Providing Effective Equitable Title I Services to Non-Public School Students

ESEA Directors InstituteOctober 2014

Title I Non-Public

Quache Bowles SpencerDivision of Consolidated Planning & Monitoring

Strategic Projects Manager Quache.Spencer@tn.gov

Why do LEA’s provide services to non-public schools?

Under Title I, local educational agencies (LEAs) are required to provide services for eligible non-public school students, as well as eligible public school students.

In particular, §1120 of Title I, Part A of the Elementary and Secondary Education Act (ESEA), as amended by the No Child Left Behind Act (NCLB), requires a participating LEA to provide eligible children attending non-public elementary and secondary schools, their teachers, and their families with Title I services or other benefits that are equitable to those provided to eligible public school children, their teachers, and their families.

Eligible students are those students that reside in Title I school zones and are failing or at risk for failure.

Services to Non-Public Students

The Title I services provided by the LEA for non-public school participants are designed to meet their educational needs and supplement the educational services provided by the non-public school.

These services may be provided by the LEA, or by a contractor who is independent of the non-public school.

Title I services or benefits must be secular, neutral, and non-ideological.

 

Best Practices For Providing Effective Services

The three main components to effective services are:

• Consultation– single most important piece to providing effective

equitable services

• Communication– timely and transparent

• Collaboration– developing a partnership with non-public school

officials can prove beneficial

Consultation

Consultation is a requirement in the implementation of an effective Title I program

Effective Consultation must be:• Timely and meaningful• Before decisions are made about services and before

services begin• Involves discussions between public and non-public

school officials• Provides a genuine opportunity for all parties to express

their points of view• Annual• Ongoing

Annual Consultation Meeting

The annual consultation meeting should be a face-to-face meeting • LEAs send invitations in advance and reminders leading up to

the meeting date• Require an RSVP prior to the meeting date• LEAs invite key players from public and non-public schools:

– Central office staff– Non-public school building administrators– Specialty areas

» Family/Community Engagement» IDEA/SPED» Title III

The annual consultation should contain the regulatory requirements

Regulatory Requirements for Consultation

Under §200.63 of the Title I regulations consultation must, at a minimum, address the following issues:

  How the LEA will identify the needs of eligible non-public school children.

  What services the LEA will offer to eligible non-public school children.

  How and when the LEA will make decisions about the delivery of services.

  How, where, and by whom the LEA will provide services to eligible non-

public school children.

How the LEA will assess academically the services to non-public school children in accordance with §200.10 of the Title I regulations, and how the LEA will use the results of that assessment to improve Title I services.

 

Regulatory Requirements for Consultation

The size and scope of the equitable services that the LEA will provide to eligible non-public school children and, consistent with §200.64 of the Title I regulations, the proportion of its Title I funds that the LEA will allocate for these services and the amount of funds that the LEA reserves from its Title I allocation for the purposes listed in §200.77 of the Title I regulations.

The method, or the sources of data, that the LEA will use (under §200.78 of the Title I regulations) to determine the number of non-public school children from low-income families residing in participating public school attendance areas, including whether the LEA will extrapolate data if a survey is used.  

The services the LEA will provide to teachers and families of participating non-public school children.

  Discussion of service delivery mechanisms the LEA will use to provide

services 

When Communicating with Non-public Officials

Be timely• Set up meetings far in advance• Set due dates far in advance

Be deliberate• Send RSVP’s with meeting notifications• Have more than one contact for each school• Communicate in writing

– E-mail– Fax

Be mindful• Different calendars• Different start times (school openings, school days)• Religious holidays

Collaboration

Collaboration between public and non-public schools creates a sense of trust

• Creates a feeling of partnership in the decision-making process

• Breaks down barriers • Decreases complaints

• Makes public school officials the first point of contact

When Collaborating with Non-Public School Officials

Be transparent• Share pertinent information with them

– Allocations– Changes coming to the district that may affect them

• Allow time for questions and answers during collaborative events

Be genuine• Read surveys and questionnaires• Respond to questionnaires • Give due consideration to requests

Delivery of Services

Services may be provided by the LEA, or by a contractor who is independent of the non-public school.• Determining who will deliver the services is discussed and agreed upon

during annual consultation– If public and non-public school officials disagree on provision of services

through a contract, the LEA will provide in writing to such public school officials an analysis of the reasons why the LEA has chosen not to use a contractor

• Ultimately the LEA has the final decision as to the provision of services

• NOTE: Tasks related to the administering services and programs are the responsibility of the LEA (purchasing, contracting, etc.)

Comparison of Delivery of Services- Services Provided By the LEA

Pros

LEAs have a direct link to non-public schools and their administration

LEA hires its own tutors (upholding licensure standards)

Decreases administration fees Creates autonomy for non-

public school students Creates increased

collaboration between non-public school teachers and LEA tutors

Cons

Creates the need for more staff• Coordinator to head the

program• Supervisor to visit and

monitor program• Technology person to

maintain technology purchased for non-public schools’ students

Comparison of Delivery of Services- Contracted Services

Can be managed by minimal LEA staff

Creates a feel of the LEA being outsiders

Tutors are hired by the contractor

Administrative cost comes into play

Contractors may use a curricular program

Decreases the need for collaboration between the non-public school teachers and contracted tutors

Title I Non-public in ePlan

Non-public schools participating in Title I should appear in ePlan in the following 4 pages:

• District Set Asides and Overview Page (parent involvement, districtwide instructional initiatives subject to non-public, etc)

• PPA Page (column H – Services to Students in Non-Public Schools for the school-level instructional PPA)

• Non-public Schools Page (from Sections Page) indicating participation and student information of non-public schools in LEA attendance areas

• Budget narratives

Questions

FRAUD, WASTE or ABUSE

Citizens and agencies are encouraged to report fraud, waste or abuse in State and Local government.

NOTICE: This agency is a recipient of taxpayer funding. If you observe an agency director or employee engaging in any activity which you consider to be illegal, improper or wasteful, please call the state Comptroller’s toll-free

Hotline:

1-800-232-5454

Notifications can also be submitted electronically at:

http://www.comptroller.tn.gov/hotline