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May 2013. Title I, Part A/LAP Spring Workshop. Agenda. Schoolwide Programs Parent Involvement Private Schools Title I, Part A iGrant Application - FP201 Charter Schools Allowable Costs – Basic Guidelines Time and Effort Learning Assistance Program (LAP). Title I, Part A.
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May 2013 Title I, Part A/LAPSpring Workshop
Agenda • Schoolwide Programs • Parent Involvement • Private Schools • Title I, Part A iGrant Application - FP201 • Charter Schools • Allowable Costs – Basic Guidelines • Time and Effort • Learning Assistance Program (LAP)
Title I, Part A Schoolwide programs
Title I, Part A Schoolwide Programs • The schoolwide program model is a comprehensive reform strategy designed to upgrade the entire reading and mathematics program for the Title I, Part A building • The primary goal of the schoolwide program is to ensure that all students, particularly those who are low-achieving, demonstrate proficient and advanced levels in the state academic achievement standards • To create schoolwide reform, the primary focus of the schoolwide program is to design and implement a well defined “schoolwide-system model”, of tiered/leveled additional interventions
Step 1 • Readiness to Benefit: Schoolwide-Systematic Reform Based Model • Clarify the vision of reform/A clear focus • Discuss with staff shared vision • Analyze ten components of schoolwide plan
Step 2 • Develop a comprehensiveneeds assessment for the entire building: • Modify schoolwide needs based on annual evaluation and review of program • Determine where the building is now and where it wants to be when its vision is realized • Collect, sort, analyze data • Reading, mathematics, language arts, and science • Set priorities and concerns • Identify strengths and weaknesses
Step 3 • Build Schoolwide comprehensive component plan to identify reform strategies: • Create a tiered/leveled model of additional intervention • Determine and identify proven researched-based strategies, designed to facilitate reform and improvement • Accept a collective responsibility for reaching and teaching all students • Tie all components to needs assessment (including which programs to be combined in the schoolwide program) • Set measurable goals-define action plan for reform • Includes list of programs combined, amount combined and how their intent and purpose of each combined program are met in the schoolwide plan and program (this will be used to determine appropriate time and effort)
Step 4 • Implementthe plan • Ongoing review of action plans • Review effectiveness of systematic-intervention model • Keep documentation of implementation • Modify and make adjustments, as needed, during the year
Consolidating Funds • Schoolwide programs may combine federal, state and local funds of programs consolidated • Schools operating schoolwide programs are not required to maintain separate accounting records for combined programs if • Combined programs are identified in the plan • School maintains records documenting intents and purposes of programs combined are met
Purpose/Benefit of Consolidation • To help schoolwide school effectively design and implement a comprehensive plan to upgrade the entire educational program in the school based on needs identified in the needs assessment • When combining BEA funds, instructional staff become schoolwide staff • Instructional staff are part of an additional tiered-model of interventions • Use of all available resources to meet needs • Flexibility in use of resources • Not required to account separately for funds used in program • Not required to meet most statutory and regulatory requirements of specific program included in consolidation
Consolidation of Funds • Treat funds as a single “pool” of funds • Lose individual identity • Use funds to support any activity of the schoolwide program • But, must meet intent and purpose of each program
Schoolwide Program Cannot Include Transitional Bilingual State Special Education State Highly Capable Other State Programs which are limited only to certain students (not available to all students in the building) I Title I, Part A Schoolwide Program Title I, Part A (Disadvantaged) Title II, Part A (Professional Development) BEA (Basic Education) Local Funding, Levy, District, etc. Title III, (Immigrant) Restricted Most ED Programs Migrant Indian Education Federal Special Education LAP Carl Perkins
Consolidated Program Review: CPRSchoolwide Non-Compliance Issues 1.7: Each Title I, Part A schoolwide building has a schoolwide building plan that contains the 10 component requirements and evidence the plan has been implemented, Section 1114(b)(1); 34 CFR 200.25
Supporting Documentation: Building Level-Schoolwide • Building Level: A copy of a schoolwide plan that includes the following 10 required components and supporting evidence: • Comprehensive need assessment • Schoolwide reform strategies • Instruction by highly qualified teachers • On-going professional development • Strategies to attract highly qualified teachers • Strategies to increase parent involvement • Transition • Measures to include teachers in assessment decisions • Strategies for additional assistance • Coordination and integration of federal, state and local services and programs
Common CPR-Non Compliance Issues Related to Schoolwide Plan • Schoolwide plan not current-not updated from original plan submission • Schoolwide plan not well-defined-statements with no evidence • Schoolwide documentation evidence reveals schoolwide model is in actuality a targeted-assistance program model • Cannot provide schoolwide plan
Common CPR-Non Compliance Issues Related to SchoolwidePlan Components The following components missing or lack of evidence: • Instruction by highly qualified teachers • Strategies to attract highly qualified teachers to high needs schools • Transition • Coordination and integration of federal, state and local services and programs
Common CPR-Non Compliance Issues Related to Schoolwide Plan Component • Component 10: Coordination and integration of federal, state and local services and programs • Component missing completely • Evidence for component list names of programs only • No matrix: Does not list funds combined, amount of funds, and the intent and purposes of combined funds • Matrix missing one or more of three required fields • Matrix lists all funds in building-allowable/restricted/or not allowable to combine
Use Correct Order • Determine which funds will be combined • Address intents and purposes in the plan • Meet and document intents and purposes • Determine how to charge
Fiscal Flexibility • Examples of ways to charge consolidated funds • Charge proportionately based on revenue • Charge sequentially • Charge based on activity (not use flexibility)
Title I, Part A Schoolwide:Supporting Documentation • OSPI Combining Funds Bulletin: Bulletin #054-12 http://www.k12.wa.us/BulletinsMemos/bulletins2012.aspx • Designing Schoolwide Programs: Non-Regulatory Guidance-March 2006 http://www.k12.wa.us/TitleI/TitleI/SchoolwideModel.aspx • ESEA/Section 1114(b)(1); 34 CFR 200.25
Title I, Part A Parent involvement policy
Parent Involvement CPR Issues District and Building Policies containing all the required elements. • District & Building CPR Monitoring Checklist Evidence of implementation: • Notification of meetings • Agendas • Sign-in Sheets
Parent Involvement CPR Issues 1% (Districts who receive an allocation of $500,000 or greater) • The district ensures parents have the opportunity to be involved in decisions regarding the 1% parent involvement funds. Evidence at district level of: • Parent survey • Meeting minutes, and/or • Agenda
FP 201-Updates Policy/Plan
Parent Involvement News Title I, Part A Parent Involvement Webpage • Survey News • OSPI Title I, Part A – New Parent Involvement Website • Parent involvement website with requirements across all federal programs (long term goal)
Parent Involvement -Resources • Parental Involvement: Title I, Part A Non-Regulatory Guidance • http://www2.ed.gov/programs/titleiparta/parentinvguid.pdf • Keys to Successful Partnerships: Six Types of Involvement • http://www.csos.jhu.edu/p2000/nnps_model/school/sixtypes.htm • CISL Website – Family Engagement, translation/interpretation • http://www.k12.wa.us/CISL/FamilyEngagement/Communicating/TranslationTips.aspx • Spanish/English glossary of education terms • http://www.k12.wa.us/CISL/FamilyEngagement/Communicating/Glossaries.aspx
Title I, Part A Private Schools
School District Responsibility to Provide Equitable Services for Eligible Private School Students, Teachers and Parents Equitable services must be provided whether the private school is within or outside school district boundaries. • Students – Supplemental instruction in reading, language arts or mathematics • Teachers of Title I, Part A Served Students – Professional development in the area of Title I, Part A services • Parents of Title I, Part A Served Students – Parent involvement activities that assist parents with the learning of their children
Eligibility Criteria for Funds and Services • Funds: Funds are generated on the basis of the number of students from low-income families who reside in the participating Title I, Part A public school attendance areas and attend private schools, whether the private schools are located within the district or outside the district boundaries • Services: Private school students who reside within a Title I, Part A attendance area and are failing or most at risk of failing to meet high standards are eligible for services
Establish Procedures to Ensure Equitable Services are Identified and Provided • Process involves multiple entities who must establish an agreeable procedure that works best for them, including the process to identify eligible students and determination and delivery of equitable services • Entities include: • Residing district of the private school student • District where the private school is located • Private school
Possible Options for Equitable Services Process • Private school contacts the districts where students live • Residing district then conducts consultation to identify eligible students • Equitable services identified – residing district and private school may work with district where private school is located to provide services • Residing district contacts private schools in the surrounding area to identify eligible students • Residing district consults with private schools and district where each private school is located • School district where private school is located contacts the private school and proceeds to contact residing districts of identified students • Conducts consultation process • Identifies all low-income students • Identifies students out of district and contacts residing district • Districts and private school work together to determine services
Providing Equitable Services Services may be provided by: • Employee of the residing district • Third party contract by residing district • District where the private school is located • Interlocal agreement between the residing district and the district where the private school is located establishes the services to be provided along with the funding amounts to provide the services • Services may be provided by an employee of the school district or a third party
Title I Equitable Services Resources • Title I Services to Eligible Private School Children, Non-Regulatory Guidance, October 2003 (Department of Education) • Ensuring Equitable Services to Private School Children: A Title I Resource Tool Kit, September 2006 (PDF with downloadable tools) (Department of Education) • Both documents available on the OSPI website at: http://www.k12.wa.us/ESEA/PrivateSchools.aspx
Title I, Part A iGrant Application – FP 201
Title I iGrantApplication (FP201) Changes • Contact Page: Please update school district contact information • Page 1: REAP Section removed • Page 2: Assurances updated • Page 3: Affirmation of Consultation form updated – If a 2012-13 affirmation form was completed for 2013-14 consultation process – okay to use for this year. • Page 4: Questions 10 & 11 Priority, Focus or Emerging Schools expanded • Page 4: Questions 14, 15 & 16 Parent Involvement updated • Pages 5-7: No changes
Title I, Part A Charter Schools
Charter Schools - Accountability • Accountability is overseen in accordance with state charter school law • The charter authorizer is primarily responsible for holding charter schools accountable under the Title I, Part A provisions unless state law specifically gives the state educational agency (SEA) direct responsibility for charter school accountability Section 1111(a)(2)(A)
Charter Schools - Allocations for Title I, Part A • If a charter school is authorized by an entity other than a traditional school district, the SEA will still be responsible for allocating Title I, Part A funds directly to the charter school, pursuant to federal and state laws • If a charter school is, under state law, part of a district, the district will allocate federal funds to the charter school on the same basis as it provides funds to its other schools
Charter Schools - Corrective Action • As with other public schools, charter schools that are unable to make adequate yearly progress (AYP) by the end of the second full school year after identification are placed under corrective action • The appropriate entity under state law has responsibility to reorganize a charter school’s management or take other corrective actions, consistent with state charter law and the state’s accountability plan for its charter schools Section 1116(b)(7)(C)
Charter Schools - Teacher Qualifications • The law provides that a teacher who teaches core academic subjects in a charter school meets the certification requirement if he or she meets the requirements set forth in a state’s charter school law regarding certification or licensure • Teachers in charter schools do not have to be licensed or certified by the state if the state’s charter law does not require such licensure or certification Section 9101(23)(A)(i)
Charter Schools - Paraprofessional Qualifications • Paraprofessional aides hired to work in programs supported with Title I, Part A funds must have a high school diploma or its recognized equivalent • Those who act as translators or conduct parent involvement activities must also have completed at least two years of study at an institution of higher education, possess at least an associate’s degree, or demonstrate subject-matter competence through a formal state or local assessment Section 1119(c)-(e) *This requirement applies only to paid paraprofessionals and not to parents or other volunteers. In addition, the term “paraprofessional” applies only to individuals who provide instructional support and not to school staff who have only non-instructional duties (e.g., providing technical support for computers, providing personal care services to students, carrying out clerical functions) [34 C.F.R. Section 200.58(a)(2)].
Title I, Part A Allowable Costs – Basic Guidelines
Allowability of Costs To be allowable a cost must: • Be necessary and reasonable for proper and efficient performance and administration of federal awards • Be allocable to federal awards • Be authorized under state and local laws, policies and procedures • Conform to any limitations in the A-87 circular • Be consistent and applied consistently (capital assets, direct vs. indirect costs, etc.)
Allowability of Costs Allowable if: • Follows generally accepted accounting principles • Not be used to meet cost sharing or matching of another federal award • Is net of all applicable credits • Is adequately documented
Reasonable Costs • Prudent Person Test • Ordinary and necessary for operation or performance of federal awards • Follows sound business practices; arms-length bargaining; follows laws/regulations federal terms • Market price for comparable goods and services • Administered with prudence • No significant deviations; consistent with non-federal • Benefits the program
Supplement-Not-Supplant (Services to Students) Presumptions of supplanting for districts and targeted assistance buildings- • Federal funds were used to provide services that the district was required to make available under federal, state or local law • Federal funds were used to provide services provided with non-federal funds in the prior year(s) • Title I, Part A or C funds were used to provide services for participating children that were provided with non-federal funds for non-participating children • Rebuttal may be possible in some cases
Supplement-Not-Supplant • Presumption of supplanting for Title I, Part A schoolwide buildings • Must show each schoolwide building received all state and local funds to which it is entitled, including those for basic education, for children with disabilities and for limited English proficient children
Title I, Part A Time and Effort reporting