Private Schools 101: A Timeline for Planning, Serving, and Assessing a New Private School Program 2014 Annual GCEL Conference February 26-26, 2014 Savannah,

Private Schools 101: A Timeline for Planning, Serving, and Assessing

a New Private School Program

2014 Annual GCEL Conference February 26-26, 2014

Savannah, GA Riverfront Marriott

Presenters

Elaine DawseyGeorgia Department of Education

Title I Education Program Specialist [email protected]

(478) 971-0114

Marijo Pitts-SheffieldGeorgia Department of Education

Title I Education Program [email protected]

(912) 269-1216

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Workshop Purpose

• To offer centralized guidance and support to district and private school officials working with Title I programs

• To ensure uniformity in the implementation of the Title I Private School Provisions in ESEA

– Consultation– Identifying eligible participants– Ensuring equitable participation of private school students– Ensuring equitable participation of private school teachers

and families of Title I participants– Ensuring equitable set-asides

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Guidance

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Guidance

The Elementary and Secondary Education Act of 1965 (ESEA) provides benefits to private school students, teachers and other education personnel, including those in religiously affiliated schools.

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Guidance

Section 1120 of the Title I Part A ESEA requires a participating district to provide eligible children attending private elementary and secondary schools, their teachers, and their families with Title I services or other benefits that are equitable to those provided to eligible public school children, their teachers, and their families.

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Guidance

Title I, Part A funds are aimed at children who are at-risk of failing to meet the state’s student academic achievement standards or other more appropriate standards for private school Title l students as determined in consultation.

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Guidance

Federal programs with equitable participation requirements:

• Title I, Part A – Improving Basic Provisions

• Title I, Part B – Even Start Family Literacy

• Title I, Part C – Education of Migratory Children

• Title II, Part A – Teacher and Principal Quality

• Title II, Part B – Mathematics and Science Partnership

• Title II, Part D – Enhancing Education Through Technology

• Title III, Part A – Language Instruction for Limited English Proficient and Immigrant Students (ESOL)

• Title IV, Part B – 21st Century Community Districting Centers

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Guidance

Who is responsible for planning and designing services for eligible private school students?

• Through the consultation process, the district must design a program that meets the needs of the private school and its students.

• The district is responsible for planning, designing and implementing the Title I program and SHALL NOT delegate that responsibility to the private school.

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Roles and Responsibilities

District Officials will:• Provide educational services or other benefits

on an equitable basis, and in a timely manner to eligible children who are enrolled in private elementary and secondary schools.

• Ensure that teachers and families of participating private school children participate on a basis equitable to the participation of teachers and families of public school children receiving these services.

• Consult with appropriate officials of private schools during the design and development of the district’s program for eligible private school children.

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Roles and Responsibilities

Private School Officials:• Participate in consultation sessions.• Provide list of addresses and grade levels of low-

income families.• Provide list of names, addresses, and grade levels

of children who meet the multiple, educationally-related, objective criteria for participation eligibility.

• Ensure that poverty is not be used for identification or services. Poverty is used only to determine funding allocation.

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Roles and ResponsibilitiesPrivate School Officials:

• Suggest ideas, program designs, and modifications that meet the needs of their eligible children, their teachers, and their families.

• Provide a dedicated space for instruction, if appropriate.• Collaborate with the district officials to ensure Title I

funds are only used to purchase materials and equipment to meet the needs of participating private school students.

• Ensure non-Title I private school students do not use materials and equipment purchased with Title I funds. These guidelines are discussed and documented at a consultation meeting with private school officials.

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Equipment Use for Participating Private Schools

• Section 1120(d)(1) of the ESEA requires that the control of the Title I funds, and the ownership of the materials and equipment, purchased with Title I funds for private schools shall be in the LEA, and the LEA shall administer the funds, materials, equipment and property. This is an LEA responsibility rather than the responsibility of the private school.

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District Officials will:• complete the requisitions forms for ordering materials

and/or equipment. • have the materials and equipment delivered to the LEA. • sign for the delivery of the materials and/or equipment. • label the equipment as Title I to include the fiscal year of

purchase and property of the respective school district.• deliver the materials and/or equipment to the private

school. • store materials and equipment in a secure location when

not in use.

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District Officials will:• maintain an inventory of all materials, equipment, and

property purchased with Title I funds for use with eligible Title I students at private schools. The inventory shall contain the same requirements for any equipment purchased with Title I, Part A funds. – These requirements are: a description of the equipment,

serial number, funding source, acquisition date and unit costs, location, use of equipment, current condition, date of disposal or transfer if applicable, and date inventory was completed.

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• Inventory must be updated as equipment items are purged or new purchases are made.

• Equipment items purchased with federal funds are to be identified and physically marked as such.

• Adequate safeguards must be in place related to the loss, damage, or theft of the equipment. Any loss, damage, or theft should be investigated and fully documented.

• Adequate maintenance procedures should be implemented to keep the equipment in good condition.

• A physical inventory of equipment items must be taken and the results reconciled with the inventory records at least once every two years.

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The GaDOE shall require:

All LEAs serving private school children to implement adequate procedures and internal controls to account for the location, custody, and security of materials, equipment, and property purchased with Title I funds for private school use. These procedures must include the proper labeling of materials and equipment purchased with Title I funds, policies and procedures to ensure that private school officials do not use these materials and equipment with ineligible children, and disposal procedures.

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Consultation

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Consultation

What is Consultation?

• It is planning discussions between public and private school officials.

• It provides a genuine opportunity for all parties to express their views and to have those views considered.

• Successful consultation establishes positive and productive working relationships.

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Consultation

Timely and Meaningful ConsultationTo ensure timely and meaningful consultation, the district must consult with private school officials prior to the district making any decision that affects the opportunities of any private school children to participate in programs.

Requirements in ESEA Section 1120(b) and 200.63 regulations

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Consultation

Regulatory Requirements for Consultation

• How the district will identify the needs of eligible private school children

• What services the district will offer to eligible private school children

• How, where and by whom the district will provide services to eligible private school children?

• How the district will assess academically the services provided and how the district will use the results of that assessment to improve services

[Sec.1120(b)(1) ESEA]

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Consultation


• The size and scope of the equitable services that the district will provide to eligible private school children and the proportion of its Title I funds that the district will allocate and reserve

• The method, or sources of data, the district will use to determine private school children from low-income families residing in participating public school attendance areas

• How and when the district will make decisions about the delivery of services

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Consultation


• How the district will involve families in the Title I program

• What professional development activities the district will offer to the private school teachers of Title I participants

NOTE:

If the district disagrees with the views of the private school official on the provision of services through a contract, district officials must provide in writing to the private school officials an analysis of the reasons why the district has chosen not to use a contractor.

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Consultation

Consultation Steps:

• In the fall, the district contacts private school officials with children who reside in the district boundaries regardless of private school location and have a written returned receipt verifying that contact was made.

• District provides the Intent to Participate Form to the private school who must complete and return it if they are interested in participation in the following school year.

• District convenes a meeting to discuss needs and service options. – Phone conversations and letters are not adequate.

• District must obtain a written affirmation from private school officials stating that timely and meaningful consultation occurred.

• District must keep documentation on file for review during cross functional monitoring.

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Documenting Consultation

Retain documentation that shows the District:• Informed private school officials of available federal

programs• Engaged in timely and meaningful consultation• Identified private schools’ needs• Allocated sufficient funds for private schools• Provided equitable services and benefits• Evaluated programs and services for effectiveness• Adequately addressed problems and complaints

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ConsultationSample Documentation

• Initial consultation• Agendas• Sign-in sheets• Supporting documentation (most current DE 1111 Forms,

letters mailed with return receipts, responses from private schools)

• On-going meaningful and timely consultations• Agendas• Sign-in sheets• Minutes

• Complaints and/or problems documents • Consultation affirmation form, signed• Equitable services affirmation form, signed

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Consultation

Disagreements and Complaints

• Consultation does not guarantee that private school officials will agree with the district’s decisions regarding Title I services.

• Private school officials may not be satisfied that their views were adequately considered during the process of initial consultation.

• District must develop procedures that will address any private school complaints.

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Consultation

Disagreements and Complaints

• It is the district’s responsibility to inform private school officials of their right to complain and the procedure to follow in filing a complaint.

• If private schools believe that the district did not engage in a timely and meaningful consultation process or did not consider their views, a complaint may be filed.

• The complaint goes to the state education agency (SEA) and the district must forward any relevant documentation about the dispute to the SEA.

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EXAMPLE OF A TIMELINE FOR DISTRICT CONSULTATION WITH

PRIVATE SCHOOL OFFICIALS(21 month cycle)

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Timeline for Consultation

October (month 1)• Start planning for the next year’s consultation cycle

– Obtain complete list of all private schools with students who are residents of the LEA

• Most current DE1111 forms submitted to district by private schools

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October (month 1) continued

• Start planning for the next year’s consultation cycle

– The LEA must send an letter to all private schools with students who are residents of the LEA inviting them to participate in the Title I program

• Invitations must be postmarked three weeks prior to consultation meeting and must include the date, time, and location of the meeting

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November/December (month 2/3)• Meet with private school officials to review timeline

and consultation process

• Establish a consultation calendar and procedures for collecting poverty data (i.e., data on low-income families)

B-4. How does a district collect poverty data on private school children?

1. Using the same measure of poverty. If available, an LEA should use the same measure of poverty used to count public school children, e.g., free and reduced price meals data.

Private School Non-regulatory Guidance, October 17, 2003

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November/December (month 2/3) continued

• Procedures for Collection of Poverty Data• Collected by:

– Principal of private schools, or– Central office official representing a group of private schools

• Collection of Poverty Data– Conduct a survey of private school parents, asking

for income data, addresses, grade levels of children, etc.– Utilize alternative poverty data, i.e. scholarships, Temporary

Aid to Needy Families (TANF), Medicaid, etc.– Or, decide, through consultation, to use proportionality

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The following individual consultation meetings will result in the development of an LEA written plan to serve eligible students, their teachers and their parents in each participating private schools.

Each individual participating private school plan must include all the components of a targeted assistance program.

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January/February (month 4/5)• Review poverty data collected• Review amount of funds available for services• Discuss pooling option• Determine the multiple, educationally-related,

objective criteria to be used to select eligible students (educationally needy students who reside in Title I attendance areas) in consultation with private school officials

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January/February (month 4/5) continued

• Review of options for service providers • Additional teachers• Tutors• Summer school• 3rd party vendors. If chosen, begin the district’s procurement

process

• Verify or decide on dates for future meetings-develop a calendar

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March/April (month 6/7)• Obtain from private school officials lists

of names, addresses, and grades of private school students who meet the multiple, educationally-related, objective criteria to select eligible students for Title I service

• Rank the students by greatest need for service by subject area

• From these lists, select for Title I services for those students most at-risk of failing, as decided in consultation

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March/April (month 6/7) continued

• Discuss how the Title I program will be evaluated– What standards and assessment will be used (pre and post

assessments)– What goals, assessments and criteria will be used to

measure the effectiveness of :– Instructional Programs– Parental Involvement– Professional Learning

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May/June (months 8/9)• Finalize the designs of the Title I programs;

ensure materials have been ordered

• Ensure LEA personnel who are providing Title I services are in place and service start date is firm

• Finalize professional development programs and activities for private school teachers

– Establish a calendar for next year’s professional learning activities

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May/June (months 8/9) continued

• Finalize parental involvement programs and activities for parents of participants

– Establish a calendar for next year’s parental involvement activities

• Provide on-going consultation affirmation form for signatures

• Provide equitable services affirmation formfor signatures

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July (month 10)• Ensure private school materials have arrived,

added to the inventory and are delivered to the appropriate location

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August/September (months 11/12) • Inform private school officials of the readiness of Title

I program services for private school participants• Begin Title I services for students identified the

previous spring as participants and provide private school officials with student names, services to be provided, and name(s) of Title I teachers

• Obtain a list of newly enrolled students who meet eligibility criteria. Consult with private school officials on how new students might be accommodated in the program

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August/September (months 11/12) continued

• Initiate professional development and parental involvement activities based on previous spring’s consultation

• Review criteria to be used for evaluation of the effectiveness of the Title I program including the following areas: academic, parent involvement, and professional development

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August/September (months 11/12) continued

• Conduct academic pre-assessments

• Host Title I parent information meeting for participating parents

• Complete a Parent Compact (optional)

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• October (Month 1)– Begin the new initial consultation cycle for the next

fiscal year

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October/November/December/January/February/ March (months13/14/15/16/17/18)

• Meet with private school officials periodically to determine if program is operating smoothly and effectively

• Meet with Title I teacher(s) periodically to determine if program is operating smoothly and effectively

• Make on-going adjustments to ensure student needs are being met

• Monitor implementation of the parental involvement component of the program

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October/November/December/January/February/March (months13/14/15/16/17/18) continued

• Monitor implementation of the professional development component of the program

• Ensure conferences are occurring between the Title I teacher and the private school teacher(s) of participating students

• Ensure conferences are occurring between the Title I teacher and the parents of the participating students

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October/November/December/January/February/March (months13/14/15/16/17/18) continued

• Conduct Title I teacher observations periodically to verify effectiveness of teaching skills and instruction

• Conduct on-site visits for periodic physical inventories of equipment(at least once every two years)

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April/May (month 19/20) • Complete parent survey• Gather documentation to evaluate the effectiveness

of the Title I program based on the criteria established at the beginning of the school year in the areas of academic, parental involvement, and professional learning

• Evaluate the effectiveness of the Title I program• Based on the evaluation of the Title I program,

determine adjustments and program changes to improve the Title I program

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April/May (month 19/20) continued • Attach Private School documentation to the

Consolidated Application no later than June 301. Affirmation of Consultation signed by private school official

for each private school served

2. Affirmation of Equitable Services signed by private school official for each private school served

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April/May (month 19/20) continued 3. Evaluation of the Title I Private School Program

• The annual evaluation of the private school program should include goals written in measurable terms, summary evaluation of each goal, and an overall narrative summarizing the progress made and identifying adjustments or changes to the private school program that will be made for the upcoming year.

– Areas to be included in evaluationo Student academic achievemento Parental involvemento Professional Developmento Additional goals based on the Title I Program

design

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April/May (month 19/20) continued 3. Evaluation of the Title I Private School Program

• The district may create their own evaluation instrument (a sample format will be provided but the format is not required)

Sample Private School Evaluation optional format

http://www.gadoe.org/School-Improvement/Federal-Programs/Pages/Title-I-Worksheets.aspx

• In addition to the required areas of evaluation, the final evaluation must include

– the dates of the consultation meetings

– a dated final narrative that reviews the effectiveness of the program and identifies modifications for the upcoming school year with signatures of the Title I Director and the Private School Administrator

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April/May (month 19/20) continued Note: The FY13 Title I conference session and PowerPoint, Serving

and Assessing the Private School Program provides additional detailed information related to evaluation of the private school program.

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ALLOCATION OF TITLE I FUNDS

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Allocation of Title I Funds

There are two ways in which private schools participate in Title I programs.

Through …• Per Pupil Allocation of Title I Funds• Equitable Participation in Programs

Control of Title I funds and title to materials, equipment, and property purchased with such funds shall be in a public agency.

[ESEA, §1120 (d): Public Control of Funds]

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Determining Private School Allocations• Eligible Students are:

– Private school students from low-income families who reside in Title I participating public school attendance areas

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Per Pupil Allocation (PPA)

• Private school students from low-income families who reside in Title I participating public school attendance areas

• Multiply the number of private school poverty students by the participating public school per pupil allocation

• Funds are used for instructional activities

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Equitable Participation

• An equitable proportional amount is available to participating private schools for:

• Instruction• Professional Learning• Parental Involvement

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Equitable Participation• An equitable proportional amount goes to private school

if districtwide activities are set-aside in the following areas:

• Instruction• Summer School• After School

• Professional Learning• Academic Coaches• Districtwide professional learning activities• Highly Qualified Professional Learning

• Parental Involvement

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[34 CFR sec. 200.64 (a)(2)(i)(A)]


Equitable Service does not apply to the following set–asides:• Required Flexible Learning Programs set-asides• Additional Priority, Focus and Alert Schools set-

asides• NCLB Choice Transportation set-asides• Homeless set-aside• Neglected and Delinquent set-aside• Pre-School set-asides• Administrative set-asides

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Calculating Equitable Participation

• Determine the number of private school students from low-income families who reside in Title I participating public school attendance areas

• Multiply the percentage of eligible private school students by the district set-aside; and

• Determine the services to be provided based on the equitable dollar amount

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Use of Funds for Equitable Services • Instructional

– Services to Eligible Participating Students• Instructional Support – materials• District Paid Instructional Staff – tutors, small group instruction

• Parental Involvement– Services to Parents of Eligible Participating Students

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Use of Funds for Equitable Services• Professional Learning

– Training for private school teachers of eligible participating students

– Not for district paid teachers of eligible participating students

– Arranged by the district through consultation with private school officials

– Private schools cannot arrange for professional learning and then submit for reimbursement

– Reimbursement for substitutes is not an allowable expenditure

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Use of Funds for Equitable Services

• Reminder

– Private schools are not to be reimbursed for services and materials provided. The district is responsible for private school program implementation.

ENSURING EQUITABLE PARTICIPATION

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Ensuring Equitable Participation

• To ensure equitable participation, the district or other entity receiving federal financial assistance must: – Assess, address, and evaluate the needs

of private school students and teachers through consultation;

– Determine amount of funds per student

• Provide private school students and teachers with an opportunity to participate in activities equivalent to the opportunity provided to public school students and teachers; and

• Offer services that are secular, neutral and non-ideological.

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Ensuring Equitable Participation

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, and professional development and parental involvement activities;

• Provides private school children with an opportunity to excel and achieve equitable to the opportunity provided to public school children; and

• Provides promise of private school children reaching high levels of academic achievement.

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Samples

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Worksheets

Private School Per Pupil Allocation (PPA) Worksheet

- Embedded in Consolidated Application

Private School Equitable Participation Worksheet

- Attached to the Consolidated Application

Title I Program Specialist Title I Program Specialist Contact InformationContact Information

Area Name Office Telephone Email

1 Robyn Planchard (404) 463-3467 [email protected]

2 Randy Phillips (770) 334-8390 [email protected]

3 Anthony Threat (706) 615-0367 [email protected]

4 Evelyn Maddox (404) 656-2045 [email protected]

5 Judy Alger (229) 838-6037 [email protected]

6 Grace McElveen 912-334-0802 [email protected]

7 Jimmy Everson (229) 723-2664 [email protected]

8 Marijo Pitts-Sheffield (912) 269-1216 [email protected]

9 Kathy Pruett (706) 540-8959 [email protected]

10 Elaine Dawsey (478) 971-0114 [email protected]

11 Olufunke Osunkoyo (678) 704-3557 [email protected]

12 Bobby Trawick (229) 246-1976 [email protected]

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Presenters

Elaine DawseyGeorgia Department of Education

Title I Education Program Specialist [email protected]

(478)-971-0114

Marijo Pitts-SheffieldGeorgia Department of Education

Title I Education Program [email protected]

(912) 269-1216

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Documents

Private Schools 101: A Timeline for Planning, Serving, and Assessing a New Private School Program 2014 Annual GCEL Conference February 26-26, 2014 Savannah,