Transcript Why guidance on the supplemental finds test?

Why guidance on the
supplemental finds test?
 What’s the confusion?
 How does this affect school turnaround?
 Why guidance now?
 What are the things to think about in
developing state-specific guidance?
 What are the next steps for your state?
Why this guidance?
The schoolwide program model is a powerful
school improvement tool, but is rarely
implemented to its full potential because of
confusion over “supplement not supplant”
Federal law sets a different test for schoolwide
program schools, but it is rarely applied
Implementing this different test could radically
change how schools and districts spend Title I
finds, and how states oversee spending, so state,
district and school staff will need guidance and
support
Taking a step back, what could
schoolwide look like?
Depending on its needs, a schoolwide programs school could
spend Title I to:
 Implement a stronger curriculum
 Implement an early warning system
 Extend the school day or school year
 Reorganize class schedules to increase teacher planning time
 Revamp the school’s discipline process
 Hire additional teachers
 Reorganized classes to promote personalized learning
 Implement career academies
 Implement school safety programs
 And so much more . . . . . .
Why doesn’t schoolwide look that way now?
Title I funds are supposed to supplement state and local
efforts
 Three presumptions of supplanting:
Mandated by state/local law
Paid for with state/local funds in prior year
Same services paid for with the Title I for Title I
students and state/local funds for non-Title I students
Historically, compliance has been reviewed
programmatically, by defining the programs and services
school districts will deliver with the state and local funds
Under the approach, Title I funds are typically limited to
separate add-on services
What is different in schoolwide?
The Title I statue takes a different approach in
schoolwides in an effort to drive
comprehensive reforms and approaches in
high-poverty schools
Instead of making sure Title I delivers “extra” programs and services. .
. . . We look at the amount of state and local money a schoolwide
school receives to make sure its all the money it would get if it did not
also receive federal funds
The goal is to make sure Title I schools, in the
aggregate, get extra money – they then have
flexibility in how they spend their money
What does this look like in
practice?
Example 1:
 A school district conducts a technology audit, which
shows Title I schools have computer labs, but nonTitle 1 schools do not
 The district reduces state/local allocations to Title I
schools in order to redirect state/local money to nonTitle I schools so they can by computer labs
Example 1 (cont)
Result
The school district violates the supplemental
funds test because Title I schools are
deprived of state and local funds because
they receive Title 1
What does this look like in
practice?
Example 2:
 A school district meets the supplemental funds test
 State and local resources have declined, forcing
school leaders to make tough decisions about what to
keep and what to cut
 Most schools decide not to cut teaching positions
 Title I schools use Title I funds to retain teacher FTEs,
while non-Title I schools do so with state/local funds
Example 2 (cont)
Result
 This scenario does not violate the supplemental funds test
(but is likely to get scrutinized)
 The supplemental funds test looks at the overall level of
resources going into a school, and not for supplementary
services
 Here, the Title 1 Schools have extra resources non-Title I
schools do not have
 The non-Title1 schools had to cut other costs in order to
retain the teacher FTEs with state and local funds, cuts Title
1 schools did not have to make. Title 1 Schools should be
getting something extra with the extra dollars they have
flowing into the school
So what is the control to ensure
Title 1 funds are spent responsibly?
All costs changed to Title 1 in a
schoolwide program must be:
Consistent with the school’s needs
Reasonably designed to improve student
outcomes
Necessary and reasonable
What does this look like in
practice?
• A school district conducts a technology
audit to prepare for new computer-based
assessments aligned to common core.
The audit reveals a Title 1 school’s newly
purchased computers do not meet test
security requirements
– While a Title 1 school could, in theory, use
Title 1 to prepare for new state assessments,
in this case upgrading new computers may
not be a necessary or reasonable use of
funds
Teeing up the next steps
• Getting schools to schoolwide status:
– This guidance deals only with the supplemental
funds test and how that affects the use of funds in
a schoolwide
– It does not address other schoolwide
requirements such as conducting a
comprehensive needs assessment, or completing
a schoolwide plan
– Many states already have guidance on these
issues
• If so, will this be incorporated into the existing
guidance, or will it be a standalone document?
• If not, will the state develop such guidance?
Next steps (cont.)
• Use of funds:
– ED guidance supports a broad range of
activities that could be supported with Title 1
in a schoolwide program
– Does the state want to provide state-specific
guidance on use of funds?
• Are there specific kinds of costs the state wants to
promote?
• Are there specific kinds of costs the state does not
want to see?
Next Steps (cont.)
• Burden reduction opportunities:
– Use of funds in a schoolwide is driven by a
school’s needs assessment and plan
– Do schools already go through a needs
assessment and planning process that can satisfy
schoolwide requirements?
– SIG related process?
– State developed process?
– Accreditation process?
– Chartering process?
– District developed process?
Next Steps (cont.)
State Oversight:
– What do these changes mean for how the state
will oversee school-level planning and spending?
– What’s the best way to balance oversight
responsibilities, burden and effective
administration
• Increased oversight at the front end (using the
application process)?
• Using existing process to help monitor fed rules
(reimbursement, financial reports, etc.)?
• Revamp back–end monitoring?
Next Steps (cont.)
Supplemental funds test:
What might this test look like in your state?
What concerns might people have over this
guidance?
What would be the best way to address those
concerns?