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Title I, Part A


Virginia Department of Education Coordinators Academy July 31 August 1, 2012 * * * * * When writing your application, it is important to be as detailed as ... – PowerPoint PPT presentation

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Title: Title I, Part A

Title I, Part A
  • Virginia Department of Education
  • Coordinators Academy
  • July 31 August 1, 2012

Purpose of Title I
  • Ensure children have fair, equal, and significant
    opportunity to obtain high-quality education and
  • Reach, at a minimum, proficiency on challenging
    state standards and assessments.

Focus of Title I
  • The program focuses on promoting reform in
    high-poverty schools and ensuring student access
    to scientifically-based instructional strategies
    and challenging academic content.

Understanding Targeted Assistance and Schoolwide
Targeted Assistance (TA) Schools
  • The TA delivery model provides supplemental
    assistance to targeted schools to assist eligible
    students in meeting the states challenging
    academic achievement standards.
  • ESEA, Section 1115

Selecting Eligible TA Students
  • The school selects eligible children by
    identifying those who are failing, or most at
    risk of failing, to meet the states challenging
    student academic achievement standards.
  • Schools make the determination based on multiple,
    educationally related, objective criteria
    established by the school division and
    supplemented by the school.
  • Children who are economically disadvantaged,
    children with disabilities, migrant children, or
    limited English proficient children, are
    eligible for services under this part on the same
    basis as other children selected to receive

Selecting Eligible TA Students
  • Certain groups of children are automatically
    eligible for services
  • Any child who participated in Head Start, Even
    Start, or Title I preschool services at any time
    within the previous two years
  • Any child attending a community day program or
    living in a state or local institution for
    neglected or delinquent children
  • Any student served in the previous two years
    under the Migrant Education Program and
  • Any child who is homeless and attending any
    school served by the school division.
  • ESEA, Section 1115 (b)(2)(A)(B)(C)(D)(E)

Schoolwide Programs
  • Schools with 40 percent or more poverty have the
    flexibility to use Title I, Part A, funds along
    with other federal, state, and local funds to
    upgrade the entire educational program in a
    school to improve the academic performance of all
    students, particularly the lowest achieving
  • With the approval of Virginias ESEA
    Flexibility Request, schools identified as
    priority or focus may become schoolwide even if
    the school does not have a poverty percentage of
    40 percent or more.
  • ESEA, Section 1114

Schoolwide Program
  • The program builds upon whole school reform
    strategies, rather than add-on services.
  • School staff take responsibility for the success
    of each student.
  • The integration and coordination of efforts
    result in greater student success.
  • All federal, state, and local funds earmarked for
    a Title I schoolwide program delivery model may
    be combined to create whole school reform.

Schoolwide Programs
  • A school is not required to
  • Identify specific students as eligible to
    participate in a schoolwide program or
  • Demonstrate that the services provided within the
    school with Title I, Part A, funds are
    supplemental to services that would otherwise be

Core Elements of a Schoolwide Program
  • To operate a schoolwide program, a school must
  • Conduct a comprehensive needs assessment of the
    entire school
  • Use data from the needs assessment to develop a
    comprehensive schoolwide plan in accordance with
    Section 1114(b) of the Elementary and Secondary
    Education Act of 1965 (ESEA) as amended by the No
    Child Left Behind Act of 2001 (NCLB) and
  • Annually evaluate the schoolwide programs
    effectiveness in terms of improving achievement
    and revise the plan as necessary.

Ten Required Components
  • Comprehensive Needs Assessment (CNA) of entire
  • A systematic effort to acquire an
    accurate thorough picture of strengths and
    weaknesses of a school community, thus
    identifying the needs of the
    students in your school through a variety of
    information-gathering techniques . It informs
    and guides ALL program aspects.

  • Comprehensive needs assessment is.
  • not just finding the right students for the
  • its finding the right program for each of the

  • 2. Reform strategies to enhance student
    achievement and meet state standards

3. Use of highly qualified teachers
4. High-quality and ongoing professional
development for teachers, principals, and
  • 5. Strategies to attract high-quality, highly
    qualified teachers to high-need schools
  • Strategies to increase parental involvement in
  • ESEA, Section 1118

7. Coordination of services in transition from
preschool programs to elementary school
  • 8. Measures to include teachers in
    decision-making as
  • related to academic assessments
  • 9. Activities designed, in a timely manner, to
  • students experiencing academic difficulties
  • 10. Coordination and integration of local,
    state, and
  • federal funds

Core Elements of a Schoolwide ProgramSupplement
not Supplant
  • Under Section 1114(a)(2)(B) of the ESEA, a
    participating schoolwide school may use Title I,
    Part A, and other federal funds available to the
    school to supplement the amount of funds that
    would, in the absence of federal funds, otherwise
    be made available from nonfederal sources for
    that school (including funds needed to provide
    services required by law for children with
    disabilities and children with limited English
  • A schoolwide school must, in the absence of any
    federal funds, receive sufficient resources from
    state and local sources to operate its regular
    educational program for all students.

What are examples of supplanting in a schoolwide
  • A school division provides a literacy coach in
    each of its non-Title I schools but not in its
    Title I schoolwide schools, instead expecting
    those schools to use their Title I funds for
    literacy coaches.
  • A school division does not provide to a
    schoolwide school sufficient nonfederal funds to
    provide a free appropriate public education to
    students with disabilities, as required by law,
    and instead relies on Title I, Part A, funds to
    meet this requirement.

What are examples of supplanting in a schoolwide
  • A school division does not provide a schoolwide
    school with sufficient non-federal funds to
    operate the basic education program that it must
    provide to all its students, and instead relies
    on Title I, Part A, and other federal funds to
    help meet this responsibility.

Are there any exceptions to the supplement, not
supplant requirement?
  • A school division may exclude from its compliance
    with the supplement, not supplant (and
    comparability) requirements, supplemental state
    or local funds expended in any school for
    programs that meet the intent and purposes of
    Title I, Part A.
  • 34 CFR Subtitle B Subpart B Section 200.79 of the
    Title I regulations defines what constitutes a
    program that meets the intents and purposes of
    Title I, Part A.
  • http//ecfr.gpoaccess.gov/cgi/t/text/text-idx?ce

Needs Assessment
Needs assessment creates an an ongoing process.
Action Plan
Program Implementation
  • Designing Schoolwide Programs Non-regulatory
    Guidance, March 2006 www.ed.gov/policy/elsec/guid
  • Title I Schoolwide Plan Peer Review Rating Rubric
  • http//www.doe.virginia.gov/federal_programs/esea/

Equitable Services to Private Schools Students
Private Schools
  • Title I, Part A, private school participation is
    governed by ESEA, Section 1120.
  • Title I statute http//www2.ed.gov/policy/elsec/l
  • Title I private school guidance

Bypass and Title I, Part A
  • Virginia is a bypass state.
  • Bypass is a means by which USED directly provides
    Title I, Part A, equitable services to private
    school students and teachers through a
    third-party provider.
  • (ESEA, Section 1120(e)(1-3))
  • Services are offered through the bypass to
    private schools in 14 school divisions.
  • The remaining 118 school divisions must provide
    equitable Title I, Part A, services to eligible
    students in interested private schools.

14 School Divisions in the Title I, Part A,
  • Alexandria City
  • Newport News City
  • Arlington County
  • Norfolk City
  • Chesapeake City
  • Portsmouth City
  • Henrico County
  • Prince William County
  • Fairfax County
  • Richmond City
  • Falls Church City
  • Stafford County
  • Lynchburg City
  • Virginia Beach City

Meaningful Consultation
  • Goal is to design and implement a program that
    will provide equitable services and meet the
    needs of eligible private school students and/or
  • Must consult with private school officials prior
    to division making any decisions that affect the
    opportunities of private school students or
    teachers to participate in programs.
  • Must discuss funds reserved at the division
    level, if applicable, for professional
    development, parental involvement, and special
    divisionwide instructional programs.

Meaningful Consultation
  • Consultation process is the responsibility of the
    school division that is responsible for providing
    equitable services.
  • The division is responsible for designing and
    implementing Title I programs for its resident
    children who attend private schools, even those
    attending private schools located in other

Meaningful Consultation
  • Public schools must maintain a written
    affirmation of consultation signed by an official
    of each participating private school on a yearly
  • (ESEA, Section 1120)
  • If private schools desire direct Title I, Part A,
    services, the school division should contact the
    Virginia Department of Educations Title I office
    for guidance in meeting requirements.
  • (ESEA, Section 1120(b)(1))

Parental Involvement
Parental Involvement
  • Parent involvement is the engaged
  • participation of parents of Title I students
  • in a consistent, organized, and meaningful way in
    the consultation, planning, implementing, and
    evaluating of programs and activities to increase
    student achievement.
  • ESEA, Section 1118

Parental Involvement
  • Local school divisions receiving Title I, Part A,
    funds must
  • Develop a jointly agreed upon written policy
    which establishes the divisions expectations for
    parental involvement and
  • Ensure that each participating school develop a
    written policy that describes the means for
    carrying out the divisions policy.
  • (The HOW)

Title I Parent Policy
  • Local school divisions receiving Title I, Part A,
  • funds must
  • Convene an annual meeting and
  • Conduct an annual evaluation of parental
  • involvement policy.

At the Annual Meeting
  • Provide parents with
  • information about the programs
  • a description and explanation of the
  • curriculum
  • forms of academic assessment and
  • opportunities for regular meetings to
  • discuss the education of their children.

  • Local school divisions receiving Title I, Part A,
  • funds must
  • Communicate a policy for promoting
  • parental involvement in program
  • implementation, school review, and
  • development of improvement plans.

  • Divisions Written
  • Parent Policy
  • Develop a written school-parent compact
  • that outlines the responsibilities of each
  • for improved student academic achievement.

What specific information must a divisions
written parent policy contain?
  • A division's written parent policy must describe
  • how the division will

1. Involve parents in the development of the
Calling All Parents
2. Provide support, coordination, and technical
assistance to schools in the planning and
implementation of effective parent activities
that aim to improve student achievement.
  • 3. Build the capacity for strong parental
  • What are the six capacities for
  • building parent involvement?

Six Capacities for Parent Involvement
  • Assist parents in understanding the states
    academic content standards, student academic
    achievement standards, and academic assessment
  • Provide materials and training to help parents
    improve their childrens achievement, such as
    literacy training and using technology, to foster
    parent involvement
  • Educate school personnel, with the assistance of
    parents, in the value and utility of
    contributions of parents, how to reach and
    communicate and work with parents

Six Capacities for Parent Involvement
  1. Coordinate and integrate parent involvement
    programs and activities with other organizations
    such as Head Start, Parents as Teachers, etc.
  2. Ensure that information related to schools and
    parents programs, meetings, and other activities
    is sent to parents in a format and language that
    parents can understand and
  3. Provide reasonable support for parent involvement
    activities as parents may request.

A division's written parent policy must describe
how the division will 4. Coordinate and
integrate parental involvement with other
programs such as Head Start and Title III
language instructional programs. 5. Conduct,
with parents, an annual evaluation of the parent
policy that includes - Identifying barriers
to greater parent participation - Using the
findings of the evaluation to design
strategies for more effective parental
involvement and - Revising the parent
policy, if necessary.
  • 6. Involve parents in the activities of Title I

Virginia Department of Education (VDOE) Review of
Parent Policies
  • The VDOE shall review the school divisions
    parent involvement policies and practices to
    determine if the policies and practices meet the
    requirements of the law. ESEA, Section 1118 (h)
  • Parent policies have been reviewed for all school
  • School divisions only need to send revised parent
    policies to VDOE when changes have been made.

Reservation of Funds for Parental Involvement
  • Local school divisions must ensure that Title I
  • Reserve at least one percent of the divisions
    total Title I, Part A, allocation to carry out
    parental involvement activities for divisions
    receiving 500,000 or more and
  • Set aside at least 95 percent of the reserved
    funds to be distributed to participating schools.

Parent Compact
  • The School-Parent Compact describes
  • Schools responsibility to meet the states
    student academic achievement standards and
  • Methods in which parents will be responsible for
    supporting their childrens learning
  • monitoring attendance, homework completion, and
    television watching
  • volunteering in their childrens classrooms and
  • participating, as appropriate, in decisions
    relating to the education of their children and
    positive use of extracurricular time.

Parent Compact
  • The School-Parent Compact addresses the
    importance of communication between teachers and
    parents on an ongoing basis through
  • Parent/teacher conferences (discuss compact)
  • Frequent reports to parents on childrens
  • Reasonable access to staff
  • Opportunities to volunteer/participate in
    childrens classes and
  • Observational classroom activities.

A Parents Right-to-Know Teacher
  • School divisions receiving Title I funds must
    notify all parents at the beginning of each
    school year that they may request and obtain
    information from the division about
    qualifications of staff instructing their
    children in Title I schools.

A Parents Right-to-Know Teacher
  • Parents may request information on
  • Whether the teacher has met state qualifications
    and licensing criteria for the grade levels and
    subject areas taught
  • Whether the teacher is teaching under emergency
    or other provisional status
  • The baccalaureate degree major of the teacher and
    any other graduate certification and
  • Whether their children are provided services by
    paraprofessionals and, if so, their

Parental NotificationIndividual Student
  • The local school division must ensure that Title
    I schools provide parents with information on the
    achievement level of their children on the
    statewide assessments as soon as is practicably
    possible after tests are taken. This notice is
    sent to all parents.

Parental NotificationNot Highly Qualified
  • The local school division must ensure that Title
    I schools give timely notice to parents that
    their children have been assigned or have been
    taught for four or more consecutive weeks by a
    teacher who is not highly qualified. This notice
    is only sent to parents of affected students as

Checklist for Parental Involvement
  • Annually review and verify that your division has
    an up-to-date divisionwide parental involvement
  • Annually review and verify that each Title I,
    Part A, school has an up-to-date parental
    involvement policy.
  • Involve parents in the development of Title I,
    Part A, annual application for funding.
  • Involve parents in decisions on how to use
    required expenditures for parent involvement

Checklist for Parental Involvement
  • Convene an annual meeting to discuss the Title I
    program and Parent Compact.
  • Provide information to parents concerning SOL
    assessment results.
  • Provide materials and training to help parents to
    work with their children to improve their
    children's achievement, such as literacy training
    and using technology to foster parental
  • Provide reasonable support to parents (i.e.
    transportation, child care, translation services,
    etc.) during parental involvement activities and

Parental Involvement Resources
  • U.S. Department of Educations Parental
  • Title I, Part A, Non-regulatory Guidance,
    April 23, 2004
  • Appendix D Sample Template for Division Parent
    Policy http//www2.ed.gov/programs/titleiparta/par
  • Virginia Department of Education
  • http//www.doe.virginia.gov/federal_programs/esea

Supplement, Not Supplant
Supplement, Not Supplant
  • At the school division level, the
    maintenance-of-effort provision requires that a
    division maintain its expenditures for public
    education from state and local funds from one
    year to the next. A division cannot reduce its
    own spending for public education and replace
    those funds with federal funds.

Supplement, Not Supplant
  • At the school building level, comparability
    requires a division to ensure that each Title I
    school receives its fair share of resources from
    state and local funds. A division may not
    discriminate (either intentionally or
    unintentionally) against its Title I schools when
    distributing resources funded from state and
    local sources simply because these schools
    receive federal funds.

Supplement, Not Supplant
  • At the individual student level, a division must,
    under the supplement, not supplant requirement,
    ensure that services to students participating in
    Title I receive from Part A funds that are
    additional to the regular services a division
    would otherwise provide to those students with
    funds from non-federal sources. Services from
    Title I resources cannot replace or supplant
    services that a division would ordinarily provide
    to all students.

Supplement, Not Supplant
  •  Targeted assistance schools
  • A school division may use Title I funds only to
    supplement the level of funds that would, in the
    absence of Title I funds, be made available from
    non-federal sources for the education of students
    participating in Title I programs. In no case
    may Title I funds be used to supplant, i.e., take
    the place of funds from non-federal sources. To
    meet this requirement, a division is not required
    to provide Title I services using a particular
    instructional method, or in a particular
    instructional setting.
  • ESEA, Section

Maintenance of Effort
Maintenance of Effort (MOE)
  • A school division may receive its full allocation
    of Title I, Part A, funds only if the state
    educational agency determines that the division
    has maintained fiscal effort with respect to
    state and local funds used to provide free public
  • A school division has maintained fiscal effort if
  • the combined fiscal effort per student or
  • the aggregate expenditures of the school division
    for the preceding fiscal year was not less than
    90 percent of the combined fiscal effort or
    aggregate expenditures for the second preceding
    fiscal year.
  • ESEA, Sections 1120A(a) and 9521
  • 34 C.F.R. 299.5

Maintenance of EffortPreceding Fiscal Year (FY)
  • Preceding fiscal year is the federal fiscal
    year (FFY), or the 12 month federal fiscal period
    most commonly used in a state for official
    reporting purposes, prior to the beginning of
    the federal fiscal year in which funds are
  • For example, for FFY 2012 funds (available July
    2012 for the 2012-2013 school year), the
    preceding fiscal year is FFY 2011 (the 2011-2012
    school year).
  • The second preceding fiscal year is FFY 2010 (the
    2010-2011 school year).
  • Any reduction in expenditures during the school
    year 2011-2012 will only become a MOE issue for
    the ESEA funds allocated in July 2013.

Maintenance of EffortExpenditures Included and
  • Maintenance of effort examines state and local
    expenditures for free public education.
  • Expenditures included
  • Expenditures for administration, instruction,
    attendance and health service, pupil
    transportation services, operation and
    maintenance of plant, fixed charges, and new
    expenditures to cover deficits for food services
    and student body activities.

Maintenance of EffortExpenditures Included and
  • Expenditures excluded
  • Expenditures for community services, capital
    outlay, or debt service
  • Supplemental expenses made as a result of a
    presidentially declared disaster or
  • Expenditures made from funds provided by the
    federal government.

Maintenance of EffortWaiver
  • The Secretary may waive the maintenance of effort
    required for a state education agency or school
    division if it is determined that a waiver would
    be equitable due to the following
  • Exceptional or uncontrollable circumstances such
    as a natural disaster or
  • A precipitous decline in the financial resources
    of the state education agency or school division.
  • ESEA, Section 1125A(e)(3), 9521(c)

State Education Agency orSchool DivisionWaiver
  • A state educational agency, school division, or
    state educational agency on behalf of its school
    divisions, may apply for a waiver of the Title I,
    Part A, maintenance of effort requirements.
  • A request must include the following information
    for each state educational agency or school
  • The school years being compared
  • Relative state and local effort (education
    expenditures compared to other types of state and
    local expenditures)
  • State and local expenditures data in the
    aggregate and per pupil and
  • State and local revenue.

  • Non-regulatory Guidance - Title I Fiscal Issues
  • Superintendent's Memo Number 271-10
  • Maintenance of Effort Requirements and Review
    Process for Title I, Part A, and Individuals with
    Disabilities Education Act http//www.doe.virginia

Carryoverand Reallocation
  • Section 1127 of the ESEA allows school divisions
    to carry over up to 15 percent of their Title I,
    Part A, allocation for any fiscal year. School
    divisions must encumber 85 percent of each award
    years Title I, Part A, allocation by September
    30 of the following year (within 15 months).

  • This section also allows eligible school
    divisions to apply for a waiver to exceed the 15
    percent limitation once every three years.
    School divisions that wish to apply for a waiver
    must submit the request in writing by September
    30 of the year following the award year to
  • Department of Education
  • Office of Program Administration and
  • P.O. Box 2120
  • Richmond, Virginia 23218

Carryover FY 2012 Funds
  • Encumber at least 85 percent of Title I, Part A,
    funds by September 30, 2013.
  • Encumber the remaining funds for that fiscal year
    by September 30, 2014.
  • Unencumbered funds may be reallocated to other
    school divisions.

Federal FY SY Funds Affected by Waiver Once in three years waiver granted to VDOE? May VDOE grant divisions a carryover waiver?
2009 2009-10 Yes Yes
2010 2010-11 Yes
2011 2011-12 No
2012 2012-13 No
2013 2013-14 Yes
Assumes division needs 2nd or 3rd carryover waiver because of influx of ARRA funds. Assumes division needs 2nd or 3rd carryover waiver because of influx of ARRA funds. Assumes division needs 2nd or 3rd carryover waiver because of influx of ARRA funds. Assumes division needs 2nd or 3rd carryover waiver because of influx of ARRA funds.

  • Section 1126(c) of ESEA mandates that the state
    educational agency (SEA) have procedures for the
    reallocation of Title I, Part A, funds that have
    not been expended within the allotted 15-month
    period of each program year.
  • Superintendents Memorandum Number 099-12Title
    I, Part A, Carryover Provisions and Reallocation
    Procedures under the No Child Left Behind Act of

  • Comparability requires the school division to
    document that services provided with state and
    local funds in Title I schools are comparable to
    those provided in non-Title I schools.
  • ESEA, Section 1120(A)

  • Virginia uses the following criteria to determine
  • Exclude schools with fewer than 100 students.
  • Exclude excess state and local cost (as
    determined by the school division) for services
    to children with limited English proficiency and
    for services to children with disabilities.
  • Compare Title I schools to non-Title I schools by
  • grade span.
  • Use student/instructional staff ratio.
  • ESEA, Section 1120(A)

Comparability(Student/Instructional Staff Ratio)
  • Determine the full-time equivalent (FTE) of staff
    paid with local and state funds assigned to each
    school listed.
  • Exclude custodial staff, cafeteria staff, nurses,
    clerical staff, and volunteers.
  • Include state and locally-funded personnel at the
    building who provide direct instruction
  • instructional staff (teachers)
  • music, art, and physical education teachers
  • guidance counselors
  • speech therapists
  • librarians and
  • instructional aides.

  • ESEA, Section 1120(A)

  • School social workers and psychologists may
  • also be included because they provide services
  • support instruction.
  • The inclusion/exclusion of positions must be
  • applied consistently across the division.

ESEA, Section 1120(A)
Comparability Report
  • Annually school divisions are requested to
    complete the Comparability Report.
  • The report is a Web application in the Single
    Sign On Web System (SSWS) labeled Comparability
  • Divisions will be notified by Superintendents
    Memo when the application opens and date that it
    must be completed.
  • The window cannot open until the fall student
    record collection is complete because data from
    that report is pre-populated in the Comparability

  • Non-regulatory Guidance, Title I Fiscal Issues
  • Maintenance of Effort, Comparability,
    Supplement Not Supplant, Carryover, Consolidating
    Funds In Schoolwide Programs, and Grantback
  • http//www.ed.gov/programs/titleiparta/fisca
  • Guidance, Funds under Title I, Part A, of the
    Elementary and Secondary Education Act of 1965
    under the American Recovery and Reinvestment Act
    of 2009 (ARRA)
  • http//www2.ed.gov/policy/gen/leg/recovery/program

Fiscal Requirements
Eligible Schools
  • Any school with a poverty level of 75 percent and
    above must be served regardless of grade span.
  • After that, a division may elect to serve
    eligible schools by grade span or by considering
    all schools as a whole.
  • Rank schools by poverty and serve
  • Any school at 35 percent and above from highest
    poverty down or
  • Any school in a selected grade span from highest
    poverty down to either the grade span average or
    division average or
  • Any school, regardless of grade span, from
    highest poverty down to the division average.
  • A division may designate as eligible any school
    attendance area or school in which at least 35
    percent of the children are from low-income
    families, i.e., the "35 percent rule.
  • ESEA
    Section 1113(a)(4)
  • ESEA Section 1113 (b)(1)(A)

Funding in a Targeted Assistance School
  • The school division/school must be able to
    demonstrate that Title I, Part A, funds have been
    used for the specific purpose of serving those
    students who are identified as being in greatest
    need of Title I, Part A, assistance based on the
    school divisions and schools Title I, Part A,
    student selection criteria.

Funding in a Targeted Assistance School
  • Documentation from federal programs monitoring
  • Title I, Part A, participant list
  • Student selection criteria
  • List of staff paid with Title I, Part A, funds
    and accompanying documentation including
  • job descriptions
  • time on task
  • students served
  • description of Title I, Part A, funded
    activities and
  • description of activities that are required for
    all students.
  • School division interviews

Funding in a Schoolwide School
  • A school may consolidate its Title I, Part A, and
    other federal, state and local funds to upgrade
    its entire educational program and implement its
    comprehensive plan. However, the following
  • Each school must identify the specific programs
    that are included in its schoolwide program and
    the amount each program contributes to the
    consolidation and
  • Maintain records that demonstrate that its
    schoolwide program addresses the intent and
    purposes of each of the federal programs whose
    funds are being consolidated to support the
    schoolwide program.

Funding in a Schoolwide School
  • Question Can Title I, Part A, funds in a
    schoolwide program school be used for basic
    operational expenses such as building maintenance
    and repairs, landscaping, and custodial services?
  • Answer Title I, Part A, funds (as well as
    consolidated federal funds) must be used to
    address the educational needs of a school
    identified by the needs assessment and
    articulated in the comprehensive plan. Section
    1114(a)(1) Accordingly, they may not be used
    for non-educational activities such as building
    maintenance and repairs, landscaping, and
    custodial services.

Presumption of Supplanting
  • To determine compliance with the supplement, not
    supplant requirement, a state must determine what
    services a school division would have provided in
    the absence of Title I funds to students in Title
    I schools.
  • Any determination about supplanting is very case
    specific, and it is difficult to provide general
    guidelines without examining the details of a
  • Because Title I funds are available, the state
    would use a set of presumptionsthat is,
    predictionsof what the school division would
    have provided in the absence of the Title I funds
    based on its behavior in other situations.

Presumption of Supplanting
  • In the following instances, it is presumed that
  • has occurred if the school division used Title I
    funds to
  • provide services
  • That the division was required to make available
    under federal, state, or local law.
  • That the division provided with non-federal funds
    in the prior year(s).
  • For children participating in a Title I program
    that the division provided with non-federal funds
    to children not participating in Title I.

Rebutting Supplement vs. Supplant
  • These presumptions are rebuttable if the division
    can demonstrate that it would not have provided
    the services in question with non-federal funds
    had the federal Title I funds not been available.
  • For example, in the second situation, a division
    could provide programmatic and fiscal documents
    showing that the teaching position paid for in
    the previous year with state and local funds was
    eliminated in the current year because of state
    and local budget cuts.
  • The division would need to ensure that it had
    contemporaneous records to confirm
  • There was in fact a reduced amount or lack of
    state and local funds available to pay for this
  • The division made the decision to eliminate the
    position without taking into consideration the
    availability of federal funding, along with the
    reasons for that decision, e.g., school board

  • An approved application must be in OMEGA before a
    school division will receive reimbursement.
  • Seek reimbursement monthly (encouraged).
  • Keep good records (i.e., invoices, payroll

  • Expenses including travel should be reasonable,
    allowable, and necessary.
  • Travel should be capped at the amount of the
    local education travel policy or state travel
    regulation whichever is less.
  • Requests should include clear justification to
    avoid rejection or delay by the finance office at
    the Department of Education.

  • For FY 2011, encumber at least 85 percent of
    Title I, Part A, funds by September 30, 2012.
  • For FY 2011, encumber the remaining funds for
    that fiscal year by September 30, 2013.
  • Unencumbered funds may be reallocated to other
    school divisions.

  • For FY 2009, a division must encumber all
    remaining funds by September 30, 2012. (Extended
    by waiver in January 2012.)
  • For FY 2010, all funds must be encumbered by
    September 30, 2012.

Time Distribution Records
  • Less than full-time employees in Title I, Part A,
    must keep a record of their time.
  • Records should be based on an after-the-fact
    determination of time and not estimates (i.e.,
    pre-determined schedules).
  • Employees should maintain these records in a
    timely manner in order to be accurate.
  • If actual time spent in Title I, Part A, is less
    than the application states, the state
    consolidated or individual application must be
  • ESEA, Section 1119 (i)

Reservation of Funds
  • Required
  • Up to 20 percent may be set aside by the division
    if there are schools identified as Priority
    and/or Focus
  • One percent for Parent involvement if a school
    division allocation is 500,000 or greater

Reservation of Funds
  • Allowable
  • Administration
  • Salary differential
  • Homeless ESEA, Section 1113(c)(A)
  • Teacher Quality five percent to ensure that
    teachers who are not highly qualified (HQ) become
    HQ ESEA, Section 1119(l)
  • Neglected and Delinquent ESEA, Section
  • Additional authorized activities
  • Preschool
  • Summer school
  • Intersession or afterschool programs
  • Coordinated activities

Budget Recommendations
  • Develop a school budget for each school based on
    its allocation.
  • Coordinate Title I, Part A, budget with the
    school board budget.
  • Reserve all funds that are not going to the
  • Sometimes reserved funds go to the schools but
    are not part of the schools allocation (i.e.,
    preschool programs, parental involvement, salary
  • Reserved funds going to the school should be
    considered for recordkeeping purposes.
  • Can you account for the location of all federal

  • Office of Management and Budget Circular A-87
  •  Cost Principles for State, Local, and Indian
  • Tribal Governments
  • http//www.whitehouse.gov/omb/circulars_a087_2004

Priority Schools
Priority Schools
  • Thirty-six (36) schools meeting one or more of
    the criteria below will be identified as
  • Criterion A
  • Schools receiving School Improvement Grant (SIG)
    funds under Section 1003(g) of ESEA in federal
    fiscal year 2009 (Cohort I) or 2010 (Cohort II)
    and identified and served as a Tier I or Tier II
  • Criterion B
  • Title I high schools with a federal graduation
    indicator of 60 percent or less for two or more
    of the most recent consecutive years

Priority Schools
  • Criterion C (See additional notes on next slide.)
  • Title I schools based on the all students
    performance in reading and/or mathematics.
  • Criterion D
  • Title I schools failing to meet the 95 percent
    participation rate in reading or mathematics for
    three consecutive years.

Priority Schools
  • Criterion C note
  • This criterion will be applied as necessary to
    identify as priority schools a number of schools
    that comprise an amount equal to five percent of
    the states Title I schools. Schools in this
    category will be rank-ordered based on the sum
    of the difference(s) between the performance of
    the all students group in reading and
    mathematics compared to the respective federal
    AMO proficiency targets. Those schools with the
    largest gaps in performance will be included in
    the priority school list, up to the number of
    schools needed to equal the five percent

Priority Schools Interventions
  • Provide meaningful interventions designed to
    improve the academic achievement of students.
  • A school division with a school receiving SIG
    funds, such as a Tier I or II school currently
    implementing a transformation or restart model,
    will be expected to continue to implement the
    model according to the time- line approved in the
    SIG application.

Priority Schools Interventions
  • School divisions with schools newly identified as
    priority will be required to hire a lead
    turnaround partner to assist with the
  • School divisions will be required to implement
    all of the requirements of the USED turnaround
  • See page 61 of Virginias Approved ESEA
    Flexibility Request http//www.doe.virginia.gov/fe

Priority Schools Exit Criteria
  • Schools will exit according to criteria for which
    they were originally identified for as follows
  • Will exit at the conclusion of the implementation
    of the chosen three-year intervention model.
  • Will exit after full implementation of a three
    year intervention model and meeting federal AMOs
    for the all students for two consecutive years.

Focus Schools
Focus School Identification
  • Excludes any schools identified as a priority
  • Seventy-two (72), or ten percent of other Tile I
    schools identified as having the highest
    proficiency gaps in reading or mathematics or not
    meeting participation rate of 95 percent for
    three proficiency gap groups

Focus School Methodology
  • See page 75-76 of Virginias Approved ESEA
    Flexibility Request
  • http//www.doe.virginia.gov/federal_programs/esea

Focus School Interventions
  • Strategies that will increase student achievement
    in underperforming proficiency gap groups
  • The school division will be required to engage in
    a VDOE-assigned and state-approved contractor via
    a memorandum of understanding (MOU) with VDOE.
  • See pages 77-84 of Virginias Approved ESEA
    Flexibility Request for additional information.
  •  http//www.doe.virginia.gov/federal_programs/e

Focus School Exit
  • In order to exit a school will be expected to
    implement interventions for a minimum of two
    consecutive years.
  • A focus school will exit the focus school status
    if the proficiency gap group(s) from which the
    school was originally identified meet(s) the AMOs
    for two consecutive years.
  • The school no longer falls into the bottom 10
    percent of Title I schools.

Reward Schools
Reward Schools
  • Virginia Index of Performance (VIP)
  • Blue Ribbon Schools
  • National and State Title I Distinguished Schools

National Title I Distinguished Schools
National Title I Distinguished School Program
  • A project of the National Title I Association,
    the Distinguished Schools program publicly
    recognizes each year qualifying Title I schools
    from each state for outstanding achievement in
  • Only two schools per state are selected in the
    following categories
  • A school that has exceeded its annual measurable
    objectives for two or more years. (ESEA, Section
  • A school that has significantly closed the
    achievement gap between students. (ESEA, Section

National Title I Distinguished School Program -
  • School has a poverty rate of at least 35 percent
    for the selected year
  • School achieves a mean score at the 60th
    percentile for both English and mathematics
  • School demonstrates high academic achievement for
    two or more consecutive years and
  • School met or exceeded state standards of annual
    measurable objectives for at least two
    consecutive years.

National Title I Distinguished School Program
  • A Superintendents Memorandum will be issued in
    late August 2012 announcing the 2012 National
    Title I Distinguished Schools Recognition Program.

  • With approval of Virginias ESEA flexibility
    request, school divisions may transfer up to 100
    percent of funds received under the authorized
    programs among the programs and into Title I,
    Part A. (ESEA Section 6123)
  • Currently Title II, Part A, Improving Teacher
    Quality is the only funded program available for
  • Once the funds are transferred into Title I, Part
    A, they cannot be transferred out and are to be
    spent in accordance with Title I requirements.

ESEA Consolidated or Individual Application
ESEA Application
  • Avoiding common errors
  • Are applications dated with names of
    superintendent and board chairman?
  • Does the budget summary reconcile with the
    detailed budget?
  • Are set-asides (reservations) clearly evident in
    the detailed budget?  (not lumped in together
    with other salaries, materials, etc.)

ESEA Application
  • Are preschool budgets clearly evident in the
    detailed budget?
  • Is there a zero balance left to reallocate on the
    allocation to schools page?  This is an issue for
    divisions with schools below 35 percent poverty.
  • Are the lines under each object code in the
    budget summary completed? (parent involvement,
    focus or priority schools, professional
    development, etc.)

Contact Information
  • Title I Coordinator
  • Becky Marable, (804) 371-0044,
  • Title I Specialists
  • Regions I , II, and VIII
  • Shady Clark, (804) 225-2901, shady.clark_at_doe.virg
  • Regions III and VII
  • Gabie Frazier, (804) 225-2907,
  • Regions IV, V, and VI
  • Dr. Philip Iovino, (804) 371-2934,
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