Equitable Services to Equitable Services to Private SchoolsPrivate Schools

Russ SweetOregon Department of EducationSummer 2013

ObjectivesObjectivesThis workshop will provide information on:

Private school participation under ESEA in Oregon

Titles I-A , II-A & III requirements and use of funds

Tips for working with private schools

Regulatory & Non-Regulatory Guidance

State contact information

Private School Participation Private School Participation Under ESEAUnder ESEA

The Elementary and Secondary Education Act (ESEA), requires districts to provide

equitable opportunities for participation to private school students, teachers and other

education personnel, including those in religiously-affiliated schools.

In Oregon, public school districts are encouraged to become partners with private schools, in the best educational interest of all

children and youth.

In Plain Language. . .In Plain Language. . . Private schools are eligible to

receive services. Private schools are not eligible

to receive funds directly. No funds are to be channeled directly through the private school.

Any payment (i.e., stipend) to private school personnel must be paid directly to the individual by the district.

Title ITitle IImproving Academic Achievement for Educationally-Disadvantaged Students

◦Part A - Improving Basic Programs

Title IITitle IIPreparing, Training and Recruiting High Quality Teachers and Principals

Part A -Teacher and Principal Training and Recruiting Fund

Equitable participation is required to the extent that the district uses the funds to provide professional development.

Title IIITitle IIILanguage Instruction for Limited English Proficient and Immigrant Students• Timely and meaningful consultation• Equitable and timely services• Secular, neutral and non-ideological• Serve private school LEP children and education

personnel directly or through third party contracts• Funds are not co-mingled with non-federal funds

The First Step is The First Step is ConsultationConsultation Timely and meaningful consultation

during the design and development of the programs

Occurs before any decisions are made that could affect the private school students and teachers from accessing services

Continues throughout the implementation and assessment of services

Title I-A Services to Private Title I-A Services to Private SchoolsSchoolsProvides supplementary

instruction by public school teachers, or through a third-party contractor, to students who are educationally disadvantaged and failing or at risk of failing to meet high academic standards, and who live in Title I attendance areas.

FundingFundingGenerated on basis of number of students

from low-income families who reside in participating public school attendance area and who attend private schools. See worksheet on pg. 36 of Title I Services to Eligible Private School

Children Located at: “Private School Participation in ESEA”: http://www.ode.state.or.us/search/page/?id=3345

Budget Narrative contains a worksheet that automates these calculations.

In some cases, the private school may be in an adjacent school district – the funding is still generated by student’s resident district.

Title I-A Instructional Title I-A Instructional ProgramProgramDuring the school day, before or

after school, during the summerOnsite at the private school (even

religiously affiliated schools), or at other locations

Targeted assisted pullout model, supplementary instruction, direct instruction, computer-assisted instruction, tutoring, family literacy, and early childhood programs

Title I-A Professional Title I-A Professional DevelopmentDevelopmentProfessional development activities for

private school teachers should address how these teachers can serve Title I students better by providing information on research-based reading and mathematics instruction.

Funding is an equitable portion of LEA Title I-A funds being used to support professional development for district staff.

Do not confuse Title I professional development funds with those in Title II-A.

There are allowable and non-allowable uses of these funds.

Title I-A Parent Title I-A Parent Involvement Involvement After consultation with private school

officials, the district may conduct these activities independently or in conjunction with the district’s regular parent involvement activities.

Parent involvement activities can vary from simple parent meetings about the Title I Program to more sophisticated activities, such as strategies to use at home to build academic success.

Needs to be an equitable portion of the district’s parent involvement set-aside.

Documentation: Consultation Documentation: Consultation & Participation& Participation

Document the ProcessInitial communicationConsultationInstructional programProfessional developmentParent involvementComplaint processEvaluation

Sample documents available at: http://www.ode.state.or.us/search/page/?id=3345

Title II-A Private School Title II-A Private School ParticipationParticipationReferences for requirements can

be found in Improving Teacher Quality State Grants ESEA Title II, Part A: Non-Regulatory Guidance

(revised October 5, 2006).

Title II-A Eligible ActivitiesTitle II-A Eligible Activities Improving the knowledge of teachers,

principals, and other educational personnel in one or more of the core academic subjects and in effective instructional teaching strategies, methods, and skills

Training in effectively integrating technology into curricula and instruction

Training in how to teach students with different needs, including students with disabilities or limited English proficiency, and gifted and talented students

Title II-A Eligible Activities Title II-A Eligible Activities (cont.)(cont.)Training in methods of improving

student behavior, identifying early and appropriate interventions, and involving parents more effectively in their children’s education

Leadership development and management training to improve the quality of principals and superintendents

Training in the use of data and assessments to improve instruction and student outcomes.

Ensuring Equitable Services Ensuring Equitable Services for Title II-A for Title II-A

Assess, address and evaluate the needs and progress of both public and private school teachers

Spend an equal amount of funds per student to serve the needs of public and private school teachers and their students

Provide private school teachers with an opportunity to participate in Title II-A activities equivalent to the opportunity provided public school teachers

Offer educational services to private school teachers that are secular, neutral, and non-ideological.

How to Ensure Equitable How to Ensure Equitable Services for Title II-AServices for Title II-A

Based on the needs assessment of the private school teachers, it may be that a private school professional development plan is different from the one developed for the district’s teachers.

Title II-A Allowable Title II-A Allowable Activities Activities Professional development

conferences put on by faith-based organizations that are sustained, comprehensive and secular

Stipends for private school teachers to attend professional development outside the teacher’s regular work day, paid directly to the teacher

Non-allowable Expenditures Non-allowable Expenditures Under Title II-A for Private Under Title II-A for Private Schools Schools (examples)(examples) Teacher, administrator or other staff salaries Substitute teacher pay Teacher or administrative certification

courses Items or costs that would otherwise be

provided to teachers by the private school*

*Supplement/Not Supplant: Title II-A funds supplement non-federal funds. Professional development provided with federal funds needs to be in addition to, and not replace, what the private school would otherwise provide.

Avoiding ProblemsAvoiding ProblemsIf problems arise between districts and private schools, it can often be attributed to any one or all of the following:

Lack of Communication

Lack of Communication

Lack of Communication

Avoiding ProblemsAvoiding ProblemsTimely and meaningful consultation

does not mean:Notifying private schools of a meeting

happening without sufficient lead time.

A meeting where the district has already pre-determined available services, so “take it or leave it.”

A one-time meeting, as it may take more than one meeting to set up the program.

Avoiding ProblemsAvoiding ProblemsTimely and meaningful

consultation does mean:

Coming away with a very clear plan that both parties agree on and understand

Continuous monitoring of the implementation of the plan

Common Monitoring Common Monitoring FindingsFindings

Lack of district documentation on process of consultation and program agreements

Perceived or real barriers to private school participation as evidenced by:◦short timelines imposed on private schools by

the LEA for meetings, consultations, etc.◦ Inconsistent responses from the district to

questions by private schools◦Consultation that is one-sided, not really

consultationPrivate school programs that do not

begin until well after public school begins

Due Diligence of EffortsDue Diligence of Efforts“I’ve tried to consult with the private schools, but they never respond.”Document due diligence efforts:Send a registered letter with receipt requiredFollow-up with a phone callTry to make an in-person visit (optional)Attempt to acquire documentation from the private school acknowledging the waiver of participation

ResourcesResourcesESEA Title IX, Part E Uniform Provisions Subpart I-Private Schools: Equitable Services for Eligible Private School Students, Teachers and Other Educational Personnel Non-Regulatory Guidance

(Revised March 2009)

ResourcesResources

Title I Services to Eligible Private School Children:Non-Regulatory Guidance

(Revised October 17, 2003)

Web-based ResourcesWeb-based Resources

Oregon Department of Educationhttp://www.ode.state.or.us/search/

page/?id=3345

US Department of Education -- Office of Non-Public

Educationhttp://www2.ed.gov/about/offices/

list/oii/nonpublic/index.html

Contacts:Contacts:ODE Office of Educational ODE Office of Educational Improvement & InnovationImprovement & Innovation Russ Sweet, Education Specialist

russ.sweet@state.or.us (503) 947-5638

Dona Bolt, Education Specialistdona.bolt@state.or.us (503) 947-5781

Tanya Frisendahl, Education Specialisttanya.frisendahl@state.or.us (503) 947-5754