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Welcome!. The webinar will begin at 3:30 p.m. Title III Program Monitoring Tier I, Tier II, & Tier III and BAAS Documentation February 6, 2014. North Carolina Department of Public Instruction K-12 Programs Title III/ESL Office . Monitoring Focus. Programmatic Success Compliance.
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Welcome! The webinar will begin at 3:30 p.m.
Title III Program MonitoringTier I, Tier II, & Tier IIIand BAAS DocumentationFebruary 6, 2014 North Carolina Department of Public Instruction K-12 Programs Title III/ESL Office
Monitoring Focus • Programmatic Success • Compliance
Areas Assessed • ELD Standards • Assessment & Accountability • Instructional Support • Fiscal Compliance
Tiered Monitoring Title III Self-EvaluationSurvey
Tiered Monitoring Needs Based Monitoring Onsite One or Two day Monitoring
Tiered Monitoring On-Site Monitoring Two(2) Day
Exploring Monitoring Documents http://eldnces.ncdpi.wikispaces.net/LEP+Coordinators
Title III Monitoring Plan 13-14 http://eldnces.ncdpi.wikispaces.net/LEP+Coordinators Title III Monitoring Plan 13-14
Monitoring Schedule Considerations 13-14 http://eldnces.ncdpi.wikispaces.net/LEP+Coordinators Monitoring Schedule Considerations 13-14
Monitoring FAQ http://eldnces.ncdpi.wikispaces.net/LEP+Coordinators Monitoring FAQ
Classroom Observations Form http://eldnces.ncdpi.wikispaces.net/LEP+Coordinators Classroom Observations Form
Guidelines for Observations http://eldnces.ncdpi.wikispaces.net/LEP+Coordinators Guidelines for Observations
Fiscal Documents http://eldnces.ncdpi.wikispaces.net/LEP+Coordinators Fiscal Documents
Title III Monitoring: Accountability SBE Policy GCS-A-012 Subgrantees receiving Title III funds (LEAs, public charter schools, & consortia) must meet a series of Annual Measurable Achievement Objectives (AMAOs) AMAO 1 – Progress AMAO 2 – Proficiency AMAO 3 – AMOs for the LEP Subgroup
Title III, Sec. 3122(b)(2) and State Board Policy reference (4) ACCOUNTABILITY- If a State educational agency determines that an eligible entity has failed to meet the annual measurable achievement objectives described in subsection (a) for 4 consecutive years, the agency shall — (A) require such entity to modify the entity's curriculum, program, and method of instruction; Policy Identification Priority: Globally Competitive StudentsCategory: TestingPolicy ID Number: GCS-A-012 Sanctions for AMAOs Not Met If the Title III subgrantee has failed to meet the AMAOs for four (4) consecutive years, the State Board of Education shall require the Title III subgrantee to modify its curriculum, program, or method of instruction.
Risk Factors Risk factors include but are not limited to: • size of subgrantee grant award, • percentage of LEP students, • program performance based on meeting AMAOs 1 and 2, • student subgroup academic performance based on AMOs for LEP students, • change in program or leadership, and • the length of time since previous onsite monitoring.
Tying It All Together • Application • Improvement Plan • Monitoring • Implementation
Budgets Basic Supplement, Not Supplant USDE, Student Achievement and School Accountability (SASA)
Title I, Part A & Title III, Part A Title I Title III Funds must supplement, and not supplant other Federal, State, and local funds. (Section 3115 of ESEA) Funds must supplement, and not supplant State and local funds (Section 1120A of ESEA) USDE, Student Achievement and School Accountability (SASA)
Title III “A Supplemental Program to Serve English Learners” • Cake– state and local funds used to provide the Core EL program • Icing/Frosting – Other federal funds • Sprinkles – Title III funds • High Quality Language Instruction Educational Program (LIEP) • High Quality Professional Development USDE, Student Achievement and School Accountability (SASA)
Developing My LEA’s Supplemental Title III Program Do all of the items on my local plan and budget narrative meet the following criteria? • Are they allowable? • Are they allocable? • Are they reasonable and necessary to carry out grant function? • Determine whether they should be included in the 2% limit as administrative costs? USDE, Student Achievement and School Accountability (SASA)
Supplement, Not Supplant Requirement – General The First Test of Supplanting: Required by Law The Department assumes supplanting exists if – An LEA uses Title III funds to provide services that the LEA is required to make available under State or local laws, or other Federal laws. USDE, Student Achievement and School Accountability (SASA)
Supplement, Not Supplant Requirement – General The Second Test of Supplanting: Prior Year The Department assumes supplanting exists if – An LEA uses Title III funds to provide services that the LEA provided in the prior year with State, local or other federal funds. This assumption can be rebutted. USDE, Student Achievement and School Accountability (SASA)
To refute the “prior year” test of supplanting, the LEA would need to have contemporaneous records to confirm…. • Budget cuts were made in a number of areas, not just for LEP students; and • There was in fact a reduced amount of State or local funds to pay for this activity/position; and • The LEA made the decisions to eliminate the position/activity without taking into consideration of Federal funds. USDE, Student Achievement and School Accountability (SASA)
Questions to Ask When Considering Whether Title III Funds Can be Used Without Violating the Supplement, not Supplant Requirement • What is the instructional program/service provided to all students? • What does the LEA do to meet Lau requirements? • What service is the LEA required by other Federal, State, and local laws or regulations to provide? • Was the program/service previously provided with State, local, and Federal funds? USDE, Student Achievement and School Accountability (SASA)
Resources • Office of Planning, Evaluation and Policy Development, Policy and Program Studies Service • Office of Management & Budget (OMB) Circular a-87: http://www.whitehouse.gov/omb/circulars_a087_2004/ • EDGAR – (See parts 76 and 80 in particular) http://www2.ed.gov/policy/fund/reg/edgarReg/edgar.pdf • Office for Civil Rights, ELL Resources http://www.ed.gov/about/offices/list/ocr/ellresources.html
All in one place! • System notification of budget/amendment submission • Changed Justification feature allows you to note reason for changes • Response from NCDPI within the system
BAAS Documentation Why is using the changed justification feature important? No additional email is needed unless there is a change to the application which requires additional documentation i.e. new staff position and additional technology purchases.
More Documentation Needed New staff positions – require approval of job description Technology purchases – requires approval of supplement not supplant rationale
NC DPI ESL Consultants Regions 5, 6, 7, 8 Ivanna (Mann Thrower) Anderson ESL/Title III Consultant NC DPI 919-807-3860 ivanna.thrower@dpi.nc.gov Regions 1, 2, 3, 4 Charlotte “Nadja” Trez ESL/Title III Consultant NC DPI 919-807-3866 nadja.trez@dpi.nc.gov Lindsey Fults ESL/Title III Consultant NC DPI 919-807-3944 lindsey.fults@dpi.nc.gov