Federal Title III Monitoring Findings

1. Federal Title III Monitoring Findings Illinois State Board of Education Division of English Language Learning Seng Naohlu, Dr. Seon Hwa Eun, Ilyse Leland, Sherry Johnson and Bill Garcia – Principal Consultants

2. Guidelines & Responsibilities of a Title III Consortium Seng Naolhu, Principal Consultant snaolhu@isbe.net

3. Purpose of this Presentation • To acquaint participants with federal Title III LIPLEPS consortium requirements • To review the responsibilities of the fiscal agent and consortium members. • To inform consortium of may be required for FY10.

4. Recommendation from USDE Federal Monitoring • LEAs receiving Title III funds as a part of a consortium must carry out the activities required under Title III. • Redistribute allocations to members may not be sufficient to fulfill requirements of the Title III State Formula Grant Program.

5. When districts choose to form part of a Title III LIPLEPS Consortium • Under the Title III State Formula Grant Program, if an LEA does not have a sufficient number of limited English proficient (LEP) students enrolled to qualify for a minimum subgrant of $10,000 under Section 3114(a), it may apply for a subgrant jointly in a consortium with other LEAs to form an eligible grant applicant entity that meets the minimum award requirements.

6. How the Consortium is figured • Two or more LEAs with one LEA designated as the fiscal agent in the consortium apply jointly to ISBE for LIPLEPS funding. • In order to enter into a consortium, participating LEAs must develop a memorandum of understanding or alternative agreement that outlines how the consortium will meet all Title III requirements just like any other individual LEA subgrantees.

7. Responsibilities of a Consortium A fiscal agent: • Maintains on file a memorandum of understanding ensuring that consortium members fulfill their fiscal and programmatic responsibilities as subgrantees under Title III, including meeting the annual measurable achievement objectives (AMAO’s) defined in Section 3122 of the statute. • Oversees all fiscal transactions of the consortium (requisitions, purchases, payments, etc.) and for maintains financial records.

8. A fiscal agent: Notifies parents of LEP students if the consortium fails to meet AMAOs for two consecutive years, Develops a consortium improvement plan in conjunction with members of the consortium if the consortium fails to meet AMAOs for two consecutive years.

9. Common plan for the Consortium Consortium partners must meet to discuss and develop a common plan that addresses the requirements of Title III and other issues including the following: • Improving services for limited English proficient students • Professional development to improve instruction for LEP students • Shared objectives and activities to effectively and efficiently use Title III funds to meet the identified needs of the consortium partners.

10. Title III Mandated Activities: • To increase the English proficiency of English language learners by providing high-quality language instruction programs that are based on scientifically based research. • To provide high quality professional development to classroom teachers, principals, administrators, and other school or community-based organizational personnel that is of sufficient intensity and duration to have a positive and lasting impact on the teachers’ performance in the classroom.

11. Other Allowable Activities: • Upgrade program objectives and effective instructional strategies • Improve the instruction program by identifying, acquiring and upgrading curricula, instruction materials, assessment and technologies. • Provide community participation programs, Adult ESL for parents, family literacy services and parent outreach and training activities.

12. Requirements for FY10 Consortium • Consortium will be required to identify the cooperative activities that the consortium as a whole jointly planned together and will be funded through the LIPLEPS consortium grant. The FY10 consortium budget may be amended to reflect the cost associated with these activities. • ISBE will include in its FY2011 eGMS consolidated application specific required activities that the consortium must collaboratively carry out to ensure compliance with Title III requirements and to maximize the use of Title III funds.

13. Non-Public School Participation Dr. Seon Hwa Eun Illinois State Board of Education Division of English Language Learning

14. I. Current requirements • Section 9510 (a) (1) of the ESEA: LEAs conduct timely and meaningful consultation with appropriate private school officials. • Section 9510 (c) (1) of the ESEA: LEAs consult with appropriate private school officials during the design and development of the Title III program.

15. II. Current guidelines • LEAs receiving Title III funds must provide educational services to LEP children and educational personnel in private schools that are located in the geographic area served by the LEA. • LEAs report private school participation in Title III programs in Consolidated Bilingual application. • The assurance is a part of districts’ plan for Title III funds. • Part B-11 Statement of Assurances • Part B-12 Private School Students Participating Title III LIPLEPS Programs • Part B-13 Private School Consultation for Title III LIPLEPS/IEP Services

16. III. Title III reports from ED • ISBE ensures that LEAs comply with ESEA requirements regarding participation of LEP students and teachers in private schools in Title III on the following: • how the children’s needs will be identified • what services will be offered • how, where, and by whom the services will be provided; and • how to services will be assessed and how the results of the assessments will be used to improve those services

17. IV. ISBE’s Plans To ensure that LEAs provide timely and meaningful consultation to appropriate private schools, ISBE plans the following: 1. A new electronic form (eGMS): It requires the school district and private school officials to explain how consultations have been implemented (e,g., identification of needs of children, services provided, time and locations of the services provided, and improvement of the services) in the new application.

18. IV. ISBE’s Plans Continued 2. Monitoring plan: From the 2009-2010 school year, interviews with private school officials will be included during on-site monitoring visits.

19. AMAO Sanctions Dr. Seon Hwa Eun Illinois State Board of Education Division of English Language Learning

20. I. Accountability • LEAs receiving Title III grants are accountable for meeting AMAOs targets including AYP for LEPs. • AMAO target 1: Progress • AMAO target 2: Proficiency • AMAO target 3: AYP (adequate yearly progress)

21. II. Sanctions for SDs not meeting AMAOs for 2 and 3 consecutive years • Section 3122 (b) (2) of the No Child Left Behind Act of 2001 and 23 IL Administrative Code Part 1, Section 1.88 (d) of Additional Accountability Requirements for Districts Serving Students of Limited English Proficiency under Title III: • If an eligible entity has failed to make progress toward meeting such objectives for 2 consecutive years, the agency shall require the entity to develop an improvement plan that will ensure that the entity meets such objectives. • The plan shall specifically address the factors that prevented the entity achieving such objectives. • The entities shall submit its plan no later than six months after it receives notification from ISBE of its failure to meet AMAOs for the second consecutive year.

22. III. Sanctions for SDs not meeting AMAOs for 4 consecutive years • Section 3122 (b) (4) of the No Child Left Behind Act of 2001 and 23 IL Administrative Code Part 1, Section 1.88 (e): - If an eligible entity has failed to meet AMAOs for 4 consecutive years, the agency shall (A) requires such entity to modify the entity’s curriculum, program, and method of instruction; or (B) (i) make a determination whether the entity shall continue to receive funds related to the entity’s failure to meet such objectives; and (ii) require such entity to replace educational personnel relevant to the entity’s failure to meet such objectives.

23. IV. Modifications of District Improvement Plans (DIPs) • ISBE is in the process of modifying DIPs to provide a clear guidance to SDs with 2, 3 and 4 years of AMAOs to meet sanction requirements. • The proposed DIPs will separate Title III section from Title I to address each AMAO targets on DIPs that the SDs fail to meet. • The proposed DIPs will guide the SDs to describe how to meet AMAOs targets corresponding specified sanction requirements in the sections of Data Analysis (I), Action plan (II), and Plan development, Review and Implementation (III).

24. IV. DIP Modifications Continued • Separate SDs with 2-3 years of AMAOs from 4 years of AMAOs: specific sanction requirements will be spelled out within the areas of curriculum, methods of instruction and program. • AMAOs with 2-3 years: focus on factors that prevent the SDs meeting AMAOs targets 1,2, and 3. • AMAOs with 4 years: redesign curriculum, methods of instructions, and program. Required to address the factors that prevented the entity from achieving objectives on DIPs.

25. V. Providing technical assistance to SDs with AMAOs for 2-4 years • Ladder Data Workshops for 2009-2010. • Separate workshops for SDs with 2-3 years of AMAOs from 4 years of AMAOs. • The identified SDs are required to attend a professional development workshop assisting their implementation of DIPs. • Workshop plan

26. VI. On-site monitoring • DELL included all SDs didn’t meet AMAOs in 2008 (three SDs) for four consecutive years in the on-site compliance monitoring schedule in 2009. • To ensure the modifications to their curriculum, program, and methods of instruction outlined in their amended DIPs have been implemented.

27. FY10 Monitoring Ilyse Leland, Bill Garcia and Sherry Johnson Illinois State Board of Education Division of English Language Learning

28. Compliance Monitoring • The State Board of Education is required to evaluate each school district’s compliance with the requirements of Article 14C of the School Code of Illinois, 23 Illinois Administrative Code Part 228, and Public Law 107-110

29. Key indicators for selecting districts for on-site monitoring • Types of programs (TBE/TPI, LIPLEPS, IEP) • Performance data (AMAO) • Funding level • DELL principal consultants concerns based on review of application (e.g. appropriate services, staff certification) • Documented concerns: conditional approvals, written complaints • ACCESS mismatch on SIS • Percentage of parent refusals • Non-public school participation in district

30. On-site Monitoring Process 1. District to be monitored will be notified one month in advance 2. DELL requests documents 3. DELL conducts on-site visit including interviews with staff members, file reviews and classroom observations 4. DELL submits report to district with findings and corrective actions 5. District responds to report 6. DELL accepts district’s response and sends close-out letter or DELL does not accept district’s response and continues to work with district until an agreement is reached

31. Ongoing/Follow-up Desktop Monitoring • Annual review of consolidated application for districts requesting funding/approval • Review of English Language Learning Delivery Education Plan (ELLDEP) for districts with ELLs that do not seek program approval or funding • Continued monitoring after on-site monitoring to ensure corrective actions have been implemented, including districts not attaining AMAO two consecutive years requiring District Improvement Plan (DIP)