Transcript Title III Program Monitoring Tier I, Tier II, & Tier III - ELD

Welcome!
The webinar will begin at 3:30 p.m.
Title III Program Monitoring
Tier I, Tier II, & Tier III
and BAAS Documentation
February 6, 2014
North Carolina Department of Public Instruction
K-12 Programs
Title III/ESL Office
Monitoring Focus
• Programmatic Success
• Compliance
Areas Assessed
• ELD Standards
• Assessment & Accountability
• Instructional Support
• Fiscal Compliance
Tiered Monitoring
Tier I
Build Capacity
Tier II
Tier III
Tiered Monitoring
Tier I
Title III
Self-Evaluation Survey
Build
Capacity
Feb. 1 – Mar. 31,
2014
Tier II
Tier III
https://www.surveymonkey.com/s/TitleIII_Tier1_Survey
Tiered Monitoring
Tier I
Build
Needs
Based Monitoring
Capacity
Onsite One or Two day Monitoring
Tier II
Ongoing
Tier III
Tiered Monitoring
Tier I
Tier II
Build
Capacity
On-Site Monitoring
Two(2) Day
Tier III
Feb. 1 2014 –
May 31. 2014
Exploring Monitoring
Documents
http://eldnces.ncdpi.wikispaces.net/LEP+Coordinators
Title III Monitoring Plan 13-14
http://eldnces.ncdpi.wikispaces.net/LEP+C
oordinators
Title III Monitoring Plan 13-14
Monitoring Schedule
Considerations 13-14
http://eldnces.ncdpi.wikispaces.net/LEP+
Coordinators
Monitoring Schedule Considerations 13-14
Monitoring FAQ
http://eldnces.ncdpi.wikispaces.net/LEP+
Coordinators
Monitoring FAQ
Classroom Observations Form
http://eldnces.ncdpi.wikispaces.net/LEP+
Coordinators
Classroom Observations Form
Guidelines for Observations
http://eldnces.ncdpi.wikispaces.net/LEP+
Coordinators
Guidelines for Observations
Fiscal Documents
http://eldnces.ncdpi.wikispaces.net/LEP+
Coordinators
Fiscal Documents
Title III Monitoring
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Title III Monitoring:
Accountability
SBE Policy GCS-A-012
Subgrantees receiving Title III funds (LEAs, public charter schools,
& consortia) must meet a series of Annual Measurable
Achievement Objectives (AMAOs)
AMAO 1 – Progress
AMAO 2 – Proficiency
AMAO 3 – AMOs for the LEP Subgroup
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Title III, Sec. 3122(b)(2) and State Board Policy reference
(4) ACCOUNTABILITY- If a State educational agency determines
that an eligible entity has failed to meet the annual measurable
achievement objectives described in subsection (a) for 4 consecutive
years, the agency shall —
(A) require such entity to modify the entity's curriculum,
program, and method of instruction;
Policy Identification
Priority: Globally Competitive Students
Category: Testing
Policy ID Number: GCS-A-012
Sanctions for AMAOs Not Met
If the Title III subgrantee has failed to meet the AMAOs for four (4)
consecutive years, the State Board of Education shall require the Title III
subgrantee to modify its curriculum, program, or method of instruction.
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Risk Factors
Risk factors include but are not limited to:
• size of subgrantee grant award,
• percentage of LEP students,
• program performance based on meeting
AMAOs 1 and 2,
• student subgroup academic performance
based on AMOs for LEP students,
• change in program or leadership, and
• the length of time since previous onsite
monitoring.
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Timeline
• AMAO 3 Calculations
• Risk Factor Analysis
• Monitoring Schedule
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Tying It All Together
•
•
•
•
Application
Improvement Plan
Monitoring
Implementation
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Budgets
Basic Supplement, Not
Supplant
USDE, Student Achievement and School Accountability (SASA)
22
Title I, Part A & Title III, Part A
Title I
Title III
Funds must
supplement, and
not supplant State
and local funds
(Section 1120A of
ESEA)
Funds must
supplement, and
not supplant other
Federal, State,
and local funds.
(Section 3115 of
ESEA)
USDE, Student Achievement and School Accountability (SASA)
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Title III “A Supplemental Program to
Serve English Learners”
• Cake – state and local funds used to provide
the Core EL program
• Icing/Frosting – Other federal funds
• Sprinkles – Title III funds
– High Quality Language Instruction
Educational Program (LIEP)
– High Quality Professional Development
USDE, Student Achievement and School Accountability (SASA)
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Developing My LEA’s
Supplemental Title III Program
Do all of the items on my local plan and
budget narrative meet the following criteria?
Are they allowable?
Are they allocable?
Are they reasonable and necessary to
carry out grant function?
Determine whether they should be
included in the 2% limit as administrative
costs?
USDE, Student Achievement and School Accountability (SASA)
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Supplement, Not Supplant
Requirement – General
The First Test of Supplanting:
Required by Law
The Department assumes supplanting exists
if – An LEA uses Title III funds to provide
services that the LEA is required to make
available under State or local laws, or other
Federal laws.
USDE, Student Achievement and School Accountability (SASA)
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Supplement, Not Supplant
Requirement – General
The Second Test of Supplanting:
Prior Year
The Department assumes supplanting exists
if – An LEA uses Title III funds to provide
services that the LEA provided in the prior
year with State, local or other federal funds.
This assumption can be rebutted.
USDE, Student Achievement and School Accountability (SASA)
27
To refute the “prior year” test of
supplanting, the LEA would need to have
contemporaneous records to confirm….
 Budget cuts were made in a number of
areas, not just for LEP students; and
 There was in fact a reduced amount of State
or local funds to pay for this activity/position;
and
 The LEA made the decisions to eliminate the
position/activity without taking into
consideration of Federal funds.
USDE, Student Achievement and School Accountability (SASA)
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Questions to Ask When Considering Whether
Title III Funds Can be Used Without Violating the
Supplement, not Supplant Requirement
1. What is the instructional program/service
provided to all students?
2. What does the LEA do to meet Lau
requirements?
3. What service is the LEA required by other
Federal, State, and local laws or regulations to
provide?
4. Was the program/service previously provided
with State, local, and Federal funds?
USDE, Student Achievement and School Accountability (SASA)
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Supplement, Not Supplant
FAQ Document
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Resources
• Office of Planning, Evaluation and Policy Development,
Policy and Program Studies Service
• Office of Management & Budget (OMB) Circular a-87:
http://www.whitehouse.gov/omb/circulars_a087_2004/
• EDGAR – (See parts 76 and 80 in particular)
http://www2.ed.gov/policy/fund/reg/edgarReg/edgar.pdf
• Office for Civil Rights, ELL Resources
http://www.ed.gov/about/offices/list/ocr/ellresources.html
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All in one place!
– System notification of
budget/amendment submission
– Changed Justification feature allows you
to note reason for changes
– Response from NCDPI within the
system
BAAS Documentation
Why is using the changed
justification feature important?
No additional email is needed unless there is
a change to the application which requires
additional documentation i.e. new staff
position and additional technology
purchases.
Changed Justification: Not Acceptable
Changed Justification: Acceptable
Changed Justification: Acceptable
Our Responses: Status
Our Responses: DPI Comments
More Documentation Needed
New staff positions – require approval of job description
Technology purchases – requires approval of supplement not
supplant rationale
Subscribe!
NC DPI ESL Consultants
Regions 1, 2, 3, 4
Charlotte “Nadja” Trez
ESL/Title III Consultant
NC DPI
919-807-3866
[email protected]
Regions 5, 6, 7, 8
Ivanna (Mann Thrower) Anderson
ESL/Title III Consultant
NC DPI
919-807-3860
[email protected]
Lindsey Fults
ESL/Title III Consultant
NC DPI
919-807-3944
[email protected]