Coordinating Nonpublic School Services

Jack ClarkAllentown City School District

Cindy RhoadsRegional Coordinator, DFP

Overview of Nonpublic Services

• NCLB provides benefits to private school students, teachers and other educational personnel, including those in religiously affiliated schools.

• Nonpublic Participation is included in the majority of programs covered under NCLB.

NCLB Programs Requiring Nonpublic Consultation & Participation

• Title I• Title I, Part B (Reading First)• Title II, Part A (Improving Teacher Quality)• Title III (LEP/Immigrant Education)• Title IV (Safe/Drug Free Schools)• 21st Century Community Learning Centers• Title II, Part B (Math/Science Partnerships)• Title II, Part D (EETT)• Title V (Innovative Education Programs)

Consultation Process

• Section 9501 of NCLB• Timely and meaningful consultation during the

design and development of the programs on such issues as:– How the children’s needs will be identified.– What services will be offered.– How/where services will be provided.– How the services will be assessed and how the

results of the assessments will be used to improve these services.

Consultation Process

– Who will provide the services– Amount of funds available to provide private

school services– Size and scope of services to be provided– How and when the agency will make

decisions about the delivery of services.

• Consultation [meetings] must continue throughout the implementation and assessment of services

Consultation Process

• Such consultation shall occur BEFORE the local educational agency makes any decision that affects the opportunities of eligible private school children, teachers and other educational personnel to participate.

Title I vs. Other NCLB Programs

• Title I has its own provisions for nonpublic involvement outlined in the law.– Title I $ follows the eligible child.– Not restricted to nonpublic buildings within

LEA attendance area.– Nonpublic consultation is the responsibility of

the LEA.

Comparison

• Title I– $$ generated by

nonpublic low income children

– $$ follows the child, regardless of attendance area.

– LEA/Nonpublic Officials coordinates services for children.

• Other NCLB Programs– Children attending

nonpublic schools within the LEA boundaries are eligible for services.

• In most cases, IUs coordinates services.– Exceptions:

• Title II, Part A• Competitive Grants

Nonpublic Structure in PA

• Catholic Schools– Diocesan Education

Representative is responsible for the nonpublic education programs in all schools within their Diocese.

• One sign off on eGrants for all Catholic Schools

• Other Nonpublic Schools– Individual consultation

required for each school.

• One sign off per school on eGrants.

Title I Nonpublic Programs – Step by Step Process• Which Nonpublic Schools to Include?

– Any nonpublic school attended by a low-income child who resides in an attendance area of a school that participates in Title I

• Poverty Data (obtain from Nonpublic)– Same measure of poverty as public schools– Survey– Proportionality– Comparable Data

• What Public School the Student would normally attend.

– Must be a Title I school.

Title I Nonpublic Programs – Step by Step Process

• Contact the nonpublic school officials– Invite to a Consultation meeting

• Intent of Title I• Role of Public and Private School officials.• Opportunity for NP officials to ask questions.

– Not adequate to merely send a letter (USDE

Guidance A-2).– Must occur BEFORE the LEA makes any

decisions that affects the opportunity for private school children, teachers and families to participate in Title I.

Title I Nonpublic Programs – Step by Step Process

• If Nonpublic School does NOT want services– Provide notice in writing with signature.– LEA keep letter on file.

• If Nonpublic School does want to participate:– On-going consultation throughout the

school year on key NCLB requirements.

Title I Nonpublic Programs – Step by Step Process• Generating Funds:

– Participating Title I School Per Pupil Allocation x Number of Poor Private Children Residing in the Title I School Attendance Area = Funds Available for Private School Title I Program

– Calculate for Each School – may have different per pupil amounts.

Sample for Generating Funds

Nonpub

A

Nonpub

B

Nonpub

C

Total

Public A (per pupil = $100)

3 low income x $100 Ea = $300

1 low income x $100 = $100

2 low income x $100 = $200

$600

Public B

(per pupil = $125)

2 low income x $125 = $250

3 low income x $125 = $375

5 low income x $125 = $725

$1350

Total $550 $475 $925 $1950

Factors Affecting Nonpublic Funds

• Reservation of Funds– LEA set asides for School Improvement/LEA

Improvement• Only public school students may benefit from these set asides• Set asides for these purposes will affect the amount available

for nonpublic services

– Set Asides requiring nonpublic consultation:• Parent Involvement• Professional Development• Summer School

– Funds set-aside for these purposes must be shared with nonpublic schools and should be part of the consultation process.

– eGrants will calculate proportionate shares for nonpublic services.

eGrant Nonpublic Reservation of Funds Info

eGrants will calculate an estimated dollar amount for equitable nonpublic services for these areas based on a proportionate percentage of the nonpublic vs. public Title I dollars.

Note: (Title I Public $ + Title I Nonpublic $)/Title I Nonpublic $ = Proportionate % used for determining equitable % of set-asides

eGrant Nonpublic Reservation of Funds Info

LEA will enter the actual dollar amount of services agreed upon during the consultation process for each nonpublic agency in this section (Nonpublic Selection of Schools)

Nonpublic Sign Offs

• Required by NCLB• eGrants Sign Off prior to submitting

application– Nonpublic school officials must be given an

adequate opportunity to review LEA applications to ensure that the program in the application matches what was agreed upon during the consultation process.

– The week prior or the day grants are due does not constitute meaningful consultation and may delay your ability to submit applications by the deadline.

– Nonpublic officials may refuse to sign off on a Title I application where a large balance remains on the Title I Selection of Schools/Ranking Screen.

Must be as close to $0 as possible.

Tracking Nonpublic Expenditures

• Budget Category on eGrants Budget– Function Line 2280 (Nonpublic Support

Services)– LEAs may use this category to record and

track nonpublic services provided under NCLB

Notes for Nonpublic Funds

• Nonpublic funds may be “pooled” to more effectively meet the needs of their disadvantaged children.

• Funds generated by private school students must be used for instructional services.

• Nonpublic schools may not receive funds (no checks) – only services.– LEA maintains fiscal control of all nonpublic funds.– LEA arranges all nonpublic services.

• Equipment purchased with federal funds for nonpublic uses remains the property of the LEA.

Identifying Eligible Nonpublic Children for Title I• In order to be eligible for Title I services in a

nonpublic school – – Child must reside in a participating Title I public school

attendance area AND– Are educationally deprived.

• Students must be selected based on multiple, educationally related, developmentally appropriate criteria (poverty is NOT a criteria).

• Exempt:– Homeless– Two (2) preceding years in Head Start, Even Start, Early

Reading First, Title I Preschool or Title I Part C (Migrant Education).

Title I – Types of Services

• Specialized Instruction outside the regular classroom

• Extended learning time (before/after school and in the summer)

• Family Literacy• Early Childhood• Home Tutoring• Take Home Computers• Computer-Assisted Instruction• Combination of Services

Title I Programs

• Materials and Supplies– May only be purchased for a nonpublic school

if there is an existing nonpublic Title I Instructional program.

– If no instructional program, other methods of equitable participation must be explored.

Title I Nonpublic Parent Involvement• Portion of 1% set aside at LEA level must

be used to provide equitable services to nonpublic parents.

• Consult with private school officials and nonpublic parents.

• Must have a compact outlining the responsibilities of the LEA and the parents in helping children achieve standards.

Nonpublic Involvement in Other Programs under NCLB

• Nonpublic Schools located within an LEA attendance area are eligible for services under:– Title II, Part A (Improving Teacher Quality)– Title II, Part D (EETT)– Title V, Part A

• Funds for these programs are administered through the IUs

Competitive Grants

• LEA writing the grant is responsible for prior consultation with nonpublic schools located within the attendance area of the LEA.– All students enrolled in nonpublic school are

eligible – not just the ones attending from the LEA.

– Nonpublic school may have different program than the nonpublic schools – especially when nonpublic has different needs than the public school.

Additional Resources

• USDE Guidance– “Title I Services to Eligible Private School

Children” – Non Regulatory Guidance• www.ed.gov

Questions/Answers