Participation of Eligible Private School Students, Their Parents and Teachers

1. Private School Equity NCLB Participation of Eligible Private School Students, Their Parents and Teachers Equitable Services Reservation AND Proportional Shares of Reserves Services only; Funds can Never Pass through Private Schools LEA Responsibility for Consultation, Program Design, Implementation & Evaluation Allowable/Non-allowable Services: Computer aide funding must come under administrative reserve – not out of instructional funds based on PPA No Teaching Assistant only funding; qualified Title I TAs must always work under HQ teachers employed by LEA No materials only funding; materials alone do not constitute a Title I program. Materials to be used in program under LEA-employed teacher Section 1119 HQ Reserve: Proportional shares for nonpublic teacher PD(but, in nonpublics, not for HQ; used to help non-Title I teachers better serve Title I students in core Gen Ed)

2. LEA Responsibilities forPrivate School Equity • Determine funding eligibility by poverty and residence in Title I school attendance area (and, when only 1 student, academic need) • Reserve funds for equitable services • Based on Per Pupil Amount (PPA) (same as public) plus; • Proportional shares of applicable reserves that were taken before calculating the PPA plus; • Proportional shares of excluded reserves if released. • Consult on timely basis with private school officials. • Design & implement the Title I program (including consultation on assessments to identify students & measure progress/success). • Evaluate the program’s effectiveness, adjusting as needed. • Maintain records. • Provide Title I Complaint Policy and Procedures, noting how nonpublic representatives may file complaint directly with NYSED.

3. Excluded Reserves(unless/until unspent portions are to be released) • SES/Choice • DINI Professional Development (PD) • Homeless • Administrative (non-public administrative costs, such as cost of computer aides, etc., are included) • Prekindergarten • Neglected (Note: Unspent portions are not released but recorded andcarried over for the neglected facility)

4. Reserves that Must Include Proportional Shares for Private Schools • 1% Parent Involvement • Discretionary Professional Development (PD) • Discretionary Instructional Initiatives, except PreK • 5% Highly Qualified (HQ) (may be less than 5% if Teacher Quality Plan shows less needed for 100% HQ but proportional share must be included) • Proportional share of HQ in private schools is not for HQ purposes but to prepare nonpublic core Gen Ed teachers to better serve Title I students in their classrooms (not to upgrade general quality of private program). • Nonpublic Title I program evaluation can play an important role in identifying appropriate PD. See Toolkit on SED Private School Equity web site at http://www.p12.nysed.gov/accountability/T1/titleia/equity.html

5. Calculating Private School Proportional Shares of Reserves Terms: N = the # of Poverty Children in the individual Private School (or all private schools if pooling funds) Who Reside in Title I School Attendance Areas T = the Total # of Students in Poverty - Public + Private – that reside in Title I School Attendance Areas M = N/T (multiplier for the individual private school obtained by dividing N by T ) Formula:M x Reserve Amt = Proportional Share for the individual school for this reserve E.g., 50 poverty students from Title I areas attend St. John’s. There are a total of 10,000 public + private poverty students in the LEA’s.Title I attendance areas. This school’s multiplier for all reserves = 50/10,000 = 0.005 The HQ reserve for the LEA is $20,000. 0.005 x $20,000 = $100, this school’s share of the HQ reserve. Repeat this process for eachprivate school for each applicable reserve. Indicate these amounts and plans for their use on all Private School Participation Forms (PSPFs).

6. Alternate Method of Calculating/Checking Proportional Shares of Reserves If you find working with decimals daunting, you can check your results using the following formula, which should yield the same results: 1) Divide the amount of the reserve (R) to be shared by the total # of public + private poverty students residing in the LEA’s Title I attendance areas (T) to obtain a reserve PPA for each reserve (PPA) . 2) Multiply the PPA for each reserve by the number of poverty students from Title I attendance areas in each private school (or in all private schools if pooling funds) (P). Calculation of St. John’s share of the HQ reserve from our previous example using this method: 1) R/T= $20,000/10,0000 = $2 PPA for HQ 2) PPA x P = $2 x 50 = $100, this school’s share of the HQ reserve. Repeat for each reserve for each private school served (or for all private schools if pooling funds) and indicate amounts and plans for their use on all PSPFs.

7. Allowable / Non-allowable Title IServices for Private School Students • Instructional Services, which must be secular and non-religious, should be emphasized: • Teachers in the Title I Program must be employed by the LEA, as district employees or by contract between the LEA and the individual (paid directly by LEA)* and must be under the supervision of the LEA, not a private school or religious entity, in the provision of services. *LEAs may also contract with third party providers, who employ and supervise teachers in compliance with ESEA/NCLB and regulatory requirements as they pertain to third party providers. • Computer aide funding must come under administrative reserve – not out of instructional funds based on PPA • No Teaching Assistant (TA) only funding; qualified Title I TAs may work only under direct supervision of HQ teachers employed by the LEA * • Materials and Equipment: • No materials only funding; materials alone do not constitute a Title I program. Materials are to be used in a program under the supervision of a district employed teacher. • All non-consumable materials & equipment remain the property of the LEA; they must be inventoried, labeled & their disposition approved by the LEA. They may not be used for non-Title I activities by the private school. • Professional Development (PD): • Section 1119 Highly Qualified (HQ) Reserve: Proportional shares must be reserved for nonpublic teacher PD butnot for HQ purposes. Instead, used to help non-Title I teachers meet the needs of Title I students in core Gen Ed classes. (Purpose must be to serve Title I students, not general upgrading of nonpublic program. Program evaluation can provide direction; see Toolkit.) • PD for Title I teachers employed by the LEA should come from district Title I PD funds. • Parental Involvement (PI): • Proportional shares of 1% PI Reserve must be set aside for involvement/capacity building of parents of participating Title I students (not for all private school parents). Any unspent PI reserve must be set aside for PI purposes in the following year. • Assessment Tools: In addition to diagnostic tools, assessments used specifically for the purpose of determining the need for Title I services (which may not be funded in public schools) may be funded under private school services for students residing in Title I attendance areas. • Unused reserves must be carried forward for private school equitable services in the following year, with unused shares of Sections 1118 (PI) and 1119 (PD) reserves set aside for their original purposes.

8. SED Websites • Title I Technical Assistance: http://www.p12.nysed.gov/accountability/T1/titleia/equity.html • Private School Equity http://www.p12.nysed.gov/accountability/T1/titleia/equity.html • Federal Guidance On Private School Equity for Title I and other Titles • Title I Toolkit with sample forms and procedures used by LEAs to comply with Private School Equity requirements • Related legislation • Parental Involvement: http://www.p12.nysed.gov/accountability/T1/titleia/pi.html and many more topics… Let us know about additional topics of interest ! For additional information, call the Title I Office at (518) 473-0295.