ARKANSAS STATE DEPARTMENT OF EDUCATION MEETING Title I Equitable Services

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ARKANSAS STATE DEPARTMENT OF EDUCATION MEETING Title I Equitable Services

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ARKANSAS STATE DEPARTMENT OF

EDUCATIONMEETING

Title I Equitable Services

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We’re #1!

Title I Equitable Services

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Title I Equitable Services

A Little Background

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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

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Title I Equitable 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.

WHY?

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Title I Equitable Services

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.

This theory was developed to comply with the Constitutional prohibition against Federal funding to private schools.

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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.

• Private schools may not operate schoolwide programs.

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Private schools are NOT Title I schools.

Title I Equitable Services

Note

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In order to meet Equitable Services requirements 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.

Title I Equitable Services

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Title I Equitable Services

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

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Title I Equitable Services

The LEA is responsible fordesigning and implementingTitle I programs for itsresident children who attend private schools.

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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.

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Title I Equitable Services

Ultimately, the LEA is responsible for ensuring that the Title I program is

compliant.

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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?

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Consultation

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Consultation

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

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Consultation

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.

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Consultation

Consultation must occur in a timely and meaningful manner during the:

• Design• Development, and • Implementation of the program.

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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.

Consultation

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When is consultation timely?

When is consultation meaningful?

It depends ……

Timely and Meaningful Consultation

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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

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ALL REQUIRED TOPICS DISCUSSED

WHAT IS MEANINGFUL CONSULTATION?

HOW CHILDREN’S NEEDS WILL BE IDENTIFIED.SELECTION CRITERIA.SERVICES TO BE OFFERED.HOW AND WHEN DECISIONS ABOUT

DELIVERY OF SERVICES WILL BE MADE.

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ALL REQUIRED TOPICS DISCUSSED

WHAT IS MEANINGFUL CONSULTATION?

METHOD AND SOURCE OF DATA THAT LEA WILL USE TO DETERMINE # OF LOW-INCOME CHILDREN.HOW SERVICES ASSESSED AND IMPROVED.SIZE AND SCOPE OF SERVICES. CONTRACT?

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ALL REQUIRED TOPICS DISCUSSED

WHAT IS MEANINGFUL CONSULTATION?

PROPORTION OF FUNDS ALLOCATED.PROFESSIONAL DEVELOPMENT ACTIVITIES FOR CLASSROOM TEACHERS OF PARTICIPANTS. ACTIVITIES FOR PARENTS OF PARTICIPANTS.

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Genuine opportunity for all parties to express their views and to have those views heard.

WHAT IS MEANINGFUL CONSULTATION?

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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.

WHAT IS TIMELY CONSULTATION?

FINDING

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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.

WHAT IS TIMELY CONSULTATION?

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TIMELY AND MEANINGFUL CONSULTATION

TIMELY AND MEANINGFUL

CONSULTATION

TITLE I PROGRAM THAT MEETS THE NEEDS OF ELIGIBLE STUDENTS

POSITIVE AND PRODUCTIVE

WORKING RELATIONSHIPS

BUY-IN FROM PRIVATE SCHOOL

STAFF

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CONSULTATION

LEA must maintain writtenaffirmation signed by each private schoolofficial or theirappropriaterepresentativethat consultationhas occurred.

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CONSULTATION

Roles for Private School Officials in Consultation

• Participate in consultation

• Provide poverty data

• Provide lists of eligible children

• Suggest program designs and modifications

• Provide a dedicated space for Title I services, if possible

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CONSULTATION

Private school officials have theright to complain to the SEA if the LEA didn’t engage in timely and meaningful consultationor give adequate considerationto the views of private school officials.

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CONSULTATION

At the end of the consultation process, LEA staff and private school officials should have identified:

• Grade(s) to be served.

• Subject area(s).

• Evaluation.

• Selection criteria.

• Method and source of data.

• Professional development activities. *

• Parent involvement activities.

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Title I Instructional Services

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Title I Instructional Services

Generating Funds for Title I Services

Step 1

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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.

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Title I Instructional Services

Public School # of Low-Income

Students

Per Pupil Amount Generated

Lincoln 6 $500 $3,000

Adams 2 $450 $900

Bentley 7 $300 $2100

Charles 1 $0 $0

TOTAL $6000

Name of Private School: St. John’s School

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Title I Instructional Services

Generating Funds for Title I Services

Step 2

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Title I Instructional Services

If the LEA has reserved funds for districtwide instructional activities,

equitable services may apply.

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Title I Instructional Services

This requirement does not apply to reservations for:• Homeless,• Pre-k, or • Neglected or delinquent

programs.

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LEA DECISIONS CAN HAVE A DOMINO EFFECT ON TITLE I EQUITABLE

SERVICES

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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.

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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.

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Title I Instructional Services

Calculating the proportionate share

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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

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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

There is now $6,157.50 available to provide the Title I instructional program for eligible children attending

St. John’s School.

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Title I Instructional Services

Types of services

• Direct instruction outside the regular classroom.

• Tutoring.

• Counseling.

• Computer assisted instruction.

• After or before school programs.

• Saturday programs.

• Summer school.

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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.

• 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.

• LEA teachers providing Title I services must meet HQT requirements.

Important

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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.

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EXAMPLES OF ALLOWABLE INSTRUCTIONAL SERVICES

• 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 on-line learning for middle and high school Title I students that is closely monitored by the LEA.

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ELIGIBILITY ► 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

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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.

ELIGIBILITY

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Findings – Instructional Costs

Title I funds used for:• Whiteboards for private school classrooms.

• Computers for the private school classrooms.

• Library books located in the library of the private school.

• LEA to hire a CAI paraprofessional who does not provide instructional services.

Unallowable Costs – Instruction

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Findings – Instructional Costs

Title I funds used for:• 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.

• Paraprofessional who is not in close proximity and under the direct supervision of an HQ public school teacher.

Unallowable Costs – Instruction

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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

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WHY? 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

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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.

• 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.

• 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 .

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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.

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OMB Circular A-87 Test:

• Reasonable and Necessary• Allocable• Authorized

Title I Instruction

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

Title I Instruction

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Yes or No?

Allowable Instructional Costs

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Title I Instructional Costs

Questions

Answers

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TITLE I PROFESSIONAL DEVELOPMENT ACTIVITIES

 

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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.

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TITLE I PROFESSIONAL DEVELOPMENT

Required VersusAllowed

Reservations

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TITLE I PROFESSIONAL DEVELOPMENT

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

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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

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TITLE I PROFESSIONAL DEVELOPMENT

Example

The LEA has reserves Title I funds for professional development activities for all its Title I middle schools.

YES

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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

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TITLE I PROFESSIONAL DEVELOPMENT

Calculating the proportionate share

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TITLE I PROFESSIONAL DEVELOPMENT

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.

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TITLE I PROFESSIONAL DEVELOPMENT

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 Public School Children who attend Title I public schools. 2,385

• 15 + 2,385 = 2,400

• 15 / 2,400 = .63%

• .63% of $10,000 = $63.00

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TITLE I PROFESSIONAL DEVELOPMENT

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.

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TITLE I PROFESSIONAL DEVELOPMENT

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 Public School Children who attend Title I public schools. 2,385

• 15 + 2,385 = 2,400

• 15 / 2,400 = .63%

• .63% of $5,000 = $31.50

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TITLE I PROFESSIONAL DEVELOPMENT

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

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

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TITLE I PROFESSIONAL DEVELOPMENT

• 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.  

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Professional development costs include:

Those costs the LEA incurs to provide professional development activities to private school teachers of participating private school children.

 

TITLE I PROFESSIONAL DEVELOPMENT

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TITLE I PROFESSIONAL DEVELOPMENT

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.

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TITLE I PROFESSIONAL DEVELOPMENT

• 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.

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EXAMPLES OF ALLOWABLE PROFESSIONAL DEVELOPMENT ACTIVITIES

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.

• Strategies for children performing below grade level in math or reading.

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Findings – Professional DevelopmentTitle I funds used for:• 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.

• Workshops on ADHD, IEPs, etc.

• Reimbursing the private school for professional development activities that it had arranged.

Unallowable Costs – Professional Development

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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

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TITLE I PROFESSIONAL DEVELOPMENT

Questions

Answers

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Mid-PointCheck

TITLE I EQUITABLE SERVICES

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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.

• 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

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• 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.

TITLE I EQUITABLE SERVICES

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TITLE I PARENTAL INVOLVEMENT ACTIVITIES

 

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TITLE I PARENTAL INVOLVEMENT ACTIVITIES

 

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

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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.

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TITLE I PARENTAL INVOLVEMENT ACTIVITIES

Calculating the proportionate share

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TITLE I PARENTAL INVOLVEMENT ACTIVITIES

The LEA reserves one percent of its Title I funds to provide parental involvement activities. That amount is $5,000.

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TITLE I PARENTAL INVOLVEMENT ACTIVITIES

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 Public School Children who attend Title I public schools. 2,385

• 15 + 2,385 = 2,400

• 15 / 2,400 = .63%

• .63% of $5,000 = $31.50

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TITLE I PARENTAL INVOLVEMENT ACTIVITIES

If the LEA reserves Title I funds for parental involvement activities, the

proportionate share is calculated on the entire amount.

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TITLE I PARENTAL INVOLVEMENT ACTIVITIES

 

• 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.

• If private school officials determine that there is no need for equitable services, those funds are available to the LEA for other allowable uses.  

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Parental Involvement costs include:

Those costs the LEA incurs to provide parental involvement activities to the parents/families of participating private school children.

 

TITLE I PARENTAL INVOLVEMENT ACTIVITIES

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EXAMPLES OF TITLE I PARENTAL INVOLVEMENT ACTIVITIES

• 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.

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TITLE I PARENTAL INVOLVEMENT ACTIVITIES

Questions

Answers

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EVALUATING THE TITLE I PROGRAM

 

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EVALUATING THE TITLE I PROGRAM

 

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

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EVALUATING THE TITLE I PROGRAM

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.

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EVALUATING THE TITLE I PROGRAM

• 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.

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EVALUATING THE TITLE I PROGRAM

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.

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EVALUATING THE TITLE I PROGRAM

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.

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FINDINGS - EVALUATING THE TITLE I PROGRAM

Findings – Evaluation

• 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 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.

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EVALUATING THE TITLE I PROGRAM

Questions

Answers

Page 105: ARKANSAS STATE DEPARTMENT OF EDUCATION MEETING Title I Equitable  Services

LAST CALL FOR QUESTIONS

Page 106: ARKANSAS STATE DEPARTMENT OF EDUCATION MEETING Title I Equitable  Services

FOR ADDITIONAL INFORMATION

Nola [email protected]

(202) 205-4158

Virginia [email protected]

(202) 260-0926