Overview of Title I Part A

1
No Child Left Behind

Title I, Part A Elementary and Secondary
Education Act (ESEA) Reauthorized by the No
Child Left Behind Act of 2001 - Public Law
107-110 (NCLB)
2
2005 Fall Workshop-Agenda

• Introductions
• Overview of Title I, Part A
• Program Options
• LAP
• Paraeducator
• Professional Development
• Parent Involvement
• Private Schools

• Complaint Procedures
• Fiscal Requirements
• Applications
• Adequate Yearly Progress
• Public School Choice and SES
• Curriculum-Reading

3
Overview of Title I, Part A

• 2005 Fall Workshops

4
The Intent of Title I, Part A

• The intent is to help all children have the
  opportunity to obtain a high-quality education
  and reach proficiency on challenging state and
  academic standards and assessments.

5

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

6
How It Works

• Title I distributes funds to schools based on
  the number of children from low-income families
  rather than achievement scores.

7

• Title I, Part A provides federal dollars to help
  supplement educational opportunities for children
  who live in high poverty areas who are most at
  risk of failing to meet states challenging
  achievement standards.

8
Two Program Models for Title I, Part A

• Targeted Assistance
• Schoolwide

9
Targeted Assistance Model

• A Targeted Assistance program is one which
  individual students are targeted to receive Title
  I services.

10

• The term targeted assistance signifies that
  the services are provided to a select group of
  children-
• those identified as failing, or most at risk of
  failing, to meet the states academic achievement
  standards.

11

• Students are identified based on multiple,
  objective, educationally- related criteria and
  assessments.

12

• Services may be delivered in a number of ways
  such as
• In-class instruction
• Pull-out model
• Extended day

13
To accomplish this goal, a targeted assistance
program must be based on

• Improving achievement of participating children.
• Using effective instructional strategies that
  give primary consideration to extended-time
  strategies.

14

• Providing accelerated, high-quality curricula.
• Minimize the removal from the regular classroom
  during regular school hours.

15

• Coordinating with and supporting the general
  education population.
• Providing instruction by highly-qualified and
  trained professional staff.
• Implement strategies to increase parent
  involvement.

16
Components of Targeted Assistance Building Plan

• 1. Comprehensive needs assessment (use Title
  I resources to help participating children to
  meet states academic standards expected for all
  children).
• 2. Ensure planning for students incorporated
  into existing plan.

17

• 3. Use effective methods and strategies that
  rely on scientifically-based research that
  strengthens the core academic program of the
  school.
• 4. Coordination and support the general
  education program, which may include services
  to assist preschool children in transition from
  preschool programs to elementary school
  programs.

18

• 5. Provide instruction by highly- qualified
  teachers and paraprofessionals.
• 6. Provide opportunities for professional
  development using Title I resources and other
  sources.

19

• 7. Provide strategies to increase parent
  involvement.
• 8. Coordinate and integrate federal, state and
  local services and programs.

20
Schoolwide Model

• A Title I school is eligible to become a
  schoolwide program when the poverty level counted
  in the most recent census data is at or above 40
  percent.

21

• A schoolwide program is designed with the
  knowledge that there is a link between poverty
  and low achievement therefore, when there are
  large numbers of disadvantaged students,
  interventions will be successful when implemented
  schoolwide.

22

• A schoolwide program has more flexibility in the
  use of Title I funds and in the delivery of
  services.

23

• Staff paid with Title I funds are free to work
  with all students in the building, for there are
  no students identified as Title I.

24

• The school works together to develop its
  curriculum and instruction to raise the
  achievement of all students.

25

• Schoolwide programs are comprehensive programs
  of school reform, intending to meet the needs of
  all students.

26

• Schoolwide programs have the latitude in
  determining how to spend their Title I, Part A
  funds.

27

• A schoolwide program can use their
• Title I, Part A funds in the manner they choose,
  as long as they engage in reform strategies that
  increase the amount and quality of learning time
  and help provide a high-quality curriculum for
  all children, according to a comprehensive plan
  to help all children to meet the states
  challenging standards.

28
Identification of Schoolwide Students

• All students are eligible to participate in all
  aspects of the schoolwide program.

29

• The statute requires schools to particularly
  address the needs
• of low-achieving children
• and those at-risk of not meeting the state
  student academic achievement standards.

30
The primary design of the Schoolwide plan must
address the following four elements

• 1. Describe how the school will implement the
  mandatory schoolwide ten components
• 2. Describe how the school will use resources
  from Title I and other sources to implement
  schoolwide components

31

• 3. Include a list of federal, state, and
  local programs that will be consolidated in the
  schoolwide program and
• 4. Describe how the school will provide
  individual student academic assessment results,
  including an interpretation of those results, to
  parents in a language they can understand.

32
NCLB of 2001 Title I, Improving the Academic
Achievement of the Disadvantaged Public Law
107-110

• Section 1114(b)(1) of the statute enumerates the
  ten components of the schoolwide program model.

33
Schoolwide Ten Components

• 1. A comprehensive needs assessment of the
  entire school based on information that includes
  the performance of children in relationship to
  the states academic achievement standards.
• 2. Schoolwide reform strategies that
• Provide opportunity for all students to meet the
  states proficient and advanced levels of student
  achievement.
• Use effective methods and instructional
  strategies from scientifically- based research.

34

• 3. Instruction by highly-qualified teachers
  and paraprofessionals.
• 4. High quality and ongoing professional
  development for teachers, principals, and
  paraprofessionals and, if appropriate, pupil
  service personnel, parents, and other staff to
  enable all children in the school to meet the
  states student academic achievement standards.

35

• 5. Strategies to attract high quality,
  highly-qualified teachers to high- need schools.
• 6. Strategies to increase parental
  involvement, such as literacy services.

36

• 7. Plans for assisting transition from early
  childhood programs to local elementary school
  programs.
• 8. Measures to include teachers in the
  decisions regarding the use of academic
  assessments to provide information on, and to
  improve, the academic achievement of individual
  students and the overall instructional program.

37

• 9. Activities to ensure that students who
  experience difficulty mastering the proficient
  or advanced levels of academic achievement
  standards are provided with effective, timely,
  additional assistance.
• 10. Coordination and integration of federal,
  state and local services and programs including
  programs related to Title I, violence,
  nutrition, housing, Head Start, adult education,
  vocational and technical education, and job
  training.

38
Schoolwide Plan

• The plan must be developed over a one-year
  period unless the LEA determines, after
  considering the recommendation of the requisite
  technical assistance providers, that less time is
  needed.

39

• The plan must be developed in consultation with
  the LEA and its support team and other technical
  assistance providers.
• Must be developed with the involvement of
  parents, and other community to be served and
  individuals who carry out such a plan, including
  teachers, principals and administrators.

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Essential Elements Consolidated Program Review
(CPR) Targeted Assistance and Schoolwide Model

• Common to both options
• Principal Attestation (highly-qualified
  certification form)
• Building Parent Involvement Plan

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• Parent-teacher student compact
• Documentation to show addressing needs of low
  achieving students
• Letter To Parents (teacher highly qualified
  qualifications)

42

• Student Monitoring Progress Reports
• Annual Evaluation of Program

43
Program OptionsSpecific Requirements

• Specific to a Schoolwide
• Schoolwide /SIP Building plan
• Specific to Targeted Assistance
• Targeted Assistance Building Plan
• Rank order list of identified students served

44
Learning Assistance Program

• Focus on low-achieving students.

45
Learning Assistance Program

• A state-funded program to serve students with the
  greatest deficits in academic basic skills
  identified by statewide assessments.
• Basic skills include reading, writing,
  mathematics, and readiness associated with those
  skills.

46
Who benefits from LAP?

• Students in kindergarten through grade 11 (moving
  through grade 12 in 2007)
• Students in grades 9-12
• Who score below standard at grade level on
  statewide assessments and
• Identified in an OSPI-approved plan to receive
  services as those with greatest academic deficits
  in basic skills.

47
Which Districts Receive LAP Funds?

• Each school district with an OSPI-approved plan
  is eligible to receive an allocation.
• Districts failing to make AYP must receive
  technical assistance in development of their
  plans.
• Schools in any of the AYP Steps must have plans
  and activities reviewed and approved in
  conjunction with state and federal school
  improvement requirements.

48
How do Districts Receive LAP Funds?
Through a distribution formula, in accordance
with the biennial appropriations act, based on
a) projected or reported enrollment and b)
family income factors, usually free/reduced
priced lunch.
49
LAP Funding Cycle

• Program runs from September to August.
• An allocation, not a grant, the amount a district
  receives each month changes during the year,
  based on reported enrollment.

• Formula figured on F203 form.
• This is the same form on which basic ed funding
  is figured, usually by or with the district
  business manager.

50
Program Decisions

• LAP funds may enhance programs in
• Title I schools.
• LAP may be distributed to non-Title I schools
  with low performing students.
• Unlike Title I funds which are distributed to
  schools on a rank order poverty formula, LAP
  funds may go to any schools with significant
  numbers of low performing students.
• LAP schools may not be schoolwides.

51
Program Plan

• By July 1, 2005, participating districts must
• submit a district plan to OSPI for approval.
• This is also their application for funds and
  must
• address one or more of the following allowable
• activities
• Extended Learning Time
• Professional development
• Consultant teachers
• Tutoring
• Parent Outreach

52
Program Plans

• Requires Accelerated Learning Plans which must
  include four elements
• Achievement goals for students
• Student, teacher and parent roles
• Communication of student progress
• Review and adjustment of the plan
• Required to be in place in 2005-06 school year.
• May be developed as part of existing student
  achievement plan processes for either individual
  students or groups of students.

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Paraeducators

• NCLB Section 1119

54
Paraeducators NCLB Section 1119

• Paraeducators must meet Title I requirements
  immediately when
• hired after January 8, 2002 and
• assist with instruction and
• funded with Title I funds and/or Title I
  Schoolwide Building.
• Paraeducators, hired prior to or on January 8,
  2002, have until the end of school year 2005-2006
  to meet Title I requirements.

55
Paraeducator Duties

• Teacher provides assessment, lesson plans, and
  modifies instruction based on evaluation.
• Paraeducators may instruct in small groups or
  tutor one-to-one if supervised by
  highly-qualified teacher in close proximity.

56
Paraeducator- Duties and Responsibilities

• Title I paraeducators may perform
  non-instructional duties if
• Other paras in building are performing for like
  period of time and
• Small amount of work day and
• Use caution when assigning non-Title I activity.

57
Professional Development
Section 1119

58
High Quality Professional Development

• 5 of the districts allocation set aside to
  ensure teachers and paraprofessionals meet the
  highly-qualified standards under NCLB unless a
  lesser amount is needed.
• Research staff personnel files to determine
  status.
• Determine staff who meet the standard.
• Create a plan for those who do not currently
  meet the standard.
• Estimate the cost to carry out the plan.
• Set Aside the amount necessary.
• Keep documentation on file.
• 34 CFR 200.60
• 34 CFR 200.58
• 34 CFR 200.56

59
High Quality Professional Development

• Funds can be set aside to increase the knowledge
  and skills of teachers, principals,
  administrators and paraprofessionals.
• Title I professional development opportunities
  need to be aligned with EALRs and the grade level
  expectations for both math and reading.
• This set aside in the Title I iGrant application
  is is located under part 2 (D4).

60
School Improvement Professional Development

• Once a school is identified for school
  improvement Step 1
• The building needs to set aside 10 of its Title
  I, Part A funds to provide the staff with
  high-quality professional development.
• Required each fiscal year the school is
  identified.
• Must address the academic achievement problems.
• On the Title I iGrants application, this type of
  professional development is under the building
  allocation section, part 3.

61
District Improvement Professional Development

• Once a school district is identified for
  improvement, the district must set aside 10 of
  the districts Title I allocation to address the
  professional development needs of the
  instructional staff.
• This 10 mandate applies each fiscal year that
  the district is identified for improvement.

62
District Improvement Professional Development

• This mandate may include any amount of funds
  reserved for professional development from the
  schools that have been identified.
• District 10 minimum commitment for professional
  development is in addition to the set aside for
  highly qualified.

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Parent Involvement
Section 1118
64
Title I Parent Involvement

• Any effort to give parents more opportunities to
  help their children learn will require a
  willingness of educators to fundamentally rethink
  the role of parents and school-family
  relationships.

65
Title I Parent Involvement
Each school district receiving Title I funds must
develop parent involvement policies at both the
district and building levels.
Building A Parent Policy
District Parent Policy
Building B Parent Policy
66
Parent Involvement

• District Parent Involvement Policy is
• a written document
• jointly developed and agreed upon with parents
  and
• distributed to all parents of participating
  students.
• If the district already has a parent policy,
  it can be amended to meet Title I requirements.

67
Title I Parent Involvement

• Components of the District Policy
• Involve parents in the development of the policy
  and the process of school review and improvement.
• Provide assistance to buildings in carrying out
  their parent involvement activities.
• Build the schools and parents capacity for
  strong parental involvement.

68
Title I Parent Involvement

• Components of District Policy
• Coordinate Title I parent involvement policies
  with other programs such as Head Start, Reading
  First, Even Start, ECEAP and other pre-school
  programs.
• Conduct, with parents, an annual evaluation of
  the content and effectiveness of the district
  Title I parent involvement policy.

69
Title I Parent Involvement

• Components of District Policy
• Identify barriers that prevent greater
  participation in Title I parental activities by
  parents of economically- disadvantaged, disabled,
  limited English proficient, racial or ethnic
  minority students.

70
Title I Parent Involvement

• When developing the district parent involvement
  policy remember
• The What Policy (generic)
• The How Procedure (specific)

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Title I Parent Involvement

• Example
• Policy The Day School District will coordinate
  and integrate parental involvement strategies in
  Title I, Part A with the parent involvement
  strategies in Head Start.
• Explains what the district will do or promote
  the statement is generic.

72
Title I Parent Involvement

• Example
• Procedure The Day School District will
  coordinate and integrate Title I, Part A parental
  involvement strategies in Head Start by
• A. Sponsoring meetings and screening involving
  Head Start Families and Kindergarten teachers
  and
• B. Inviting Head Start families to school
  activities such as Books and Blankets and
  Preschool Fun Time.
• Explains how the district will meet or
  accomplish this aspect of the policy the
  statement is more specific.

73
Title I Parent involvement

• Districts receiving Title I allocations of
  500,000 or more must set aside not less than 1
  of the districts Title I allocation for parent
  involvement purposes, including promotion of
  parent literacy and developing parenting skills.
• Parents of students receiving Title I services
  are to be involved in decisions regarding how the
  district parent involvement funds are allocated
  for parent involvement activities.

74
Title I Parent Involvement

• School-Parent Involvement Policy (Plan) is
• Written policy (plan).
• Agreed upon by parents.
• Describes the means for carrying out parent
  involvement activities at the building level.
• Distributed to parents, and the local community,
  in a format and language, to the extent
  practicable, that parents can understand.
• If the school has a parental involvement
  policy that applies to all parents, it may be
  amended to meet the requirements of Title I.

75
Title I Parent Involvement

• Building Parent Policy Involvement
• Annually convene a meeting for parents of
• Title I students to explain the Title I program
  requirements.
• Offer flexible number of meeting times, and may
  provide, with Title I funds, transportation,
  child care, or home visits, as such services
  relate to parental involvement.

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Title I Parent Involvement

• Building Parent Policy Involvement
• Provide timely information about programs.
• Involve parents in an on-going, timely planning,
  review, and improvement of the school parental
  involvement policy and the joint development of
  the school wide program plan.
• Include a description and explanation of the
  curriculum in use at the school, the forms of
  academic assessment used to measure student
  progress, and the proficiency levels students are
  expected to meet.

77
Title I Parent Involvement

• Building Parent Policy Involvement
• If parents request opportunities for regular
  meetings to formulate suggestions and to
  participate, as appropriate, in decisions
  relating to the education of their children,
  respond to such suggestions as soon as
  practicably possible and
• If the schoolwide program plan is not
  satisfactory to parents of participating
  children, submit any parent comments on the plan
  when the school makes the plan available to the
  LEA.

78
Shared Responsibility for High Student Academic
Achievement

• Compact
• Each Title I school shall jointly develop with
  parents, for all children served, a school-parent
  compact that outlines how parents, the entire
  school staff, and students will share the
  responsibility for improved student academic
  achievement and the means by which the school and
  parents will build and develop a partnership to
  help children achieve the states high standards.

79
Shared Responsibilities for High Student Academic
Achievement

• Components of Compact
• Describe schools responsibility to provide
  high-quality curriculum and instruction in a
  supportive and effective learning environment.
• Identify ways in which parents will be
  responsible for supporting their childrens
  learning (i.e., monitoring attendance, homework
  completion, volunteering in the classroom, and
  participating as appropriate in decisions
  relating to the education of their children).

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Shared Responsibilities for High Student Academic
Achievement

• Components of Compact
• Address the importance of communication between
  teachers and parents on an on-going basis
  through, at a minimum
• Parent-teacher conference, at least annually,
  during which time the compact will be discussed
  as it relates to the individual childs
  achievement
• Frequent reports to parents on their childrens
  progress and
• Reasonable access to staff, opportunities to
  volunteer and participate in their childs class,
  and observation of classroom activities.

81
Building Capacity for Parent Involvement

• To ensure effective involvement of parents and to
  support a partnership among the school involved,
  parents, and the community to improve student
  academic achievement, each school and LEA
  assisted with Title I

82
Building Capacity for Parent Involvement

• SHALL
• Provide assistance to parents of children served
  in understanding the states academic content
  standards, state student academic achievement
  standards, state and local assessment standards,
  and how to monitor a childs progress and work
  with educators to improve their childrens
  achievement.
• Provide materials and training, as appropriate,
  to help parents work with their children to
  improve achievement and foster parent
  involvement.
• Educate teachers, pupil services personnel,
  principals, and other staff with the assistance
  of parents, in the value and utility of parents,
  and how to reach out, communicate with and work
  with parents as equal partners, implement and
  coordinate parent programs, and build ties
  between parents and the school.

83
Building Capacity for Parent Involvement

• SHALL
• To the extent feasible and appropriate,
  coordinate and integrate parent involvement
  programs and activities with Head Start, Reading
  First, Even Start, public preschool and other
  programs, and conduct other activities such as
  parent resource centers, that encourage and
  support parents in more fully participating in
  the education of their children.
• Ensure that information related to school and
  parent programs, meetings, and other activities
  is sent to the parents of participating children
  in a format and, to the extent practicable, in a
  language the parents can understand.

84
Building Capacity for Parent Involvement

• MAY
• Involve parents in the development of training
  for teachers, principals, and other educators.
• Provide necessary literacy training from funds
  received, if the LEA has exhausted all other
  reasonably available sources of funding for such
  training.
• Pay reasonable and necessary expenses associated
  with local parental involvement activities,
  including transportation and child care costs, to
  enable parents to participate in school-related
  meetings and training sessions.
• Train parents to enhance the involvement of other
  parents.

85
Building Capacity for Parent Involvement

• MAY
• Arrange school meetings at a variety of times, or
  conduct in-home conferences between teachers or
  other educators, who work directly with
  participating children, with parents who are
  unable to attend such conferences at school, or
  in order to maximize parental involvement and
  participation.
• Adopt and implement model approaches to improving
  parental involvement.
• Establish a district-wide parent advisory council
  to provide advice on all matters related to
  parental involvement in programs supported by
  Title I.
• Develop appropriate roles for community-based
  organization and businesses in parent involvement
  activities.
• Provide reasonable support for parental
  involvement activities as parents may request.

86
Accessibility

• LEAs and schools, to the extent practicable,
  shall provide full opportunities for the
  participation of parents with limited English
  proficiency, parents with disabilities, and
  parents of migratory children, including
  providing information and school reports in a
  language the parents understand.

87
Review of Parent Involvement Policies

• The state educational agency will review the
  LEAs parental involvement policies and practices
  to determine if the policies and practices meet
  the requirements of Title I.

88
Providing Equitable Services to Private
School Students
Section 1120
89
Goal

• To provide equal educational opportunities under
  Title I, Part A to students attending
  participating private schools.

90
Title I, Part A-Equitable Services

• Services are equitable if the district
• Addresses and assesses the specific needs and
  educational progress of eligible private school
  children on a comparable basis as public school
  children.
• Meets the equal expenditure requirements for
  instructional programs, professional development,
  and parental involvement activities.
• Provides private school children with an
  opportunity to participate that
• Is equitable to the opportunity provided to
  public school children and
• Provides promise of private school children
  reaching high levels of academic achievement.
• NCLB Section 1113(a) and 200.78

91
Eligibility to Participate

• Funds are generated by poverty
• To be eligible the student
• Must live in an attendance area served by a Title
  I building
• AND
• be low income.
• NCLB 1115(b)

92
Services are based on students
achievement needs

• Must reside in participating public school Title
  I attendance area AND are failing or most at risk
  of failing to meet high standards.
• Selected on the basis of multiple,
  educationally-related, criteria.
• Homeless, two preceding years in Head Start, Even
  Start, Early Reading First, Title I Preschool or
  Title I, Part C (Migrant Education).
• Poverty is NOT a criterion.
• District chooses children to be served from the
  list that the private school provides of eligible
  students.

93
Serving Options

• In consultation with the district and private
  school officials, one or both of these serving
  options may be selected
• 1) School-By-School Basis or
• 2) Pooling
• Combining funds from more than one district to
  serve eligible private school students from those
  districts (Requires agreement between districts
  with one acting as lead).

94
Determining Poverty

• The district may calculate the number of private
  school children from low-income families who
  attend private schools by
• Using the same measure of poverty as district.
• Using comparable poverty data from a survey and
  allowing the survey results to be extrapolated if
  complete actual data are unavailable.
• Geographic information verifying residence
• Grade level of each child
• Income level of parents
• NCLB 1120(c)(1) and 34 CFR 200.78(2)

95
Documentation of Poverty

• Private school officials should maintain the
  poverty data in their files.
• If the district or an auditor wish to review the
  data, they may review the data at the private
  school.

96
Timely and Meaningful Consultation

• To ensure timely and meaningful consultation,
  the district must consult with private school
  officials prior to making any decision that
  affects opportunities of private school children
  to participate in programs.
• NCLB Section 1120(b) and 34 CFR 200.63

97
Consultation

• Begins with Intent to Participate Form.
• The district must contact private school
  officials with children who reside within
  district boundaries, even if the private school
  is located outside those boundaries.
• It is the primary responsibility of private
  school officials to initiate contact but public
  school officials and parents may initiate as
  well.
• The district convenes a meeting to discuss needs
  and service options.

98
Consultation

• Must include
• Identification of needs
• Services to be offered
• How
• Where
• By whom
• Assessment and evaluation of services

99
Consultation

• Includes
• Services that will be provided to teachers and
  families.
• Discussion of service delivery mechanisms the
  district will use to provide services.
• Consideration of the private school officials
  views on whether the district should contract
  with a third-party provider.
• Final decision and responsibility rests with the
  district.

100
Affirmation of Consultation

• Affirmation of consultation should be signed by
  private school officials when consultation on the
  planning and design of the next years program
  has been completed.
• Exact timing for signing should be part of the
  consultation discussion.
• It is important to keep documentation on file.

101
Right to Complain

• Private school has the right to complain if they
  believe that the district did not engage in a
  timely and meaningful consultation process or did
  not consider their views.
• The complaint should be submitted to OSPI, the
  State Education Agency.

102
Identification of Needs

• Must be timely.
• Responsibility of public school.
• Complete rank order based upon
• Multiple assessments
• Teacher referral
• Parent input
• Through consultation, design and delivery of
  services to best meet needs of students.

103
Services Offered

• DIRECT FUNDING IS NEVER PROVIDED TO THE PRIVATE
  SCHOOL!!!
• Only services are provided.
• Services may be provided at private school, at
  public school or other agreed-upon location.
• May be offered in sacred location, but services
  must be secular.

104
Services

• May be offered by employee of public school
  district or person with whom the district
  contracts.
• Private school teachers may only provide services
  under a separate contract with the public school
  for hours in addition to their private school
  contract.
• Private school may not be reimbursed for teacher
  hours.

105
Services

• Equipment, curricula, books, etc., used for the
  Title I program in the private school remain the
  property of the public school and reverts to the
  public school when no longer used in the private
  school program.
• Simply providing a private school with
  instructional materials and supplies is NOT an
  option.

106
District Set Asides

• Calculated on Part 2 of the Title I Application
• Eligible students attending private schools
  within the district
• Set aside allocation and equitable share
• Eligible students attending private school
  outside the district
• Set aside allocation

107
District Set Asides

• The amount set aside for equitable services to
  private school students, parents and teachers is
  calculated based on the proportion of low income
  private school students compared to the total
  number of public and private low income students
  living in the district.
• This is calculated on the Title I iGrant
  application.

108
Parent Involvement

• Parents are an essential component of the childs
  education.
• Funds set aside on application to be used for
  parent involvement.
• Consult with parents in same manner as public
  school parents.
• Include parents in public school parent
  activities and/or parent activities at the
  private school.
• NCLB 1118 and 34 CFR 200.65

109
Professional Development

• Funds set aside on application to be used for
  professional development.
• Private school staff may be included in
  professional development activities at the public
  and/or private school.
• Subs for private school teachers may not be paid
  out of Title I.
• Reasonable and necessary stipends may be paid
  directly to private school teachers.
• NCLB 1119 and 34 CFR 200.77

110
Fiscal Requirements
Section 1120A
111
Complaint Procedures

• WAC 392-168

112

• WAC 392-168-110  Purpose. The purpose of this
  chapter is to provide complaint procedures in
  compliance with 20 U.S.C. 7844 and 7883, and
  with 34 C.F.R. 299.10-299.12.

113
WAC 392-168-115  Applicability. This chapter
shall apply to federal programs authorized under
the Elementary and Secondary Education Act and
administered by the superintendent of public
instruction, including the following

• (1) Title I, Part A Improving Basic Programs
  Operated by Local Educational Agencies
• (2) Title I, Part B, Subpart 1 Reading First
• (3) Title I, Part B, Subpart 3 William F.
  Goodling Even Start Family Literacy Program
• (4) Title I, Part C Education of Migratory
  Children
• (5) Title I, Part D Prevention and Intervention
  Programs for Children and Youth Who Are
  Neglected, Delinquent, or At-Risk
• (6) Title I, Part F Comprehensive School
  Reform
• (7) Title II, Part A Teacher and Principal
  Training and Recruiting Fund
• (8) Title II, Part D Enhancing Education
  Through Technology
• Title III--Language Instruction for Limited
  English Proficient and Immigrant Students
• (9) Title III, Part A English Language
  Acquisition, Language Enhancement, and Academic
  Achievement

114

• (10) Title IV--21st Century Schools
• (11) Title IV, Part A, Subpart 1 Safe and Drug
  Free Schools and Communities
• (12) Title IV, Part B 21st Century Community
  Learning Centers
• Title V--Promoting Informed Parental Choice and
  Innovative Programs
• (13) Title V, Part A Innovative Programs
• Title VI--Flexibility and Accountability
• (14) Title VI, Part A, Subpart 1 Improving
  Academic Achievement, Accountability, Grants for
  State Assessments and Enhanced Assessments
• (15) Title VI, Part B, Subpart 1 Small, Rural
  School Achievement Program
• (16) Title VI, Part B, Subpart 2 Rural and
  Low-Income Schools
• (17) Title IX--General Provisions
• (18) Title IX, Part E (Section 9532) Unsafe
  School Choice

115
WAC 392-168-125  Definition--Complaint

• As used in this chapter, the term "complaint"
  means an allegation, by the complainant, that the
  state, a local school district, an educational
  service district, or other subgrantee receiving
  federal funds has violated a federal statute or
  regulation or a related state regulation that
  applies to a federal program covered under this
  chapter.

116
WAC 392-168-132  Informing citizens about
complaint procedures

• The superintendent of public instruction shall
  inform parents and other interested individuals
  about the citizen complaint procedures in this
  chapter. Specific actions to be taken by the
  superintendent of public instruction include
• (1) Disseminating copies of the state's
  procedures to parents, advocacy agencies, ((and))
  professional organizations and other appropriate
  entities
• (2) Conducting inservice training sessions on
  the complaint process through educational service
  districts and
• (3) Including information about the system in
  statewide conferences.

117
WAC 392-168-135  Right to register a complaint

• Any individual or organization may file a signed,
  written complaint.

118
WAC 392-168-140  Contents of complaint

• A written complaint filed under this chapter
  shall include
• (1) A statement that the state, a local school
  district, an educational service district, or
  other subgrantee has violated one or more
  requirements of federal statutes or regulations
  or state regulations that apply to a federal
  program covered under this chapter
• (2) The specific requirement alleged to have been
  violated
• (3) The facts on which the complaint is based
• (4) The name and address of the complainant
  ((and))
• (5) The expected resolution of the alleged
  violation and
• (6) In the case of a complaint alleging a
  violation by an entity other than the state and
  filed directly with the superintendent of public
  instruction, the name and address of the
  allegedly offending entity.

119
WAC 392-168-145  Procedure for filing a complaint

• The procedure for filing a complaint shall be as
  follows
• (1) A complaint alleging a violation by a local
  school district, an educational service district,
  or other subgrantee shall be filed directly with
  the superintendent of public instruction.
• (2) The superintendent of public instruction,
  upon receipt of a signed, written complaint
  against a local school district or other public
  agency, an educational service district, or other
  subgrantee, shall refer the complaint to the
  educational entity for action pursuant to this
  chapter. A complaint against the state shall be
  investigated pursuant to WAC 392-168-180.
• (3) Receipt of a complaint by the superintendent
  of public instruction activates a time limit not
  to exceed sixty calendar days, unless an
  extension of the time limit is approved by the
  superintendent of public instruction on the basis
  of exceptional circumstances with respect to a
  particular complaint.

120
WAC 392-168-155  Investigation of and response to
complaints against a school district or other
public agency, educational service district, or
other subgrantee

• Investigation of and response to a complaint
  shall be as follows
• (1) Upon receipt of a properly filed
  complaint, the superintendent of public
  instruction shall send a copy of the complaint
  to the educational entity, for investigation of
  the alleged violations.
• (2) The educational entity shall investigate
  the complaint. The responsible official of the
  educational entity shall respond in writing to
  the superintendent of public instruction, and
  include documentation of the investigation, no
  later than twenty calendar days after the date
  of receipt by the entity of such complaint.
• (3) The response to the superintendent of
  public instruction shall clearly state either
• (a) That the educational entity denies the
  allegations contained in the complaint and the
  basis for such denial or (b) Propose reasonable
  corrective action(s) deemed necessary to correct
  the violation.

121
WAC 392-168-155  Investigation of and response to
complaints against a school district or other
public agency, educational service district, or
other subgrantee

• (4) The superintendent of public instruction
  shall provide the complainant a copy of the
  entity's response to the complaint.
• (5) The superintendent of public instruction will
  provide the complainant the opportunity to submit
  additional information or a rebuttal, either
  orally or in writing, about the allegations in
  the complaint.
• (6) Upon review of all relevant information
  including, if necessary, information obtained
  through an independent on-site investigation by
  the superintendent of public instruction, the
  superintendent of public instruction will make an
  independent determination as to whether the
  public agency is in violation of any federal
  program requirement covered under this chapter.

122
WAC 392-168-155  Investigation of and response to
complaints against a school district or other
public agency, educational service district, or
other subgrantee

• (7) The superintendent of public instruction
  shall issue a written decision to the complainant
  that addresses each allegation in the complaint
  including findings of fact, conclusions, and the
  reasonable corrective measures deemed necessary
  to correct any violation. The superintendent of
  public instruction will also determine whether to
  accept any reasonable corrective action proposed
  by the local entity or other subgrantee. The
  state may provide technical assistance
  activities negotiations and corrective measures
  necessary to resolve a complaint. All actions
  shall be instituted, as soon as possible but in
  no event later than thirty calendar days
  following the date of the decision, unless
  otherwise agreed to, or for good cause.
• (8) The written decision by the superintendent of
  public instruction is the final decision in the
  matter. A complaint is considered resolved when
  the superintendent has issued a written decision
  and corrective measures, if warranted, have been
  completed.

123
WAC 392-168-155  Investigation of and response to
complaints against a school district or other
public agency, educational service district, or
other subgrantee

• (9) If compliance by a local district or other
  public agency, educational service district, or
  other subgrantee is not achieved pursuant to
  subsection (7) of this section, the
  superintendent of public instruction shall
  initiate fund withholding, fund recovery, or any
  other sanction(s) deemed appropriate.
• (10) For complaints arising under 20 U.S.C.
  7883 (participation by private school children),
  a complainant may appeal the superintendents
  resolution to the Secretary of Education (U.S.
  Department of Education) within 30 days of
  receiving the written decision from the
  superintendent of public instruction.

124
WAC 392-168-180  Complaints against the
superintendent of public instruction--investigatio
n of and response to complaints

• (1) The staff responsible for investigating the
  alleged violation shall commence investigation
  within ten days of receipt of the complaint by
  the superintendent of public instruction.
• (2) Investigation by the superintendent of public
  instruction may include on-site investigations as
  appropriate.
• (3) Upon completion of the investigation,
  investigating staff shall provide the
  superintendent of public instruction with a
  written report on the results of the
  investigation, no later than sixty calendar days
  after the receipt of such complaint.

125
WAC 392-168-180  Complaints against the
superintendent of public instruction--investigatio
n of and response to complaints

• (4) The superintendent of public instruction
  shall respond in writing to the complainant as
  expeditiously as possible but in no event later
  than ten calendar days after the date of receipt
  of the written report described in subsection (3)
  of this section.
• (5) The response shall clearly state either
• (a) That the complaint is without merit, the
  allegations are denied, and the basis for such
  denial or
• (b) The reasonable corrective measures deemed
  necessary to correct any violation provided,
  that any such corrective measures deemed
  necessary shall be instituted as expeditiously as
  possible, but in no event later than thirty
  calendar days following the date of the response
  to the complainant.

126
Supplement Not Supplant

• Considers services
• Section 1120A(b) and (d) of NCLB
• 34 CFR 200.79

127
Supplement Not Supplant

• Targeted Assistance Schools
• Title I funds must be used only to supplement the
  level of funds that would, in the absence of
  Title I, be available from non-federal (state and
  local) sources for Title I students.
• The district is not required to provide Title I
  services using a particular instructional method
  (i.e., pull out programs, in class, etc.).
• Based on services.

128
Supplement Not Supplant

• Schoolwide Program Schools
• Must use Title I funds only to supplement the
  amount of funds that would, in the absence of
  Title I funds, be made available for that
  schoolwide program (including funds needed to
  provide services required by law for disabled
  children and LEP children).
• Similar to MOE.

129
Supplement Not Supplant

• Presumption of supplanting
• The district has used the Title I funds to
  provide services that the district was required
  to make available under federal, state or local
  law.
• The district used Title I funds to provide
  services it provided with non-federal funds in
  the prior year(s).
• The district has used Title I funds to provide
  services for participating children that it
  provided with non-federal funds for
  non-participating children
• Rebuttals are possible, see OSPI website

130
Supplement Not Supplant

• Exclusions
• The district may exclude supplemental state or
  local funds expended in any school for programs
  that meet the intent and purposes of Title I,
  Part A.

131
Supplement Not Supplant

• Program meets the intent and purposes of Title I
  in a schoolwide program if
• It is implemented in a school with 40 or more
  poverty
• It is designed to promote schoolwide reform and
  upgrade the entire educational operation of the
  school
• It is particularly designed to meet the
  educational needs of at-risk students and
• It uses the states assessment system to review
  the effectiveness of the program.

132
Supplement Not Supplant

• Program meets the intent and purposes of a Title
  I program in a targeted assistance program if
• It serves only children who are failing or most
  at risk of failing to meet the states
  performance standards
• It provides supplementary services designed to
  meet the educational needs of the children who
  are participating in the program and
• It uses the states assessment system to review
  the effectiveness of the program.

133
Comparability

• Building level
• Section 1120A(c) and (d)
• 34 CFR 200.79
• OSPI Bulletin 011-04

134
Comparability

• A district may receive Title I, Part A funds
  only if it uses state and local funds to provide
  services in Title I schools that, taken as a
  whole, are at least comparable to services
  provided in non-Title I schools.

135
Comparability

• If all schools in the district are Title I
  schools, the district must use state and local
  funds to provide services that, taken as a whole,
  are substantially comparable in each school.

136
Comparability

• Comparability is met if the district provides
  written assurance it has established and
  implemented
• A district wide salary schedule
• A policy to ensure equivalence among schools in
  teachers, administrators, and other staff and
• A policy to ensure equivalence among schools in
  the provision of curriculum materials and
  instructional supplies.

137
Comparability

• Alternative Criteria
• The district may meet the comparability
  requirement if it establishes and implements
  other measures for determining compliance such as
  student/teacher ratios, student/instructional
  staff salary ratios or total expenditures per
  school.
• Staff salary differentials for years of
  employment may not be included in comparability
  determinations.
• The district need not include unpredictable
  changes in student enrollment or personnel
  assignments that occur after the beginning of a
  school year.

138
Comparability

• Documentation
• The district must develop procedures/policies
  for meeting the comparability requirement and
  maintain records that are updated at least
  biennially.

139
Comparability

• Exclusions
• Bilingual education for children of limited
  English proficiency.
• Excess costs of providing services to children
  with disabilities.
• Supplemental state and local funds spent for
  programs that meet the intent and purposes of
  Title I, Part A (LAP).

140
Time and Effort Reporting

• Why Does it Take So Much Time and Require So Much
  Effort?

141
Where is the Requirement?

• Time and effort reporting is required under the
  Federal Office of Management and Budgets
  Circular A-87, Cost Principles for State, Local,
  and Indian Tribal Governments.
• Attachment B, Selected Items of Cost, Item 11,
  Compensation for personnel services.

142
When is Time and Effort Required?

• Time and effort reporting is required when any
  part of an individuals salary is charged to a
  federal program.
• Charge may be direct or indirect.

143
What type of reporting is needed?

• Single cost objective ?Semi annual certification.
• Multiple cost objectives ?Monthly time reports or
  Personnel Activity Reports (PARs).

144
What is a cost objective?

• Work activities allowable under the terms and
  conditions of a
• funding source.

145
What are some examples of a single cost objective?

• 100 charged to a single federal program
  activity.
• Exceptions
• Title I, Part A and LAP
• Federal Special Education and State Special
  Education
• Schoolwide programs
• Multiple activities in a single federal program

146
What are some examples of multiple cost
objectives?

• Salary charged to more than one activity in a
  single federal program.
• Salary charged partially to federal program and
  partially to state and/or local sources.
• Salary charged partially to sources combined into
  a schoolwide program and partially to those not
  included.

147
What is a semi-annual certification?

• Statement individual(s) worked solely on
  activities related to single cost objective.
• Completed at least every six months.
• Signed by employee or supervisor with first-hand
  knowledge of work performed.

148
What is a monthly time report?(PAR)

• Accounts for total activity
• Prepared at least monthly
• Signed by employee
• Reflects actual work performed (not budget)
• Agrees to supporting documentation

149
When are adjustments to actual made?

• If payroll is initially based on budgeted or
  estimated time/amounts, payroll and time and
  effort reports must be compared at least
  quarterly.
• If the difference is 10 or more
• and any needed adjustments made.
• Payroll records must be adjusted to actual.
• Following quarters estimates must be adjusted.

150
What time and effort is reported?

• Report time actually worked in a specific
  activity not time budgeted.
• Budgets are reconciled to actual at least
  quarterly.

151
Who should sign the reports?

• Monthly reports (PARs) should be signed by the
  employee.
• Semi-annual certifications should be signed by
  employee or supervisor having first-hand
  knowledge of work performed.
• For internal control purposes, districts may
  require both the employee and supervisor to sign.

152
What type of supporting documentation is needed?

• Documentation is VERY important.
• Examples include, but are not limited to
• Class schedules
• Number of students
• Number of minutes
• Remember
• DOCUMENT! DOCUMENT! DOCUMENT!

153
Supplemental Contracts, Stipends, Extra Hours

• Primary contract and additional contracts may be
  considered separately.
• Based upon whether or not charged to federal
  program.
• Time and effort may be required for primary
  contract but not supplemental (or vice versa).

154
Administrators

• Superintendent, assistant superintendent,
  principal, assistant principal usually not
  allowable charge to federal program.
• Requires good documentation to support.
• Could be a supplant issue.

155
What is a substitute system?

• Other method for determining time and effort
  report based on sample of work performed.
• Must be approved by OSPI prior to use.
• JoLynn Berge is responsible for approval.
• Must be statistically sound.
• Should be periodically reviewed to determine if
  still appropriate.

156
Schoolwide Programs

• Schoolwide plan must specify programs to be
  included (not all programs may be included).
• A schoolwide program is a single cost objective
• If employee works 100 on programs combined ?
  Semi-annual certification
• If employee works partially on programs combined
  and partly on those not combined, ? Monthly time
  report (PAR).

157
For Additional Information

• OSPI Bulletin 006-04 (Time and Effort Reporting)
• Examples
• Sample forms
• OSPI Bulletin 077-5 (Combining Funds in
  Schoolwide Programs)
• OMB Circular A-87, Cost Principles for State,
  Local, and Tribal Governments

158
Timely Submission of Applications
159
History

• Title I, Part A applications are from July 1,
  Year 1 through August 31, Year 2.
• Applications have always been due
• July 1.

160
Extenuating Circumstances

• In 2002-2003, OSPI converted from WebApps to
  iGrants. Issues associated with the conversion
  necessitated pushing the due date back.
• OSPI has not received district allocations from
  the US Department of Education until late spring.
  To accommodate for this the due date was pushed
  back to August 19, 2005.

161
Current Practice

• Some districts are taking increasingly more time
  to submit their applications.
• Late applications are accepted.

162
The Problem

• Determination of carryover and reallocation funds