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ED 021 881 UD 000 838GUIDELINES: SPEICAL PROGRAMS FOR EDUCATIONALLY DEPRIVED CHILDRER ELEMENTARY AND SECONDARYEDUCATION ACT OF I965/TITLE I.
Office of Education (DfiEW), Washingion, ID.C. f3ureau of Fiementary and 'Secondary E:ducation.Repor t No- 0E- 35079Pub Date 65Note-.48p.Avadable from- Superintendent of Documents, U.S. Government Printing Office, Washington, D.C. 20402 ($35)MRS Price MF-$0.25 HC Not Available from EDRS.Descriptors- ANNUAL REPORTS *COMPENSATORY EDUCATION PROGRAMS DISADVANTAGED YOUTH, *FEDERAL
PROGRAMS FINANCIAL POLICY, *GUIDELINES, *PROGRAM ADMINISTRATION, PROGRAM BUDGETING, PROGRAMDESIGN, PROGRAM DEVELOPMENT, PROGRAM EVALUATION. RECORDS (FORMS)
Identifiers-Elementary and Secondary Education Act, Esea Title 1Published in 1965, thee guidelines outline the requirements for the fiscal and
general admin'stration of Title 1 projects, for project design and evaluation, and forreporting project activities. Exhibits of forms for reporting activities and administrativeprocedures at the state and local levels are included. (LB)
U.S. DEPARTMENT Of HEALTH, EDUCATION & WELFARE
OFFICE Of EDUCATION
0E-35079THIS DOCUMENT HAS BEEN REPRODUCED
EXACTLY AS RECEIVED fROM THEPERSON OR ORGANIZATION
ORIGINATING IT. POINTS Of VIEW OR OPINIONSSTATED DO NOT NECESSARY REPRESENT OFFICIAL OFFICE OF EDUCkTIONPOSITION OR POLICY.
Guidelines:Special Programs for
Educationally Deprived Children
ELEMENTARY AND SECONDARY EDUCATION ACT OF 1965 / TITLE I
I
Ci BUREAU OF ELEMENTARY AND SECONDARY EDUCATION / DIVISION OF PROGRAM ^PERATIONS
LNO (14,
4fci N0 U.S. DEPARTMENT OF HEALTH, EDUCATION, AND WELFARE
0 4Z John W. Gardner, Secretary
tk) OFFICE OF EDUCATION, Harold Hove II, Commissioner
DISCRIMINATION PROHIBITEDTitleVI of the Civil Rights Act of 1964 states:"No person in the United States shall, onthe ground of race, color, or national ori-gin, be excludeCfrom participation in, bedenied the benefits of, or be subject todiscrimination under any program or ac-tivity receiving Federal financial assist-ance." Therefore, the Elementary andSecondary Education Act of 1965, Title Iprogram, like every program or activityreceiving financial assistance from theDepartment of Health, Education, andWelfare, must be operated in compliancewith this law.
For sale by the Superintendent of Documents, U.S. Government Printing OfficeWashington, D.C., 20402 - Price 35 cents
I,
FOREWORDTitle I of the Elementary and Secondary
Education Act of 1965 authorizes Federal sup-port to local public educational agencies for,special educational programs for educationallydeprived children in attendance areas wherelow-income families are concentrated. Its aimis to help broaden and strengthen education forthe children of poverty, wherever they may befoundin public schools, in private schools, orout of school.
On September 23, 1965, President Johnsonmade the following remarks :
I have just signed into law a bill providing. . . supplemental appropriations for . . .
more than one billion dollars . . . for pro-grams that are authorized by the Elemen-tary and Secondary Education Act of 1965,which we signed a short time ago.
T oday, we reach out to 51/2million childrenheld behind their more fortunate school-mates by the dragging anchor of poverty.
- Act now. Get your plans made. 0 pen yourschools to the promise of these new pro-gram. I hope that not a single day willbe lost. F or in education, the time we wastetoday can mean a life wasted tomorrow.
Congress has made available for fiscal year
1966 the full 'amounts authorized as determinedby the current formulas for Title I for grantsto local educational agencies, to State agenciesproviding free public education for handi-capped child: en, and to State educational agen-cies for the performance of duties under thistitle. Authorizations for fiscal year 1967 willbe determined by further action of the Congressconcerning the formulas for determining maxi-mum grants.
The President, as required by Title I, hasappointed a National Advisory Council on theEducation of Disadvantaged Children. TheCouncil must make its first report to the Presi-dent by March 31, 1966, on its evaluations andrecommendations concerning the Federal pro-grams for disadvantaged children includingprograms under Title I.
State and local educational agencies are urgedto give prompt attention to the initiation ofquality programs for this first year, includingthe summer months of 1966.
ARTHUR L. HARRISAssociate COMMi8sioner
Bureau of Elementary and Secondary Education
JOHN F. HUGHESDirector
Division of Program Operations
FnRywnRn
CONTENTS
SECTION I. ADMINISTRATION AND FINANCEPage
PART A. ADMINISTRATION AND REPORTING 1
General Information 1
Administrative Responsibilities 1
U.S. Commissioner of Education 1
State Educational Agencies 1
Local Educational Agencies 2
Emphasis on Evaluation 2
Related Statutes 2
Civil Rights Act of 1964 2
Economic Opper .dpity Act of 1964 2
Financial Assistance for Local Educational Agencies in Areas Affected byFederal Activity (Public Law 81-874) 2
Others 3
Eligibility and Maximum Grants 3
Determination of Eligibility of Local Educational Agencies 3
School District Basis 3
County Basis 3
Individual School District Basis Within an Ineligible County 3
Determination of Maximum Basic Grants to Local Educational *Agencies__ _ _ 4Determination by the U.S. Commissioner of Education 4Formula Used in Computation, 1965-66 4
Determination by State Educational Agencies 4
Limitation on Amount of Maximum Basic Grants, 1965-66 4Grants for State Agencies Operating or Supporting Programs for Handicapped
Children 4
Reporting Requirements 5
Project Reporting 5
Fiscal Reports 5
Evaluative Reports 5
PART B. FISCAL ADMINISTRATION
Accounting Basis To Be UsedAccounting at State Level
For State A.dministrationFor Project Approvals
Accounting at Local Level
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Page5
5
6
6
6
6Liquidation of Obligations at State and Local Levels _ 6
Use of Letter of Credit System 7Estimating and Reporting Requirements_ 7
Local Estimates of Need for Federal Funds 7Project Completion Reports: Preliminary and Final 7State Quarterly Estimates of Obligations 8Annual Financial Report 8
Local Records of Project Transactions 8Records of Accountability and Documentation of Costs 9
Documentation of Receipt of Material and Equipment Purchased 9Keeping an Equipment Inventory 9
Audits 10Local Agency Audits 10Specific Audit Considerations 10Responsibility of State Agency To Provide an Adequate Audit Program 11Federal Audits 11Availability of Audits to Departmental Auditors and the U.S. Commissioner
of Education 11Audit Exceptions I tOffice of Education Services Available in the Areas of Fiscal Control Account-
ing and Audits 11Some Limitations on the Use of Project Funds 12
Transfer or Reallocation of Funds_ 12Reallocation of Funds Between Projects_ 12Deviation in Utilization of Project Funds 12Exceeding the Maximum Basic Grant 12Adjustments Due to Overpayments 12
Exhibits13
SECTION L. PROJECT DESIGN AND EVALUATIONPage
PART A. PROJECT DESIGN 21
Statutory Requirements Under Section 205(a) of Title I 21Overall Design
Educationally Deprived Children 21
Special Educational Needs 22School Attendance Areas Having High Concentrations of Children
From Low-Income Families 23Size, Scope, and Quality 23
Provision for Participation by Educationally Deprived Children Enrolledin Private Schools 24
Public Control of Funds and Property 25Construction of Facilities 26Procedures for Evaluation 26Reports and Records 27Cooperation With Community Action Agencies 27Dissemination of Information 28
Other Factors in Project Planning 29Program and Project Design 29Number of Projects To Be Planned 30Age and Grade of Children To Be Served 30Types of Projects, Activities, and Services Which Deserve Special Men-
tion 30Preschool Projects 30Dropout Projects 31
Projects Involving Children Enrolled in Schools Operated by theBureau of Indian Affairs 31
Projects for Handicapped Children 31
Projects for Migrant Children 31
Projects for the College-Bound 31Innovative Projects 32Pilot Projects 32Cooperative Projects 32Extension of Ongoing Projects 32
Projects Combining the Resources of Title I With Those of OtherTitles of the Act 32
Projects Using Parents, Volunteers, and Subprofessional Aides 33Projects Involving an Increase hi Teacher Pay 33Projects Involving the Construction of Facilities 33
PagePART B. EVALUATION 34
Introduction 34
Why Evaluate? 34
Funding and Annual Reporting 35
The Evaluation Process 35Steps in the Process 35
An Example 35Importance of Measurement of Change 36
Standards_ 36Norms 36Units 36
Evaluation Designs 36Change Compared With an Absolute Standard 37
Change Compared With a Designated Norm 37
Change Compared With a Control Group 37
Change Compared With Projected Change of the Group 37Change Reported Without Comparative Data 38Design Involving One Measurement 38Supplementary Evaluative Techniques 38
Case Studies 38Anecdotal Records 39Related Devices 39
Comprehensive Evaluation 39Planning for Evaluation 39
Preparation of the Proposal 39Use of Standardized Tests 39Nontest Sources of Evaluative Data 40Division of Groups Possible 40Use of Sarning 40
Final Considerations 40
SECTION I
ADMINISTRATION AND FINANCE
PART A. ADMINISTRATION AND REPORTING
GENERAL INFORMATIONTitle I of the Elementary and Secondary
Education Act of 1965 is the major thrust ofthe national effort to "bring better educationto millions of disadvantaged youth who need itmost." 1 The Congress has made available morethan $1 billion for 1965-66, the first year of thistitle.
Administrative ResponsibilitiesThe act places responsibilities for achninister-
ing programs supported by Federal funds underTitle I on the U.S. Commissioner of Education,State educational agencies, and local educationalagencies. It is incumbent upon all concernedto use such funds in accordance with the spiritand intent of the act and regulations.
U.S. C ommissioner of Education
The U.S. Commissioner of Education is re-sponsible not only for the overall conduct of theprogram at the national level but also for thedetermination of the maximum amounts to beallocated to eligible districts or counties andto State agencies that operate or support schoolsfor handicapped children. Federal control ofany aspect of education at any level, however,is prohibited.
In the performance of its responsibilities, theOffice of Education-
1 Message from the President of the United States trans-mitting the education program, Jan. 12, 1965.
797-086 0-66-2
Approves applications submitted byState educational agencies for participa-tion in the program.Makes funds available for the program.Develops regulations, guidelines, andother materials relating to the adminis-tration of the program.Provides consultative services to Stateeducational agencies in carrying out theirresponsibilities.Reviews and assesses programs andprogress made under Title I throughoutthe Nation.Compiles from report submitted by theState agencies various fiscal and programreports to the Congress and to the public.
State Educational AgenciesIn its formal application to the Commissioner
of Education to participate in the Title I pro-gram, a State educational agency includes assur-ances that it will administer the program andsubmit reports in accordance with the provi-sions of the law and the regulations. Followingthe approval of its application, it furnishes tothe Office of Education a description of its plansfor staffing, organizing, and administering theprogram (see p. 13, exhibit No. 1, 0E-4315) .In the administration of the program, its majorresponsibilities are to
Suballocate basic grant funds, where nec-essary, to eligible local educational agen-cies.
1
Assist local educational agencies in thedevelopment of projects.Approve proposed projects in accordancewith the provisions of section 205( a) ofTitle I and make payment of funds tolocal educational agencies.Maintain fiscc,,I records of all grant funds.Prepare and submit fiscal and evaluativereports to the Office of Education.
Local Educational AgenciesThe local educational agency is responsible for
developing and implementing approved projectsto fulfill the intent of Title I. It is thereforeresponsible for identifying the educationallydeprived children in areas where there are highconcentrations of children from low-incomefamilies, for determining their special needs,for designing projects to carry out the purposesof the legislation with regard to such children,and for submitting applications to the appro-priate State educational agency for grants tofund proposed projects. The local educationalagency is also responsible for
Using grant ands in accordance withapproved project budgets and for thepurposes for which the projects have beenapproved.Making available for inspection by thepublic the terms and provisions of eachapproved project.Maintaining adequate fiscal records on allproject funds and reporting to the Stateeducational agency on the use of suchfunds.Maintaining fiscal effort with respect tototal current expenditures for educationand also with respect to such expendi-tures in the project areas.
Emphasis on Evaluation
In view of the pioneering nature of this na-tional program and of the amount of newground that will be broken under it, Title I em-phasizes and contains special provisions for theevaluation of the extent to which projects andprograms conducted under it are effective inimproving the educational attainment of educa-tionally deprived children and for Periodic re-
ports on the results of this evaluation. It alsocreates a National Advisory Council on theEducation of Disadvantaged Children whichwill review the effectiveness of the Title I pro-gram in improving the educational attainmentof educationally deprived children and makerecommendations for the improvement of itsprovisions, administration, and operation. TheCouncil will make its first annual report to thePresident not later than March 31, 1966; thePresident will transmit this report, with hiscomments and recommendations, to the Con-gress.
Related Statutes
Civil Rights Act of 1964Title VI of the Civil Rights Act of 1964
states : "No person in the United States shall,on the grounds of race, color, or national origin,be excluded from participation in, be deniedthe benefits of, or be subjected to discriminationunder any program or activity receiving Fed-eral financial assistance." Programs underTitle I of the Elementary and Secondary Edu-cation Act of 1965 must be operated in com-pliance with this law, and. State and local edu-cational agencies must provide satisfactoryassurance of compliance.
Economic Opportunity Act of 1964In any area where a community action pro-
gram under Title II of the Economic Oppor-tunity Act of 1961 is in effect, any project underTitle I of the Elementary and Secondary Edu-cation Act must be developed in cooperationwith the public or nonprofit agency responsibbfor the conimunity action program:
Finameial Assistance for Local EducationalAgencies in Areas Affected by Federal Ac-tivity (Title I of Public Law 81-874)
Title I of the Elementary and SecondaryEducation Act of 1965 amends Public Law 81-874 by adding Title II "Financial Assistanceto Local Educational Agencies for the Educa-tion of Children of Low-Income Families."Title III "General" of Public Law 81-874, asamended, contains various definitions which,with minor exceptions, are applicable to boththe program for federally affected areas and
the program for children of low-incomefamilies.
OthersA number of other statutes, including the
Manpower Development and Training Act, theVocational Education Act of 1963 (programsfor potential school dropouts and unemployedyouth), and the National Defense EducationAct (institutes for training teachers of the dis-advantaged), as well as other titles of the Ele-mentary and Secondary Education Act itselfprovide educational programs designed to bene-fit the educationally deprived. Public Law 89313 amended Title I to provide for grants toState agencies operating or supporting schoolsfor handicapped children.
ELIGIBILITY AND MAXIMUMGRANTS
Determination of Eligibility of LocalEducational Agencies
A local educational agency is defined as anagency which has administrative control anddirection of free public education up to andincluding, but not beyond, grade 12 in a county,township, independent, or other school district.To be eligible to participate in the Title I pro-gram ui 1965-66, such an agency must servea school district in which the concentration ofchildren aged 5 through 17 from families withan annual income of less than $2,000, as shownin the 1960 census, meets the minimum statutoryrequirements. The bases on which the Com-missioner of Education determines whether anagency meets these requirements are outlinedbelow.
School District BasisThe Commissioner determines the eligibility
of local educational agencies on a school dis-trict basis, if satisfactory census data are avail-able by school district. The 1960 census data,which are the most recent available, are inmost cases not satisfactory for making such de-terminations. Where, however, the 1960 censusdata are satisfactory for this purpose, thesedata are used, and the eligibility of school dis-
'
tricts is determined in accordance with thefollowing criteria :
All school districts in which the totalnumber of children aged 5 through 17from families with an annual income ofless than $2,000 represents at least 3 per-cent of all children aged 5 through 17 inthe Aistrict and tAtals nnt 1"Q fhnn 10are eligible to receive grants underTitle I.All districts containing 100 or more chil-dren aged 5 through 17 from familieswith an annual income of less than $2,000are automatically eligible, regardless ofthe percentage of such children.
County BasisWhen satisfactory census data are not avail-
able on a school district basisas was the casefor most districts in fiscal year 1966the Com-missioner determines eligibility on a countybasis. If a county, according to the 1960 census,contained 100 or more children aged 5 through17 from families with an annual income of lessthan $2,000, the county is eligible and all localeducational agencies within that county are alsoeligible. It should be noted, however, that ifthe county is coterminous with the district ofa local educational agency, that is, if the bound-aries of the county conform substantially to theboundaries of the school district, the eligibilityof that agency is determined in accordance withthe criteria given above for determining eligi-bility on a school district basis.
Individual School District Basis Within anIneligible Cownty
Even when a county is ineligible on a countybasis, it is still possible that an individualschool district within that county might bedetermined to be eligible to receive grants. Toobtain such a determination, the State educa-tional agency should provide the Commissionerwith sufficient information concerning theboundaries of the school districts within thecounty to enable him to determine from avail-able census data that, in the district in question,the number of children aged 5 through 17 fromfamilies with an annual income of less than
3
$2,000 was at least 10 and was equal to at least3 percent of the total number of children inthis age bracket in the district.
Determination of ilflaylmum Basic Grants toLocal Educational Agencies
Title I provides that the U.S. Commissionerof Education shall make payments to theStates, in amounts to be determined in accord-ance with the act, for grants to local education-al agencies. These grants are to be of twokinds : Basic grants for each of the 3 years be-ginning July 1, 1965, and incentive grants foreach of the 2 years beginning July 1, 1966.These guidelines deal only with basic grants.
Determination bi the U.S. Commissioner ofEchwation
The computations :II the amounts of maxi-mum basic grants follow a pattern similar tothat just outlined regarding eligibility. Thelaw provides that the Commissioner determinemaximum basic grants for each eligible districtfor which the requisite census data are avail-able. When they are notas was the case inmost instances for the year ending June 30,1966the Commissioner determines the aggre-gate maximum basic grant for each eligiblecounty.
Fromukt Used in, Computation,1965-66In all cases the formula used in the computa-
tion of maximum basic grants for the year end-ing June 30, 1966, was the same. It was basedon an impartial count of children aged 5through 17 of low-income families without re-gard to whether these children were in publicschool, in private school, or out of school. Itinvolved the following three factors :
A. The number of children aged 5 through17 from families with an annual incomeof less than $2,000.
B. The number of children aged 5 through17 from families with incomes exceeding$2,000 in the form of aid to familieswith dependent children under Title IVof the Social Security Act.
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C. One-half the average per pupil expend-iture in the State for the second pre-ceding year.
Substituting the symbols used above for thefactors themselves, the formula applied was :
(A+ B) X C=the number of dollars of themeximum basic grant.
Determination by State Ethwational AgenciesWhere the boundaries of an eligible county
do not conform substantially with the bounda-ries of a single school district, the State educa-tional agency determines suballocations to indi-vidual local educational agencies within thatcounty in accordance with criteria set forth inthe regulations. The regulations require thatthe State educational agency inform the Com-missioner of the bases used in determiningthese suballocations and of the maximumamount allocated to each local educationalagency.
Limitation on Amount of Basic Grants,1965-86
During fiscal year 1966 (but not during sub-sequent years) the amount of a maximum basicgrant may not exceed 30 percent of the amountbudgeted by the local educational agency forcurrent expenditures. Current expendituresare expenditures from current revenues Withthe exception of eipenditures for the acquisi-tion of land, erection of facilities, interest, anddebt services, and expenditures from Federalfunds received un ler this title or other titlesof the Elementary and Secondary EducationAct of 1965.
Grants to State Agencies Operating orSupporting Programs for HandicappedChildren
Separate allocations of maximum basicgrants are made to State agencies directly re-sponsible for providing free public education,not beyond grade 12, for handicapped childrenon a nondistrict basis. Their free public educa-tion may be provided in State-operated orState-supported schools. A State agency'smaximum grant under this portion of the pro-gram is based on the average daily attendances
of all of the handicapped children for whomit provides free public education, multiplied byone-half the average per pupil expenditure inthe State for the second preceding year. Theallocations for 1965-66 tO State agencies do notin any way affect allocations to local education-al agencies.
REPORTING REQUIREMENTS
In order to insure the proper and effectiveuse of the funds granted for the conduct of pro-grams under Title I and make it possible toappraise the effectiveness of the programs them-selves, fiscal and evaluative reports must bemade by the local educational agencies, the Stateeducational agencies, and the Office of Educa-tion. Basic to this three-tiered reporting systemare the reports on local projects required of theState educational agencies; the reports requiredof the State educational agencies will be basedlargely on the reports these agencies require oftheir participating local educational agencies.
Project Reporting
Each State educational agency has been re-quested to send to the Office of Education onecopy of each approved project application (pts.I and II). The narrative portions of these ap-plications, however, are transmitted to the
PART B. FISCAL
This part is intended to spell out for theparticipating State and local agencies the pro-cedures that are to be used in accounting forFederal funds ; the records that are to be main-tained for fiscal purposes; and the fiscal auditsthat are to be made.
ACCOUNTING BASIS TO BE USED
Section 116.46 (b) of the regulations states :
For purposes of the regulations in this parta use of funds under Title . . . [I] ofthe Act by a State 01' local educational
Office on a sample basis only. This flow of cur-rent information on State approvals of projectsenables the Office to compile up-to-date financialand statistical information for use in reportingto the Congress and up-to-date program infor-mation for use in reporting to the Nation.
Fiscal Reports
Detailed information about the fiscal reportsrequired of the States and about the reports theStates will undoubtedly seek from their par-ticipating local educational agencies is given inPart B of this section.
Evaluative Reports
Annual Project Evabuation ReportAn annual project evaluation report on each
of its Title I projects must be submitted by thelocal educational agency to the State educa-tional agency at the end of the fiscal year. Thefirst such reports will be due in the fall of 1966.The exact format and submission date will bedetermined by the State agency.
Annual Statewide Program Evaluation .RepOrtThis report must be submitted by the State
educational agency to the Office of Educationeach November 1. The first annual statewideprogram evaluation report is due November 1,1966.
ADMINISTRATION
agency will be determined on the basis ofdocumentary evidence of a binding com-mitment for the acquisition of goods orproperty, for construction, or for the per-formance of work, except that use for serv-ices of persons and for travel shall be de-termined On the basis of the time suchservices were rendered or such travel wasperformed.
This is interpreted to mean that all State andlocal educational agencies will use the obliga-tion basis of accounting in maintaining fiscalrecords and reporting.
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Accounting at State Level
For State AdministrationObligations of Federal funds for State ad-
ministration will occur when the State agencyissues purchase orders, executes contracts, or in-curs obligations for services. Such obligationsmay not be incurred earlier than the effectivedate of the U.S. Office of Education approval ofthe State agency's application to participate inthe program and not later than June 30 of thefiscal year. These obligations will be recordedas charges against the appropriation availableat the time the obligations are incurred, and ad-justed to the amounts of the final net paymentsby the State. All such adjustments will be re-corded and reported as adjustments of the ex-penditures for the fiscal year in which the obli-(rbations were incurred.
Claims by the State educational agency forprogram administration must be comprised onlyof costs which are directly related to carryingout the program. Overhead costs-unrelated tothe program are not eligible costs under thistitle. Thus, any costs of State administrationmust be adequately documented so as to identifythem as direct costs of administrative operationsand technical assistance under the Title Iprogram.
For Project ApprovalsObligation of Federal funds will occur when
the State agency gives written approval of thelocal project and assigns a project number. Allprojects to be financed with funds appropriatedfor a particular fiscal year must be approved bythe State agency by June 30 of that. fiscal year.
As of June 30 of a fiscal year the State agencyshall compute the total 'amount approved forprojects during the fiscal year in order to ascer-tain the amount of funds available for Stateadministration. Such amount shall not exceed1 percent of the total of such approved projectsor $75,000 ($25,000 in the case of the outlyingparts) , whichever is greater.
Accounting at Local Level
All local agencies including those using anaccounting system other than an obligation onewill need to maintain an accounting of Title I
6
funds on an obligation basis. Section 116.46(d)of the regulations states :
Federal funds distributed to local educa-tional agencies shall not be available for usewith respect to obligations incurred by suchagencies for a I, Aject prior to the effectivedate of the approval by the Commissionerof the State application for participationor prior to the date on which the applica-tion of the local educational agency for agrant with respect to that project was re-ceived by the State educational agency insubstantially approvable form.
Obligating documents may be issued duringthe months of July and August of the next fiscalyear provided they are permitted under theprojects approved, are for services and activitiesto be carried out prior to August 31, and arecharged to the fiscal year in which the projectwas approved. Thus, local obligating docu-ments for items within an approved projectbudget may be issued during the 2 months afterthe end of the fiscal year in which the projectwas approved. This will permit financing ofsummer projects with grant funds available forthe year in which the project is approved. Obli-gating documents for construction may be is-sued later than August 31 of the following fiscalyear, but must be executed within a reasonabletime considering the nature of the project.
Liquidation of Obligations at State andLocal Levels
If the final payment for a previously re-ported obligation for either State administra-tion or a local project is not completed before theend of the fiscal year following the fiscal yearin which the obligation was incurred, the un-liquidated (unpaid) portion of the .obligationmust be canceled. There may be no Federalfinancial participation in such costs extendingbeyond this period, except in the case of con-struction costs where the nature of the consthic-tion will determine the length of the paymentperiod.
Obligations incurred at the local level will beadjusted to the amounts of the actual net pay-ments by the local agency when the payments are
made. All such adjustments will be recordedand reported as adjustments of expendituresfrom the allotment available at the time theproject was approved.
USE OF LETTER OF CREDITSYSTEM
The following indicates the use that will bemade under Title I of the "Letter of Credit Sys-tem for Payment of Grants to States" whichhas been sent to State Treasurers and ChiefState School Officers by the U.S. Office of Edu-cation.
Upon the approval of a State educationalagency's application to participate in the TitleI program, the agency should proceed to usethe Letter of Credit System to withdraw fundsfor the operation of its programs. With-drawals of Federal cash by the State agencywill be limited to the amount needed for current.disbursement.
Upon receipt of notification of approval of aState application for participation in the TitleI program, the State may include its cash re-quirements for local grants and State adminis-tration for the program in determining theamount of funds to be withdrawn in accordancewith the Letter of Credit procedures. Thesefunds will be deposited with the State Treas-urer, or other authorized officers. Upon' theapproval of a local agency application, theState educational agency will direct its paymentofficer to advance to the local educational agencyfunds in the amount needed for anticipated ex-penditures to be incurred during the remainderof the current quarter. Thereafter, eithermonthly or quarterly advances may be made onthe basis of the "Quarterly Disbursement andEstimated Requirement of Federal Funds" re-ports (see exhibit No. 5) submitted by the localeducational agency, or on a reimbursementbasis.
ESTIMATING AND REPORTINGREQUIREMENTS
Outlined below are the procedures to be fol-lowed by local and State agencies for reportingpurposes.
Local Estimates of Need for Federal FundsThe local agency's application for a grant to
the State agency (form 0E--4305) should be ac-companied by an estimate of the total amountof funds needed for the project for the re-mainder of the current quarter.
Upon approval Af an application and receiptof the initial pay ment the local agency will sub-mit to the State agency a quarterly estimateshowing estimated requirements for Federalfunds by month. For each quarter thereafterthe local agency will submit by the 10th of thefirst month of each quarter its "Quarterly Dis-bursement and Estimated Requirement of Fed-eral Funds" for each project.
Project Completion Reports: Preliminaryand Final
Following the completion of a project by alocal educational agency for each fiscal year, thelocal agency shall report to the State agency onthe total costs of that project. Thus, the Stateagency should design a financial report formwhich the local agencies will use in renderingtheir reports. A preliminary report should besubmitted to the State agency soon after thetermination of the project, which will be eitherafter June 30 or August 31 depending upon theperiod for which the project was approved. Afinal fiscal report for each project as of June 30of the following fiscal year should be submittedshortly after that date.
Such a report should include the followingitems of financial information :
The amount approved for the project.The total of all Federal funds receivedfor the project during the fiscal year, in-cluding the amount for summer programsif such were approved under the project.The total amount of all obligations in-curred under the project.The total of all funds disbursed underthe project, broken down by expenditureaccounts in the project budget showingthe Federal funds disbursed underTitle I.Outstanding unliquidated obligations.Title I Federal funds on hand.
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Federal funds received but not needed--cash balance.
State Quarterly Estimates of ObligationsFor each quarterly period commencing with
the date of withdrawal of funds for the pro-gram under the Letter of Credit System theState agency will report to the U.S. Office ofEducation on form 0E-4316, "Quarterly Esti-mate of Obligations" (exhibit No. 2) :
Total dollar amount estimated to be ap-proved for local projects during eachmonth of the following quarter.Net amount of obligations to be incurredfor State administration during eachmonth of the following quarter.Total dollar amount actually approvedfor local projects from the beginningof the fiscal year to the end of the pre-vious mport period.Net amount of obligations incurred forState administration from the beginningof the fiscal year to the end of the pre-vious period.
The State agency's "Quarterly Estimate ofObligations" will also serve as its report of obli-gations incurred by local educational agenciesand by the State for administration. Such areport serves to advise the Office of Educationof the actual rate of expenditures as comparedto the estimated rate of expenditures. This in-formation is necessary to maintain fiscal controlof Federal funds and to support requests foradditional funds from the U.S. Congress if re-quired in the light of the current rate of obliga-tions.
Annual Financial Report
By November 30, following the close of eathfiscal year, the State agency on "Annual Finan-cial Report" (see 0E-4318, exhibit No. 3) willreport the total obligations incurred during thefiscal year and any adjustments due to liquida-tion of obligations for prior years for bothState administration and for approved localprojects. Such reports -will serve as a basic fi-nancial document at the time of Federal auditand program reviews and as a basis of reportingt o Congress.
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LOCAL RECORDS OF PROJECTTRANSACTIONS
The State educational agency shall prescribesuch fiscal control and fund accounting proce-dures as may be necessary to assure proper dis-bursement of funds paid to local educationalagencies.
It is necessary that the local agency maintainsome type of record of transactions for eachapproved project. Exhibit No. 4, "Record ofProject Transactions," is a sample of a methodwhich could be used in establishing and main-taining such records. If such a record isadopted, it can be maintained manually or ona typewriter, with a carbon cropy to be sent tothe State agency at the end of each calendarquarter; or a single original record can bemaintained in such form that a photo-copy canbe made and sent to the State agency at the endof each calendar quarter.
Important items to remember are :
Entries must be made'daily as the trans-actions occur.A separate record should be maintainedfor each numbered project.
The "Record of Project Transactions" is de-signed to accomplish several purposes. This re-port form will serve to fulfill the local agency'scash reporting requirements. This form, show-ing all of the basic fmancial transactions in-volved, also
May help those not yet familiar with ob-ligation accounting to' understand thenecessary steps of obligating, liquidating,and disbursing.Can serve as a local project journal, ifthe local agency does not already have asystem.Will serve as a report to the State agencyof all transactions as they actually oc-curred and as a basis for preparing theusual financial report upon completion ofeach project.Will be of assistance at the time of anaudit at the State level.
Use of this form will permit the local andState agency to know exactly what purchases
were made, when the purchase orders were is-sued, when they were paid, and the exact amountof the final payment, without requiring the re-ceipt at the State level of actual copies of pur-chase orders and invoices. It provides soundfiscal control in that it eliminates any general-izations or summaries which cannot be sup-ported by specific detail upon request of theState agency or any auditor who may have juris-diction. Each entry can be easily related to thebasic document which should be readily avail-able for review at the local level.
For those local agencies which already havean accounting system on an obligation basis,the form may be used as a subsidiary projectjournal to separate the transactions of eachproject from the regular local agency activitiesand from other projects. This separation willbenefit the local agency in its current manage-ment operations. It will also provide a recordthat will be easily accessible to project auditorsand one that will be separated from regularlocal agency transactions.
RECORDS OF ACCOUNTABILITYAND DOCUMENTATION OFCOSTS
The law requires all State and local educa-tional agencies receiving grants under this titleto keep records relating to claims for Federalfunds. There can be no Federal financialparticipation in overhead costs which are ar-rived at on a straight percentage basis. Suchoverhead costs may be allowed as can be docu-mented and substantiated as directly related tothe project. Supporting documentation forentries in the accounting, records is very im-portant at the State and local agency level. Inthis program the prorating of employees' timemay be a special problem. The proration oftheir salaries to more than one program or proj-ect is a "must" for those employees who are notassigned full time to one program or approvedproject. Such proration must be based uponthe amount of time an individual actually de-votes to the approved program and thereforemust be documented by a before-the-fact state-ment of the time estimated that each employeewill devote to the program and an after-the-
797-086 0-66-3
fact statement of the actual time such persondid devote to the program, signed by the re-sponsible official. These documents must beavailable at the time of audit to support claimsfor part-time personnel in the Title I program.States should insure that the total amount oftime prorated among the various Federal-Stateprograms to which a staff member is assigneddoes not exceed 100 percent of the time of suchstaff member. There are two other aspects ofdocumentation at the local and State agencylevel which warrant careful attention. In-formation on these aspects is given below.
Documentation of Receipt of Material andEquipment Purchased
Although in many cases formal receiving re-ports are not necessary, there should at least bea notation on the invoice that such materials orequipment were received in good condition andin the quantities indicated on the invoice.
Keeping an Equipment inventory
The act requires that. the title to property ac-quired under this title shall be in a publicagency which will be responsible for adminis-tering such property. Inventories of equip-ment purchased by State and local agenciesshould be maintained on all items costing $100or more per unit for the useful life of the equip-ment or until some disposition of the equipmenthas been made. The inventories should alsoinclude all items of equipment temporarilyplaced on the premises of or in a private school,regardless of their cost.
In addition to the records mentioned above,the State agency must maintain all financialreports submitted to it by the local agencies.State fiscal records should be sufficient to sub-stantiate and document all amounts of Federalfunds granted, obligated, and disbursed (1) byspecific project and programs, separately fromother Federal projects and programs, and (2)by type of expenditure.
Records must be kept for 3 years or until theState agency is notified that such records are notneeded for administrative review, or until com-pletion of the Federal audit, whichever date islater.
9
AUDITSAll financial activities under this program
are subject to audit at both the local and Stateagency level.
Local Agency Audits
Project expenditure records will be auditedlocally. Such audits may be done as a regularpart of the local school audit proceduresprescribed by State laws or regulations. Localagency audit programs should be developed inaccordance with generally accepted auditing.standards, with due consideration for Federalpolicies governing the use of grant funds as wellas State or local policies and procedures. Thelocal audit report should include separate finan-cial schedules or statements identifying receiptsand expenditures applicable to each specificproject with appropriate certification as to thetruth of the report.
Reports and workpapers of local Laditsshould be available for review by appropriateState and Federal auditors and should include adescription of the method and extent of tests,examinations, and other techniques used inmaking the required verifications.
Swift Audit ConsiderationsFor audits of local agencies, it is essential that
specific audit procedures be developed to verifythat
Funds disbursed by the local agencywere received and properly accountedfor.Payments reported by the local agencywere actually made to the vendors, con-tractors, and employees and that theyconform to applicable laws and regula-tions, including procurement require-ments.Refunds, discounts, etc., were properlycredited to the specific programs as re-ductions of the gross expenditures.Payments are supported by adequateevidence of the delivery of goods or per-formance of services.Obligations reported were actually in-curred during the fiscal year or project
10
period, for which the project was ap-proved and, upon liquidation, were prop-erly adjusted.The same item is not reported as an ex-penditure for 2 fiscal years, e.g., obliga-tion in one year and payment in another.All obligations claimed for federally sup-ported Title I projects were made forproperly approved projects and areeasily identifiable with these projects.State and local agmcy rules applicablet.) equipment rocords and control are fol-lowed.Costs, su" :-, as salaries, travel, etc., arecorrectly 1).Corated.The sources of funds expended for fed-erally reimbursed projects were s,:atedcorrectly, and that the same expenditureswere not claimed under more than oneFederal program.Unexpended or unearned Federal fundsadvanced or overpaid were returnedpromptly or otherwise correctly ac-counted for.If the local agency is on a fiscal year dif-ferent from the Federal fiscal year, theaudit report reflects outstanding obliga-tions as of June 30 or August 31, which-ever the case may be, in sufficient detailto permit identification of subsequentpayments. Such obligations should becompared with reports submitted by thelocal agency to the State agency.
The audit report should be properly certifiedby the auditor to the effect that the procedureshe used to verify and otherwise substantiate hisfindings are in accordance with the proceduresoutlined above.
The Office of Education will continue to workwith State authorities toward the fulfillment ofState and local responsibilities for general andspecific audits of local records. Effective stand-ards for local audits related to specific programsshould include as a minimum :
Sufficient information for the local au-ditor regarding the requirements andlimitations of the program to enable himto certify as to the eligibility of the ex-penditures reported.
11.
Specific information in the audit reportsufficient to permit reconciliation withamounts shown on the records in theState office and assurance that such re-conciliation is actually made.Assurance that exceptions reported bythe auditor are brought to the attentionof officials in the State office responsiblefor the operation of the program and as-surance that appropriate adjustments orother administrative actions are taker. bysuch officials. (Specific audit steps andother information regarding financialmanagement of Federal-State educationprograms may be found in the pamphlet,Financial Management of Federal-StateEducation Programs (0E-10019) , whichwas distributed by the U.S. Office ofEducation to all State agencies in 1962.Additional copies of this pamphlet areavailable.)
Responsibility of State Agency To Providefor an Adequate Audit Program
It is the responsibility of the State educa-tional agency to see that audits performed forlocal agencies are within State laws and prac-tices and are adequate in terms of the stand-ards and conditions described above, whetherconducted by the State agency or by outsideauditors. The agency should verify audits per-formed by it or other auditors either on a sam-pling basis by verifying the accuracy of projectdocumentation at the State level or on a testcheck basis at the local level. Such audit re-ports must be made available for use of the Stateagency and representatives of the U.S. Depart-ment of Healtli, Education, and Welfare.
All such records and documents at the Stateoffice will be examined by program review teamsand Federal auditors.
Federal Audits
As a part of their regular activity of programand administrative reviews of State operations,staff members from the Office of Education willexamine certain fiscal aspects of State adminis-tration including status of project approvals,
obligations incurred for administration, cashwithdrawn, and disbursements made. Regularannual audits will be conducted by the Depart-ment of Health, Education, and Welfare Officeof Audit on a substantially current basis. Au-dits will also be conducted by the U.S. GeneralAccounting Office.
Audits by Federal agencies will normally belimited to the State agency level. Where Stateagency control has been such that records thereare not adequate, Federal agency auditing maybe extended to the local agencies.
Availability of Audits to Departmental Au-ditors and the U.S. Commissioner ofEducation
Audits of project accounts when completed atthe local level by local or State auditors shouldbe Set.out from the normal school audit, filed atthe State level, and made available to auditors inthe Department of Health, Education, and Wel-fare, or representatives of the Commissioner ofEducation. To the extent that reports of localaudits are complete and adequate, they maymeet the requirements of departmental audi-tors. However, where such reports are found tobe inadequate, local project expenditure rec-ords must be made available as required to thedepartmental auditors or representatives of theOffice of Education.
Audit Exceptions
An audit exception is a determination by anappropriate authority that an item questionedby the auditor is not properly chargeable tothe program and should be disallowed. TheCommissioner of Education determines the al-lowance or disallowance of items questioned bythe auditor.
Office of Education Services Available In theAreas of Fiscal Control Accounting andAuditsThe staff of the Office of Education may be
of assistance in the formulation of sound finan-cial management practices which will enableagencies handling Title I funds to accountreadily for such funds and to minimize fiscaladjustments resulting from Federal post audits.
11
SOME LIMITATIONS ON THE USEOF PROJECT FUNDS
Transfer or Reallocation of Funds
Neither the State nor the local educationalagencies may transfer or reallocate funds fromone local educational agency to another. This,however, does not preclude participation oflocal educational agencies in cooperative proj-ects.
Reallocation of Funds Between Projects
If a local educational agency with more thanone approved project desires to transfer fundsfrom one to another of these projects, it mustfirst submit to the State educational agency thenecessary amendments to the projects as orig-inally approved. No transfer of this kind maybe made until the State educational agency hasapproved these amendments. Before approvingsuch amendments, the State ai;ency should as-sure itself that the transfer of funds involvedwill not alter the projects in such a way as torender them unapprovable from the standpointof size, scope, quality, or other criteria,.
Deviation in Utilization of Project Funds
Whenever the utilization of project funds isexpected to vary by more than 10 percent over
12
or under the total amount approved for a proj-ect, the local agency should seek the approvalof the State agency. State agencies should alsoinform local educational agencies of the extentto which deviations in budgeted line items ofprojects will be permitted.
Exceeding the Maximum Basic Grant
The number of projects that a local educa-tional agency may propose as parts of its totalprogram under Title I during any one year isnot limited; but the total amount requested forall its projects may not exceed the total of themaximum basic grant for which the agency iseligible during that year.
Adjustments Due to Overpayments
In the event that a local educational agencyhas been paid funds in excess of actual approvedproject costs, such excess funds should be cred-ited as an advance payment on a current projectof that local educational agency, or returnedby check to the State educational agency.Likewise, any audit exceptions sustained by theState from its own audit findings or by the U.S.Commissioner of Education from the findingsof Federal auditors will constitute an over-payment.
EXHIBITS0E-4315 Exhibit No. 1
Department of Health, Education, and WelfareOffice of Education
Washington, D.C., 20202
DESCRIPTION OF STATE PROGRAM ORGANIZATION AND ADMINISTRATIONPublic Law 89-10, Utio 1
ADMINISTRATION
I. Briefly describe the unit or units within the State agency responsible for the administration of the Title I program.Attach a complete organization chart of the State agency showing the relationship between this unit or units andthe rest of the agency.
II. Provide information which will reflect the cooperative relationships that will exist between the State agencyTitle I administrative units and other State agencies, organizations, or institutions in the State concerned witheducational programs for the educationally deprived.Provide specific information which will describe procedures to be followed at the State level to coordinate Title Iprograms with community action programs. Describe arrangements made with State technical a)3sistanceofficials to exchange project and program information to the end that each office is fullyinformed and its activitiesare coordinated with the other.
III. Describe the steps taken by the State agency prior to the approval of its application in getting the programunderway, including:A. Use of State employees and consultants.B. Technical assistance provided to local schools. (Be specific.)C. Meetings and conferences.D. The development of instructions, guidelines, policies, and materials relevant to program implementation.
(Please enclose copies.)IV. List by name the officers in charge or designated to perform the following functions:
A. Overall program administration.B. Approval of projects.C. Measurement and evaluation including State evaluation and assistance to local districts oil specific projects.D. Liaison with the State technical assistance program, Office of Economic Opportunity (see sec. 205(a) (7)).E. Reports to the State educational agency and to the Commissioner of Education.F. Acquisition and dissemination of research and other information to assist applicants in planning and operating
projects.G. Receipts and custody of Federal funds under this program.H. Authotization of payments to local educational agencies.
V. Describe the State's procedures for accounting and for auditing local projects.VI. List by pcisition title the number of all personnel to be engaged in administering the program at the State level,
including those who will provide technical services in program development, fiscal, statistical, and evaluationactivities (indicate by asterisk (*) the titles representing new positions):
Title Number of positions Percent of time to be devoted to program
13
"7";''',"7
PROGRAM OPERATION
I. Describe any State policies, requirements, or standards for approving and rejecting projects with respect to:1. Selection of project areas.2. Identification of special educational needs in the project area.3. Size, scope, and quality.4. Provisions for children enrolled in private schools.5. Procedures for evaluation including objective measures of educational achievement.6. Coordination with local community action programs approved under the Economic Opportunity Act.7. Procedures for acquiring and disseminating information relevant to the planning and operation of projects
for educationally deprived children and for the adoption of promising practices.II. Cite any State statutes, regulations, or Attorney General's opinions governing the relationship of local educational
agencies to children enrolled in private schools.III. Describe the basis used for determining maximum basic grants to local educational agencies. (See regulations
116.4, 116.6, and 116.33.)Attach a list of all of the local educational agencies in the State showing the maximum grants allocated to eachagency.
IV. What arrangements will be made for the participation of State technical specialists and for consultants to provideassistance to State and local educational agencies for:A. Planning and development of programs for educationally deprived children, including handicapped children
within the State.B. Evaluation of programs and projects approved, including objective measurements of educational achievement.
V. Anticipated, estimated expenditures for projects and for State administration:
Period
From date of application approval to Dec. 31, 1965From Jan. 1, 1966, tO June 30, 1966
Total
14
State administration Projects
(Date) Signature of Chief State School Officer
IDE-4316
CE4316 (11-65) DEPARTMENT OF HEALTH,EDUCAT1ON, AND WELFAREOFFICE OF EDUCATIONWASHINGTON, D.C. 20202
QUARTERLY REPORT OF OBLIGATIINIS
Elementary and Secondary Education Act of 1965
NOTE: Please read instructions on the reverse before completing this report.
Exhibit No. 2
STATE
FOR FY ENDING
JUNE 30 19FOR QUARTER ENDING ("i" ow)
OSEPTEMBER 0 MARCH
---F1DECEMBER 1.-1 JUNE
PART A NUMBER OF PROJECTS APPROVED FROM JULY 1 THROUGH END OF PREVIOUS QUARTER1. NUMBER APPROVED FOR TITLEA
I 2. iUMBER APPROVED FOR TITLE II
PART B - ANTICIPATED AND AC AL OBLIGATIONS
ITEM
_ 1
TITLE I TITLE I I TITLE VLOCAL AGENCY
PROJECTAPPROVALS
2
STATEADMINISTRATION
3
LOCAL AGENCYPROJECTAPPROVALS
4
STATEADMINISTRATION
5
STATE
DEPARTMENTOF EDUCATION
6
1
ENTER MONTHS OF THIS QUARTER
MONTH
2 MONTH _
3 MONTH
4TOTAL ANTICIPATED OBLIGATIONS(sum OF 1, 2, AND 3)
.
5ACTUAL OBLIGATIONS FROM JULY 1THROUGH Er OF PH610118 QJARTER
,
6.
TOTAL ANTICIPATES AND ACTUALOBLIGATIONS (SUM OF 4 ANS 5)
. . . . . . . -
I CERTIFY THAT ALL THE INFORMATION CONTAINED HEREIN. INCLUDING THE REPRESENTATION AS TO THE Ah:INTS OF OBLIGATIONSDURING THE STATES PERIM, IS TRUE, COMPLETE, AND CORRECT TO THE BEST OF MY KNOWLEDGE AND BELIEF.
SUBMITTED.BY (TYPE NAME AND TITLE) SIGNATURE OF REPORTING OFFICIAL SATE
.FOR.0FrICE,OF EDUCATION USE ONLY
APPROVED el, DIRECTOR OF DIVISION OF PROGRAM OPERATIONS)
_PREVIOUS OBLIGATIONS FROM LASTQUARTERLY REPORT FOR THIS FY
TITLE I TITLE .11 I TITLE V
NET CHANGE IA OSLIGITIONS FORTHIS REP3RT 14 OR !
TRANS.CODE
1
DOC.REF.
2
OBLIGATIONNUMBER
3
FY4
UNIFORMACCTING. NO,
5
OBJECT .ExweAt.....
CLASS
6
PHOGRAM CODESVOUCHERNUMBER
11
SCHEDULENUMBER
1 2CLASS
7PAY8 9
SEC.REPT.
JO
GEO.
CODE13
GOY70/NONGOVT.
14
VENDOR
NUMBER1 5
AMOUNT
1 6
R."M1 7
,GENERAL LEDGER APPROPRIATIONSYMBOL,
20,
DEBIT18
CREDIT19
.........._,
BUDGET BUREAU NO. 514531,
15
0E-4318 (Proposed)
Department of Health, Education, and WelfareOffice of Education
Washington, D.C., 20202
ANNUAL FINANCIAL REPORT
Public Law 89-10
Set:I:act; oaucm1ier: /4.1 1965, T!!!- !
Exhibit No. 3
State For fiscal yearending ,
INSTRUCTIONSReturn original and 3 copies of this report, not later than November 30 for each fiscal year, to: Director, Division of Program Operations, U.S. Office ofEducation. Account number refers to code series in the handbook, "Financial Accounting for Local and State School Systems" available from the U.S.Otte° of Education or the Government Printing Office. "Expenditure" includes disbursements plus unliquidated obligations to be paid as of August 31.
SECTION ISTATE ADMINISTRATION
Accountnumber
Expenditure accountsExpenditures of Federal funds
Salaries Other Total
100 Administration $ $ $
200 Instruction
1230 BC Office equipment
Other (specify)
Total $ $ 5
16
SECTION IILOCAL EDUCATIONAL AGENCY
Item 1Project Expenditures
Accountnumber Expenditure accounts
Actual expenditures of Federal funds
Salaries Other Total
100 Administration 04, a',I, $
200 Instruction
300 Attendance service
400 Health services
500 Pupil transportation service
' 600 Operation of plp.nt
700 Maintenance of plant
800 Fixed charges
900 Food services
1000 Student body activities
1100 Community services
1220 (c) Minor remodeling
1230 Initial or additional equipment
Other (specify)
Total (item 1) $ $ $
Item 2School Facilities Expenditures
Account1220
Expenditure accounts Actual expenditures of Federal funds
Salaries Other Total
A. Constructior. $ $ $
B. On-site utilities: connections
C. On-site improvements
D. Equipment
E. Plan preparation and construction supervision,
F. Legal and administrative
G. Other (specify)
H.
Total (item 2) $ $ $
Total (add items 1 and 2) $ $ $
Wd,q...g,.....gyyyrp.g..ywowy.p.,
17
SECTION IIIADJUSTMENTS OF PRIOR YEAR EXPENDITURES
State
(Adjustments Enter plus or minus)
Total expenditures of Federal funds
Stateadministration
Projectexpe.dimres
School.m....ii
utus.vs-ies
1. Fiscal year $ $ $
2. Fiscal year-
3. Fiscal year-
4. Total adjustment (1 plus 2 plus 3)
5. Expenditures during current fiscal year (same as section 1 and 11)
(Add 4 and 5) Total: $ $ $
CERTIFICATION
I certify that all the information contained herein is true, complete, and correct to the best of my knowledge and belief.
Signature (Head, State Education Agency)
18
Date reported
1
Exh
ibit
No.
4
RE
CO
RD
OF
PR
OJi
CT
TR
AN
SA
CT
ION
SL
ocal
age
ncy
Stat
eFe
dera
l pro
gram
Proj
ect N
o.D
ate
appr
oved
Am
ount
app
rove
d $5
,000
OB
LIG
AT
ION
S
Obl
igat
ion
refe
renc
eIt
em o
r N
ame
of V
endo
r
(3)
Acc
ount
No.
I
(4)
Unp
aid
(5)
Paid
(6)
Dat
e pa
id o
rca
ncel
ed
(7)
Che
ckN
o.
(8)
Ava
ilabl
eba
lanc
e
,.....
Dat
e
(1)
Num
ber
(2)
,
Sept
. 3, 1
965
497
Stan
dard
Sch
ool
'23
0c$6
47.
50$4
, 352
.50
Supp
ly.
Sept
. 15,
196
5._
_ -_
736
Scho
ol E
quip
men
t Co_
_12
30c
2, 5
00.
001,
852
.50
Sept
. 30,
196
5__-
___
____
_-_
Sept
embe
r pa
yrol
l21
3$3
00Se
pt. 3
0, 1
965
355
1, 5
52.
50O
ct. 1
5, 1
965
740
Stan
dard
sch
ool
supp
ly.
230c
150.
001,
402
.50
Oct
. 18,
196
549
7do
230c
(647
.50
)64
0O
ct. 1
8, 1
965
749
1, 4
10.
00O
ct. 3
0, 1
965
Oct
ober
pay
roll
213
450
Oct
. 31,
196
573
8-40
960.
00O
ct. 3
1, 1
965
736
Scho
ol E
quip
men
t Co
1230
c(2
, 500
.00
)3,
460
.00
Tot
als
150.
001,
390
3, 4
60.
00
The
ava
ilabl
e ba
lanc
e (c
ol. 9
) w
ill b
e th
e am
ount
of
the
prev
ious
bal
ance
min
usth
e ne
t am
ount
obl
igat
ed a
s sh
own
in c
olum
n 5
and
min
us th
e am
ount
pai
din
col
umn
6. T
he a
mou
nt li
quid
ated
sho
uld
be e
nter
ed in
col
umn
5 as
a n
egat
ive
figu
re (
item
No.
497
). T
o re
cord
and
rep
ort c
ance
llatio
n of
a p
urch
ase
orde
r, th
eam
ount
ori
gina
llyre
cord
ed a
s an
obl
igat
ion
will
be
reve
rsed
by
a ne
gativ
e en
try
in c
olum
n 5
with
a ne
wda
te e
nter
ed in
col
umn
1, w
hich
sho
ws
the
date
of
the
canc
ella
tion.
The
eff
ect o
fth
is w
ill b
e to
incr
ease
the
avai
labl
e ba
lanc
e.1
see
proj
ect b
udge
t, ac
coun
t num
bers
, ite
m 1
0, p
t. II
.
NO
TE
Thi
s re
port
sho
ws
that
the
tota
l dis
burs
emen
ts to
dat
e wer
e...
.$1
,390
Unp
aid
oblig
atio
ns, f
or 1
out
stan
ding
pur
chas
e or
der
150
Tot
al f
unds
, use
d or
obl
igat
ed1,
540
Bal
ance
stil
l ava
ilabl
e fo
r ne
w p
ayro
lls o
r pu
rcha
se o
rder
_3,
460
Tot
al o
rigi
nally
app
rove
d5,
000
1 i
,.
Exhibit No. 5
QUARTERLY DISBURSEMENT AND ESTIMATED REQUIREMENTOF FEDERAL FUNDS
Elementary and Secondary Education Act of 1965Title I
INSTRUCTIONSPlease complete this report for each project.Submit original and two copies no later than 10 days after the close of each quarter to the State educational agency.
Project No. State serial Nos. Fiscal year project approved
Part IDisbursements for past quarter ending.
Items Amount ofdisbursements
1. Disbursements of Federal cash previously reported
2. Disbursements of Federal cash for reporting quarter
$
3. Federal cash on hand at end of quarter
4. (Federal cash accounted for) Total $
Part IIEstimated requirements for next quarter ending.
Month Federal cash is needed Estimated amottntneeded
1. Enter month $
2. Enter month
3. Enter month
4. (Add 1, 2, and 3) Total-
5. Less: Federal cash on hand at end of quarter (same as pt. I, item 3)
6. Net amount of Federal cash required (item 4 minus 5) $
Remarks:
Name of local educational agency IMailing address
Submitted by (type name and title)
Signature of Chief Local School Officer I Date
20 U.S. GOVERNMENT PRINTING OFFICE : 1966 0-797-006
1
SECTION II
PROJECT DESIGN AND EVALUATION
PART A. PROJECT DESIGN
Title I relies on local initiative for its opera-tion. It is the responsibility of local educa-tional agencies to design, develop, and prepareprojects that will fulfill the legislative intent ,)fthis title. It is the responsibility of State edu-cational agencies to assure that all proposalsmeet certain statutory requirements set forth insection 205 (a) of the title and are in otherrespects correct according to the law and theregulations. If the State educational agencycannot assure that a project meets these re-quirements, the proposal must be revised ordisapproved. The State agency may return aproject with specific recommendations for itsrevision or modification. The State agencyshall not finally disapprove an application inwhole or in part without providing the localagency reasonable opportunity for a hearing.
The first part of this section is devoted to thestatutory requirements that all proposals mustmeet, if they are to be eligible for approval bythe State educational agency. The second partdeals with other factors to be considered in thedesign and development of proposals.
In general, the term "program" is used in thissection to denote the sum of the projects pro-posed by a local educational agency for supportunder Title I in a given year. The specific proj-ects that the agency may propose in order to hn-plement its total program of operations underthe title may be one or more than one, dependingupon its overall plan for meeting the specialeducational needs of the educationally deprived
children in its district. But the total funds thatit may receive during any fiscal year cannot ex-ceed the total of the maximum basic grant forwhich it is eligible.
STATUTORY REQUIREMENTS UN-DER SECTION 205(a) OF TITLE I
Overall Design
Under section 205(a) (1), the State educa-tional agency must determine
that payments under this title will be usedfor programs and projects (including theacquisition of equipment and where neces-sary the construction of school facilities)(A) which are designed to meet the specialeducational needs of educationally deprivedchildren in school attendance areas havinghigh concentrations of children from low-,income families . . .
Educationally Deprived ChildrenFor the purpose of this program, the term
"educationally deprived children" means thosechildren in a particular school district who havethe greatest need for special educational assist-ance in order that their level of educational at-tainment may be raised to that appropriate forchildren of their age. The term includes chil-dren who are handicapped and children whoseneed for such special educational assistance isthe result of poverty or cultural or linguistic iso-lation from the community at large.
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Benefits under the title are not limited toeducationally deprived children presently en-rolled in school. They extend also to childrenof preschool age ; to those who have dropped outof school ; and to children of migrant farmwork-ers who, at certain times during the school year,may pass through some school districts in sub-stantial numbers.
Clearly, not every child who fits into thisclassification is educationally deprived to. thesame degree or in the same way. Some of thesechildren will be severely deprived in manyways ; it is upon them that Title I projectsshould be focused.
As with any other group of young people,educationally deprived children differ from oneanother. Each child is an individual, with indi-vidual characteristics. But when these childrenare considered as a gioup, certain characteristicsare discernible. Testimony printed in the Sen-ate hearings indicates what the characteristicsand needs of educationally deprived childrenare likely to be.
From the point of view of the teacher, thecharacteristics of educationally deprived chil-dren are :
Lack of response to conventional class-room approaches.Inadequate perfoimance in communica-tion skills.Socially unacceptable behavior.Indifference to responsibility.Nonpurposeful activity.Physical defects and poor health habits.Exaggerated importance of status sym-bols.
Further study of the child reveals that :
He is overage for his grade.His school attendance is poor.He has a high rate of failure.He has a high dropout rate.His aspiration level is low.He is without kindergarten experience.He has low achievement in reading andin arithmetic.His participation in cultural activities isnegligible.His potential appears to exceed what testdata show.1
Special Educational Needs.
In designing its program for educationallydeprived children in its district, the local educa-tional agency must identify the special educa-tional needs of these children and provide proj-ects to meet these needs. The identification andunderstanding of these special needs requiresa knowledge of the children and their back-grounds, much as the diagnosis of physical con-dition precedes treatment to improve that con-dition.
The special educational needs of education-ally deprived children vary, since children inthis group vary as much as children in mostlarge groups. But there are special educationalneeds which are common to these children as agroup but are not common to other children.To meet these needs is the responsibility thatschools are asked to assume with the extra helpoffered under Title I.
Specifically, these special educational needsinclude :
Improved skills in reading, arithmetic,and in other academic areas.Knowledge concerning living in modernAmerican society.Experimental backgrounds that willmotivate learning.
Speech in conformity with patterns ofstandard English.Heightened aspiration and motivationto realize their potential capacities anda willingness to initiate self-improve-ment.
Understanding of the purposes of educa-tion.Teachers wi.t understanding of thebackground problems of thesepupils.
1 Taken from a statement prepared under the direction ofthe Research Council of the Great Cities Program for SchoolImprovement. See Elementary and Secondary Education dmof 1966: Hearings Before the Subcommittee on Education ofthe Committee on Labor and Public Welfare, United StatesSenate, Eighty-Ninth Congress, First Session, on S. 370(Washington, 1985), pt. 2, pp. 1194, 1196.
School Attendance Area8 Haming High Con-centrations of Children From Low-IncomeFamilies
The applying local educational agency will,unless otherwise instructed by the State educa-tional agency, attach to its part I applicationa list of all school attendance areas with highconcentrations (at least as high as for the dis-trict as a whole) of children from low-incomefamilies, ranked in order of concentration. Theranking should be based on family income dataor data indicative of low income, such as pay-ments of aid to families with dependent chil-dren (AFDC) under title IV of the SocialSecurity Act, and other welfare data ; healthstatistics; housing statistics; and data fromschool surveys that contain information on orrelated to family income. In all cases, the list-ing should show how and on what basis areas ofhigh concentration of low-income families wereselected and ranked.
Usually an individual school attendance areais a fairly well-defined part of the school dis-trict and has fixed boundaries. Some schools,however, have no fixed boundaries; they drawgenerally from the children who live aroundthem but are also open, on a space availablebasis, to any child from any part of the schooldistrict. But regardless of whether school at-tendance area boundaries are fixed or not, thelocal educational agency can still rank its schoolsin order on the basis of the concentration ofchildren from low-income families that eachschool serves.
The school attendance areas with concentra-tions of children from low-income families atleast as high as for the district as a whole maybe selected and ranked on a percentage basis or,in the event that there are wide variances in thesizes of the schools, on a numerical basis. Acombination of these two methods may be used,if necessary, to avoid inequities in the adminis-tration of programs. The objective is to reachthe children in areas with high concentrationsof low-income families. The local educationalagency should use the ranking in such a waythat this objective can be reached mosteffectively.
Secondary school attendance areas may beranked separately from elementary school at-tendance areas on the basis of numbers of sec-ondary school-age children from low-incomefamilies; or they may be ranked on the basisof the number or percentage of such childrenaged 5 through 17 residing in the elementaryattendance areas served by the secondary schoolor schools. In general, a, secondary schoolwhose attendance area comprises several ele-mentary aleas with high concentrations of chil-dren from low-income families should also beconsidered an eligible area for a project.
If projects are approved for each of the at-tendance areas having as high a concentrationof children from low-income families as thedistrict as a whole, additional attendance areasin descending order of concentration may bedesignated as project areas, but only if the Stateagency determines that projects to meet themost pressing needs of educationally deprivedchildren in areas of higher than average concen-trations have been approved and, adequatelyfunded.
In certain cases, a whole school district or acombination of contiguous school attendanceareas may be regarded as a single area of highconcentration of children from low-incomefamilies. This may be done, however, only ifthere are no wide variances in the concentra-tions of such children among the several schoolattendance areas.
Size,Seope,and Quality -
Under section 205(a) (1), the Stateeducationagency must also determine
that payments under this title will be usedfor programs and projects . . . (B) whichare of sufficient size, scope, and quality togive reasonable promise of substantialprogress toward meeting those needs, andnothing herein shall be deemed to precludetwo or more local educational agencies fromentering into agreements, at their option,for carrying out jointly operated programsand projects under this title.
Proposals should be approved on the basisof their applicability to the education of thedisadvantaged and handicapped pupils in a
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given school district at thi8 time, without regardto how many disadvantaged and handicappedchildren might have existed in a school districton the basis of the 1960 census supplementedby AFDC figures for 1962, as long as programsproposed are of sufficient size and scope in rela-tion to the number of pupils served as to havea significant impact on meeting the special editcational needs of the pupils to be served. Proj-ects in the first year of the title's operationshould be designed to meet the needs of the mostseverely deprived children. Real progress withthese children will entail a substantial expendi-fure per child, a concentrated program, and,perhaps, a saturation of different types of edu-cational services and activities.
An applicant's total program should concen-trate sufficient resources, in relation to the num-ber of educationally deprived children in itsdistrict, to insure that the special educationalneeds of these children will be significantly re-duced, and that the help provided will not befragmentary. For example, a remedial readingproject might be so widespread that it coveredmuch of the séhool district and expended muchof the allocation, and in so doing starved otherelements needed in the total program. Childrenwithout needed eyeglasses, without enough food,without enough books, and without proper moti-vation would be unlikely to benefit from reme-dial reading instruction alone; in that case theremedial project would itself become ineffectivebecause the total program would have ignoredthe other special educational needs of the chil-dren it was designed to serve.
The total program should therefore include avariety of coordinated approaches toward meet-ing the needs of the educationally deprived chil-dren in a school district, if this is possible withinthe amount of the applicant's maximum basicgrant. And it should be designed to meet theneeds of these chlidren, whether they are in orout of school. Unless there are special reasonsfor concentration on certain grade levels, theprogram should also be available to children atvarious grade levels.
A program or project would be of sufficientquality if it included the use of resources andmethods that had been carefully selected to meet
24
the special needs of educationally deprivedchildren and if it gave grounds for reasonableexpectation that it would be successful in meet .ing these needs.
Size should be considered in terms of thebreadth and intensity of the impact on eachchild involved. A project might appear to beof considerable size in terms of cost, staffing,and so forth, but might in fact be too small forthe number and needs of the children it wouldserve. On the other hand, a far les, costly pro-ject might be considered to be of sufficient sizeif it provided intensive services and extra edu-cational opportunities in considerable depth forthe needs of a limited number of children.
Provision for Participation by Education-ally Deprived Children Enrolled in PrivateSchools
Under section 205 (a) (2), the State educa-tional agency must determine
that, to the extent consistent with the num-ber of educationally deprived children inthe school district of the local educationalagency who are enrolled in privati3 elemen-tary and secondary schools, such agencyhas made provision for including specialeducational services and arrangements(such as dual enrollment, educational radioand television, and mobile educational serv-ices and equipment) in which such childrencan participate.
This title does not authorize direct grants orbenefits to private schools. The services andarrangements provided for educationally de-prived children enrolled in private schoolsshould be designed to benefit the children ratherthan the school they attend.
The responsibility for identifying areas ofconcentration. and designing projects restswholly with the public educational agency. Itwould be advisable, however, for the applicantto consult with private school officials so as tobetter determine the special educational needsof educationally deprived children enrolled inprivate schools.
Before a State educational agency may ap-prove a grant, it must determine that the appli-cant has provided sufficient opportunitiei for
the participation of educationally deprived chil-dren enrolled in private schools who reside inproject areas. Opportunities for these childrento participate on the basis of geographical areamust Le substantially comparable to those pro-vided to children enrolled im public schools.
To the maximum extent possible the childrenenrolled in private schools who will participatein a project should be children who reside in theproject area. In any event, the needs of educa-tionally deprived children residing in the proj-ect area should determ ine the nature of theproject or projects. Children who attend pri-vate schools in the project area but do not residethere may participate in the project if they havethe same needs and if it would defeat the pur-pose of the project to segregate them from thosewho also attend such private schools but residein the project area.
The requirement under section 205 (a) (2) isinterpreted as applying to the total program ofthe local educational agency, not necessarily toeach project. But each project application mustshow the degree or manner of the expected par-ticipation by educationally deprived childrenenrolled in private schools; so that the Statemay judge the total program in this respect.
Title I provides for the participation of pri-vate school pupils in special educational servicesand arrangements. Where special educationalarrangements, such as dual enrollment, are pro-vided in public schools for private school chil-dren, classes should, if administratively feasi-ble, not be separated on the basis of the schoolin which the children are enrolled. Only specialservices and arrangements of a therapeutic,health, remedial, welfare, guidance, counselingor a similar nature may be provided on privateschool premises and then only when such serv-ices or arrangements are not normally providedby the private school. All special services or ar-rangements provided under Title I must, how-ever, be specifically designed to meet the specialeducational needs of educationally deprivedchildren. The extent of the opportunity forparticipation by private school children in Title
programs should be based on the numbers ofeducationally deprived children enrolled in such
schools who are in need of the services so pro-vided.
The law prohibits the paying of salaries ofteachers or other employees of private schoolsor the construction of private school facilities.Mobile educational equipment, if necessary forthe successful operation of project activities,may be temporarily placed in private schoolsbut title to equipment must be in a public agency.Such equipment must not be allowed to remainon private school premises any longer thannecessary, and in no event after the end of theperiod for which the project was approved.
If there are educationally deprived childrenwho reside in the applicant's district but attenda private school located in the district of an-other local educational agency and if there is nopracticable way for the applicant to provideopportunities for their participation in theproject, the applicant may wish to considerentering into a cooperative agreement with theother local educational agency. Under such acooperative agreement, the local educationalagencies could jointly provide educational op-portunities geared to the needs of the educa-tionally deprived children in both districts whoare enrolled in that private school.
Public Control of Funds and Property
Under section 205 (a) (3), the State educa-tional agency must determine
that the local educational agency has pro-vided satisfactory assurance that the con-trol of funds provided under this title, andtitle to property uerived therefrom, shallbe in a public agency for the uses and pur-poses provided in this title, and that a pub-lic agency will administer such funds andproperty.
The statutory expectatic i here is that thelocal educational agency will take reasonablesteps to assure that funds provided and title toproperty acquired with such funds shall be usedfor the purposes of carrying out approved TitleI projects, and shall remain under the controland administration of the public agency. Ptoj-ect funds or property cannot be used for thebenefit of any private agency or school. Equip-
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ment acquired with project funds may in certaincases be temporarily placed on private premises,but in any event title to and administrative con-trol over all such equipment must remain in apublic agency.
The project application must assure that proj-ect funds will at all times be under the controlof, and be administered by, a public agency andused only for the purposes for which they havebeen granted.
Construction of Facilities
Under section 205(a) (4), the State educa-tional agency must determine
in the case of any project for constructionof school facilities, that the project is notinconsistent with overall State plans forthe construction of school facilities and thatthe requirements of section 209 will be com-plied with on all such construction projects.
Section 209 of this title and .section 116.21 ofthe regulations relate to requirements concern-ing working conditions, wages, responsibilitiesof contractors, nondiscrimination, and so forth.
The local educational agency must demon-strate to the satisfaction of the State educationalagency that the implementation of the approvedproject would require the construction proposedin the application and that the constructionwould be consistent with overall State plans.If such construction is approved, the State edu-cational agency will send the applicant the nec-essary information concerning labor standardsand nondiscrimination in employment.
Procedures for Evaluation
Under section 205 ( a) ( 5 ) , the State educa-tional agency must determine
that effective procedures, including provi-sion for appropriate objective measure-ments of educational achievement, -will beadopted for evaluating at least annuallythe effectiveness of the programs in meet-ing the special educational needs of educa-tionally deprived children.
The National Advisory Council on the Edu-cation of Disadvantaged Children establishedunder Title I must report to the President each
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year on the effectiveness of the programs sup-ported under Title I and make recommendationsfor improvement. The Council will make use ofthe evaluative data developed by the local andState agencies and reported to the Office ofEducation.
Every Title I project must include a plan forevaluation. Projects which benefit children whodo not attend public schools should be evaluatedto the same extent as any other projects. Everyproject application should set forth the proce-dures and techniques to be Utilized in determin-ing the extent to which the project meets thespecial educational needs of educationally de-prived children. The procedures should bebased upon criteria which are ronsistent withthe objectives set forth in the application andshould provide for reporting to the State agencyat least annually, on a before-the--Fc!ct and after-the-fact basis, (1) the educational achievementof children served by the program ; (2) the edu-cational deficiencies of such children ; and (3)the educational opportunities available, in theschool and elsewhere, to alleviate identified edu-cational deficiencies. The success of the evalua-tion process will be' highly dependent upon anearly establishment of baseline data, since thenecessary information may not be availablehter.
Evaluative criteria for the total programshould be related to changes in the educationalstatus and opportunities of the children in theprojects. Indices of such change may include,but are not limited to, objective measurementsof
Educational achievement in the basiceducational skills.Levels of educational attainment, as evi-denced, for example, by dropout rates.Educational motivation, as evidenced byattention, performance, and attendance.Behavioral deviations and other specialhandicaps to educational progress.Cultural and social conditions related toeducational opportunity and progress.Educational opportunities provided inthe school setting, including curriculums,special programs and services, staffingfacilities, and community support.
Part B of this section deals more fully withthe subject of evaluation.
Reports and Records
Uncle section 205(a) (6), the State educa-tional agency must dei:ermine
that the local educational agency will makean annual report and such other reports tothe State educational agency, in such formand containing such information, as maybe reasonably necessary to enable the Stateeducational agency to perform its dutiesunder this title, including information re-lating to the educational achievement ofstudents participating in programs carriedout under this title, and will keep suchrecords and afford such access thereto as theState educational agency may find neces-sary to assure the correctness and verifica-tion of such reports.
The reporting function is a three-tiered oper-ation. Every participating local educationalagency must make an annual report to the Stateeducational agency on the effectiveness of itsTitle I program in meeting the special educa-tional needs of its educationally deprived chil-dren. The State in turn must make annual andperiodic reports on Title I programs to theU.S. Commissioner of Education on the basisof the evaluative data it receives from its par-ticipating local educational agencies. The an-nual report and recommendations of the Na-tional Advisory Council on the Education ofDisadvantaged Children will be based in parton the reports submitted to the Commissioner.It is therefore highly important that, insofar aspossible, the kinds of data gathered and the sur-vey and reporting forms used by all local educa-tional agencies within a State be identical orcomparable. Comparability can be achievedonly by thorough planning and establishment ofguidelines at the State level at the very start ofTitle I operations.
The applying agency should also maintainrecords that will show with maximum claritythe use cf Title I funds. These records shouldindicate (1) the receipt and disbursement ofproject funds, (2) the lmount of time spent on
project activities by each child and by eachteacher or other individual employed, (3) for-mal and informal evaluations of individualchildren, and (4) evaluations of the project andof each of its related activities.
Cooperation With Community ActionAgencies
Under section 205(a) (7), the State educa-tional agency must determine
that wherever there is, in the area servedby the local educational agency, a commu-nity action program approved pursuant totitle II of the Economic Opportunity Actof 1964 (Public Law 88-452), the programsand projects have been developed in co-operation with the public or private non-profit agency responsible for the commu-nity action program.
Cooperation here means continuous andgenuine working relationships during the pe-riod when programs are being planned anddeveloped, as well as when they are being car-ried out. A healthy working arrangement be-tween the local community action agency andthe school system, already started in manycommunities, will help to create a climate inwhich these two agencies, as well as others, canfashion and shape their respective programs tocomplement and supplement one another, inaccordance with the wording and intent of boththe Elementary and Secondary Education Actand the Economic Opportunity Act, therebyavoiding competition, waste, and duplication.Cooperation does not permit the comminglingof funds, but does permit the simultaneous useof funds under each of these acts to financeidentifiable portions of a single project.
Cooperation between the local educationalagency and the local community action agencyshould insure that
Programs are tailored to the interest ofeach act.Programs proposed under one act rein-force programs proposed under the otheract.Comprehensive plans are developed totake advantage of other available legis-
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lation, such as the Manpower Develop-ment and Training Act, the VocationalEducation Act, the Higher EducationAct, by working with other agencies ofsocial welfare to attack the problemalong conceptual lines rather than in-stitutional lines.
Some evidence to substantiate the coopera-tion to the, State wnuld be
A description of the representation of thelocal community action agency on plan-ning and advisory committees during theplanning, development, and operationalstages of projects and programs.A description of the procedure for con-tinuous review and discussion of plansand operations between the local educa-tional agency and the community actionagency with regard to their respectiveprograms.A letter from the local community actionagency stating that the communityaction agency has worked cooperativelywith the local educational agency to de-velop the proposed projects and intendsto continue its cooperation through thelife of the projects or programs.A description of the attempts by the localeducational agency to enlist the coopera-tion of the community action agencyfrom the beginning of the planningstage.A description of the representation of thelocal educational agency on the board ofthe public or private nonprofit agencyresponsible for the community actionprogram.
In any case, a letter from the local com-munity action agency should be included withthe proposed project, stating that the commu-nity act:on agency has seen the project and con-curs or does not concur with it. The localeducational agency should be willing to includea similar letter in proposals made by local com-munity action agencies to the Office ofEconomic Opportunity.
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Responsibility for carrying out the projectsauthorized under Title I of Public Law 89-10is, of course, lodged with local educationalagencies, and these guidelines should in noway be interpreted as giving local communityaction agencies a veto over Title I programs.What is required is that local educationalagencies develop their program in cooperationwith local community action agencies. Simi-larly it is expected that when community actionprograms are planned, cooperation will besought with the local educational agencies.
At the State level a check system sliould bedeveloped, if it does not already exist, to assurethe coordination of these two programs. Sucha system would allow the State technical assist-ance coordinator of the Office of Economic Op-portunity to examine Title I projects to see thatcommunity action agencies are working withlocal educational agencies. Similarly, theState educational agency should be able to ex-amine community action projects in the field ofeducation to insure that local educationalagencies are working with community actionagencies. Any persistent disagreement be-tween a community action agency and a localeducational agency might be made the subjectof a joint inquiry by the State educationalagency and the State technical assistanceagency.
Dissemination of Information'Under section 205 (a) (8), the State educa-
tional agency must determinethat effective procedures will be adoptedfor acquiring and disseminating to teachersand administrators significant informationderived from educational research, demon-stration, and similar projects, and foradopting, where appropriate, promisingeducational practices developed throughsuch projects.
Emphasis should be placed on the dissemina-tion of information that can be related to theassessment of needs and to project design so thatteachers and other professional staff may bettercontribute to the design and implementation oflocal projects.
Procedures and activities for disseminationof such information include, but are not limitedto
Inservice education.Professional libraries or informationalsystems.Professional workshops, seminars, etc.Gathering and making available toteachers information on research and theresults of research, demonstrations, andprojects which are applicable to and mayhold promise for the local school district.
The State educational agency may also wantto take leadership in the area of disseminatinginformation on educational research, demon-stration, and similar projects. For example, itmight wish to establish
A State clearinghouse of outstandingideas for Title I projects.A system to disseminate, after a period oftime, information on the most promisingand innovative Title I projects approvedby the State.A system to distribute and otherwisemake available books, brochures, book-lets, reports, documents, films, tapes, andother articles which would help localeducational agencies pian and evaluatetheir' projects.A system to make use of the EducationalResearch Information Center at the U.S.Office of Education, and possibly a sim-ilar or complementary center at the Statecapital or State university.A roster of Sthte educational agency, uni-versity, and other personnel who couldserve as consultants to local educationalagencies to help them with the debignand evaluation of their projects.A system for gathering and dissemi-nating the research and demonstrationactivities of universities and school sys-tems which have had a good deal of ex-perience in meeting the special educa-tional needs of the educationallydeprived.
OTHER FACTORS IN PROJECTPLANNING
Program and Project DesignThe total program of the local educational
agency should be based on evidence describingthe special educational needs of the education-ally deprived children in the areas of high con-centration of children from low-income familiesand should be designed to make substantialprogress toward meeting the special educationalneeds of such children. Each project shouldbe judged on its ability to make a substantialcontribution toward achieving the goals of thetotal program.
Each project in an applicant's total programshould incorporate a set of related services andactivities. The main activities or services pro-posed in any project should be directly relatedto and designed to help meet the special educa-tionally needs of educationally deprived chil-dren. The success of the project might alsodepend upon supplementary services needed toassist these children to overcome physical, psy-chological, or emotional conditions that wouldotherwise prevent them from benefiting to thefullest possible extent from their participationin the project. Examples of such supplemen-tary services might be psychological testing,counseling, parent education, and the provisionof food and clothing.
Proposals devoted exclusively to the acquisi-tion of equipment, for instance, or the construc-tion of facilities, or evaluation, or transporta-tion, or administration, or the provision of food,clothing, and materials could not be consideredprojects, although each of these activities maybe desirable as a component of a project.
Some projects -will by their very nature tendto benefit all children in a school, whether theyare educationally deprived or not. Exampleswould be projects -which devoted substantialresources to reduct;on in class size ; to the ad-dition of guidance counselors, teacher aides, andlibrarians ; to the acquisition of classroomequipment; or to the inservice training of ele-mentary school teachers. Other projects maybe more selective and devote substantial re-
29
sources to services that tend to benefit recipientson the basis of their special educational needs.Examples of these services might be remedialclasses ; special classes; -provision of food orclothing; or afterschool study centers. Proj-ects of the first type would lend themselvesparticularly to schools that are severely de-pressed and overwhelmingly impacted by edu-cationally deprived children from low-incomefamilies. Projects of the second type would bemore suitable to schools which serve areas withhigh concentrations of children from low-in-come families but at the same time have sub-stantial numbers of children who are not edu-cationally deprived.
No child in a project area should be deniedthe benefits of a project because his family doesnot qualify as "poor" by some definition. Butprojects should be so limited in size and sofocused in the schools that those educationallydeprived children who most need the services oropportunities offered will be adequately served.
Number of Projects To Be Planned
Within the limits of its maximum basic grant,a local educational agency may submit as manyprojects as seems appropriate to its particularcircumstances. A project may provide manyactivities for one school or one activity for manyschools. An applicant with . a small districtand a limited number of children might wish toconcentrate its activities by focusing its pro-gram on one or two schools and propose a sep-arate project for each school. On the otherhand, a local educational agency with a largedistrict may propose a dozen projects, each ex-tending through a number of schools havinghigh concentrations of low-income families.
A local educational agency which intends tosubmit several projects need not submit themall at the same time. To allow the State tomake some judgment about the balance of theoverall program, hovever, the applicant shouldattach to its first project application a brief de-scription of its proposed total program. Evena listing of contemplated projects would behelpful.
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Age and Grade Level of Children To Be Served
The age and grade level of the children to beServed will largely depend on the nature of theproject and the needs it is designed to meet.Grant funds may be used at any grade levelthrough grade 12 or any age level not beyondage 21 ; or they may be used for preschoolprojects; or for projects for out-of-schoolyouth. If an overemphasis on certain grades orcertain age levels seems likely to result in an un-balanced program, the State educational agencyshould not approve such a program unless thelocal educational agency presented sufficientevidence to show that the imbalance was de-liberate and based on good reasons.
Types ipf Projects, Activities, and ServicesWhich Deserve Special Mention
The approaches which can be used are almostwithout limit. Programs focused upon the edu-cationally deprived might include the services ofcounselors, psychologists, psyckometrists, doc-tors, nurses, social workers, and speech andhearing specialists. Specific projects might beSaturday morning special opportunity classesfor pupils who need additional help :A. master-ing basic skills ; evening school library servicesto provide a proper place for study ; early iden-tification programs both for the gifted and forpotential dropouts; preschool programs; com-bined work-study programs; or special remedialand enrichment classes. The aim should alwaysbe to design a project which will give reasonablepromise of substantial progress toward meetingthe special educational needs of educationallydeprived children in school attendance areashaving high concentrations of children fromlow-income families.
Preschool ProjectsEducational deprivation is usually associated
with an inadequate home environment. Pre-school programs can provide such childrenwith educational experiences commonly pro-vided by more affluent parents.
Preschool projects designed to prepare 4-yearolds or even younger children for kindergartenor Head Start programs are not only permis-sible but encouraged. Kindergarten, Head
Start, or other programs of this type designedto prepare children for school are especially en-couraged in school districts which do not al-ready have such programs. Also specially en-couraged are projects which build upon gainsalready made through Head Start or other pre-school programs.
Tf: is r000gniiza1 that an applicant's justifica-tion for preschool programs cannot usually bebased on measurements of educational defi-ciency of the children to be served. Evidencecan probably be gathered, however, of educa-tional deficiencies, including lack of readinessfor regular school Programs present in childrenalready enrolled in the primary grades ofschools in the project areas.
Dropout ProjectsIt is unlikely that a local educational agency
with a significant nunnber of dropouts couldhave a balance program if it did not make pro-vision for them. Specific projects designed topersuade dropouts to return to school might in-volve changes in the school environment thatwould lessen the likelihood of their leavingschool again before graduation ; or curriculumchanges might be devised to dissuade childrenidentified as potential dropouts from actuallyleaving school Counseling, guidance, on-the-job training, placement, and psychological serv-ices might also be proposed.
Projects Invotving Children Enrolled inSchools Operated by the Bureau of IndianAffairs
In certain cases children who were counted 'Anthe 1960 census as being from low-income fam-ilies were attending schools operated by the Bu-reau of Indian Affairs. In developing projects,local educational agencies should therefore con-sider the needs of children attending schools op-erated by the Bureau of Indian Affairs as wellas thE needs of children enrolled in public andprivate schools. They should especially con-sider the needs of Indian children not enrolledin any school, and provide opportunities forthese children to participate in such projects.
Projects for Handicapped ChildrenSome school districts may have a number of
handicapped children who lack the extensiveservices offered by wealthy school districts. Infact, some handicapped children may lack anyopportunity to be in school or to be helped by ateacher. Although the needs in poorer schooldistricts are massive when compared with re-sources, handicapped children should not be ex-cluded, and the State migla well question thebalance of a program that did not provide forthem.
Projects for Migrant ChildrenSome local educational agencies have large
numbers of migrant children passing throughtheir school districts at some time during theyear. The local educational agency has the re-sponsibility for reaching the educationally de-prived, and certainly many children of migrantfarmworkers fall into this category. Any localeducational agency which has substantial num-bers of migrant children passing through its dis-trict should make specific provision for thesechildren. It should insure that
They are identified.Their special educational needs are iden-tified.There is a special effort to see thatattendanca laws are met, and that thechildren have a way to get to school.Projects are designed and establishedwhich will meet their special educationalneeds.Special arrangements are made wherenecessaryincluding mobile classes,summer schools, and traveling teachersto increase the educational opportunitiesof such children.
Projects for the College-BoundOne important way to meet the special educa-
tional needs of deprived children is to help themget a college or other postsecondary education.A great number of young people from poorareas never get to college for reasons other thanlack of ability: Some lack motivation; othershave received little encouragement or counsel-ing ; almost all lack money. Many have littleknowledge of professional career possibilitiesand no close relationship with persons in pro-
31
,41.1411.01.11.111111.11.10.111.11111MiniiiiiM
fessional careers who might serve as models forthem. And, of course, a large number are sim-ply underprepared for college entrance.
Under Title I local educational agencies coulddesign and carry out projects to meet. theseneeds. Reaching the goal of equal educationalopportunity for all demands that a greater pro-portion of educationally deprived youngsters inlow-income areas not only be given a betterchance of getting to college but also be equippedpsychologically and educationally for success incollege.
Innovative ProjectsInnovative projects in the comparatively new
field of education of the disadvantaged can beof the greatest value. Projects which constituteextensions of ongoing programs are, of course,the easiest to plan and the safest to execute.Any imaginative and untried approach to reach-ing the educationally deprived is bound to carrywith it a certain risk of failure; but projectswhich succeed may make up many times overfor those which fail. Moreover, although proj-ects of this kind must be designed for the benefitof the educationally deprived, it is difficult toconceive of a truly innovative project whichwould not have a great deal of spin-off benefitfor many other children in the district and thusstrengthen the district's whole educationaleffort.
Detailed local and State reports on innova-tive programs, whether successful or not, shouldbe distributed by State educational agencies inorder that. other educational agencies may bene-fit from the experience acquired.
Pilot ProjectsPilot projects, limited in size and scope to
children in one or two schools in a district butinvolving relatively high administrative ex-penditures for planning and evaluation, fallwithin the province of Title I. A small-scaleproject of this type might involve activities toidentify the needs, and possible ways of meetingthe needs, of deprived children in the district ;the inservice training of teachers; the use ofnew personnel with special skills; and the test-ing of new methods and techniques. Such pilot
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projects should not be so expensive that theycould not be generally replicated.
Cooperative ProjectsTwo or more local educational agencies, par-
ticularly those with small maximum basicgrants, may decide to submit a proposal for aproject under cooperative auspices. Such aproject should be cooperatively planned byappropriate representatives of each of the agen-cies concerned. The actual administration ofthe project might be delegated to one of the lo-cal educational agencies and its authorizedrepresentative, or to an intermediate educa-tional agency.
The amount of funds contributed by each ofthe 3ducational agencies to the project shouldbe determined by the number of children fromeach to be involved in the project. The Stateeducational agency may pay to the agency des-ignated to administer a cooperative projectthose portions of the allocations of the partici-pating agencies approved for that specific proj-ect. In that event, the administering agencywould become custodian of all project fundsand would assume all responsibilities for theproper accounting of such funds and for themaintenance of fiscal records.
Extension of Ongoing ProjectsIf a local educational agency is already op-
erating a special project whose aim falls with-in the purposes of Title I, it may apply for agrant to expand and improve the project if theproject falls within the total program designedto meet the special educational needs of educa-tionally deprived children in school attendanceareas having high concentrations of childrenfrom low-income families. The local agency,however, must maintain the fiscal effort it -wasputting into the project before the passage ofthis legislation.
Projects Combining the Resources of Title IWith Those of Other Titles of the Elemen-tary and Secondary Education Act
Local educational agencies may legitimatelypropose Title I projects which would makeimaginative and effective use of the resourcesavailable under other titles of the act. Certain
Title I projects might incorporate research anddemonstration results from title IV regionalAncational laboratories or from title III sup-plementary centers and services; or Title Ifunds might provide for an elementary schoollibrarian while title II funds provide new li-brary resources.
Similarly local educational agencies mayseek to reinforce the gains possible under theact by making available Title I resources to re-inforce activities under other titles, as long asthe purposes of each title are met.
Projects Using Parents, Volunteers, and Sub-professional Aides
Where appropriate, projects should use theservices of voluntary and paid workers, includ-ing parents. Such persons can help to bridgethe gap in communication that frequently ex-ists between the home and school. At the sametime they may often, as a result of their servicein ihe school, modify their own attitudes andbehavior.
These persons will usually not be certified;but all school assignments do not depend oncertification. Adequate use of subprofessionalpersonnel would free teachers, coaches, schoolsocial workers, guidance counselors, recreationdirectors, and home-school visitors to concen-trate on what only they can do. In manycases, the aide's background may well providea valuable adjunct to the work of the profes-sional. Furthermore, the employment of aideswho need to supplement their family incomewould contribute to overcoming deprivation inthe project area, especially if the emphasis insuch employment were on creating careeropportunities.
Projects for educationally deprived childrenwill have a greater chance of success if parentsare involved to a far greater extent than theyhave been in the past. Education does notstart when the child arrives at school or stopwhen he returns home. Parents are an essentialpart of the educational process. If they do notrealize or do not know how to .fulfill their re-sponsibilities, th;.,. child suffers. Difficultthough it may sometimes be, the local edu-cational agency should find a way to interest
parents in their children's education and tohelp them to make a greater contribution to it.
Projects Involving an Increase in T eacher PayTitle I is not intended to finance an across-
the-board increase in teacher salaries. ButTitle 1 funds may be used to pay teachers forwork performed beyond the normal school day.
Projects Involving the Construction ofFacilities
The construction of school facilities for theregular school program is not the purpose ofTitle I. Applicants should therefore makeevery effort to lease facilities or to adapt existingfacilities to the requirements of the activitiesand services proposed under their projects.
If existing facilities cannot be leased oradapted, the applicant should consider alterna-tive project activities and services that areequally promising and 'for which facilities arealready available.
In addition to the restraining language inthe act and the regulations, construction shouldbe undertaken only in extraordinary cases be-cause
Is a capital investment of long dura-tion. A new building contributes to theeducational achievement of children overa long period of time and, in the mean-time, many children will not receive serv-ices which could have been bought withthe money used for construction.Reduction of the number of pupils perteacher or per adult can be accom-plished immediately, without construc-tion, by using a teacher aide or assigningmore than one teacher to a class.The number of children who could be ac-commodated in any one year in regularschool facilities constructed with theamounts available under Title I wouldbe extremely small in proportion to thetotal number of educationally deprivedchildren who have special educationalneeds.Present facilities can often be betterutilized by initiating projects afterschool, on Saturdays, and during the
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summer. Many buildings remain openonly 180 7-hour school daysa fractionof their potential.Most important, a local educationalagency must weigh the merit of sacri-ficing a remedial and enrichment pro-gram to one that would erect a facility.A million dollars spent on constructionis a million dollars not spent on variousaction programs that would directly af-fect the lives of educationally deprivedchildren this year.
A portion of an applicant's Title I funds maybe used for the construction of school facilitiesbut only if such facilities are necessary to enablethe applicant to carry out a specific project asapproved by the State educational agency.This means that the applicant local educationalagency must describe the nature and scope of aproject that will meet the special educationalneeds of educationally deprived children. Ifthe State educational agency concurs with theapplicant that no facilities are available for the
proposed project, then it may approve fundsfor construction under Title I.
A Title I project in any fiscal year should notbe solely a construction project. The greaterportion of the funds allocated to a school dis-trict in a fiscal year should be used for opera-tional purposes.
The scope of construction should be limitedtn tbnca fneilitipe which arP requireA for aspecific project.
In requesting funds for construction, the ap-plicant is expected to submit evidence to theState that (1) existing facilities cannot beadapted to the project by remodeling or byrental, and (2) the facilities proposed for con-struction are the minimum school facilities re-quired for the operation of a project underwhich certain specific services will be provided.
Even where facilities are needed before schoolinstruction can take place, there are services andactivities for children arid their parents whichcould be carried on while waiting for a build-ing to be built.
PART B. EVALUATION
INTRODUCTION
Why Evaluate?
Evaluation is an important part of the proc-ess of education. Evaluation helps us in diag-nosing pupils' strengths and weaknesses, in pre-scribing plans of action based on the diagnoses,in seeing whether our educational practices aresucceeding, and in setting up revised plans tomeet our objectives. The effectiveness of TitleI projects depends to a considerable extent onthe feedback that comes from good evaluation.
The measurements of pupil changes and at-tainments in Title I projects must be more care-fully assessed and controlled than casual teacherjudgment. On the other hand, an elaborate re-search study is not required.
The crucial importance of evaluation is un-derscored by its inclusion in four different sec-tions of Title I: 205(a) (5), 206(a) (3), 207 (b),and 212(a). Note that the law, in effect, re-quires evaluation at four different govern-
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mental levelslocal, State, U.S. Office of Edu-cation, and a National Advisory Council ap-poirited by the President. The results of eval-:uation at all these levels of course will be of/ /crucial importance in any congressional reviewof activities under Title I.
Any review of Title I at the national levelcannot be effective unless the State and localeducational agencies supply the necessary eval-uative data. Consequently, it is essential thatadequate data be gathered by each local edu-cational agency and that such data be analyzedand synthesized by the State educationalagency. Evaluation must be carried out by thelocal educational agency at two levelsfor eachdiscrete project and for a total program com-prising all of the agency's projects.
The central question is : Have the educationalattainments of children participating in TitleI programs been raised? The only way thisquestion can be answered is for State and localeducational agencies to define what they mean
by attainment (by stating specific objectives) insuch a way that it can be measured.
Although these guidelines are designed for'use by local educational agency personnel, manyof the concepts will be applicable at the Statelevel as well. Since each State educationalagency has the responsibility of synthesizingthe results nf flick avaluation reports for allprojects and programs under its jurisdiction,the early grouping of approved projects andprograms according to objectives, designs, andmeasuring instruments utilized will greatly fa-cilitate the assessment of the overall impact ofTitle I in the State.
Funding and Annual Reporting
Since evaluation is required by Public Law89-10 "at least annually," it is essential thatbaseline or reference data be secured very earlyin the project period. In some projects the at-tainment of specified objectives will not occurin a year or even in several years. Nevertheless,the evaluation of progress toward all objectivesshould be attempted and reported every year.Descriptions of the increases in educational op-portunity provided by Title I (new programs,teachers, etc.) should also be included in annualreports from local and State educationalagencies.
The costs of evaluation, including consultantfees, can be charged to the Title I project bud-get. A small investment in evaluation thatleads to more effective practices can pay richdividends.
THE EVALUATION PROCESSPrior to considering the evaluation of Title I
projects and programs in detail, it is importantto recognize the universality of evaluation as aprocess independent of the content of any par-ticular project or program being evaluated.As used here, evaluation is the process of deter-mining the extent to which specified objectiveshave been reached. Stated in another way,evaluation is the process of assessing the extentand direction of change resulting from an edu-cational experience.
Steps in the Process
The steps in evaluating educational outcomescan be enumerated as follows:
Step 1. Definition of educational objec-tives (preferably in terms of specific unitsof output) to be achieved through the ex-perience being evaluated. These objectivesshould reflect the most pressing needs ofthe educationally deprived residing in theproject area.Step 2. Translation of the educational ob-jectives into descriptions of behavior whichwill be displayed if the objectives areachieved.Step 3. Identification of situations inwhich the presence or absence of the desig-nated behavior can be observed andrecorded.Step 4. Establishment of some type of in-terpretive device (standard or norm)which can be used in measuring desiredgrowth.Step 5. Application of the evaluation meth-ods derived from steps 3 and 4 above to allthose participating in the program.Step .6. Analysis of evidence obtained by'he evaluation devices in terms of progresstoward the defined objectives.Step 7. Statement of conclusions regardingeffectiveness in terms of the extent to whichobjectives were achieved.
An Example
To illustrate, let it be assumed that one of theobjectives of a swimming class is to be evalu-ated. Let it be assumed also that all pupils areunable to swim at the start of the class.
Objective: To teach pupils enrolled in theclass to swim at least 25 yards. (Note : ob-jective is expressed in output terms of 25yards.)Translation to behavior: Students whohave reached this objective will be able toswim under indoor pool conditions.Situation: After an instructional period,each pupil will be given a chance to swimin an enclosed and uncrowded pool. Nodiving will be involved.
Standard: Each pupil must swim 25 yardsusing any stroke he chooses without touch-ing the bottom of the pool.Appliadion: Each pupil attempts to swim25 yards.Analysis: The number of pupils meetingthe standard is recorded.Conclusion: Based on the results of theanalysis, a generalization regarding the ef-fectiveness of the instruction is made. If80 percent of the pupils swim 25 yards, wecan conclude that the instruction techniquewa . Sective.
IMPORTANCE OF MEASUREMENTOF CHANGE
The objectives of proposed projects should be
related to specific characteristics possessed bypupils prior to the initiation of a Title I project.The evaluation procedures and designs appro-priate for Title I, therefore, will involve meas-uring changes in pupil behavior over a periodof time. This means, in most instances, thatevaluation procedures will involve obtainingappropriate measurements at the start of a TitleI project, during the project period, and at theconclusion of the project. The difference be-tween these successive measurements, if prop-erly selected, will be an,indication of changeand of the effectiveness of the use of Title Ifunds. Consequently, it is imperative that localeducational agencies gather baseline data onstudents when Title I projects are initiated.
The difference between only two successivemeasurements of the same characteristics indi-cates the general direction of change but usuallydoes not indicate whether the improvement ineducational attainment is significant. Interpre-tation of change or progress is achieved when-ever the amount (and direction) of change canbe related to ,(1) standards, (2) norms, or (3)meaningful units of measurements. Althoughthese interpretive devices may sound compli-cated, they are used by many educators everyday.
Standards
Standards, as used here, refer to points alonga continuum or to discrete categories in a classi-
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fication which permits the assigning of pupilsto groups according to accepted definitions im-plying specified degrees of a characteristic.Examples of standards from die educationalrealm include : can or cannot tie shoestrings ; canor cannOt read newspaper articles; can or can-not spell all the words in a given list; and per-fect or less than perfect attendance during aparticular period. Whenever a standard is em-ployed to interpret student performance, pre-cise definitions must be provided.
Norms
Norms are used here to refer to numericalvalues that describe performance of specified
groups. Educational norms are frequently themean or median measurements of achievementof a large group on a certain test. Publishednorms for tests are often assumed to be repre-sentative of the Nation as a whole. However,regional, local, or district norms may be moredesirable for comparison with specific groups.While norms may be expressed in raw scoreform, more frequently age scores, grade place-ment, standard scores, stanines, or percentileranks are used. When national norms do notprovide adequate differentiation at the lowerend of the aptitude or ability scale, specialnorms, established locally, are often useful.
Units
Units are generally defined as increments ofchange expressed in meaningful quantities.Units may be expressed with respect to othernorm data or simply as progress toward a stand-ard. A few examples follow : number of timeschosen as a leader of the class, parental attend-ance at workshops, number of students seekingservice of counselors, voluntary registrationsfor a second (advanced or continuing) course instudy skills, and ratio of library cards issued to
cards used.
EVALUATION DESIGNS
There are two basic considerations in select-
ing procedures (designs) for evaluating TitleI projects. The first of these is the manner in
which change will be assessed (tests, observa-
tic'', etc.) in the project group and the second isthe selection of comparative data which willmake the results meaningful. Comparativedata in the form of standards, norms, and unitshave already been mentioned. The appropriateuse of such data will be apparent as the designsin the following paragraphs are discussed.
Design A. Change in a Title I Project GroupCompared With an Absolute Standard atthe Start of the Project and at the End
Example .1. Proportion of eligible 10th,11th, and 12th grade studentsenrolled in a work-studyprogram.
Example 2. Proportion of students re-tained in school between the11th and 12th grades.
In these examples, it is assumed that thestandard is 100 percent and that the closer theresults are to 100 percent, the more effective theexperience has been.
Design B. Change in a Title I Project GroupCompared With a Designated Norm
Example. A. norm is obtained by achninis-tering an evaluation device suchas a test to a National, State, orlocal group. When a standard-ized achievement test is admin-istered to a group participatingin a Title I project, the changein achievement of students inthe project can be comparedwith expected change based onpublished norms for the groupin the Nation, region, or locality.
Design C. Change in a Title I Project GroupCompared With Change in a Control
GroupA control group as used here is one similar to
the Title I group with respect to variables im-portant to the specific project or program suchas ability, socioeconomic level, etc. Ideally, thestudents would be randomly assigned to the Ti-tle I and the control groups, but such assign-ment is not necessary when it can be assumed
.......... .....................*
that the students in both groups are equallyprepared for the project. The control groupcan be drawn from students outside the Title Iproject area who have the same type ofdeprivation.
Example .1. Both groups may be requiredto take a comprehensiveachievement test in October toestablish a baseline and be re-quilt cl to repeat the test inMay. The baseline test shouldbe administered before or atthe time the Title I project isstarted.
Example 2. Last year's class in the sameschool setting may be desig-nated as the control group,provided that the childrenhave comparable backgroundsand the same evaluation de-vices are used to measurechange at the appropriatetime during the "control"year. The group in the TitleI project may then be com-pared to last year's class.
Design D. Change in a Title I Project GroupCompared With Projected or Hypothesized
Change Based on Past Progress of theGroup
Example. Mean achievement reading testscores of 97, 93, and 89 were re-corded in grades one, three, andfive respectively for members ofa Title I project group at thebeginning of the Title I proj-ect. In the seventh grade, theprojected average for the samegroup without the benefit of theTitle I project would be 85. Theactual average in the seventhgrade of the project groupwould then be contrasted withthe projected average. (Oftenthese quotients of educationallydisadvantaged children tend todecrease as further yearly eval-uations are made. In this exam-
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ple, it would be encouraging tosee that this trend had beenarrested.)
This design is relatively easy to implementand will provide a sound measure of educationalattainment.
Design E. Change in a Title I Project GroupReported Without Comparative Data
Example 1. To evaluate a first grade read-ing project, a comparison canbe made of scores earned on astandardized reading test ad-ministered in the fall as theproject gets underway andagain at the end of the projectyear.
Example 2. To evaluate a program inwhich the pupil-teacher ratiohas been reduced at each ofthe several grade levels andlanguage arts md arithmeticsupervisors employed, a com-parison can be made of scoresfor each subtest in a compre-hensive achievement test ad-ministered at the beginningand end of the project period.
Since the procedures cited in the above twoexamples merely report results and do not afforda meaningful comparison, they are notas desirable as any of the preceding fourdesigns.
Design F. Design involving One Measure-ment Only
When one measurement only is made of somecharacteristic of a Title I project group, as-sumptions must be made about the degree ofacquisition of educational achievement 1-p tothe time of the measurement. It is, therefore,not possible to assign an amount of growth toa particular period. However, some indicationof growth can be obtained by comparing stand-ing at the time of measurement with standingrecorded by previous classes and/or with norms.Since it is not possible to determine growth dur-ing the period of the Title I project, designs in-
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volving only one measurement a: the projectgroups are not as satisfactory as those whichmeasure change directly.
Example. In Eastern Park School an en-riched and individualized read-ing project was inaugurated inthe first grade. In May, thisgroup of children earned a sightvocabulary test average score of200. Comparison was made withthe average of 180 posted lastyear by Eastern Park Schoolfirst-graders, and average scoresof 208 last. year and 214 this yearearned by first-graders in theWestern Park School.
Supplementary Evaluative Techniques
Some local educational agencies might havedifficulty reporting significant changes in edu-cational attainment for a project group, be-cause the nature of the project is such that con-clusive results will not be available for 2 or 3years. In the interim, however, individualcases may serve to demonstrate meaningful in-creases in educational attainment.
Case StudiesAppraisals by teachers or Title I project di-
rectors of changes in attitudes and behaviormust be well documente&to be reliable. Eachteacher in the course of observing and testinghis students, as well as in numerous other ways,acquires many important facts about. them. Forreporting purposes under Title I, it would behelpful if the accumulated facts were presentedin terms of some specific aspect of the partici-pant's development.
Such appraisals should be based on more thanmere "feeling," for a "feeling" cannot be repli-cated or checked. This is not to say that a "feel-ing" is not useful, but it must be su pported bya carefully marshalled, detailed description ofcases and observations to be of convincingvalue. Observations are a more reliable evalu-ative device if made by skilled "outside" ob-servers not connected with the project or pro-gram.
Anecdotal RecordsAnecdotal records may be employed by
teachers and counselors to evaluate Title I proj-ects. An anecdotal record consists of an ac-cumulation of a series of observations of asignificant aspect of a studenthis leadershipqualities, reading achievement, socialization.The individual report of each incident shouldconsist of a brief, clear, objective statement ofwhat took place. Interpretation or recom-mendations may be included, but should bewritten on a separate section on the anecdotalcard. The observations must be objectivelyrecorded and taken at periodic intervals inorder to show individual development. Teach-ers and other project personnel may need totrain themselves to observe incidents and torecord them at a later time.
Related DevicesAttitudinal scales, personal evaluat ions,
teacher rating forms, pupil self-rating in-ventories, audiological surveys, physical ex-aminations, participation in recreation pro-gram surveys, and many other instruments anddevices may be used with professional staff ob-servations to collect evidence about the total im-pact of Title I project.
Comprehensive Evaluation
A comprehensive evaluation program will gowell beyond testing for the mere acquisition ofspecific skills, facts, and knowledge in thecognitive domain. Comprehensive evaluationwill extend into the measurement of the stu-dents' ability to interpret, to evaluate, and/or toextrapolate information to solve real problems.In fact, the purpose of American education goesfar beyond student achievement in the cognitivedomain to include concern for areas such as :
The affective domain : attitudes, motiva-tions, interests, adjustments, anxieties;Social development : acceptance, recogni-tion, belonging, leadership, interaction;Physical development : general healthand ability, speech, motor skills,dexterity ;Academically related problems : reaction
of employers, continuing professionaldevelopment of teachers.
PLANNING FOR EVALUATION
Preparation of the Proposai
Steps in preparing for evaluation should bedescribed in each project proposal submittedunder Title I. Preparation for the evaluationof each project should begin by listing each ob-jective in specific and behaviorial terms andmaking a parallel listing of instruments. (teits,observations, etc.) to be used in evaluatingprogress toward that objective.
Use of Standardized Tests
Public Law 89-10 states that whenever pos-sible, "objective measures of educationalachievement" will be used for the evaluation.In many instances this will mean nationallystandardized tests. Extreme care must betaken, however, to assure that the standarizedtests are valid measures of the types of be .
havioral change indicated by the objectives.Two of the more important aspects of reli-
ability of measurement involve test length anddifficulty of the items. Generally, the morereliable evaluations result from conditions inwhich a number of items measure each conceptand the items are neither so easy tint most areanswered correctly nor so difficult that most arefailed. In selecting tests, evaluators must as-sure themselves that the tests contain enoughitems which deal with concepts that were taughtand that these items are comprehended by thestudents. When standarized tests contain toofew items for a particular concept involved ina Title I project and/or the problems are toodifficult, locally constructed tests should be usedto supplement the evaluation.
The importance of early planning of eval-uation procedures cannot be overemphasized.Consultants located in other school systems, in-stitutions of higher education, State depart-ments of public instruction or elsewhere will beeffective at this stage. In most school systemsfunds will need to be designated for personneltraining and employment of consultants. TheState department of education can furnish in-
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formation about reliable consultants. Schoolguidance personnel are another possible sourceof assistance in evaluation design.
Nontest Sources of Evaluative Data
information will sometimes be sought fromparents, school personnel, and others in thecommunity as objectives dictate. Opinions andattitudes of parents will be particularly impor-tant. While questionnaires and other surveyinstruments may be used, their effectiveness islimited because action that will take place whena person is faced with a choice is describedrather than observed. Attendance at school ac-tivities, participation in conferences, and otherexamples of adult behavior such as watchingcertain television programs, providing a quietplace for homework, and using library facili-ties wil. provide indices of opinion throughchoices of behavior. Professional judgmentsof teachers, specialists, and supervisors can beobtained about children in a project with spe-cially constructed rating scales.
While the emphasis of the evaluation planmust be on discovering what happens to pupils,it would be interesting also to observe efNets onteacher attitudes, behavior, and methotl withdisadvantaged children. Such "intermediate"results may appear before significant changeshave taken place in the pupils' educational at-tainment and should be included in the annualproject report. Other examples of "inter-mediate" elects that should be noted in reportsare changed pupil attitudes and improvedhealth.
Division of Groups Possible
When objectives in the cognitive domai arebeing evaluated, it may be desirable to considersubclassifying pupils according to sex, abilitylevel, and/or achievement level. Such a prac-tice is suggested by several previous researchstudies in which it has been found that certaineducational practices result in substantial gainsfor some groups but not for others. Such sub-classification of Title I program pupils oftenprovides insights into educational practiceswhich might otherwise be "masked" throughpooling divergent groups together in an analy-sis of evaluative data.
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Use of Sampling
Achievement testing is often criticized be-cause of its influence on pupils and teachers .
who wish to show up well on the tests. Inassessing the progress of Title I, no individualpupil or classroom need show up at all. Sam-ples of children carefully chosen to be repre-sentative would provide data without anyone orany classroom taking a fuP assessment batteryor getting a score or report from it. Instead, areport would indicate, for example, that 90 per-cent of the children in a Title I project can com-prehend certain reading or arithmetic problems.
Because sample assessment exercises can begiven individually and by interview, it is pos-sible to sample more than achievement as shownon traditional paper and pencil- tests. Per-formance, interests, skills, habits and the likecan be included. Hence assessment should beindicative of the range of educational objec-tives being sought in modern schools ratherthan limited to a small part of the educationalprogram. Reports made every few yearswould provide information about educationalprogress.
FINAL CONSIDERATWNSEvaluation is part of the teaching process and
should contribute information during the proj-ect period as well as at the end. Evaluativeinformatic.. may lead to changed methods, orchanged objectives, or both. For instance, dataon pupil attainment gathered around the mid-point of the project may show that the originalobjectives were unrealistic and should be scaleddown. Case studies may indicate that educa-tional methods are succeeding for some typesof pupils but not others. Since applicants willnot have had experience with Title I projects,continuous or interim evaluation is especiallyimportant this first year.
Although well-conceived evaluation methodsmust be an integral part of a Title I project,they should not eclipse ate project itself. TitleI programs must meet the needs of children,not the needs of research specialists. In short,an able Title I project director will find waysto collect and analyze evaluation data witl,tdistoe.ion of the program.
U.S. GOVERNMENT PRINTING OFFICE:1965 0-797-086
