office of field services ensuring equitable services for school children attending private...

Office of Field Services

Ensuring Equitable Services for School Children Attending Private

Non-Profit Schools

Office of Field Services

Katie Doerr ParkerGayle Green

Yvonne W. Mayfield

Field Services Consultants Office of Field Services

www.michigan.gov/ofs

Reference MaterialsThe following handouts are available on MDE’s website, www.michigan.gov/ofs:

Ensuring Equitable Services for Private Non-Profit School Children -

Power Point Overview Technical Assistance Packet – Working with Private Schools Allocation Worksheets Non-Regulatory Guidance Private School Questions and Answers Equitable Worksheet

Reference MaterialsTechnical Assistance Packets –

Title I, Part ATitle I, Part CTitle II, Part ATitle III, Part A

REQUIREMENTS

Equitable Services Requirement-District Responsibility

Equitable Participation in:Title I, Part A Improving the Academic Achievement

of the DisadvantagedTitle I, Part C Migrant EducationTitle II, Part A Teacher & Principal Training &

Recruiting Title III, Part A Language Acquisition Program

(English Learners and Immigrant Students)

Mayfield, Yvonne (MDE)

Equitable Services Requirement

In order to meet Equitable Services requirements, a Local Educational Entity

(LEA) must annually notify all private, non-profit schools within its boundaries and outside of district if resident students

attend, of eligibility for equitable participation with Title programs

Equitable Services Requirement

Low-income parents with private school children are included in

census poverty counts that generate funds the Local

Educational Agencies (LEAs) use forTitle I services

Equitable Services RequirementChild Benefit Theory

This theory was developed to comply with the Constitutional prohibition against Federal funding to private schools. No funds go directly to private schools.

Under the Child Benefit Theory, Title I services – • Benefit the individual child, not the private school• Are provided by the LEA, not the private school

Equitable Services RequirementsIn order to meet equitable services

requirement, an LEA must: Provide eligible private school children with an

opportunity to participate; Meet the equal expenditure requirements for

instruction, professional development, and parent involvement;

Assess student needs and the effectiveness of the Title I program; and

Begin Title I programs at the same time as the Title I programs for public school children.

Equitable Services Requirement Program Responsibility

The LEA is responsible for designing and implementingTitle I programs for its resident children who attend private schools, even those attending private schools located in other LEAs

Equitable Services Requirement Program Responsibility

The LEA is responsible for making program and budgetary decisions based on timely and meaningful consultation with the private school.

Consultation

Consultation RequirementsWhat is Consultation?

Consultation involves discussions between public and private school officials on key issues that affect

the ability of eligible private school children to participate equitably in

Title I programs

Consultation RequirementsConsultation…Must occur during the design, development, and

implementation of the Title I programsMust include meetingsMust occur prior to the LEA making any decisionsMust continue throughout implementation of

programsMust be documented (Reference the Private School

Consultation Checklist)Complete the process by May 1st

Consultation Requirements

What topics must be addressed during consultation?

Consultation RequirementsAt a minimum, consultation must address:How the LEA will identify the needs of eligible

childrenWhat services the LEA will offer How and when the LEA will make decisionsHow, where, and by whom the LEA will provide

servicesHow the LEA will assess the Title I program and use

the results to improve Title I services

Consultation RequirementsAt a minimum, consultation must address:The size and scope of the equitable services and the

proportion of funds the LEA will allocate for servicesMethod or sources of data the LEA will use to

determine the number of low-income studentsServices the LEA will provide to teachers and families

of participating childrenDiscussion of service delivery mechanism the LEA can

useA thorough consideration and analysis of the views of

private school officials services through a contract with third-party provider

Consultation RequirementsPrivate school officials have the right to

complain to the SEA for the following reasons: The LEA did not engage in timely and meaningful

consultation The LEA did not give consideration to the views

of private school officials The LEA disputes the low-income data provided

by private school officials

The SEA resolves the complaint

Equitable Services for Teachers & Families Professional Development

REQUIRED CONSULTATION TOPIC:LEA must consult with private school officials prior to the LEA designing and implementing

professional development activities that increase the private school teachers’ skills and

knowledge on how to better instruct their students

Funding for Equitable Services

Funding for Equitable ServicesCollecting Poverty Data

An LEA may calculate the number of private school children* who are from low-income families and live in participating public school attendance areas in several ways: Use same measure of poverty as for public school

children. The majority of districts in Michigan use free and reduced price meals eligibility as its source of data

Use comparable poverty data from a survey and must extrapolate results if actual data are unavailable

Use comparable data from a different source Use an equated measure

* LEA must collect poverty data on their resident low-income children attending private schools in other LEAs.

Funding for Equitable ServicesGenerating Funds for Instruction

Low-income public and private school children residing in the same Title I attendance areas generate the same per-pupil amount (PPA)

PPA x the number of low-income private school children residing in participating public school attendance areas = instructional funds for the Title I programs for eligible private school children


Funds may be generated from multiple LEAs with students attending a private school or from multiple attendance areas within a district.


e complaintEligible Public School Attendance Area(1)

Grade Span Group(2)

Percent Low- -Income(3)

Amt. Per Low-Income Child(4)

Public Low Income Count(5a)

Section 31a Funding Per Child(5b)

Public Amount(5c)

Carryover and Parent Involvement Reservations(5d+5e+5f)

Total Public Amount(5g)

Private Low Income Count(5h)

Private Amount(5i)

School A K – 8 85% $780 460 0 $358,800 $23,000 $381,800 29 $22,620

School B K – 8 79% $780 516 0 $402,480 $36,500 $438,980 0 0

School C K – 8 65% $780 375 0 $492,500 $13,000 $305,500 15 $11,700


Funds generated by low-income private school children who reside in Title I attendance areas must be used only for instructional services

Funding for Equitable ServicesReservation of Funds

If an LEA elects to reserve funds for district level instructional activities, such as summer school, for public school students, the LEA must also provide from those reserved funds equitable services to eligible private school children. These funds are in addition to per pupil funds designated for instructional services.

Title I Funds for Equitable ServicesDistrict-Wide Instructional Activities

Districtwide Instructional Program(s) Reservation (does not apply to preschool programs) in participating public school attendance areas: No. of private school children from low-income families divided by total no. of children, public and private, from low-income families equals proportion of reservation_______5,000____ ÷ ______10,000_______ = _____5%___

(Proportion of Reservation)__5% x _$50,000__Reservation = $___2,500 for Equitable Services

Funding for Equitable Services Carryover

LEAs must consider the equitable services requirements when making any decision about the use of district reservations and carryover funds:•Instructional Programs•Professional Development•Parent Involvement

Equitable Services for Children

Equitable Services for ChildrenSelection of Students

Private school children who reside in Title I participating public school attendance areas AND are failing or most at risk of failing to meet student academic achievement standards

Homeless; 2 preceding years in Head Start; Great Start Preschool Program; Title I Preschool; Title I, Part C (Migrant Education)

Grades pre-K-2: selected solely on the basis of teacher judgment, interviews with parents, developmentally-appropriate criteria and local assessments

Grades 3 and above: selected using multiple written selection criteria

Poverty is NOT a criterion!

Equitable Services for ChildrenStandards

The LEA should use: Standards that are aligned with the

curriculum of the private schoolDepending on the number of private schools,

there may be more than one standardThe State Educational Agency cannot impose

standards, achievement levels, or assessments

Equitable Services for ChildrenTypes of Services for Children

Equitable services for children must be designed as a Targeted Assistance Title program.

Equitable Services for ChildrenTypes of Services for Children

Direct instruction outside the regular classroom = pull out model

TutoringAfter- or before-school programsSaturday programs

Equitable Services for ChildrenAssessments

After consultation, LEA establishes the assessment it will use to measure the effectiveness against the agreed-upon standards

May use the State assessment or another assessment that is aligned to the agreed-upon standards, such as the assessment used in the private school

All participants are assessed annually, including children receiving nonacademic services

Equitable Services for ChildrenSupplement, Not Supplant

The supplement, not supplant provision applies

Title I services must be in addition to, and cannot replace or supplant, services that would be provided by private schools to their private school participants

Equitable Services for ChildrenSubject Areas and Grade Spans

Title I services for private school childrenDO NOT need to be in the same subject areas or the same grade levels as Title I

services for public school children. Needs of private school participants determine

what Title I services are appropriate.

Equitable Services for ChildrenSubject Areas and Grade Spans

The providing LEA has the option of providing services for the private school within any grade of the public school’s

grade span. Private school services do not have to be for the same grade levels as

services at the public school, but they must be within the same grade span.

Equitable Services for ChildrenService Providers – LEA Employees

Provider of Title I services must be either an employee of the LEA or an employee of a third party under contract with the LEA

Private school teachers may be employed by both the private school and the LEA; however, they must be independent of the private school during the time they are employed by the LEA to provide Title I services

Equitable Services for ChildrenService Providers – LEA Employees

• Paraprofessionals must meet the paraprofessional qualification requirements, provide instructional support, and be under the direct supervision of and in close and frequent proximity to a highly qualified public school teacher

• Private school officials may not sign time and effort records

• Private school officials cannot establish requirements for LEA-employed teachers

Equitable Services for ChildrenMaterials and Equipment

Title I funds may only be used to meet the needs of participating children

Non-Title I private school children, nor non-Title I teachers and parents non-Title students may not use materials purchased with Title I funds

LEA must retain title to all materials purchased with Title I funds

Equitable Services for ChildrenMaterials and Equipment

All materials, etc., purchased with Title I funds must be labeled “Property of… School District” and placed in a secured location when not in use

Private school officials have no authority to obligate Federal funds

There must be an instructional program before the purchase of supplemental materials

Equitable Services for Teachers and Families

Equitable Services for Teachers & Families Requirements

An LEA must provide equitable services to private school teachers and families of participating private school

children from funds reserved for professional development (§1119) and

parental involvement (§1118)

Equitable Services for Teachers & Families

Use of FundsThe LEA must use these funds to provide equitable

services to teachers and families of participantsThere is no authority under Title I for an LEA to

transfer these funds to instructionIf teachers or families of participating private

school students do not have a need for equitable services, those funds are available to the LEA for other allowable uses

Title I Funds for Equitable ServicesDistrict Professional Development Reservation

Professional Development Reservation under Sec. 1119 of ESEA in participating public school attendance areas:No. of private school children from low-income families divided by total no. of children, public and private, from low-income families equals proportion of reservation___5,000 ÷ _____100,000_______ = _____5%___

(Proportion of Reservation)__5 % x $360,000__Reservation = $__18,000 for Equitable Services

Title I Funds for Equitable ServicesDistrict Parental Involvement Reservation

Parental Involvement Reservation under Sec. 1118 of ESEA in participating public school attendance areas: No. of private school children from low-income families divided by total no. of children, public and private, from low-income families equals proportion of reservation________5,000____ ÷ _____100,000_______ = _____5%___

(Proportion of Reservation)__5% x $60,000__Reservation = $__3,000__ for Equitable Services

Additional Programs

Equitable ServicesTitle I, Part C

AllocationUse the Title I, Part C Calculation of Private Schools’ Equitable Share screen to determine the appropriate per pupil amount for students eligible for Title I, Part C services. This is located on the OFS website under 2014-15 Consolidated Application Important Information. Services require consultation. Contact the Title I, C Consultant.

www.michigan.gov/ofs

Equitable ServicesTitle II, Part A

Under Title II, Part A, LEAs are required to provide equitable services for private school teachers and other educational personnel only to the extent that they use the funds for professional development

Equitable ServicesTitle II, Part A

• Amount of Title II Budgeted for PD• Box C

Current Title II , Part A Allocation Box B $715,604

Amount of Title II, Part A Budgeted for PD Box C $715,604

FY 2001 Eisenhower Funds Box D $96,822

Base Amount Box E $715,604

$715,604 Divided by Total Pupil Count of 18,691 = Current Per Pupil Amounts = $38.29

List of Private Schools within the LEA Boundary

Private School Enrollments

Private School Title II, Part A Allocations

School A 230 $8,806.70

School B 159 $6,088.11

School C 271 $10,376.59

School D 217 $8,308.93

LEA Enrollment17,814 (Box A)

Equitable Services Title II, Part ATransfer of Funds/Other Uses

The amount of Title II, Part A that the district would use to calculate what is due to the private school would be the amount of the Eisenhower Grant:If an LEA was putting all of it’s Title II, Part A funds into class size reduction, merit pay or bonuses Transferring all of Title II, Part A into Title I, Part A. The amount of Title II, Part A that the district would use to calculate what is due to the private school would be the amount of the 2000 - 2001 Eisenhower Grant. This calculation would have to be done for the private school before budgeting other LEA uses of the funds.

Equitable ServicesTitle III, Part A- Language Acquisition

Program Participation is considered equitable if the LEA:Assesses, addresses and evaluates the needs and progress of public and private school students and educational personnel on a comparable basisProvides, in the aggregate, approximately the same amount of services to students and educational personnel with similar needs

Equitable ServicesTitle III, Part A- Language Acquisition

Programs Spends an equal amount of funds to serve

similar public and private school students and educational personnel

Provides both groups of students and educational personnel equal opportunities to participate in program activities

Resource – Private School Participation Fact Sheet

Equitable ServicesTitle III, Part A

LEA (LEP) Enrollment151

Current Title III, LEP Allocation Base = $15,100

Total enrollment for LEA & Private Schools (263) divided by the base amount =

Total enrollment for LEA & Private Schools (263) divided by the base amount = $57.42

List of Private Schools within the LEA Boundary

Private School Enrollments

Private School Title III,Part A (LEP) Allocations

School A 16 $918.72

School B 25 $1,435.50

School C 40 $2,296.80

School D 31 $1,780.02

Evaluation

Evaluation

After consulting with private school officials, the LEA must establish standards it will use to

measure the effectiveness of the Title I program as indicated by the academic achievement of its

participantsThe MDE Program Evaluation Tool is a viable

option for evaluating Title programs and services.

EvaluationAnnual Progress

Every year, the LEA, after consulting with private school officials, must determine what constitutes acceptable annual progress for the Title I program

This decision must be made before Title I services begin

It’s not enough to just assess participants – the LEA must determine the effectiveness of the total program in raising academic achievement

Other Considerations

General RequirementsSuggested Timeline

January/FebruaryMail letter (see sample of letter)

MarchConduct initial meeting (see sample of documentation) Review demographicsPlan program

April - JulyAwait allocations Meet to confirm Submit application

Provide consultation throughout the year

General Requirements

Reminder - Meetings and consultation must occur before district makes decisionsConsultation continues throughout implementation

Determining Private School Participation—Student Numbers

Private School Students Residing Within District Boundaries

(who attend a private school within or outside of district boundaries)

Students Attending Private School Within District Boundaries (regardless of their

residency)

Title I, Part AFunding Generated By: Low-income students who reside in a Title I school attendance areaStudents Eligible to be Served: Identified by a Needs Assessment for achievement below standard and reside in a Title I school attendance area*

Title I, Part C Meet criteria for migrant? Meet priority for services?Title II, Part ATitle III, Part A Meet criteria for ELs/Immigrant? Completes Home Language Survey?

Allowable Uses of Funds for Private Non-Profit (PNP) Schools

LEA for PNP Schools Title I, Part A Title I, Part C Title II, Part A Title III, Part A

Salaries for PNP personnel No No No No

Salaries of LEA staff who service PNP

Yes Yes Yes, if providing PD Yes

Substitutes for ANY reason No No No No

StipendsProfessional Development in core academic areas – secular content onlyReasonable & necessaryOutside of school dayPaid directly to teacher by LEA

Yes Yes Yes Yes

Purchase of Computers Yes for Eligible students

Yes for Eligible students No Yes for Eligible students

Supplies Yes, for Title I students

Yes, for Migrant students Yes for Professional Development

Yes for Eligible students

Class Size Reduction No No No No

Support for PNP staff to become HQ

No No No NoYes for ESL/Bilingual

Endorsement

Professional Development Yes, for helping Title I students

Yes Yes Yes

What Happens When a PNP Closes or the Program Ends?

If a program is terminated or if the private school closes, the non-consumable materials and equipment must be returned to the district

District Fiscal Responsibilities• Write a check?

NO!• Generate a purchase order• Pay for professional development

registrations• Pay wages of district employees

who serve the private school• Pay for services of third-party

employees who serve the private schools (“purchased services”)

YES!

Other Resources

Further Assistance

U.S. Department of Education Guidance Documents

www.ed.gov/policy/elsec/guid/list.jhtml Office of Nonpublic Education

www.ed.gov/about/offices/list/oii/nonpublic/index.html Michigan Department of Education

Office of School Improvement, Field Services Unit Technical Assistance packets on each grant source Call your Field Services Consultant

Questions, Comments and Concerns

Contact your Field Services Consultant: Regions 1 - 5 . . . . . . . . .517-373-4004 Special Populations…….517-373-6066

Homeless, Migrant, Section 31a, Section 41, Title I, D and Title III

Finance………………….517-373-2519