Private School Equitable Services: Updates and Overview
Equitable Services: Updates and Overview Good Morning! We will begin shortly. Please mute yourself as you enter the webinar. OVERVIEW OF TODAYS SESSION 1. ESSA: What is New (a Review) 2. Roles and Responsibilities: SEA, LEA, PRIVATE SCHOOL 2. Timely and Meaningful Consultation Suggested Timelines Affirmation of Consultation 3. Title IA Eligibility: Allocation and Services Administrative Costs Considerations 4. Title IIA and IVA 5. Transferability 6. Questions and Next Steps
School District Administrators Private School Administrators ODE Program Staff Other EQUITABLE SERVICES: BASIC PREMISE Federal programs are supported by tax dollars, so all children and teachers (both public and private) are eligible to access these programs. Applicable Federal Programs Equitable services requirements for non-public/private schools apply to programs under 1117 or 8501: Title I, Part A (Improving Basic Programs)
Title I, Part C (Migrant Education) Title II, Part A (Supporting Effective Instruction) Title III, Part A (English Language Acquisition) Title IV, Part A (Student Support & Academic Enrichment) Title IV, Part B (21st CCLC) Changes with ESSA---A Review Ombudsman Expanded Consultation Affirmation of Consultation No Carryover Transferability Making Progress
The vast majority of districts and private schools have established good working relationshipsthese are all OUR kids Continuing to work with private schools administrators to provide education on opportunities and responsibilities FAQs-General Information and Equitable Services https:// www.oregon.gov/ode/schools-and-districts/grants/ESEA/Pages/Private-Schools.aspx Building Toolkit https:// www.oregon.gov/ode/schools-and-districts/grants/ESEA/Pages/ESEA-Monitoring.aspx Private School Partnership meets quarterly Equitable Services Workgroup meets quarterly List of private schools coming soon Listserve coming soon
ODE Webpage Resource: Private Schools Participation under ESSA This webpage provides resources and information for both private school and district administrators to include: Calculating Proportionate Share Consultation (Checklist and Took Kit samples & Guidelines) Needs Assessment, Plan Development and Evaluation Other resources (e.g., compliance, sample Income survey, Title IIA Reimbursement/Stipend Process, etc.) The full link: https ://www.oregon.gov/ode/schools-and-districts/grants/ESEA/Pages/Priv ate-Schools.aspx RESPONSIBILITIES
SEA, LEA and Private School SEA LEA PRIVATE SCHOOL Designate Ombudsman Conduct and document ongoing, timely and meaningful consultation Attend consultation meeting Collect Affirmation of Consultation forms from districts Provide services that meet the needs of PS students and
staff Provide necessary reports/documentation when requested Mediate, investigate and resolve conflicts Allocate a proportionate share for equitable services Be prepared to provide annual needs assessment Oversight and monitor Assess/evaluate programs Determine (in consultation with LEA) method to
determine poverty Provide technical assistance Obligate funds in year they are received Be familiar with Targeted Assistance Title IA program CONSULTATION The of Equitable Services CONSULTATION GOAL of consultation: reach an agreement between the school district and private school officials on how to provide equitable and effective programs for eligible private school children. TIMELY
Before the LEA makes any decisions During the design and development of program Throughout the implementation and assessment of services MEANINGFUL Genuine opportunity for parties to express their views Views seriously considered LEA may initiate consultation with a proposal for services Consultation must occur before final decision are made by LEA CONSULTATION Needs of Private School Students and Teachers NEW December How & When Decisions are Made
Amount of Funds Available for Services October September Services Offered and Delivery of Services Assessment of Services August Pooling of Funds February
November Size and Scope of Services rd Party 3rd Providers January Timely and meaningful consultation must continue throughout the implementation and assessment of services and shall occur before the local education agency makes any decision
that affects the opportunities to participate of eligible private school July June students, teachers, and other education personnel. March April Providing Services Directly or Via Another Entity How Amount of Funding is Determined
Requires Written Affirmation May 13 Systems of Support CONSULTATION Identify private schools within district boundary Develop annual consultation calendar Send out consultation invitation letter (adequate notice typically 2 to 3 weeks) Establish LEA and private schools roles and responsibilities Discuss/exchange applicable LEA and private school fiscal and program policies Discuss and require private school signature of Federal requirements governing the provision of federally funded services (In toolkit https:// www.oregon.gov/ode/schools-and-districts/grants/ESEA/Pages/ESEA-Monitoring.aspx )
Access existing resources to guide collaboration Document, document, document CONSULTATION TIMELINE Inform private school officials annually (late winter) Engage in timely and meaningful consultation (ongoing) Identify needs (early spring) Determine per pupil amount for private school services equal to per pupil amount for public school services. (late spring/ early summer) Discuss logistics of program operation (summer) Provide services, programs, materials, and resources (to begin in
fall and continue throughout the school-year) Minimum of one on-site visit (November through March) Evaluate programs and services for effectiveness (spring) This is one of many suggested timelines. Many districts have developed plans that meet the needs of the district and their private schools.. Topics of Consultation by Title Program Topics of Consultation by Title Program I II III IV a.
How the district will identify the needs of eligible non-public school children and their educators a. What services the district will offer to eligible non-public school children and their educators a.
How and when the district will make decisions about the delivery of services a. How, where and by whom the district will provide services to eligible non-public school children, including a thorough consideration and analysis of the views of the non-public school officials on the provision of services through a contract with a third-party provider
How the district will assess academically the services to eligible nonpublic school children and how the district will use the results of that assessment to improve services The size and scope of the equitable services that the district will provide to eligible non-public school children and the proportion of funds that will be allocated to provide these services, and how that proportion of funds is determined
The method or sources of data that the district will use to determine the number of non-public school children from low income families residing in participating public school attendance areas, including whether the district will extrapolate data, if a survey is used a. The equitable services the district will provide to teachers and families of participating non-public school children a. Whether the district shall provide services directly or through a separate government agency, consortium, entity, or thirdparty
contractor a. a. a. Topics of Consultation by Title Program a.
I II III Topics of Consultation by Title Program - continued Whether to consolidate and coordinate the use of funds to eligible private school children: by creating a pool or pool of funds with all the funds allocated under Titles I, II, III, and IV; or on a school-by-school basis based on each the proportionate share of funds available to provide services in each school
a. When, including the approximate time of day, services will be provided a. The option for private school officials to indicate such officials belief that timely and meaningful consultation has not occurred or that the program design is not equitable with respect to eligible private school children
a. IV How the LEA administrative costs were determined AFFIRMATION OF CONSULTATION (must be sent to Ombudsman within 30 days of consultation with private school) Districts may continue to use TransACT form PS-02 (Verification) or the Affirmation of Consultation form posted in Private School Equitable Services Toolkit https:// www.oregon.gov/ode/schools-and-districts/grants/ESEA/Pages/ESEA-Monitoring.aspx
All documentation (i.e. agendas, invitations, meeting notes/minutes should be maintained at the district level) TITLE IA Improving Basic Programs TITLE IA Allocating Funds for Equitable Services Expenditures for equitable services to eligible private school children, teachers and other educational personnel, and families must be equal to the proportion of funds allocated to participating public school attendance areas based on the number of children from low-income families who reside in those attendance areas and attend private schools. An LEA must determine the proportionate share of Title I funds available for equitable services based on the total amount of Title I funds received by the LEA prior to any allowable expenditures or transfers of funds. Section 1117(a)(4)(A)
FAQs O-1 to O-5 20 Title I Equitable Services: Process for Title I Equitable Services: Process Determining ALLOCATION and SERVICE for Determining Allocation and Private school determines service (registration form) the resident district https:// www.oregon.gov/ode/schools-and-districts/grants/ESEA/Pages/ESEA-Monitorin g.aspx
for each student Private school determines poverty level of all students (most commonly used is free and reduced lunch data; although there are 4 methods) Private school sends districts a list of all students residing within district boundaries and their poverty level District determines which student reside in a Title I school attendance area District sends private school list of ALL students in Title I school attendance area Private school screens ALL students from district list to determine academic need during (i.e. DIBLES, CBM etc.) Private school ranks students with highest needs ALLOCATION is determined by poverty AND residence
SERVICE is determined by need AND residence !Important Distinctions! Private schools are targeted assist schools and only those students identified as being at risk for academic failure can be served Although a student may generate funds because of residence and poverty, the student may not be at risk of academic failure so would not be eligible for services Title I-A Equitable Services The Title I non-public equitable share is based on the percentage of non-public low income students residing in Title I participating schools Example: Total Public Low Income: 1,350 Total Non-public Low Income: 150
Total Low Income: 1,500 Percentage of Non-public Low Income: 10% (150/1,500) Allocating Funds for Equitable Services Allocating Funds Equitable Allocating Funds for for Equitable Services Services Guidance administering equitable services From the proportionate
share of Title I funds available to provide equitable services, an LEA may reserve an amount that is reasonable and necessary to administer equitable services. An LEA determines this amount separately from funds needed to administer the Title I program for students in public schools. The LEA should discuss administrative costs for implementing equitable services during consultation with appropriate private school officials. ADMINISTRATIVE COSTS Must be reasonable and necessary Focus of all federal funds is students Must be discussed during consultation process Includes: grant management, processing purchase orders, negotiating contracts, conducting meetings, accounting activities, grant activity documentation/reimbursement, file maintenance, program implementation and monitoring, inventory management
COMMON TITLE IA ACTIVITIES Tutoring Paraprofessionals Summer school Supplies/materials Professional development Extended day programs Computer assisted instruction !CONSIDERATIONS! Title IA funds may not be used for screening assessments Preschoolers are not eligible for equitable services (Oregon
education system is K-12) Services for private school students should begin at the same time as services for public school students Services may be delivered directly through district or indirectly through contracts with public and private organizations/individuals District controls all funds, materials and equipment Delivery of services must be neutral, secular and non-ideological Services for private school students must be for the same grade span as the services provided for public school students !CONSIDERATIONS! The private school must notify families of their students participation in the Title IA program (sample letter in Toolkit) Spring calculations are an estimate and may change with final allocation amounts from ODE Private school officials have no authority to obligate or receive federal funds. No federal funds may be paid directly to a private school A private school may never be reimbursed for materials/supplies purchased for Title programs
Services must hold reasonable promise that the academic performance of private school students will improve Annually, the district must access the annual progress of the Title IA program PROVIDING SERVICES The district may provide services either directly using district personnel or indirectly through contracts with public or private organizations/individuals Contracted services must be independent of the private school and under the supervision of the district Private school teachers may be employed by both the private school and the district ; however, they must be independent of the private school during the time IA services are being provided Private school officials may not sign time and effort records TITLE IIA Supporting Effective Instruction
Title IIA Roles and Responsibilities Private School District Participate in annual consultation Conduct a needs assessment and identify prioritized needs Contact all eligible private schools within district boundaries in February to schedule consultation Participate in annual consultation Calculate equitable share for each participating private school and create a line item in district narrative including school name, date of consultation, and equitable service amount Provide district with a list of strategies tied to identified needs that include WHAT, WHO, HOW and how the strategy meets the USED definition of professional development (see current guidance)
Include information on strategies provided by private school in line item Submit district application when district is ready, regardless of submission from private school If private school plans are provided after district submission, revise district IIA submission to reflect private school strategies once received Work with district contact to arrange for billing and payment of activities. The district serves as the fiscal agent for the school. Schools cannot be reimbursed for costs If no plans are received by the district by February 1, notify the private school with a registered, return receipt letter that equitable service funds will be reallocated to the district unless a plan is received by March 30 If private school equitable service funds are reallocated to
the district, revise district IIA submission to reflect how funds were spent at the district level Needs Assessment A comprehensive Needs Assessment helps answer the question: What professional learning and support do teachers and principals need to help students succeed? Steps Identify data sources Analyze data for trends and gaps in performance Determine prioritized needs Develop a plan Describing Strategies and Activities WHAT is the intended objective? List the prioritized need the activity addresses Describe the knowledge and skills will staff receive as a result of participation and how funds will be spent
Indicate how the strategy meets the USED definition of professional learning 34 Describing Strategies and Activities WHO will participate? List the type and number of staff participating (e.g., 10 teachers, 1 principal) HOW is impact being measured? Identify what measures will be used to determine whether the strategy is generating the results you expect. Professional Learning Strategies and activities must meet USED definition high quality, sustained, intensive, and classroom-focused in order to have a positive and lasting impact on classroom instruction and the teachers performance in the classroom and not 1-day or short-term workshops or conferences. [ESEA
Section 8101(42)] Conferences and workshops are approvable when they are included as part of larger strategy, not as an end in themselves How is the conference part of a sustained, job-embedded plan for professional learning? What is the plan for delivering the content so that the learning extends beyond those who attended? Important Reminders PS activities are based on the schools needs assessment Non-Allowable Salaries/benefits, substitutes Religious content
Schools may not be reimbursed the district is the fiscal agent Title II, Part A Allocation Title II, Part A Allocation Guidance Calculating the Equitable Services allocation EXAMPLE OF FORMULA TO DETERMINE AMOUNT FOR TITLE II, PART A EQUITABLE EXEPNDITURES CHART A. Number of Students A1: LEA Enrollment 900 A2: Participating Private School Enrollment 100 A3: Total Enrollment A1 + A2
1,000 B. Title II, Part A Allocation B1: Total LEA Allocation B2: Administrative Costs (for public and private school programs) B3: LEA Allocation minus Admin Costs = B1-B2 $1,000,000 $50,000 $950,000 C. Per Pupil Rate C1: B3 divided by A3 $950 D. Equitable Services Amount LEA must reserve for equitable services for private school teachers and other educational personnel A2 x C1
$95,000 Calculating Equitable Services Equitable service amounts are based on the LEAs total allocation less administrative costs Costs to operate the grant at both the district and private school (e.g.; conducting meetings, negotiating contracts, accounting activities, etc.) Total cannot exceed the districts indirect rate Note: Total enrollment for IIA is all students in district and private school, not the same as IA TITLE IVA Student Support and Academic Enrichment Title IVA 1. Allocations determined the same as IIA 2. Needs assessment must be used to determine priorities/goals 3. Provides a great deal of flexibility within three
broad categories 1. Well-rounded Schools 2. Safe and Healthy Schools 3. Effective Use of Technology 4. List of allowable activities TRANSFERABILITY Transferability is a flexibility authority under the Every Student Succeeds Act (ESSA) which allows Local Educational Agencies (LEAs) to transfer up to 100% of the funds they receive under Title II, Part A and Title IV, Part A to other programs to better address the needs of their unique student populations Transferred funds become funds of the program to which they are transferred and are subject to all the rules and requirements of the programs to which the funds are transferred. In accordance with ESEA Section 5103(e)(1), funds transferred from Titles II, Part A and IV, Part A are subject to each of the rules and requirements applicable to the programs to which the transferred funds are transferred, which may include transferring to Title I, Parts A, C, and D, Title III, Part A, and Title V, Part B as well as to Titles II, Part A or IV, Part A. BEFORE an LEA may transfer funds from a program subject to equitable services requirements, it must engage in timely and meaningful consultation with
appropriate private school officials. With respect to the transferred funds, the LEA must provide private school students and teachers equitable services under the program(s) to which, and from which, the funds are transferred, based on the total amount of funds available to each program after the transfer. For example, if an LEA transfers 100% of funds received in Title IV, Part A into Title I, Part A, the LEA would provide equitable services under Title I, Part A, since no funds are remaining under Title IV, Part A. MOST COMMON FINDINGS Unallowable expenditures No prior approval Inadequate documentation Not reasonable and necessary Private school paid directly
Unallowable reimbursement Source: State Ombudsman Collaborative and USDE Resources ESSA Resources ESSA Guidance (right click on links below to open hyperlink) Non-Regulatory Guidance: Fiscal Changes and Equitable Services Requirements Non-Regulatory Guidance for Title II, Part A: Building Systems of Support for excellent Teaching and Leading
Non-Regulatory Guidance: English Learners and Title III of the Elementary and Secondary Education Act as amended by the Every Student Succeeds Act Non-Regulatory Guidance Student Support and Academic Enrichment Grants (Title IV, Part A) Key ESSA Resources USED: Office of Non-public Education Resources (right click on links below to open hyperlink)
Title IIA web page Title IIA Listserv Federal Non-Regulatory Guidance Oregon Federal Funds Guide Course to Endorsement Catalogue Standards for Professional Learning (Learning Forward standards) Guide to Increasing the Effectiveness of Profes sional Learning Next Steps A Common Questions document will be sent out with comments/questions from today, as well as other commonly asked questions
Affirmation of Consultation will be posted on web as well as sent out to all ES district staff Thank You
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