Title Programs in Nonpublic Schools: A Tale of Two Cities

1. Title Programs in Nonpublic Schools: A Tale of Two Cities Carolyn J. Cherry, Ed. D., Coordinator, ESEA Minneapolis Public Schools Lynn Moore, Supervisor, St. Paul Public Schools Debra Landvik, Educational Specialist II, Parent Involvement & Nonpublic Minnesota Department of Education March 22, 2013

2. Overview—Nonpublic Process • Consultation • Maintaining Documentation • Contracting with Third Party Providers • Maintaining Fiscal Authority • Maintaining Oversight & Control

3. Carolyn Cherry, MPS • Fourth year for nonpublic service coordination • 15 schools • Title I: 10 • Title II: 15 • Title III: 5 • Catholic: 7 • Other Christian denomination: 5 • Independent (Waldorf, Montessori, etc.): 3

4. Lynn Moore, SPPS • Seventh year for nonpublic service coordination • 19 schools, including West St. Paul • Title I: 10 • Title II: 18 • Title III 1 • Majority Catholic • Independent • Lutheran: 2 • Jewish: 2

5. The Consultation Process-Overview • Goal: to design and implement programs that will provide equitable services and meet the needs of eligible private school students and teachers • Timely: Occurs prior to decisions being made about programs, must continue throughout implementation and evaluation • Meaningful: Private schools will be able to have an impact on the content and delivery of program and services Deb Landvik, MDE-2007

6. Consultation Process Requirements • Determine how eligible children’s needs are identified (data sources); • What services will be offered; • How, where, and by whom the services will be provided; • How services will be assessed and improved based upon assessment results;

7. Consultation Process Requirements • Size and scope of services and the proportion of funds allocated to provide those services; • How and when decisions about the delivery of services will be made; • Method for determining poverty data; • Equitable services to teachers and parents of participants.

8. Documentation—Required • Record of visits by LEA to nonpublic schools • August • MPS: Review/update eligibility lists from previous spring • SPPS: Gather F/R lunch/school testing information • September • MPS: Distribute eligibility lists to providers, send eligibility notification to families • SPPS: Gather testing information from schools, assess students for services • SPPS: Send notification for assessment, participation

9. Documentation—Required • October • MPS: Updated Eligibility lists due • November/December • MPS/SPPS: Collect Nonpublic Fall Report (MDE) • MPS: data from fall report determines F/R student count for following year’s budget • SPPS: collects updated information to determine F/R counts • MPS: Verification of Resident/Nonresident Status Form (free and reduced) • Annual Title I/III Meetings

10. Documentation—Required • January/February/March • Ongoing consultation • Budget reallocations/revisions • MPS: Reallocation deadline coincides with MDE ESEA Application amendment deadline(s) • April • Updated Eligibility Lists • Affirmation of Consultation Letters • Intent to Participate • May/June • Consultation Meetings with Nonpublic Administrators • Develop Program Plans

11. Contracting with Third Party Providers • LEA’s may not contract without going through the consultation process • LEA must maintain authority over the relationship between the Third Party Contractor and the Nonpublic school • LEA may not delegate its obligation or responsibility to Nonpublic school officials or Contractors

12. Contracting with Third Party Providers • Proposals from providers should include costs related to: • Instruction • Administration • Professional development, and • Parental involvement • Standards and Assessment • Compliance with local, state, and federal regulations and guidance Virginia Berg, DOE-2008

13. Maintaining Fiscal Authority • Keys to staying out of Nonpublic Jail: • Taking responsibility for the administration and oversight of all Title related funds; • Ensuring communication and developing a feedback loop regarding processes, procedures, and rules; • Ensuring all requests for Nonpublic expenditures be preapproved • Compliance, program efficacy, and finance • Tracking the ‘life cycle’ re: use of federal funds See MDE Monitoring Tool for more information

14. Helpful Websites • MDE Nonpublic Website: http://education.state.mn.us/MDE/SchSup/SchFin/Nonpublic/ • DOE Nonpublic Website, NCLB: http://www2.ed.gov/about/offices/list/oii/nonpublic/nclbinfo.html • DOE Nonpublic Website, Private Schools: http://www2.ed.gov/programs/titleiparta/ps.html

15. Helpful Websites • DOE Nonpublic Website, Non-regulatory Guidance: http://www2.ed.gov/programs/titleiparta/psguidance.doc • MPS Nonpublic Forms: http://fundedprograms.mpls.k12.mn.us/non-public_resources • SPPS Nonpublic Forms: http://title1spps.org

16. Activities Consultation Scenario Public school and Nonpublic school officials had a phone conversation in April about Title I services for the following fall. The nonpublic school is new to receiving Title I services. In September, a Title I tutor comes to the nonpublic school to provide services to students; the nonpublic administrator, somewhat confused, has the tutor start working with students who were ‘low’. Discuss.

17. Activities Maintaining Documentation Scenario MDE is coming to your district to do an audit of nonpublic Title I files. What documentation should you have on hand to show that the nonpublic school has been involved throughout the school year(s)? Discuss.

18. Activities Maintaining Oversight and Control Scenario A nonpublic school requests that books be purchased as part of a Title II request involving a presentation to staff at the nonpublic school. The vendor/presenter is instructed to mail books to the district office for inventory. However, the vendor sends the materials directly to school. What are the next steps? Should the district pay for the books? Discuss.

19. Activities Contracting with Third Party Providers Scenario The Contractor is planning the Title I Family meeting and, upon the request of the nonpublic administrator, agrees to pay for the food for the event. The nonpublic administrators tells the Contractor that they (the contractor) can just ask the District/LEA to reimburse them for costs. After the event, the Contractor submits a receipt for reimbursement. Discuss.

20. Activities Maintaining Fiscal Authority Scenario A nonpublic school sent in a preapproval request for three (3) staff to attend an out-of-state conference. The District gave approval for those 3 staff. After the conference occurred, five (5) staff sent in receipts requesting reimbursement for the conference—including airfare, hotel, shuttle and baggage. Discuss.