Transcript Document

Office of Field Services
Ensuring Equitable Services for
School Children Attending Private
Non-Profit Schools
Office of Field Services
Katie Doerr Parker
Gayle Green
Yvonne W. Mayfield
Field Services Consultants
Office of Field Services
www.michigan.gov/ofs
Reference Materials
The following handouts are available on MDE’s
website, www.michigan.gov/ofs:
Ensuring Equitable Services for Private NonProfit School Children  Power Point
 Overview Technical Assistance Packet –
Working with Private Schools
 Allocation Worksheets
 Non-Regulatory Guidance
 Private School Questions and Answers
 Equitable Worksheet
Reference Materials
Technical Assistance Packets –
Title I, Part A
Title I, Part C
Title II, Part A
Title III, Part A
REQUIREMENTS
Equitable Services RequirementDistrict 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)
Equitable Services Requirement
In order to meet Equitable Services
requirements, a Local Educational Entity
(LEA) must annually notify all private, nonprofit schools within its boundaries and
outside of district if resident students
attend, of eligibility for equitable
participation with Title programs
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
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
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.
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
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.
Consultation
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
Consultation Requirements
Consultation…
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 Requirements
What topics must be addressed during
consultation?
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 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
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
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
Funding for Equitable
Services
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 lowincome children attending private schools in other LEAs.
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
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 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
LowIncome
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
0
$358,800
$23,000
$381,800
29
$22,620
School B
K–8
79%
$780
516
0
$402,480
$36,500
$438,980
0
0
School C
K–8
65%
$780
375
0
$492,500
$13,000
$305,500
15
$11,700
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
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.
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
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
Equitable Services
for Children
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, developmentallyappropriate criteria and local assessments
 Grades 3 and above: selected using multiple written selection
criteria
 Poverty is NOT a criterion!
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
Equitable Services for Children
Types of Services for Children
Equitable services for children
must be designed as a Targeted
Assistance Title program.
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
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
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
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.
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.
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
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
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 nonTitle 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
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
Equitable Services for
Teachers and Families
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)
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
Title I Funds for Equitable Services
District Professional Development Reservation
Professional Development Reservation under Sec. 1119 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
Title I Funds for Equitable Services
District Parental Involvement Reservation
Parental Involvement Reservation under Sec. 1118 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
Additional Programs
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
2014-15 Consolidated Application Important
Information. Services require consultation. Contact
the Title I, C Consultant.
www.michigan.gov/ofs
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
Equitable Services
Title II, Part A
LEA
Current Title II , Part A Allocation
Box B
Enrollment
of Title
II II,Budgeted
for
PD Box C
• Amount Amount
of Title
Part A Budgeted
for PD
17,814 (Box A)
• Box C FY 2001 Eisenhower Funds
Box D
Base Amount
Box E
$715,604
$715,604
$96,822
$715,604
$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
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 2000 - 2001 Eisenhower Grant.
This calculation would have to be done for the private school
before budgeting other LEA uses of the funds.
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
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
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
Evaluation
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.
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
Other Considerations
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
General Requirements
Reminder Meetings and consultation must occur
before district makes decisions
Consultation continues throughout
implementation
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?
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
No
No
No
Salaries of LEA staff who service
PNP
Yes
Yes
Yes, if providing PD
Yes
Substitutes for ANY reason
No
No
No
No
Stipends
 Professional Development in
core academic areas – secular
content only
 Reasonable & necessary
 Outside of school day
 Paid directly to teacher by LEA
Yes
Yes
Yes
Yes
Purchase of Computers
Yes for Eligible
students
Yes for Eligible students
No
Yes for Eligible students
Supplies
Yes, for Title I
students
Yes, for Migrant students
Yes for Professional
Development
Yes for Eligible students
Class Size Reduction
No
No
No
No
Support for PNP staff to become
HQ
No
No
No
No
Yes for ESL/Bilingual
Endorsement
Yes, for helping Title
I students
Yes
Yes
Yes
Professional Development
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
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!
Other Resources
Further Assistance
 U.S. Department of Education
 Guidance Documents
 www.ed.gov/policy/elsec/guid/list.jhtml
 Office of Nonpublic Education
 www.ed.gov/about/offices/list/oii/nonpublic/index.html
 Michigan Department of Education
 Office of School Improvement, Field Services Unit
 Technical Assistance packets on each grant source
 Call your Field Services Consultant
Questions, Comments and
Concerns
Contact your Field Services Consultant:
 Regions 1 - 5 . . . . . . . . .517-373-4004
 Special Populations…….517-373-6066
Homeless, Migrant, Section 31a,
Section 41, Title I, D and Title III
 Finance………………….517-373-2519