Title I-A : Topics Roundup

1. Title I-A: Topics Roundup Karl Koenig and Ed Peltz · April 3, 2014

2. Around the Horn Timeline Primary Goal Guidance Building Eligibility Page School Allocations Eligibility Criteria Title I Fiscal Requirements Around Title I Topics Onsite Reviews

3. Federal Programs TimelineCCIP Doc Library • Planning/Evaluation • Data • HQT/Qualifications of Paraprofessionals • Fiscal • ESEA Flexibility Waiver 20% Set-Aside Requirement • Parent Involvement

4. Primary Goal of Title I-Part A To provide supplemental instruction… to the students most at risk of failing to meet the State’s academic content standards… in the buildings with the highest percentage of low-income students.

5. Guidance

6. Title I General Information Targeted Assistance School (ESEA Sec. 1115) Schoolwide School (ESEA Sec. 1114, U.S. Department of Education Guidance on Designing SW Programs, March 2006)

7. Know What You Can & Can’t Do U.S. Department of Education (ED.gov) Non-Regulatory Guidance: • Identification/Selection of School Attendance Areas and Allocation of Title I Funds, 2003 • Nonpublic Services, 2003 • Title I Fiscal Issues, 2008 • Parent Involvement, 2004 • School Wide, 2006 • Preschool, 2012

8. Know What You Can & Can’t Do CCIP Doc Library/Help Links ESEA Flexibility Waiver –ODE Homepage OMB Circular A-87 – Cost Principles Education Department General Administrative Regulations (EDGAR)

9. Know What You Can & Can’t Do Substantially Approved Date Uniform School Accounting System (USAS) Annual Carryover: 15 percent of allocation for allocations of $50,000 or more • Once in three years waiver request

10. Know What You Can & Can’t Do Time and Effort vs. Semi Annual Certification OMB’s New Uniform Guidance for Federal Grants – stay tuned! Decision Framework to inform the Needs Assessment

11. Fiscal Issues Failure to meet program objectives • Failure to demonstrate compliance with program requirements Serving ineligible students Unallowable/inadequately documented costs

12. Necessary and Reasonable Proposed cost relates to a valid educational or administrative decision Does the cost make sense in light of Title I Requirements Adequate Documentation

13. Eligibility Criteria

14. Title I, Part A Funding • State grants funds to LEAs based on statutory formula • LEA allocates funds to schools based on ranking and serving • Allocations based on low income data (same for nonpublic) • Service based on academic need (same for nonpublic)

15. Eligibility Criteria At/above 35% low income At/above district-wide low income average Rounding, feeder patter, previously served (one time), less than 1,000 students in district

16. Eligible School Attendance Areas • Must rank all schools based on percentage (not the number) of low-income children eligible for free and reduced-priced lunches. • CCIP Doc Library Title I-A, USDE Guidance: Eligible School Attendance Areas

17. 75% Rule 75% Rule: Must first serve, in rank order of low-income percentage, its schools above75percent

18. Rank Order Exceptions Title I Eligible High Schools identified as a Priority School Districts with less than 1,000 students

19. Eligible School Attendance Areas Default sort order by low income. May Sort Order by grade span for eligible schools below 75% low-income. If sort order, each group must be ranked in order of low-income percentage.

20. Building Eligibility Page

21. **Building Eligibility Page *Claims Reimbursement and Reporting System-Office of Child Nutrition **Doc Lib: Title I-A, USDE 2003 Guidance, Eligible School Attendance Areas

22. Building Eligibility Page Use these columns only to serve buildings that do not qualify on their own.

23. Building Eligibility CEO • Sort order is by default, highest to lowest low income percentage.

24. Building Eligibility Sort Order • What determines the sort order?

25. Building Eligibility Sort Order • Sort Order by Grade Span

26. Building Eligibility Sort Order • Can the LEA sort by Grade level? • Are they required to serve the 75% building?

27. Building Eligibility Sort Order • What “other” factor qualifies School B?

28. Building Eligibility Sort Order • How does the 5-8 school qualify as SW-New?

29. Building Eligibility Sort Order • Feeder Pattern qualifies the high school

30. Skipped Schools Must provide “Comparable Services Supplement with state/local funds for Title I-like program equal to district per pupil amount Comply with comparability assurances and provides nonpublic services

31. School Allocations

32. School Allocations • School Allocation PPA Page (Help link references) • Based on school’s total low income number • Higher PPAs must be in higher schools on ranked list • 125 vs. 100 Percent Rule • Non-public allocation • Remaining balance

33. School Per Pupil Allocations Determines School Budget Based on school’s total low income number Higher PPAs must be in higher schools on ranked list

34. School Allocation PPA List 125% Rule • Per Pupil Amount (PPA) = $548.32

35. School Allocation PPA List 100% Rule • Per Pupil Amount (PPA) = $527.73

36. School Allocation PPA List 100% Rule • Per Pupil Amount (PPA) = $548.32

37. Title I Fiscal Requirements

38. Title I Fiscal Requirements Maintenance of Effort (MOE) Comparability of Services Supplement, Not Supplant

39. Comparability CE To be eligible to receive Title I funds, districts must use state and local funds to provide services in Title I schools at least comparable to services provided in non-Title I schools.

40. Comparability • If all schools in an LEA are Title I schools, an LEA must use State and local funds to provide services that, taken as a whole, are substantially comparable in each school.

41. Exempt from Comparability E Districts with only one building per grade span, e.g., K-5, 6-8, 9-12.

42. Grade-Span Overlap Rule Comparability applies if grade spans overlap by at least two grade levels. Does not apply if there are three or more grade levels outside of the overlap, either above or below, but not combined.

43. Methods for Determination 3 Student-Instructional Staff Ratio Expenditures Per Pupil Student/Instructional Staff Salary Ratio

44. Written Procedures Update Annually Identify the Method to Determine Comparable Services Establish Procedures for Making Adjustments if Schools are not Comparable

45. Documentation PDF Reports – saved in web-based system Signed/Dated Records – 3 years Include District Organizational Chart

46. Early Determination Enables Districts to make Adjustments with the Least Amount of Disruption CCIP Doc Library includes EXCEL Templates that can be used to Test Comparability (Financial-Comparability-Title I)

47. Comparability & MOE Website ACCESS CCIP Funding Option in left Menu Bar CCIP Funding Option in left Menu Bar SAFE Account Superintendent, Treasurer, Data Entry Funding-CCIP Superintendent, Treasurer, Data Entry Funding-CCIP

48. Maintenance of Effort Districtmay receive funds under Title I, Part A for any fiscal year only if the Ohio Department of Education finds that either the combined fiscal effort per student or the aggregate expenditures of the district’s state and local funds for preceding fiscal year was not less than 90 percent of combined fiscal effort or aggregate expenditures for the second preceding fiscal year. - ESEA 9521

49. Maintenance of Effort Ohio Department of Education must reduce amount of allocation of funds under covered programs in any fiscal year in exact proportion by which the district fails to maintain effort by falling below 90 percent of combined fiscal effort per student and aggregate expenditures (using measure most favorable to the district.)

50. Supplement Not Supplant District must use Part A funds to supplement, notsupplant regular non-federal funds. – ESEA 1120A (b)