Title I, Part A

1. Title I, Part A Marlene Padernacht CREC Curriculum Council October 24, 2013

2. Topics • ESEA Historical Perspective • Understanding Title I Allocations • Title I Programs • Parent Involvement and Notification • Verification of Compliance • Private School Equitable Services • Supplement not Supplant • Comparability and Monitoring

3. ESEA Historical Perspective • 1965 Elementary and Secondary Education Act (ESEA) • President Lyndon B. Johnson’s “ War on Poverty,” vision of a “Great Society” • Marked the federal government’s first substantial direct involvement in elementary and secondary education • Federal funds were to offset the effects of poverty

4. ESEA Historical Perspective • 1970’s –Rules added to increase fiscal control and accountability. Schools separated Title I programs from regular instruction in order to establish a clear audit trail. • 1981 –Education Consolidation and Improvement Act pared regulations, loosened fiscal rules and restrictions on selection of schools and state monitoring requirements. Eliminated parental-involvement mandates and renamed the program Chapter 1 (focus on basic skills). • 1983 – National Commission on Excellence in Education issued A Nation at Risk decrying America’s mediocre educational performance. President Reagan did not support an increased federal role in education and limited the report’s impact at the federal level.

5. ESEA Historical Perspective • 1988 – Hawkins-Stafford Elementary and Secondary School Improvement amendments restored some of the parental involvement and administrative rules, targeted more funds on the neediest areas and added program-improvement provisions mandating state intervention in failing local programs. Linked the Chapter 1 program with the regular school program and encouraged a greater focus on “higher-order” thinking skills. • 1994 – Improving America’s Schools Actrenamed the program Title I. Established the principle that Title I students will be taught to the same high standards as other children. Integrated Title I into state accountability systems. Title I schools and students would be judged according to the same state standards and assessments that apply to other children.

6. ESEA Historical Perspective • 2001 No Child Left Behind (NCLB) • Mandatory national achievement deadline • Minimum qualifications for teachers in all public schools – new requirements for paraprofessionals • Stronger accountability for results • Timely information for parents • Options for parents - SES and NCLB public school choice

7. ESEA Historical Perspective • 2012 ESEA Flexibility Waiver • New indicators • New targets • Waived SES and NCLB Public School Choice • Still in place - Not waived • Highly qualified teacher requirements • Parent involvement requirements • Private school equitable services

8. Understanding Title I Allocations • Congressional appropriations - $14 billion • Connecticut’s 2013-14 state allocation - $107 million • U.S. Census poverty estimates -statistical estimates of school-age children from families living in poverty - used in formula to distribute Title I funds to states - updated annually. • No correlation to free/reduced lunch data • National “poverty pie” - each state gets a share

9. Understanding Title I Allocations • Poverty estimates based on statistical model that incorporates data from: • Census Bureau’s American Community Survey • Administrative records from federal income tax returns • Supplemental Nutrition Assistance Program • Most recent decennial Census • Update to population estimates • Data on Supplemental Security Income recipients • Economic data from the Bureau of Economic Analysis

10. Understanding Title I Allocations • Non-Census counts used in formula • Children living in local institutions for neglected or delinquent children • Children living in foster care • Children from families living above the poverty line receiving Temporary Assistance for Needy Families • State per-pupil expenditures

11. Understanding Title I Allocations • Increases or decreases in poverty in states results in changes to the relative distribution of Title I funds. • Changes in district poverty (U.S. Census poverty estimates) affect district allocations.

12. Understanding Title I Allocations • Redistricting or school reconfigurations have no impact on district Title I allocations • Statutory district hold-harmless provisions apply • Limits the reduction of a district’s allocation compared to the previous year • 85, 90 or 95 percent hold-harmless thresholds

13. Understanding Title I Allocations • Small Area Income and Poverty Estimates (SAIPE) Branch at the Census Bureau • For information about the data sources and the methodology used to prepare these data please see the frequently asked questions fact sheet prepared by the Census Bureau available at: http://www.census.gov/did/www/saipe/about/faq.html

14. Understanding Title I Allocations • District Title I Allocation: • Four separate grants • Basic Grants - 10 “formula” children, number of those children exceeds 2 percent of the district’s total population of children ages 5-17 • Concentration Grants - number of children in Basic Grant formula exceeds 6,500 children or 15 percent of the total population of children ages 5-17

15. Understanding Title I Allocations • Targeted Grants- at least 10 “formula” children and equals or exceeds 5 percent of district’s total population of children ages 5-17. • Education Finance Incentive Grants - an effort factor that measures a state’s effort to provide financial support for education compared to its relative wealth as measured by its per capita income, and an equity factor that measures the degree to which education expenditures vary among school districts within a state.

16. Title I Programs • Targeted Assistance Program • Schoolwide Program

17. Title I Targeted Assistance Program • Provide supplementary services to eligible children identified as having the greatest need for special assistance: • failing, or most at risk of failing to meet state standards • based on multiple, educationally related objective criteria • preschool through second grade – developmentally appropriate measures; teacher judgment, interviews with parents, etc. • Automatically eligible for services: • any child who participated in Head Start, Title I preschool services, neglected or delinquent children, homeless children

18. Title I Schoolwide Program • Comprehensive reform strategy designed to upgrade the entire educational program • Eligibility - 40% poverty threshold (waived for Focus and Turnaround schools) • Primary goal is to ensure that all students, particularly those who are low-achieving, demonstrate proficient and advanced levels of achievement on state academic achievement standards.

19. Parent Involvement Requirements • District Policy • School Policy (plan) • school-parent compact

20. Parent Involvement • District policy: • develop jointly with Title I parents • distribute to all Title I parents • evaluate annually, with parents, the content and effectiveness of the policy

21. Parent Involvement • School policy (plan): • develop jointly with Title I parents • distribute to all Title I parents • how parents will be involved in meaningful ways in making decisions about the Title I program and how parents will be involved in the school • hold annual meeting and regular meetings of Title I parents to discuss the Title I program and parents’ rights • update policy periodically to reflect changing concerns of parents

22. Parent Involvement • School policy (plan): • school-parent compact* • outlines how parents, the entire school staff, and students will share the responsibility for improved student achievement, and • how the school and parents will build and develop a partnership to help children achieve the state’s high standards *Department’s new model of a school-parent compact: ctschoolparentcompact.org

23. Parent Notification Requirements • Title I Parents Right-to-Know Requirements: • At the beginning of each school year, a district shall notify the parents of each student attending a Title I school that the parents may request, and the district will provide the parents on request (and in a timely manner), information regarding the professional qualifications of the student’s classroom teachers, including, at a minimum, the following:

24. Parent Notification Requirements • Whether the teacher has met state qualification and licensing criteria for the grade levels and subject areas in which the teacher provides instruction; • Whether the teacher is teaching under emergency or other provisional status through which state qualification or licensing criteria have been waived; • The baccalaureate degree major of the teacher and any other graduate certification or degree held by the teacher, and the field of discipline of the certification or degree; and • Whether the child is provided services by paraprofessionals and, if so, their qualifications

25. Parent Notification Requirements • A Title I school shall provide to each individual parent timely notice that the parent’s child has been assigned, or has been taught for four or more consecutive weeks, by a teacher who is not highly qualified

26. Verification of Compliance • Each principal of a Title I school must attest annually in writing as to whether such school is in compliance with the teacher and paraprofessional requirements • Copies of the attestations must be maintained at each Title I school and at the main office of the school district

27. Private School Equitable Services • Supreme Court decisions • 1985 Aquilar vs. Felton • 1997 Agostino vs. Felton • Statutory public control of funds requirement - Section 1120(d) and Section 9501(d)(1) • Section 1120 - Participation of children enrolled in private schools

28. Private School Equitable Services • 1985 Aguilar vs. Felton • Public school employees could no longer provide educational services in private schools • Neutral sites (mobile vans, portable units) • Public schools • Computer-assisted instruction

29. Private School Equitable Services • 1997 Agostini v. Felton - Court overruled Aquilar • Title I instructional services can be provided in private schools • Totally separate from the private school’s educational program and under the sole control of the district. District is responsible for planning, designing and implementing the Title I program. • Public employees are accountable only to their public school supervisor • Cannot engage in team teaching or other cooperative instructional activities with private school personnel • Materials and equipment used for Title I services must be properly identified as district property purchased with Title I funds

30. Private School Equitable Services • Eligible private school children: • Must live in a Title I public school attendance area • Have the greatest educational need (those who are failing, or most at risk of failing to meet high academic achievement standards) • Poverty is not a criterion • Funds may only be used to improve the academic achievement of eligible students who are selected for participation

31. Private School Equitable Services • Provision of Title I services: • Public school teacher (must meet highly qualified NCLB teacher requirements) • Public school paraprofessional (must meet highly qualified NCLB paraprofessional requirements and work in close proximity and under direct supervision of a highly qualified public school teacher – a program staffed entirely by paraprofessionals is not allowable)

32. Private School Equitable Services • Employees of third party contractor (do not have to meet highly qualified NCLB requirements) • Private school teacher (must meet the highly qualified NCLB requirements and be independent of the private school in the provision of Title I services – be employed by public school district for Title I purposes outside of the time employed by private school and must be under the direct supervision of the district)

33. Private School Equitable Services • Public control of funds: • The control of funds provided under this part, and title to materials, equipment, and property purchased with such funds, shall be in a public agency, and a public agency shall administer such funds, materials, equipment, and property. • No Title I funds may be paid to a private school. • Private school officials may not order or purchase materials and supplies and be reimbursed by school districts.

34. Supplement not Supplant • Title I funds are to be used to supplement, not supplant non-federal funds • Intended to ensure that services provided with Title I funds are in addition to, and do not replace or supplant, services that students would otherwise receive

35. Supplement not Supplant • Presumption of supplanting: • An LEA used Title I funds to provide services that the LEA was required to make available under federal, state or local law • An LEA used Title I funds to provide services that the LEA provided with state or local funds in the prior year • An LEA used Title I funds to provide services for participating children that the LEA provided with non-federal funds for non-participating children

36. Supplement not Supplant Presumption of supplanting is rebuttable if the LEA can demonstrate that it would not have provided the services in question with state and local funds had the Title I funds not been available.

37. Supplement not Supplant • To rebut presumption show: • Fiscal or programmatic documentation to confirm that, in the absence of federal funds, would have eliminated staff/services in question • State or local legislative action • Budget histories and information • Fact and case specific

38. Supplement not Supplant LEA may exclude state and local funds expended for carrying out a program that meets the intent and purposes of Title I, Part A – • A program meets the intent and purposes of Title I, Part A if the program either- • Is implemented in a school in which the percentage of children from low-income families is at least 40 percent (“schoolwide like” programs); • Is designed to promote schoolwide reform and upgrade the entire educational operation of the school to support students in their achievement toward meeting the state’s challenging academic achievement standards that all students are expected to meet; • Is designed to meet the educational needs of all students in the school, particularly the needs of children who are failing, or most at risk of failing, to meet the state's challenging student academic achievement standards; and • Uses the state's system of assessment under 34 CFR 200.2 to review the effectiveness of the program.

39. Supplement not Supplant • Or (“targeted assistance like” programs) – • Serves only students who are failing, or most at risk of failing, to meet the state's challenging student academic achievement standards; • Provides supplementary services designed to meet the special educational needs of students who are participating in the program to support their achievement toward meeting the state’s student academic achievement standards; and • Uses the state’s system of assessment under 34 CFR 200.2 to review the effectiveness of the program

40. Coming Soon • Comparability • Monitoring

41. Title I Comparability • Districts with Title I and non-Title I schools: • Use state and local funds in Title I schools to provide services that, taken as a whole, are at least comparable to services in non-Title I schools • Districts with all Title I schools: • Use state and local funds to provide services that are substantially comparable in each Title I school

42. Title I Comparability • Title I schools must be comparable each year • Districts must demonstrate compliance once every two years • Written assurance • Calculations: students/instructional staff ratios or per pupil expenditures • Maintain documentation

43. Monitoring • Focus • Parent Involvement • Equitable Private School Services • Three levels • Self Assessment • Desk Review • Onsite Visit

44. And….Title II, Part ATeacher and Principal Training and Recruiting Fund • 100 percent transferability option • Programmatically “transfer” Title II grant funds for allowable activities under: • Title I, Part A - Improving Basic Programs • Title II, Part D - Enhancing Education Through Technology • Title IV, Part A - Safe & Drug-Free Schools • Title V, Part A - Innovative Programs

45. Title I Resources Marlene Padernacht 860-713-6568, marlene.padernacht@ct.gov Parent Involvement: Judy Carson 860-807-2122, judy.carson@ct.gov CT State Department of Education Title I Web Site: http://www.csde.state.ct.us/public/cedar/nclb/title1/index.htm Supplement not Supplant section, federalTitle I Fiscal Non-Regulatory Guidance, February 2008. http://www.ed.gov/programs/titleiparta/fiscalguid.pdf