Equitable Services: Updates and Overview

1. Good Morning! We will begin shortly. Please mute yourself as you enter the webinar. Equitable Services: Updates and Overview

2. OVERVIEW OF TODAY’S SESSION • ESSA: What is New (a Review) • Roles and Responsibilities: SEA, LEA, PRIVATE SCHOOL 2. Timely and Meaningful Consultation • Suggested Timelines • Affirmation of Consultation • Title IA • Eligibility: Allocation and Services • Administrative Costs • Considerations • Title IIA and IVA • Transferability • Questionsand Next Steps

3. ODE Team • Deb Lange, Director deb.lange@state.or.us • Joni Gilles, Ombudsman joni.gilles@state.or.us • Stacie Ankrum, Administrative Assistant Stacie.ankrum@state.or.us • Lisa Plumb, Federal Program Specialist lisa.plumb@state.or.us • Jen Engberg, Federal Program Specialist jennifer.engberg@state.or.us • Sarah Martin, Title IIA Program Specialist sarah.martin@state.or.us

4. Who is on-line and in the room? • School District Administrators • Private School Administrators • ODE Program Staff • Other

5. EQUITABLE SERVICES: BASIC PREMISE Federal programs are supported by tax dollars, so all children and teachers (both public and private) are eligible to access these programs.

6. Applicable Federal Programs • Equitable services requirements for non-public/private schools apply to programs under § 1117 or § 8501: • Title I, Part A (Improving Basic Programs) • Title I, Part C (Migrant Education) • Title II, Part A (Supporting Effective Instruction) • Title III, Part A (English Language Acquisition) • Title IV, Part A (Student Support & Academic Enrichment) • Title IV, Part B (21st CCLC)

7. Changes with ESSA---A Review • Ombudsman • Expanded Consultation • Affirmation of Consultation • No Carryover • Transferability

8. Making Progress • The vast majority of districts and private schools have established good working relationships…these are all “OUR” kids • Continuing to work with private schools administrators to provide education on opportunities and responsibilities • FAQ’s-General Information and Equitable Services https://www.oregon.gov/ode/schools-and-districts/grants/ESEA/Pages/Private-Schools.aspx • Building Toolkit https://www.oregon.gov/ode/schools-and-districts/grants/ESEA/Pages/ESEA-Monitoring.aspx • Private School Partnership meets quarterly • Equitable Services Workgroup meets quarterly • List of private schools coming soon • Listserve coming soon

9. ODE Webpage Resource:Private Schools Participation under ESSA This webpage provides resources and information for both private school and district administrators to include: • Calculating Proportionate Share • Consultation (Checklist and Took Kit samples & Guidelines) • Needs Assessment, Plan Development and Evaluation • Other resources (e.g., compliance, sample Income survey, Title IIA Reimbursement/Stipend Process, etc.) The full link: https://www.oregon.gov/ode/schools-and-districts/grants/ESEA/Pages/Private-Schools.aspx

10. RESPONSIBILITIESSEA, LEA and Private School

11. CONSULTATION The of Equitable Services

12. CONSULTATION • GOALof consultation: reach an agreement between the school district and private school officials on how to provide equitable and effective programs for eligible private school children. • TIMELY • Before the LEA makes any decisions • During the design and development of program • Throughout the implementation and assessment of services • MEANINGFUL • Genuine opportunity for parties to express their views • Views seriously considered • LEA may initiate consultation with a proposal for services • Consultation must occur before final decision are made by LEA

13. CONSULTATION Needs of Private School Students and Teachers NEW How & When Decisions are Made Pooling of Funds Timely and meaningful consultation must continue throughout the implementation and assessment of services and shall occur before the local education agency makes any decision that affects the opportunities to participate of eligible private school students, teachers, and other education personnel. Amount of Funds Available for Services Providing Services Directly or Via Another Entity Size and Scope of Services How Amount of Funding is Determined Services Offered and Delivery of Services Requires Written Affirmation 3rd Party Providers Assessment of Services

14. Systems of Support

15. CONSULTATION • Identify private schools within district boundary • Develop annual consultation calendar • Send out consultation invitation letter (adequate notice typically 2 to 3 weeks) • Establish LEA and private schools roles and responsibilities • Discuss/exchange applicable LEA and private school fiscal and program policies • Discuss and require private school signature of Federal requirements governing the provision of federally funded services (In toolkit https://www.oregon.gov/ode/schools-and-districts/grants/ESEA/Pages/ESEA-Monitoring.aspx ) • Access existing resources to guide collaboration • Document, document, document

16. CONSULTATION TIMELINE • Inform private school officials annually (late winter) • Engage in timely and meaningful consultation (ongoing) • Identify needs (early spring) • Determine per pupil amount for private school services equal to per pupil amount for public school services. (late spring/ early summer) • Discuss logistics of program operation (summer) • Provide services, programs, materials, and resources (to begin in fall and continue throughout the school-year) • Minimum of one on-site visit (November through March) • Evaluate programs and services for effectiveness (spring) This is one of many suggested timelines. Many districts have developed plans that meet the needs of the district and their private schools..

17. Topics of Consultation by Title Program

18. Topics of Consultation by Title Program - continued AFFIRMATION OF CONSULTATION (must be sent to Ombudsman within 30 days of consultation with private school) Districts may continue to use TransACT form PS-02 (Verification) or the Affirmation of Consultation form posted in Private School Equitable Services Toolkit https://www.oregon.gov/ode/schools-and-districts/grants/ESEA/Pages/ESEA-Monitoring.aspx All documentation (i.e. agendas, invitations, meeting notes/minutes should be maintained at the district level)

19. TITLE IA Improving Basic Programs

20. TITLE IAAllocating Funds for Equitable Services Expenditures for equitable services to eligible private school children, teachers and other educational personnel, and families must be equal to the proportion of funds allocated to participating public school attendance areas based on the number of children from low-income families who reside in those attendance areas and attend private schools. An LEA must determine the proportionate share of Title I funds available for equitable services based on the total amount of Title I funds received by the LEA prior to any allowable expenditures or transfers of funds. Section 1117(a)(4)(A) FAQs O-1 to O-5

21. Title I Equitable Services: Process for Determining ALLOCATION and SERVICE https://www.oregon.gov/ode/schools-and-districts/grants/ESEA/Pages/ESEA-Monitoring.aspx Title I Equitable Services: Process for Determining Allocation and service • Private school determines (registration form) the resident district for each student • Private school determines poverty level of all students (most commonly used is free and reduced lunch data; although there are 4 methods) • Private school sends districts a list of all students residing within district boundaries and their poverty level • District determines which student reside in a Title I school attendance area • District sends private school list of ALL students in Title I school attendance area • Private school screens ALL students from district list to determine academic need during (i.e. DIBLES, CBM etc.) • Private school ranks students with highest needs • ALLOCATION is determined by poverty AND residence • SERVICE is determined by need AND residence

22. !Important Distinctions! • Private schools are targeted assist schools and only those students identified as being at risk for academic failure can be served • Although a student may generate funds because of residence and poverty, the student may not be at risk of academic failure so would not be eligible for services

23. Title I-A Equitable Services The Title I non-public equitable share is based on the percentage of non-public low income students residing in Title I participating schools Example: Total Public Low Income: 1,350 Total Non-public Low Income: 150 Total Low Income: 1,500 Percentage of Non-public Low Income: 10% (150/1,500)

24. Allocating Funds for Equitable Services

25. Allocating Funds for Equitable Services Allocating Funds for Equitable Services Guidance – administering equitable services • From the proportionate share of Title I funds available to provide equitable services, an LEA may reserve an amount that is reasonable and necessary to administer equitable services. • An LEA determines this amount separately from funds needed to administer the Title I program for students in public schools. • The LEA should discuss administrative costs for implementing equitable services during consultation with appropriate private school officials.

26. ADMINISTRATIVE COSTS • Must be reasonable and necessary • Focus of all federal funds is students • Must be discussed during consultation process • Includes: grant management, processing purchase orders, negotiating contracts, conducting meetings, accounting activities, grant activity documentation/reimbursement, file maintenance, program implementation and monitoring, inventory management

27. COMMON TITLE IA ACTIVITIES • Tutoring • Paraprofessionals • Summer school • Supplies/materials • Professional development • Extended day programs • Computer assisted instruction

28. !CONSIDERATIONS! • Title IA funds may not be used for screening assessments • Preschoolers are not eligible for equitable services (Oregon education system is K-12) • Services for private school students should begin at the same time as services for public school students • Services may be delivered directly through district or indirectly through contracts with public and private organizations/individuals • District controls all funds, materials and equipment • Delivery of services must be neutral, secular and non-ideological • Services for private school students must be for the same grade span as the services provided for public school students

29. !CONSIDERATIONS! • The private school must notify families of their student’s participation in the Title IA program (sample letter in Toolkit) • Spring calculations are an estimate and may change with final allocation amounts from ODE • Private school officials have no authority to obligate or receive federal funds. No federal funds may be paid directly to a private school • A private school may never be reimbursed for materials/supplies purchased for Title programs • Services must hold reasonable promise that the academic performance of private school students will improve • Annually, the district must access the annual progress of the Title IA program

30. PROVIDING SERVICES • The district may provide services either directly using district personnel or indirectly through contracts with public or private organizations/individuals • Contracted services must be independent of the private school and under the supervision of the district • Private school teachers may be employed by both the private school and the district ; however, they must be independent of the private school during the time IA services are being provided • Private school officials may not sign time and effort records

31. TITLE IIA Supporting Effective Instruction

32. Title IIA Roles and Responsibilities

33. Needs Assessment A comprehensive Needs Assessment helps answer the question: “What professional learning and support do teachers and principals need to help students succeed?” Steps • Identify data sources • Analyze data for trends and gaps in performance • Determine prioritized needs • Develop a plan

34. Describing Strategies and Activities • WHAT is the intended objective? • List the prioritized need the activity addresses • Describe the knowledge and skills will staff receive as a result of participation and how funds will be spent • Indicate how the strategy meets the USED definition of professional learning

35. Describing Strategies and Activities • WHO will participate? • List the type and number of staff participating (e.g., 10 teachers, 1 principal) • HOW is impact being measured? • Identify what measures will be used to determine whether the strategy is generating the results you expect.

36. Professional Learning • Strategies and activities must meet USED definition “high quality, sustained, intensive, and classroom-focused in order to have a positive and lasting impact on classroom instruction and the teacher’s performance in the classroom and not 1-day or short-term workshops or conferences.” [ESEA Section 8101(42)] ” • Conferences and workshops are approvable when they are included as part of larger strategy, not as an end in themselves • How is the conference part of a sustained, job-embedded plan for professional learning? • What is the plan for delivering the content so that the learning extends beyond those who attended?

37. Important Reminders • PS activities are based on the school’s needs assessment • Non-Allowable • Salaries/benefits, substitutes • Religious content • Schools may not be reimbursed – the district is the fiscal agent

38. Title II, Part A Allocation Title II, Part A Allocation Guidance – Calculating the Equitable Services allocation EXAMPLE OF FORMULA TO DETERMINE AMOUNT FOR TITLE II, PART A EQUITABLE EXEPNDITURES CHART

39. Calculating Equitable Services • Equitable service amounts are based on the LEA’s total allocation less administrative costs • Costs to operate the grant at both the district and private school (e.g.; conducting meetings, negotiating contracts, accounting activities, etc.) • Total cannot exceed the district’s indirect rate • Note: Total enrollment for IIA is all students in district and private school, not the same as IA

40. TITLE IVA Student Support and Academic Enrichment

41. Title IVA • Allocations determined the same as IIA • Needs assessment must be used to determine priorities/goals • Provides a great deal of flexibility within three broad categories • Well-rounded Schools • Safe and Healthy Schools • Effective Use of Technology • List of allowable activities

42. TRANSFERABILITY • Transferability is a flexibility authority under the Every Student Succeeds Act (ESSA) which allows Local Educational Agencies (LEAs) to transfer up to 100% of the funds they receive under Title II, Part A and Title IV, Part A to other programs to better address the needs of their unique student populations • Transferred funds become funds of the program to which they are transferred and are subject to all the rules and requirements of the programs to which the funds are transferred. • In accordance with ESEA Section 5103(e)(1), funds transferred from Titles II, Part A and IV, Part A are subject to each of the rules and requirements applicable to the programs to which the transferred funds are transferred, which may include transferring to Title I, Parts A, C, and D, Title III, Part A, and Title V, Part B as well as to Titles II, Part A or IV, Part A. • BEFOREan LEA may transfer funds from a program subject to equitable services requirements, it must engage in timely and meaningful consultation with appropriate private school officials. With respect to the transferred funds, the LEA must provide private school students and teachers equitable services under the program(s) to which, and from which, the funds are transferred, based on the total amount of funds available to each program after the transfer. For example, if an LEA transfers 100% of funds received in Title IV, Part A into Title I, Part A, the LEA would provide equitable services under Title I, Part A, since no funds are remaining under Title IV, Part A.

43. MOST COMMON FINDINGS • Unallowable expenditures • No prior approval • Inadequate documentation • Not reasonable and necessary • Private school paid directly • Unallowable reimbursement Source: State Ombudsman Collaborative and USDE

44. Resources ESSA Guidance (right click on links below to open hyperlink) ESSA Resources • Non-Regulatory Guidance: Fiscal Changes and Equitable Services Requirements • Non-Regulatory Guidance for Title II, Part A: Building Systems of Support for excellent Teaching and Leading • Non-Regulatory Guidance: English Learners and Title III of the Elementary and Secondary Education Act as amended by the Every Student Succeeds Act • Non-Regulatory Guidance Student Support and Academic Enrichment Grants (Title IV, Part A) • Key ESSA Resources • USED: Office of Non-public Education

45. Resources(right click on links below to open hyperlink) • Title IIA web page • Title IIA Listserv • Federal Non-Regulatory Guidance • Oregon Federal Funds Guide • Course to Endorsement Catalogue • Standards for Professional Learning (Learning Forward standards) • Guide to Increasing the Effectiveness of Professional Learning

46. Next Steps • A Common Questions document will be sent out with comments/questions from today, as well as other commonly asked questions • Affirmation of Consultation will be posted on web as well as sent out to all ES district staff

47. Thank You