Creating a Title III Program that Meets Federal Requirements - Webinar for WI Title III Network...
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Transcript of Creating a Title III Program that Meets Federal Requirements - Webinar for WI Title III Network...
Creating a Title III Program that Meets Federal Requirements - Webinar for WI Title III NetworkMillie Bentley-Memon, Ph.D.Title III Group, US Department of Education
With Supreet Anand, Group Leader, Title III Group
Tuesday, April 13, 2010
Increased Student Achievement
Rigorous Standards & Assessments
Rigorous Standards & Assessments
Great Teachers & Leaders
Great Teachers & Leaders
Effective Use of DataEffective Use of Data
Turning Around Low Achieving Schools
Turning Around Low Achieving Schools
Pillars of Reform ESEA Priority Areas
College and Career Ready Students
College and Career Ready Students
Equity and Opportunity for all
Students
Equity and Opportunity for all
Students
Great Teachers and Leaders in Every
School
Great Teachers and Leaders in Every
School
Raise the Bar and Reward Excellence
Raise the Bar and Reward Excellence
Fosters… Results in…
Effective Teaching &
Learning
Effective Teaching &
Learning
Achievement Gap Closing
Increased Graduation and
College Enrollment Rates
Measure growth towards attainment of language proficiency
Statewide Common Standards, Assessments, Identification and Exit Criteria
ELP Assessments and Accountability
Valid and Reliable InstrumentsELP Assessments Aligned to ELP StandardsELP Standards Linked to Content Standards
Effective Use of Native Language Assessments
Update – Reauthorization Workand 2011 Education Budget
http://www.ed.gov/blog/2010/01/the-presidents-cabinet-reports-to-you/
Title III – A Supplemental Program to Serve English Learners
instructional program/serviceprovided by the district
to all students instructional program/service
required by Federal laws/regulations
instructional program/servicerequired by State and local laws/regulations
Title III-funded activities
Building Blocks to an Effective Title III Program that Meets Title III Requirements
high-qualityprofessional development
high-quality language instruction educational program
Building Blocks to an Effective Title III Program that Meets Title III Requirements
professional development
high-quality language instruction educational program
students
supplementary activities (with expenditures that are reasonable, allowable, and allocable)
Students Served Under Title III: Students in grades K-12 identified as limitedEnglish proficient (LEP) based on the StateEnglish language proficiency (ELP) assessment.
- Students identified and placed using valid measures of English language proficiency – not surname or language minority status (section 3302(f) of the ESEA)
LEP students enrolled in private schools served by the local educational agency (LEA).- The LEA is responsible for assisting private schools with identifying these students, if needed. (section 9501(a)) (*Note – Title III funds may be used for ELP assessment of LEP students enrolled in private schools, but not in public schools.)
Parent Refusal Refusal of Title III services – Parents have
the right to immediately remove their child from
a Title III program, decline Title III services, or
to choose another program or method of
instruction, if available. (section 3302(a)(8))
Note that the LEA is still responsible for meeting the child’s educational needs and for ensuring that Lau requirements are met.
ELP Assessment - All LEP students in grades
K-12 in the State should be annually assessed for English language proficiency.
(sections 1111(b)(7) & 3113(b)(3)(D) of the ESEA)
Federal Criteria for Title III ActivitiesCosts must be…
reasonableA cost is reasonable if, in its nature and amount, it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost.
allocableA cost is allocable to a cost objective if the goods or services involved are chargeable or assignable to the cost objective in accordance with the relative benefits received.
allowableA cost is allowable if it is necessary and reasonable for proper and efficient performance of the award and allocable to the award. (OMB Circular A-87)
Examples of Unallowable Costs Alcoholic beverages
Donations and contributions Entertainment costs
-tickets to shows or sports events, meals, lodging, rentals, transportation, gratuities
MAY be allowable –
reasonable lunch for participants in a professional development activity, if there is no other opportunity to eat, and the activity is all day
reasonable snacks for students for Title III-funded summer orafter school programs, and transportation for these programs, if needed and not provided by the district
tickets and transportation for educational field trips, if part ofhigh-quality language instruction educational program
reasonable refreshments for parent outreach activities
Title III 2% Cap on Administrative Costs Districts have a limit of 2% of the Title III grant award for
administration. (section 3115(b))
Administration = administrative costs + indirect costs
Examples of administrative costs:support staff, coordinators, & other personnel that perform
administrative functions
Indirect costs = 1) incurred for a common or joint purpose benefiting more than one cost objective, and 2) not readily assignable to the cost objectives specifically benefitted
Examples of indirect costs: percentage of cost to administer Federal programs acrossthe district
(OMB Circular A-87)
Supplement not Supplant Requirement - General
Title III funds must be used to supplement
the level of Federal, State and local funds
that, in the absence of Title III funds, would
have been expended for programs for LEP
students and immigrant children and youth.
(section 3115(g))
Supplement not Supplant Requirement - General
The First Test of Supplanting: Required by Law
The Department assumes supplanting exists if –
A local educational agency (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.
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.
Supplement not Supplant – Rebuttal:
The LEA would need to have contemporaneous records to confirm:
Budget cuts were made in a number of areas, not just services 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 decision to eliminate the position/activity without taking into consideration Federal funds.
Supplement not Supplant RequirementQuestions to Ask When Considering Whether Title III
Funds Can be Used Without Violating the Supplement notSupplant Requirement
1. What is the instructional program/service provided to all students? 2. What does the LEA do to meet Lau requirements? 3. What services 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? Based on the answers to the above questions, would the proposedfunds be used to provide an instructional program/service that is inaddition to or supplemental to an instructional program/service thatwould otherwise be provided to LEP students (or be required to beprovided by other laws/regulations) in the absence of a Title III grant?
State Law
Mario
Mr. Gomez
Supplemental Instruction Paraprofessionals
Summer Program
Summer School BusSupplemental Texts and Staff
Supplement not Supplant – ELP Assessment
Neither Title I nor Title III funds may be used to develop or administer ELP assessments for identification and
placement purposes, except that Title III funds may be used for identification & placement assessments for private school students
(if the use of such funds would not supplant other Federal, State or local funds that may be used for such purposes.)
Title I and Title III funds may not be used to administer State ELP assessments for progress because:
• Title I does not specifically authorize this expenditure, which is necessary because the requirement applies to all LEP students (not just Title I students). • Use of Title III funds for this purpose would violate the supplement not supplant requirement since the ELP assessment is a requirement under Title I.
Public School
ELP Placement Test ELP Progress Test
Private School
ELP Placement Test ELP Progress Test
State Law Consultation
Case Study Conversations
Case Study Conversations #1Use of Funds
Review the following scenarios and apply the information discussed . Consider which questions could arise in each scenario, and a proposed answer.
A) District A proposes using Title III funds to provide monthly dinners for its English language learner (ELL) parent advisory council. The amount proposed for these dinners is about 1/10 of the district’s Title III allocation. What questions could you ask regarding this proposed expenditure? How would the principles of allowable, allocable, and reasonable apply?
B) District B wishes to use its Title III allocation to pay the salary of its ELL administrator. Is this a permissible use of Title III funds? Why or why not?
Case Study Conversations #1Use of Funds
Review the following scenarios and apply the information discussed . Consider which questions could arise in each scenario, and a proposed answer.
C) District C proposes using its $147,000 Title III allocation as follows:$20,000 to partially fund English as a second language (ESL) teachers who will be the primary providers of ESL instruction for the students that they service. $50,000 for two paraprofessionals to deliver ESL instruction to LEP students in two of the district’s elementary schools.$1,000 for interpreters to participate in parent conferences.$1,000 to translate district documentation to increase school participation for LEP students and their families.$75,000 for “ESL textbooks, software and other materials.”What are the considerations when determining whether each expenditureis allowable, allocable, and reasonable, and whether it is supplemental?
Building Blocks to an Effective Title III Program
high-qualityprofessional development
high-quality language instruction educational program
students supplementary activities
Provision of Title III Services to LEP Students in Private Schools Districts must conduct timely and
meaningful consultation with appropriate
private school officials. - documented Districts must provide educational services (not
funds) to LEP children, their teachers, or other
educational personnel in private schools that are
located in the geographic area served by the
district. (section 9501)
Provision of Title III Services to LEP Students in Private Schools
Timely and meaningful consultation must include:
How the needs of the private school students will be identified.
The services the LEA will provide to meet the needs.
The amount of funding available to provide services.
How the services will be assessed.(section 9501(c))
Provision of Title III Services to LEP Students in Private Schools
Title III funds may be used for the initial ELP assessments for private school students (in
cases where the use of such funds would not supplant other Federal, State and/or local
funds that may be used for such purposes or other legal requirements).
Provision of Title III Services to LEP Students in Private Schools
Annual ELP assessments:
Title III does not require LEAs to administer theirState’s annual English language proficiency assessments for
identified English language learners in private schools.
However, LEAs are required under Title IX uniform provisions toconsult with the private school officials about:
how the Title III, Part A services provided to private schools and teachers will be assessed, and
how the results of the assessment will be used to improve those services. (section 9501(c)(1)(D))
Case Study Conversations
Case Study Conversations #2Private Schools
D) In order to fulfill its obligations with respect to private school students in the LEA, District D gives the private schools in the LEA a dollar amont of its allocation the per pupil Title III award amount per each LEP student. District D tells the schools they can use the dollar amount however they wish as long as the services are for the private schools’ LEP students. Private schools then secure reading services, textbooks, and other materials for the LEP students’ use, and submit invoices to the LEA that the LEA pays directly to the vendors (reading teacher, publisher, etc.). Does this practice satisfy Title III obligations for private school students? Why or why not? What questions arise from this scenario?
Case Study Conversations #2Private Schools E) District E asks the private school in the city of Edualia to report the number of LEP students that attend the private school, so that District E can determine who must be served in the private school.
Is this an appropriate practice? Why/why not?
District E then further determines, based upon the number of LEP students, what “supplies and materials will be provided to the private school in order to assist the private school staff in serving the LEP students in the private school.”
Is this an appropriate practice? Why/Why not?
Questions and Answers
Resources National Clearinghouse for English Language
Acquisition:http://www.ncela.gwu.edu/
Office of Management and Budget Circulars:
http://www.whitehouse.gov/omb/rewrite/grants/grants_circulars.html
Title I fiscal guidance:http://www.ed.gov/programs/titleiparta/fiscalguid.doc
Office for Civil Rights, ELL Resources:http://www.ed.gov/about/offices/list/ocr/ellresources.html