Why guidance on the supplemental finds test?

1. 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?

2. 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

3. 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 . . . . . .

4. 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

5. 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

6. 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 non-Title 1 schools do not • The district reduces state/local allocations to Title I schools in order to redirect state/local money to non-Title I schools so they can by computer labs

7. 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

8. 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

9. 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

10. 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

11. 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

12. 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?

13. 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?

14. 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?

15. 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?

16. 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?