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Introduction to Title I Fiscal Requirements

Introduction to Title I Fiscal Requirements. Presented by Kristen Tosh Cowan, Esq. Brustein & Manasevit, PLLC ktoshcowan@bruman.com Spring Forum 2011 . Overview . 1) LEA-to-School allocations 2) Set asides 3) Equitable Services allocation 4) Carryover 5) Comparability

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Introduction to Title I Fiscal Requirements

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  1. Introduction to Title I Fiscal Requirements Presented by Kristen Tosh Cowan, Esq. Brustein & Manasevit, PLLC ktoshcowan@bruman.com Spring Forum 2011

  2. Overview 1) LEA-to-School allocations 2) Set asides 3) Equitable Services allocation 4) Carryover 5) Comparability 6) Reauthorization Predictions

  3. Resources -- Allocations • Statute • Section 1113 • Regulations • 34 CFR §200.77-78 • Non-regulatory Guidance • August 2003

  4. Resources – Cross-cutting • “Title I Fiscal Issues” Feb 2008 www.ed.gov/programs/titleiparta/ fiscalguid.doc • Consolidating funds in schoolwide programs, MOE, SNS, Comparability, Grantbacks, Carryover

  5. LEA-to-School Allocations “Ranking and Serving” Rules • 1) Identify Eligible Schools • 2) Rank Schools in Order of Poverty • 3) Serve Schools Strictly in Accordance with Rank

  6. Step 1: Identify Eligible Schools

  7. Eligible School Attendance Areas • Percentage of children from low-income families who reside in area . . . . AT LEAST AS HIGH AS . . . . • percentage of children from low-income families in LEA

  8. LEA Discretion: Eligibility • “35 Percent Rule” • May designate as eligible • Must still serve in order

  9. LEA Discretion: Eligibility • “Grandfathering” option • Continue if served last year • But, only continue for one year

  10. 5 Poverty Measures: • Census data • Free and reduced lunch • TANF • Medicaid eligibility • Composite of above

  11. Step 2: Rank Eligible Schools in order of poverty

  12. Ranking and Serving • Exceeding 75% poverty • Strictly by poverty • Without regard to gradespan • At or below 75% poverty • May rank by gradespan

  13. Exception: NO Rank & Serve if • Small LEA exclusion • If <1000 students • One school at each gradespan

  14. Step 3: serve schools STRICtLY in order of rank

  15. Allocation to Schools • BUT first, calculate set-asides • Allocate to schools based on total # of students from low income families residing in area (including nonpublic) • Discretion on amount of PPA • Higher PPAs must be in higher schools on ranked list

  16. Allocations given without regard to schoolwide or targeted assistance model Title I funding . . . . . . To school based on poverty . . . To student based on academics

  17. “125 Percent” Rule • If serve any school <35% • Then PPAs for all schools must be at least 125% of LEA’s PPA under Title I allocation • Entire LEA Title I-A Grant # of low income on census

  18. EXAMPLE: $1,000,000 total Title I grant 2,000 poverty students = $500/ student PPA If serve school <35% poverty, $500 x 1.25 = $625 PPA

  19. Exception: Rank & Serve • “Skip” school, if: • Comparability met • Receiving supplemental state/local funds used in Title I-like program • Supp. State/local funds meet or exceed amount would be received under Title I • Still count and serve nonpublic in area

  20. Title I Set-Asides

  21. LEA MUST reserve specific percentage: • 20% choice transportation and SES • 1% parental involvement • 10% professional dev (if LEA ID)

  22. LEA MUST reserve but not specific percentage: • Administration (public and private) • Homeless • Neglected & delinquent

  23. LEA MAY reserve: • Incentives to teachers in ID schools (<5%) • Professional development • “other authorized activities” • Summer school • Preschool • Districtwide program

  24. CAUTION: DON’T CIRCUMVENT “RANKING AND SERVING” RULES!

  25. Calculating % set asides • Take off entire LEA grant • Transferability: • Includes transferred amounts • Carryover: • Does not include carry over (apply % only in first year available)

  26. Example • Title I, Part A = $500,000 • Transferred $30,000 from Title II • Carried over $50,000 from prior year • Each % set aside applies to $530,000

  27. Funds for Supp Ed Services and Choice Transportation • Amount equal to 20% of LEA allocation (unless lesser amount needed) • To pay transportation for choice • To satisfy all requests for SES services • Both

  28. If no SES, then 20% on choice • If no choice, then 20% on SES • If both, then minimum of 5% for choice, 5% for supp services, and 10% for either

  29. Credit for “Parent Outreach” • Allow limited amount of funds for “parent outreach” to count toward 20% • Capped at 0.2% of LEA Part A grant • May spend more for outreach, but only 0.2% counts toward 20% • EX - $1 million LEA grant; • 20% = $200,000 • 0.2% = $2,000 can count toward $200,000

  30. What costs count as “parent outreach”? Parent notices, communication through the media, internet, and community, displaying information on LEA’s website, and parent fairs Allowance, not a requirement

  31. “Amount equal to 20%” • May use Title I, Part A; school improvement (sect. 1003); ARRA • transferability • State, local, or private funds

  32. If use Title I Funds, from where? • Off the top of LEA allocation OR from individual school allocations? • Both permitted • If school in corrective action or restruct, <15%

  33. Use 20% “unless a lesser amount is needed” How do you know if less is needed?

  34. To spend less than 20%, LEA must: 200.48(d)(2)(i) • Partner, to extent practicable, with outside groups (CBO, FBO, etc.) • Send timely, accurate notice to parents • Ensure SES sign-up forms given directly to all eligible students/ parents • Ensure SES sign-up forms made widely available through broad dissemination (Internet, other media, public agencies)

  35. 5. Provide (at a minimum) two enrollment windows at separate points in school year of sufficient length 6. Ensure SES providers are given access to school facilities, using a fair, open and objective process, on same basis as others

  36. Does LEA need SEA’s permission before reallocating the 20%? NO!

  37. LEA must document and notify SEA! Before reallocating remainder of 20%, LEA must: Maintain records demonstrating it has met criteria Notify the SEA that it met criteria Notify SEA of amount of remainder it intends to spend on other allowable activities

  38. SEA monitors 20% compliance through: (200.48(d)(3)) • Regular monitoring (on multi-year cycles) • Ensure 6 criteria are met • More frequent monitoring • For LEAs that have spent “significant portion” of 20% on other activities AND subject of “multiple complaints, supported by credible evidence,” regarding implementation of choice or SES • SEA must complete its review by the beginning of the next school year

  39. Consequences for non-compliance200.48(d)(4) • If SEA finds LEA did not meet all 6 criteria, then LEA must in the subsequent year: • Spend amount equal to the remainder of 20% in the subsequent year on choice/ SES, in addition to new 20%, OR • Meet all 6 criteria and obtain permission from the SEA before spending less than full 20% in subsequent year.

  40. How to reallocate? • If took school allocations, then reallocated to those schools • Subject to equitable participation of private school students

  41. Set Aside for Parent Involvement • For LEAs with Part A allocations >$500,000 • 1% minimum reserved • Proportional amount to private students • 95% of remainder to schools • 5% of remainder kept at LEA

  42. Equitable Services for Private School Students

  43. Equitable Services:Deriving Allocation General Formula: • Based on number of: • Private school students • From low-income families • Who reside in Title I-participating public school attendance areas

  44. Calculate Allocation for Instruction: • Identify eligible school attendance areas • Rank in order of poverty • Strictly serve in rank order (i.e., ID who is “Participating Public School”) • Calculate PPA for each area • Derive allocation amount for each area • must include nonpublic low-income # • Reserve nonpublic amount • PPA x # of nonpublic low-income students who reside in participating public sch area

  45. Reservation for districtwide instruction • If LEA reserves for “districtwide instructional programs for public elementary and secondary” • Then proportional amount goes to nonpublic • 34 CFR sect 200.64(a)(2)(i)(A)

  46. Example • LEA reserves $500,000 for districtwide reading initiative • Of all low-income in LEA residing in participating attend areas, 5% are private • 5% of $500,000 to private allocation

  47. Applies to: • Summer school • After school programs • Reading coaches DOES NOT APPLY TO: • SES/ Choice (20%) • Preschool

  48. Reservation for teachers and families • If LEA reserves funds for parental involvement or professional development • Then proportional amount to nonpublic • 34 CFR sect 200.65(a)

  49. Example • LEA reserves 1% of $500,000 allocation for parental involvement, or $5,000. • Of all low-income families residing in participating attend area, 6% are private. Then 6% of $5,000 used for families of participating private school students.

  50. Carryover • General Rule: May carryover up to 15% of Title I, Part A • Reallocated by state if exceeds • Waiver

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