Private School Participation in Federal Programs

1. Private School Participation in Federal Programs January 2014

2. Private School Participation • The Elementary and Secondary Education Act (ESEA) requires equitable services be provided to private school students, teachers, and parents. • Why? Federal programs are supported by tax dollars, so all children and teachers are eligible to access these programs.

3. Equitable Participation • Services should be equitable to the public school, not necessarily identical, and designed to meet the needs of the private school students and teachers. • Expenditures for services on a per pupil basis shall be equal to the expenditures for participating public school children. (iGrants calculated) • Services for private school students should begin at the same time as the public school.

4. Key Word is Services • No public funds are distributed to private schools, only services and materials. No reimbursement to private schools allowed. • The local school district retains control over the services provided to the private school. • These services must be supplemental, secular, neutral, and non-ideological.

5. Equitable Programs under ESEA • Title I, Part A – Improving Basic Programs* • Title I, Part C – Education of Migrant Children • Title II, Part A – Teacher and Principal Quality • Title III, Part A – ELL/Emergency Immigrants • Title IV, Part B – 21st Century Learning Centers (Competitive) • Carl Perkins/Career and &Technical Education* * Programs are covered with their own provision requirements all other programs are covered by Uniform Provisions.

6. Private School Process to Participate Private Schools must initiate the approval process: • State Board Two-Part Approval Process • Complete the Annual Approval – State Board approves non-profit elementary and secondary schools. • Complete the P105 Enrollment Data – October headcount. These approved schools are eligible for federal program services.

7. Intent to Participate Process • Approved private schools must complete the Intent to Participate Form on the EDS System. Site opens February 3, 2014. • Site closes March 7, 2014. • Services to begin: 2014-2015 school year. • Consultation with districts to plan for following year begins.

8. District Process to Ensure Equitable Participation • Review the Intent to Participate on the EDS system • Contact private schools that have not filled out their form. Enter attempts to contact private schools on the Contact Log maintained on the EDS system (required). • Contact the schools that did apply and begin the consultation process.

9. Consultation Includes • District must consult prior to making decisions that will affect the private schools and prior to submitting their annual federal grant application. • District maintains administrative control over services. • District regularly monitors teachers and providers who deliver services.

10. Consultation Includes • Communication must continue throughout the implementation and assessment of activities. • Title I, Part A requires school districts to submit a written Affirmation of Consultation for each participating private school. Districts will include this information in the Title I iGrants #201 application.

11. Consultation Items to Discuss • How the student’s needs will be identified. • What services are offered. • How and when the services will be provided. • How the services will be assessed and results used to improve services.

12. Consultation Items to Discuss • Who will provide the services. • Amount of funds available to serve the private school students, teachers, educational personnel, and in some cases, parents. • During the consultation process the district must review the complaint procedures with the private school.

13. Complaint Process • If the private school officials believe timely and meaningful consultation has not occurred or the district did not give due consideration to their views, the private school should first contact the Federal Programs representative or superintendent at the school district to discuss the concerns. • If the concern is not satisfactorily resolved, the private school has the right to contact the Federal Programs office at OSPI for resolution. In the event the concern is not resolved, the private school has the right to file a formal written complaint with OSPI. (Bulletin 044-09; WAC 392-168)

14. Complaint Process Steps A formal written complaint should include: • Statement that the district, or other educational agency, or in some cases OSPI, has violated a requirement of a federal statute or regulation that applies to a program requiring equitable participation. • The specific requirement alleged to have been violated. • The facts on which the complaint is based. • The name and address of the complainant. • The expected resolution of the alleged violation. • The signature of the complainant. • The complaintshould be sent directly to: Office of the Superintendent of Public Instruction Attn: Title I/LAP and Consolidated Program Review Office P.O. Box 47200 Olympia, WA 98504-7200

15. Title I, Part AImproving Basic Programs • Purpose: Provides supplemental educational services for eligible public and private school students to ensure all children have a fair, equal, and significant opportunity to obtain a high-quality education and reach, at a minimum, proficiency on challenging academic achievement standards and assessments. Governed under Title I, Part A Guidance

16. How Are Title I Funds Determined and Eligible students identified for equitable services? • Funds: Funds are generated on the basis of the number of students from low-income families who: • reside in the participating public school attendance areas and • attend private schools, whether the private schools are located within the district or outside the district boundaries. • Eligible Students: Private school students who: • reside within a participating Title I public school attendance area and • are failing or most at risk of failing to meet high standards are eligible for services.

17. Title I, Part A: Eligible Students • Must reside in a participating Title I public school attendance area AND be failing or most at risk of failing to meet high standards (rank order). • Selected on the basis of multiple educationally-related, developmentally-appropriate criteria. • Poverty is not a criterion for services. • District chooses children to be served from the list the private school provides of eligible students. • District ensures a process is in place to meet the needs of eligible students who attend a private school outside the district.

18. Title I, Part A: Student Services Services: • Supplemental – methods and instructional strategies for improving academic achievement, based on scientifically based research. • Instructional program that not only supplements but is also well coordinated with the instruction that the private school children are receiving in their regular classrooms. Service Options, include but are not limited to: • Instructional services outside the regular classroom. • Extended learning time (before/after school and in the summer). • Family literacy. • Counseling (academic). • Early childhood. • Home tutoring. • Computer-assisted instruction.

19. Title I, Part A: Who Provides services? • School district employee or a contracted party (individual, association, agency or organization). • Employees • Teachers must meet ESEA highly qualified teacher standards. • Paraeducators must meet Title I personnel requirements. • Employees must complete Time and Effort reports. • Private School Teachers • May provide services outside time employed by the private school. (Must meet highly qualified teacher requirements when also employed by the school district to provide Title I services to private school students.) • Paraprofessionals • Must work under the direct supervision of a public school teacher or a Title I coordinator. • Direct supervision: Teacher-designed program, scheduled meetings, evaluation of services.

20. Title I, Part A: Additional Services Additional services: • The law requires equitable services for teachers and parents of Title I-served students. • Services are identified through the consultation process. • Professional development activities for teachers. • Should address how the teachers can serve Title I students better, in the subject area or areas, in which their students are receiving Title I services. • Parent involvement activities • May be conducted independently or in conjunction with the school district’s regular parent involvement activities.

21. InterlocalAgreementsAgreeements between public school districts to provide services for title IA eligible private school students • Pooling permitted using agreed upon criteria required under ESEA 1115(b), Non-Regulatory Guidance B-16 • Interlocal agreement should address “powers, rights, objectives, and responsibilities of contracting parties” in RCW 39.34.080 including; • Duration • Purpose(s)

22. How financed; how budget established and maintained • Which district will be fiscal agent • How districts will be charged • Where funds will be coded • When charges will occur • What accounting for funds will be provided and by whom • Timeframe for consultation and delivery of services • Method of termination of agreement and disposal of property

23. Other issues, such as • Who will determine eligibility of students • Who will assess the students and assessment tools to be used • Who will provide services to eligible students • Where services will be provided • How student performance will be measured • Other agreed upon items

24. Title I, Part CMigrant Education • Purpose: To improve education for migrant children. • Eligible private children must: • Meet the statutory and regulatory definition of a migrant child. • Meet the priority for services criteria (in ESEA Section 1304(d)). • Have special educational needs identified through the state’s comprehensive needs assessment and service delivery plan. • Equitable participation for private school migrant students in schools located in targeted areas (only schools that receive Title I, Part C funds).

25. Title II, Part AProfessional Development • Purpose: Opportunity for private school teachers and other educational personnel to participate in professional development. • Services are based on the private school needs assessment and can be provided in a variety of ways: • Participation in scheduled professional development at the school district. • Qualified school district staff providing services to private school staff. • Third party services (registration to conferences or contracted trainer).

26. Title II, Part A Private School Funds • The per pupil allocation is determined by the amount allocated for professional development divided by the total number of public and private students. • Per pupil amount is then multiplied by the total number of private schools students. This amount is set aside for equitable participation. This amount is subject to the hold harmless clause (2001 Eisenhower Funds). (iGrants calculated)

27. Eligible Activities May Include • Improving knowledge and skills of teachers and staff in core academic subjects. • Effective instructional strategies, methods, and skills. • Integrating technology into curricula. • Teaching students with different needs. • Methods to improve student behavior/classroom management. • Principal training. • Training in the use of data and assessments to improve instruction.

28. Take Note • Title II, Part A funds can be used for professional development for teachers and staff, not student materials. • Professional development around core academic subjects, which can include faith-based conferences. • Professional development must align to the needs of the private school educators.

29. State Level Activity Funds • Professional development activities provided by the state based on private school needs and in consultation with private school representatives. • Notification to private schools via: • WIFIS, ACIS, CIS, PNAIS, Diocese websites, and PSAC. • OSPI bulletins to private schools.

30. Title II, Part A State Level ActivityPrivate Schools Conference in partnership with Gonzaga’s School of Education and Seattle Pacific University’s Center for Professional Education SAVE THE DATES • June 2014 –Seattle Pacific University • Response to Intervention & • Explicit Instruction: Your Path to Common Core State Standards • August 2014– Seattle Pacific University • Explicit Instruction: Your Path to Common Core State Standards • August 2014–Gonzaga University • Explicit Instruction: Your Path to Common Core State Standards Gonzaga and SPU hosting facilities

31. Title III, Part AEnglish Language Acquisition • Purpose: Provides assistance for helping limited English proficient (LEP) children to attain English proficiency. • Services can be used for increasing the English proficiency for LEP students by providing assistance, such as professional development and materials for teachers of English to LEP children. • Services for students and teachers in schools that are located within the district that receives Title III funds.

32. Carl PerkinsCareer and Technical Education • Purpose: Allows, upon written request, the participation of private school personnel in pre-service and in-service career and technical education (CTE) professional development programs and for the participation of students in CTE programs, supported by this act. • Contact the CTE office at OSPI for further information.

33. Competitive Grant Programs • What are competitive grants? • Different than “ flow through” funding. • Application required by public schools to participate in programs. • During the competitive grant application process, the district mustcontact the private school and provide the opportunity to participate in the development of the grant and implementation of competitive programs for which they may qualify.

34. Title IV, Part B21st Century learning Centers • Purpose: Before/After school programs, including enrichment programs to support student’s academic needs. • A public school or private organization that is awarded a grant must provide equitable services to private school students, their families, and educators if those students are part of the population identified for assistance.

35. Title VI REAP Flexibility and Accountability Option (District Only) • If a districts uses the Title VI REAP Flexibility and Accountability option, they must consult with private schools prior to making any decisions that could affect their ability to benefit from programs for which they are eligible. • Private school students and teachers will receive equitable services from the district under the programs to which the funds are used.

36. Consolidated Program Review (CPR) • Washington State is responsible for monitoring district activities for reasonable assurance to ensure State/Federal awards are administered in compliance with requirements. (OMB Circular, A-133) • Districts are monitored regarding equitable participation by private schools, if applicable. • Private school visits and interviews are scheduled as part of the district monitoring.

37. Child Nutrition Programs • Annual Agreement/Renewal • Eligible Students: any child enrolled • Reimbursement: Breakfast: $1.58 Free $1.28 Reduced $0.28 Paid Lunch: $2.93 Free $2.53 Reduced $0.28 Paid Performance Based Reimbursement: .06 cents for lunches

38. What Are Meal Pattern Requirements? • Must meet the new USDA meal pattern requirements: Lunch: 8 oz. fluid milk, 1 % milk fat or less 1-2 bread/grain + half whole grain rich 1-2 oz. meat/meat alternate ½ - 1 cup serving fruit ¾ -1 cup serving vegetable + sub groups • New LEAs must be certified before coming on the program.

39. What about the Special Milk Program? • Annual Agreement/Renewal • Eligible Students: any child enrolled • Reimbursement (depends upon price paid) • Pricing • Non-Pricing • Collect Free Milk Applications • Not collect Free Milk Applications (paid milk served to non-needy children will be reimbursed at $0.2050 per half-pint)

40. Who Do I Contact? • For information on any of the child nutrition programs, please contact: Kathleen Wilcox, Administrative Assistant for School Nutrition Programs (360) 725-6203 kathleen.wilcox@k12.wa.us

41. Resources • OSPI: ESEA Private School Website http://www.k12.wa.us/ESEA/PrivateSchools.aspx • OSPI: Office of Private Education Website (approved private schools)http://www.k12.wa.us/PrivateEd/default.aspx • Title I Services to Eligible Private School Students Guidance: http://www.ed.gov/programs/titleiparta/psguidance.doc • Uniform Provisions – Equitable Services to Eligible Private School Students, Teachers, and Other Educational Personnel, Non-Regulatory Guidance: http://www.ed.gov/policy/elsec/guid/equitableserguidance.doc • Ensuring Equitable Services to Private School Children: A Title I Resource Tool Kit: http://www.ed.gov/programs/titleiparta/ps/titleitoolkit.pdf • OSPI: Consolidated Program Review Website http://www.k12.wa.us/consolidatedreview/default.aspx

42. Additional Questions? Contact the Federal Programs Office at OSPI 360-725-6225 Anne Renschler:anne.renschler@k12.wa.us Pat Smithson: pat.Smithson@k12.wa.us Jody Hess: jody.hess@k12.wa.us Kathleen Wilcox: kathleen.wilcox@k12.wa.us John Bresko: john.bresko@k12.wa.us Thank you for your participation!