instruction. TITLE I EQUITABLE SERVICES

86. The LEA has also decided to use Title I funds to provide extra readers for the third grade class at the private school.The LEA has also decided to use Title I funds to provide extra readers for the third grade class at the private school. Since the private school is implementing a new curriculum in math, Title I funds will be used to provide professional development for teachers to implement this new curriculum.Since the private school is implementing a new curriculum in math, Title I funds will be used to provide professional development for teachers to implement this new curriculum. TITLE I EQUITABLE SERVICES

87. T ITLE I P ARENTAL I NVOLVEMENT A CTIVITIES

88. From funds reserved for parental involvement, an LEA must provide equitable services to families of participating private school children.

89. TITLE I PARENTAL INVOLVEMENT ACTIVITIES The LEA must consult with private school officials in designing and implementing parental involvement activities that assist parents in helping their children achieve high academic standards.

90. T ITLE I P ARENTAL I NVOLVEMENT A CTIVITIES Calculating the proportionate share

91. T ITLE I P ARENTAL I NVOLVEMENT A CTIVITIES The LEA reserves one percent of its Title I funds to provide parental involvement activities. That amount is $5,000.

92. T ITLE I P ARENTAL I NVOLVEMENT A CTIVITIES Calculating the Proportionate Share # of Low-Income Children from St. John’s residing within the boundaries of a Title I public school. 15 # of Low-Income Children from St. John’s residing within the boundaries of a Title I public school. 15 # of Low-Income Public School Children who attend Title I public schools. 2,385 # of Low-Income Public School Children who attend Title I public schools. 2,385 15 + 2,385 = 2,40015 + 2,385 = 2,400 15 / 2,400 =.63%15 / 2,400 =.63%.63% of $5,000 = $31.50.63% of $5,000 = $31.50

93. T ITLE I P ARENTAL I NVOLVEMENT A CTIVITIES If the LEA reserves Title I funds for parental involvement activities, the proportionate share is calculated on the entire amount.

94. TITLE I PARENTAL INVOLVEMENT ACTIVITIES The LEA must use these funds to provide equitable services to families of participants.The LEA must use these funds to provide equitable services to families of participants. There is no authority under Title I for an LEA to transfer these funds to instruction.There is no authority under Title I for an LEA to transfer these funds to instruction. If private school officials determine that there is no need for equitable services, those funds are available to the LEA for other allowable uses.If private school officials determine that there is no need for equitable services, those funds are available to the LEA for other allowable uses.

95. 94 Parental Involvement costs include: Parental Involvement costs include: Those costs the LEA incurs to provide parental involvement activities to the parents/families of participating private school children. Those costs the LEA incurs to provide parental involvement activities to the parents/families of participating private school children. T ITLE I P ARENTAL I NVOLVEMENT A CTIVITIES

96. E XAMPLES OF T ITLE I P ARENTAL I NVOLVEMENT A CTIVITIES Establishing a Title I parent center or resource library in the Title I classroom which would be staffed by the LEA with computers, DVDs, and other resource materials that parents of Title I participants may use after school or in the evenings;Establishing a Title I parent center or resource library in the Title I classroom which would be staffed by the LEA with computers, DVDs, and other resource materials that parents of Title I participants may use after school or in the evenings; Providing additional resources for parents of Title I participants to use at home with their children.Providing additional resources for parents of Title I participants to use at home with their children.

97. T ITLE I P ARENTAL I NVOLVEMENT A CTIVITIES Questions Answers

98. E VALUATING THE T ITLE I P ROGRAM

99. “Begin with the end in mind.” - Stephen Covey

100. E VALUATING THE T ITLE I P ROGRAM After consulting with private school officials, the LEA must establish standards it will use to measure the effectiveness of the Title I program being provided to private school children.

101. E VALUATING THE T ITLE I P ROGRAM After consultation, LEA establishes the assessment it will use to measure the effectiveness against the agreed upon standards.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.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.All participants are assessed annually, including children receiving nonacademic services.

102. E VALUATING THE T ITLE I P ROGRAM 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 -- LEA must determine the effectiveness of the total program in raising academic achievement.

103. E VALUATING THE T ITLE I P ROGRAM If the expected annual progress is not met, the LEA, after consultation, must review its program and determine modifications it should make in order to improve the effectiveness of the Title I program in raising the achievement of private school participants.

104. F INDINGS - E VALUATING THE T ITLE I P ROGRAM Findings – Evaluation The LEA was not evaluating the Title I program being provided for private school children.The LEA was not evaluating the Title I program being provided for private school children. The LEA administered a pre and post test to participating Title I children; however, it had not established a benchmark or standard.The LEA administered a pre and post test to participating Title I children; however, it had not established a benchmark or standard. The private school tested all children in all grades with the Terra Nova Test. The LEA used Title I funds to pay for the tests for the Title I children.The private school tested all children in all grades with the Terra Nova Test. The LEA used Title I funds to pay for the tests for the Title I children.

105. E VALUATING THE T ITLE I P ROGRAM Questions Answers

106. L AST C ALL F OR Q UESTIONS

107. Nola Cromer nola.cromer@ed.gov (202) 205-4158 Virginia Berg Virginia.berg@ed.gov (202) 260-0926