Equitable Participation Designed to Meet the Needs of Private School Students and Teachers

1. Equitable Participation Designed to Meet the Needs of Private School Students and Teachers Private School Participation in Federal Programs OFFICE OF SUPERINTENDENT OF PUBLIC INSTRUCTION Special Programs and Federal Accountability March 21, 2019

2. Agenda • ESEA General Program Requirements • Basics • Intent to Participate Process • Consultation Process and Requirements • Complaint Resolution Process • Individual ESEA Programs and Carl Perkins • Consolidated Program Review (CPR)

3. Private School Participation in Federal Programs Equitable Services for Eligible Private School Students, Teachers, and Parents ESEA | Elementary and Secondary Education Act as amended by the ESSA | Every Student Succeeds Act Required by Federal Law

4. Private School Participation in Federal Programs …Why? Public tax dollars support federal programs.Children and teachers in approved, non-profit private schools are eligible to access the services these programs provide.

5. ESEA Equitable Services Guidance–ESSA Section 8501 • Uniform Provisions (2009): Title IX, Part E Equitable Services to Eligible Private School Students, Teachers, and Other Educational Personnel, is the non-regulatory guidance that covers: • Education of Migrant Children–Title I, Part C • Teacher and Principal Quality–Title II, Part A • ELL/Emergency Immigrants–Title III, Part A • Student Support & Academic Enrichment–Title IV, Part A • 21st Century Community Learning Centers–Title IV, Part B • ESEA Title I, Part A Equitable Services Guidance–ESSA Section 1117 • Non-regulatory Guidance(2003) • Updated guidance to arrive soon! • Title I, Part A Resource Toolkit • Ensuring Equitable Services to Private School Children Law, Regulation, Guidance, Resources Private School Participation in Federal Programs

6. ESSA Updates for Federal Programs • Non-Regulatory Guidance: Fiscal Changes & Equitable Services (2016) • Carl D. Perkins Career and Technical Education ActNon-regulatory Guidance │ Carl D. Perkins CTE Act (U.S. Dept. of Education) • ESEA Private Schools Webpage • Private School Participation in Federal Programs • State Board of Education Website • Private School Initial Application/Renewal Law, Regulation, Guidance, Resources Private School Participation in Federal Programs

7. Private School Participation in Federal Programs Equitable Participation—The Basics • Equitable Services • Services should be equitable to the public school—not necessarily identical—designed to meet the needs of private school students and teachers. • Equal Expenditures on a Per-pupil Basis • Expenditures must be equal to the amount of funds expended for participating public school children. iGrants calculates this amount. • Same Start Date • Services for private school students should begin at the same time as services begin in public schools.

8. Private School Participation in Federal Programs • Key Word Is Services • Services and materials only. • District monitors teachers and providers who deliver services. • District maintains administrative control over services. • Districts do not distribute public funds to private schools. • No reimbursement to private schools.

9. Private School Participation in Federal Programs Private School Requirements Private schools may participate in federal program equitable services in 2019–20 if they: • Are a state approved, non-profit, elementary or secondary school certified through the State Board of Education. • Have completed the Private School October Enrollment Report P105B form in 2018. • Complete the Intent to Participate portion of the Private Participation in Federal Programs application in EDS in the Spring of 2019–due April 15.

10. Private School Approval Washington State Board of Education To become an approved private school in Washington– Private schools must initiate approval through the Washington State Board of Education.

11. Private School Approval Washington State Board of Education State Board of Education—Initial Approval Complete the Application for Private School Initial Approval Renew approval annually State Board of Education—Annual Approval (Renewal) Annually—apply for approval from the State Board Complete the P105B Enrollment Data Report

12. Private School Approval • Washington State Board of Education State Board of Education Approval • Questions? Contact the State Board of Education | 360-725-6433 |Privateschools@k12.wa.us Law & Regulation Minimum Standards for Private School Approval Chapter 28A.195 RCW | Chapter 180-90 WAC

13. Intent to Participate Process

14. Private School Participation in Federal Programs Private Schools must notify the school district and OSPI of intent to participate through the Private Participation in Federal Programs Application in EDS. 1. Enter your Federal Tax ID number 2. Choose Participationor Nonparticipation 3. Check federal program boxes to indicate participation 4. Enter enrollment data 5. Select all the public school districts where your students reside–necessary for Title I, Part A and Title IV, Part B

15. Helpful Tips for Completing the EDS Application • For school name changes, a change in address or school district, contact OSPI’s customer support– • CustomerSupport@k12.wa.usor 1-800-725-4311. • State Board of Education| 360-725-6433 • Submit the application even if the private school decides NOT to participate. • Once submitted, the application goes to OSPI and the school district in which the private school is located. Private School Participation in Federal Programs Important! Make sure the information entered is correct. Once entered, you cannot modify.

16. Private School Participation in Federal Programs District Process: Ensure Equitable Participation 1 Review the Intent to Participate form in EDS. Contact the private schools that completed the form and begin the consultation process. Contact private schools that have not filled out the form. 2 Required: document each contact attempt in the Contact Log. Mandatory: Two attempts by the district. Use multiple strategies to make contact.

17. Consultation Process

18. Consultation • The goal of all parties should be to reach an agreement on how to provide equitable and effective programs for eligible private school children and teachers. • District must provide “timely and meaningful” consultation with appropriate private school officials. ESSA Section 1117(a)(1)(A) and (b) ESSA Section 8501(c)(1)

19. What is Timely? ESSA Section 1117(b)(3)/8501(c)(3)– • Before the district makes any decisions about opportunities for private school students’ and teachers’ participation. • Includes the district decision to transfer eligible federal program funds to another federal program. • Consultation should continue throughout the implementation and assessment of services. Observation A letter on the intent of program is not enough. ED suggests invitation to meet to explain. Document that you attempted contact and held meetings. Logging these attempts in the contact log is a district requirement.

20. What is Meaningful? EDGAR 76.652– • Genuine opportunity for parties to express their views–the district may initiate consultation with a proposal for services. • Final decisions made by the district after consultation.

21. Private School Participation in Federal Programs Initial Consultation: Required Topics for Discussion -Identification of student’s need -What services will be offered -How, where, and by whom the services will be provided -How the district will academically assess these services -How the results of this assessment will improve future services

22. Private School Participation in Federal Programs Initial Consultation: Required Topics for Discussion -Size and scope of the equitable services that the district will provide -How much funding is available to serve private school students, teachers, educational personnel, and in some cases, parents and if the funds will be pooled

23. Private School Participation in Federal Programs Initial Consultation: Required Topics for Discussion • Transferability and REAP Flexibility • Consult with private schools before any decisions are madethat could affect the ability of private schools to benefit from programs for which they are eligible. • Private school students and teachers must receive equitable services under the programs that the funds are transferred to. • Eligible programs to transfer or REAP into other federal programs include: • Title II, Part A • Title IV, Part A

24. Affirmation of Consultationincludes all required areas of discussion for the consultation process. Districts must review the complaint procedureswith private school officials. Upload one signed Affirmation of Consultation, in the Private Participation in Federal Programs application for each participating private school. Consultation Private School Participation in Federal Programs

25. Private School Participation in Federal Programs January February December March November Timely, Meaningful Consultation… October April April …must continue throughout the implementation and assessment of services September May August June July

26. ComplaintResolution Process

27. Private School Participation in Federal Programs Complaints: Try Local Resolution First If the private school officials believe timely and meaningful consultation has not occurred… OR …the district did not give due consideration to their views The private school should contact the federal programs representative or superintendent at the school district to discuss these concerns.

28. Private School Participation in Federal Programs Complaints: OSPI and the Formal Complaint If the concern is not resolved satisfactorily, the private school should contact the OSPI Federal Program Ombudsman for resolution. If the concern is not resolved, the private school has the right to file a formal written complaintwith OSPI. |WAC 392-168

29. Formal, Written Complaint 1. Statement that the district, or other educational agency, or in some cases OSPI, has violated a requirement of a federal statute or regulation that applies to a program requiring equitable participation. 2. Specific requirement alleged to have been violated. 3. Facts on which the complaint is based. 4. Name and address of the complainant. 5. Expected resolution of the alleged violation. 6. Signature of the complainant. Complaints Private School Participation in Federal Programs Mail to Office of the Superintendent of Public Instruction Private Schools Unit P.O. Box 47200 Olympia, WA 98504-7200

30. Federal Programs • Title I, Part A • Title I, Part C Migrant Education • Title II, Part A • Title III • Title IV, Part A • Title IV, Part B • Carl Perkins • See Attachment A of Bulletin B012-19 Private School Participation in Federal Programs for more information about each program.

31. Title I, Part A Improving Basic Programs

32. Title I, Part A Private School Participation Purpose Supplemental educational services to provide all children significant opportunity to receive a fair, equitable and high-quality education, and to close educational achievement gaps.

33. Title I, Part A Private School Participation Level of Funding for Services Funds are generated based on the number of private school students from low-income families… Who Reside in the participating Title I, Part A public school attendance areas Attend private schools, whether the private schools are located within or outside the district’s boundaries And

34. Title I, Part A Private School Participation Eligible Students for Services Private school students… Reside in the participating Title I, Part A public school attendance areas Who Are failing or most at risk of failing—rank order—to meet state academic standards And

35. Title I, Part A Private School Participation Selection & Process Poverty Is Not a Criterion for Services Students are selected on the basis of multiple, educationally-related, developmentally-appropriate criteria. District chooses children from the list of eligible students the private school provides. District has a process to meet the needs of eligible students who attend a private school outside the district.

36. Title I, Part A Private School Participation SupplementalServices Methods and instructional strategies proven to increase academic achievement. Instructional program that not only supplements, but is well coordinated with the instruction private school children receive in their regular classrooms.

37. Service Options for Students ― Instructional services outside the regular classroom ― Extended learning time before/after school and through the summer ― Family literacy ― Academic counseling ― Early childhood learning support ― Home tutoring ― Computer-assisted instruction Title I, Part A Private School Participation in Federal Programs There are many more…

38. Options for Teachers & Families Title I, Part A By law, equitable services may extend to the teachers and parents of Title I-served students. Districts make decisions about these services through the consultation process. • Professional Development • ― Should address how teachers can support academic achievement of students served in Title I. • Parent Involvement • ― Conducted independently, or in conjunction with the district’s regular parent involvement program. Private School Participation in Federal Programs

39. Title I, Part A Private School Participation Who Provides Services? District Employee or Third-Party Contractor Individual | Association | Agency | Organization • Private school teachers are allowed to provide services outside the timethey are employed by the private school. • Paraeducators and teachers must meet Title I, Part A requirements if an “employee” of the district.

40. The Title I, Part A Record of Agreed Upon Services serves as documentation of the services agreed to during consultation, and only applies to Title I, Part A. Upload one Title I, Part A Record of Agreed Upon Services in the Private Participation in Federal Programs application, for each private school participating in Title I, Part A. Title I, Part A Record of Agreed Upon Services Private School Participation in Federal Programs

41. Title I, Part A Out-of-District Services

42. Title I, Part A Private School Participation Out-of-District Services: Communication Process • Eligible students who attend a private school outside the local school district can receive services. • Districts must develop a processto communicate with their neighboring districts and private schools.

43. Out-of-District Services Title I, Part A Out-of-District Services The Intent to Participate portion of the Private Participation in Federal Programs application includes information about the resident districts of private school students. Federal program directors should use this data to communicate with private schools who have students from their districts. Private School Participation in Federal Programs

44. Interlocal Agreements

45. Title I, Part A Private School Participation Interlocal Agreements: Definition • Agreements between public school districtsin which the districts agree to provide services for eligible students in private schools.

46. Law & Regulation State Law | Interlocal agreement should address “powers, rights, objectives, and responsibilities of contracting parties” in RCW 39.34.080. Include duration and purpose. Sample interlocal agreements are posted on the OSPI ESEA Private School website: http://www.k12.wa.us/ESEA/PrivateSchools.aspx. Interlocal Agreements Private School Participation in Federal Programs

47. Key Questions to Answer in an Interlocal Agreement • Funds, Fund Codes, & Accounting Interlocal Agreements • How will you finance services for private school students? • How will you develop and maintain the budget? • Which district will be the fiscal agent? • How will you charge for services? • How will code services for federal/state reporting? • How will the accounting work? • Which district(s) does the accounting? • Services, Timeframe, &Termination • When will services begin? • What timeframe is in place for consultation and service delivery? • How will you terminate this interlocal agreement and dispose of any property associated with it? Private School Participation in Federal Programs

48. Title I, Part A Private School Participation Interlocal Agreements: Important Issues • Who determines student eligibility? • Who assesses the students? Which assessments? • Who provides the services? • Where will the services be provided? • How will student performance be measured?

49. Ask Questions. Get Help. Title I Office 360-725-6100

50. Title I, Part C Migrant Education