Jennifer Davenport, Ed.D. Title I, Part A Program Manager Federal Programs – Title I

1. An LEA’s Guide to Updated Title I RequirementsFebruary 24-26, 2014GCEL Conference – Savannah, Georgia

2. Margo DeLaune Title Programs Director Federal Programs – Title I mdelaune@doe.k12.ga.us (404) 657-1796 Jennifer Davenport, Ed.D. Title I, Part A Program Manager Federal Programs – Title I jedavenp@doe.k12.ga.us (404) 463-1955

3. Title I – Breaking Through the Myths – Then and Now

4. Title I and Schoolwide Programs THREE CORE ELEMENTS • A Title I schoolwide program is a comprehensive reform strategy designed to upgrade the entire educational program in a Title I school with a poverty percentage of 40 percent or more in order to improve the achievement of the lowest-achieving students.

5. Title I and Schoolwide Programs THREE CORE ELEMENTS • Comprehensive needs assessment of the entire school. • Comprehensive schoolwide plan based on the needs assessment. • Annual review of the schoolwide plan and revising the plan, as necessary, to ensure continuous improvement.

6. MYTH: TITLE I, PART A FUNDS MAY ONLYBE USED FOR READING AND MATH • Title I, Part A funds may be used to improve the achievement of low-achieving students in subjects other than reading and mathematics. • The funds may be used to support any core academic areas that the school’s needs assessment identifies as needing improvement.

7. MYTH: TITLE I FUNDS MAY ONLY BE USEDTO SERVE LOW-ACHIEVING STUDENTS • Title I funds may be used to upgrade the entire educational program in a schoolwide program school in order to raise the achievement of the lowest-achieving students. • In upgrading the entire educational program, all students in the schoolwide school program may benefit from the use of Title I funds; however, the focus remains on improving the achievement of the lowest-achieving students.

8. MYTH: TITLE I FUNDS MAY ONLY BEUSED FOR INSTRUCTION • Title I funds may be used for any activities designed to raise the achievement of low achieving students identified by a school’s needs assessment and articulated in the school’scomprehensive schoolwide plan. • Definition of Intervention: An intervention is a systematic attempt by educators to provide students with research-based supports that ensure meaningful access to the curriculum. These data-based interventions ensure students are provided with supports they need to meet and exceed grade-level standards.

9. MYTH: TITLE I FUNDS MAY ONLY BEUSED FOR INSTRUCTION • For example, Title I funds may be used to improve attendance, improve school climate, counteract bullying, or provide positive behavioral and intervention supports, as long as, the school’s needs assessment provides the data to support this need and the school’s comprehensive schoolwide plan provides an explanation of this supporting documentation on how the school will address this need.

10. MYTH: TITLE I FUNDS MAY ONLY BEUSED FOR INSTRUCTION • Simply adding an attendance clerk would not provide students with research-based supports that ensure meaningful access to the curriculum. Interventions must be data-based and ensure that students are provided with the supports they need to meet and exceed grade-level standards.

11. MYTH: SUPPLANTING IS NOT APPLICABLEIN A SCHOOLWIDE PROGRAM • A schoolwide program school does not need to provide services that supplement, and do not supplant, the services participating students would otherwise receive if they were not participating in a Title I program. (ESEA §1114(a)(2)(A)(ii)) As long as, from the non-Federal funds available to an LEA in a given year, the LEA must make available for the school the amount the school would have received if it were not a Title I schoolwide school, including the funds needed to provide services that are required by law for students with disabilities and ELs. (ESEA § 1114(a)(2)(B)) Note: Due to local control of state funds, LEAs in Georgia may not be able to provide supporting documentation for non-supplanting issues.

12. ALLOWABLE USE OF TITLE I, PART A FUNDS • The purpose of Title I, Part A is to improve the achievementof low-achieving students in high-poverty schools. • Title I, Part A funds may be used only to benefit students who are participating in a Title I program: • All students in a schoolwide program, but particularly those who are low-achieving. • Students in a targeted assistance school who are failing, or mostat risk of failing, to meet State academic achievement standards.

13. ALLOWABLE USE OF TITLE I, PART A FUNDS • Title I, Part A funds may not be used to benefit the general needs of students in a targeted assistance school or an LEA as a whole unless – • There is express authority to do so; or • All schools in the LEA are Title I schools operating schoolwide programs.

14. MYTH: TITLE I, PART A FUNDS MAY ONLYBE USED FOR REMEDIAL COURSEWORK • Title I, Part A funds may be used for supplemental activities to prepare low-achieving students in Title I schools to take advanced courses. For example, • Intensive summer school classes for low-achieving high school freshmen and sophomores to prepare them for the rigors of taking advanced courses in their sophomore and junior years. • After-school tutoring for low-achieving students who are taking advanced courses. • Elective courses to prepare low-achieving students to take advanced courses.

15. MYTH: IT IS SUPPLANTING TO USE TITLE I,PART A FUNDS FOR CREDIT • Generally, using Title I, Part A funds for courses that provide credit needed to meet graduation requirements would be supplanting because, in the absence of the Title I, Part A funds, an LEA would need to provide sufficient opportunities for students to earn the requisite credits for graduation.

16. MYTH: IT IS SUPPLANTING TO USETITLE I,PART A FUNDS FOR CREDIT • An LEA may use Title I, Part A funds for courses that allow low-achieving students to receive credit toward high school graduation requirements if those courses: • Are an expansion of the options for receiving credit; and • Do not replace or reduce the courses normally provided.

17. MYTH: TITLE I, PART A FUNDS MAY ONLYBE USED FOR INSTRUCTION IN ACADEMICSUBJECTS • Schoolwide program schools may use Title I, Part A funds to support non-academic needs that stem from the school’s needs assessment – i.e., attendance interventions, school climate. NOTE: See slide #8 for a definition of intervention

18. MYTH: TITLE I, PART A FUNDS MAY ONLYBE USED FOR INSTRUCTION IN ACADEMICSUBJECTS • Targeted assistance schools may also use Title I, Part A funds to support non-academic needs of Title I students that stem from the school’s needs assessment – i.e., attendance interventions, health, nutrition, other social services not otherwise available to eligible children in such school, if appropriate, and such school has engaged in comprehensive needs assessment and established a collaborative partnership with local service providers; and

19. MYTH: TITLE I, PART A FUNDS MAY ONLYBE USED FOR INSTRUCTION IN ACADEMICSUBJECTS • Funds are not reasonably available from other public or private sources to provide such services, then a portion of the funds provided under this part may be used as a last resort to provide such services, including-- • The provision of basic medical equipment, such as eyeglasses and hearing aids; • Compensation of a coordinator; and • Professional development necessary to assist teachers, pupil services personnel, other staff, and parents in identifying and meeting the comprehensive needs of eligible children. (ESEA § 1115(e)(2))

20. MYTH: AN LEA MAY NOT RESERVE TITLE I,PART A FUNDS TO PROVIDE SERVICESAT THE DISTRICT LEVEL • This myth has some basis in law. • Title I is basically a program operated at the school level. • Title I, Part A funds may be used only to benefit students who are participating in a Title I program—that is, all students in a schoolwide program, but particularly those who are low-achieving and students who are failing, or most at risk of failing, to meet State academic achievement standards in a targeted assistance program.

21. MYTH: AN LEA MAY NOT RESERVE TITLE I, PART A FUNDS TO PROVIDE SERVICES AT THE DISTRICT LEVEL • Title I, Part A funds may not be used to benefit the general needs of students in an LEA as a whole unless— • All schools in the LEA are Title I schools operating schoolwide programs; or • There is express statutory authority to do so.

22. MYTH: AN LEA MAY NOT RESERVE TITLE I, PART A FUNDS TO PROVIDE SERVICES AT THE DISTRICT LEVEL • An LEA may reserve Title I, Part A funds off the top of its allocation for “district-wide” activities that are focused on all, or a subset of, Title I schools. For example, an LEA might— • Reserve Title I, Part A funds off the top of its Title I allocation to implement a specific school reform strategy in each of its Title I Priority schools, Focus schools, or schools in restructuring. • Hire outside data experts to work with staff in priority or focus schools or schools in corrective action and restructuring to build their capacity to analyze student data more effectively to improve instruction.

23. MYTH: IT WOULD BE SUPPLANTING TO USETITLE I, PART A FUNDS TO REPLACE LOCALFUNDS IN A TITLE I PROGRAM • Due to reduced Title I, Part A funds caused by sequestration, some LEAs used local funds to make up the difference. Using Title I, Part A funds in subsequent years would usually raise a presumption of supplanting in a targeted assistance school. • Because the local funds were used to continue a Title I program, which would have been less robust absent the use of local funds, the LEA may use Title I, Part A funds in subsequent years in place of the local contribution without supplanting.

24. MYTHS ABOUT THE SUPERCIRCULAR WHAT DOES IT COVER? • Combines eight cost circulars to make them consistent. • Single Audit coverage • Fiscal Requirements • Allowable Costs including time distribution • Flexibility, accountability (internal controls) and a move towards a performance based perspective. The circular is located at: https://www.federalregister.gov/articles/2013/12/26/2013-30465/uniformadministrative-requirements-cost-principles-and-audit-requirements-forfederal-awards

25. MYTHS ABOUT THE SUPERCIRCULAR WHEN DOES IT TAKE EFFECT? • Immediately for Federal agencies • Affects audits of fiscal years that begin after December 26, 2014. • Federal agencies must implement the policies and procedures applicable to Federal awards by promulgating a regulation to be effective by December 26, 2014, unless different provisions are required by statute or approved by OMB.

26. OMB Circular A-87 Time & Effort Who must participate? • All employees paid with federal funds!! • Some employees paid with non-federal funds • When salaries are used for match purposes • NOT contractors

27. Time Distribution Records STANDARDS FOR DOCUMENTATION OF PERSONNEL EXPENSES • Must be maintained for all employees whose salaries are: - Paid in whole or in part with federal funds 200.430 (i)(1) - Used to meet a match/cost share requirement 200.430(i)(4)

28. Time Distribution Records Federal Stipends If a State-funded employee is paid a stipend with federal funds for attending professional development, does time and effort documentation have to be kept? • Yes • No

29. Time Distribution Records Federal Stipends • Federal funds can generally be used to pay for stipends for professional development or other extra-curricular activities. • Time and Effort documentation must be kept. • Maryland January 2013 ARRA Audit • Documentation not kept for employees partially funded with federal funds.

30. Time Distribution Records DE Minimus Benefit If a teacher works on a single cost objective but also has limited other responsibilities, such as cafeteria or bus duties. This teacher must keep: • Monthly PARs • Semi-annual certifications

31. Time Distribution Records DE Minimus Benefit • Limited work on another cost objective does not need to be captured in time and effort records. • Employees may work 5% or less on another cost objective. • The work performed on these limited duties cannot deprive a benefit from the intended beneficiaries.

32. Time Distribution Records Substitute Teachers Are substitute teachers paid with federal funds required to track their time? • Yes • No

33. OMB Circular A-87 Time & Effort PART-TIME EMPLOYEES Are part-time employees required to track their time? • Yes • No

34. What Questions Do You Have?

35. Margo DeLaune Title Programs Director School Improvement—Federal Programs mdelaune@doe.k12.ga.us (404) 657-1796 Jennifer Davenport, Ed.D. Title I, Part A Program Manager School Improvement—Federal Programs jedavenp@doe.k12.ga.us (404) 463-1955