What Does Supplement, Not Supplant Mean?

1. What Does Supplement, Not Supplant Mean?

2. Fiscal Requirements • The Elementary and Secondary Education Act began in 1965 • Purpose is to contribute additional resources to provide targeted services beyond the regular education program to specific categories of students

3. Fiscal Requirements • Supplement, not Supplant • Maintenance of Effort • www.michigan.gov/mde • Under Offices, click on State Aid & School Finance • See Publications (Procedures for Determining Maintenance of Effort) • Districts must demonstrate that the level of state and local funding is maintained from year to year

4. Fiscal Requirements • Title I, Part A Comparability • Districts must document that services provided with state and local funds in Title I schools are comparable to those provided in non-Title I schools. • If all schools in a grade span are Title I, then the comparison is made between higher poverty schools and lower poverty schools.

5. Supplanting [Title I, Part A Section 1120 A (b)] • Substituting or replacing funds from non-federal sources (state/local) for existing or previously existing instructional programs or non-instructional services • Substituting or replacing funds from other federal/state programs required by law for specific categories of students

6. Supplementing • Categorical funds are additional resources to provide targeted services beyond the basic educational program • Categorical funds do not replace, nor are they a substitute for, Foundation dollar expenditures

7. Supplement, Not Supplant • State and local funds must be used for all activities that are a district responsibility • A district is responsible for all school operating requirements under state and local laws or policy

8. District Responsibility This includes, but is not limited to: • Basic education classroom teacher salaries • Support personnel salaries • Administrator salaries • Basic classroom supplies and materials • Operation and maintenance • Contractual agreements with employees • Transportation • Required state assessments

9. Supplement, Not Supplant Analogy Core Curriculum = The Cake ELA, Math, Science, Social Studies, Arts • Basic cost responsibility to the district is… • The Cake

10. Supplement, Not Supplant Analogy Other Curriculum = Frosting PE, Technology, Business, etc. • Basic cost responsibility to the district is… • The Cake and • The Frosting

11. Supplement, Not Supplant Analogy Supplementary=The Sprinkles and the Cherry • Title I, Part A - Extends Learning Time for Eligible Students • Title I, Part C - Services to Migrant Students • Title II, Part A - Professional Development/Class Size Reduction • Title III - Services to Limited English Proficient Students • Section 31a - Direct Support or Direct Instruction to Eligible Students

12. Analogy • Categorical federal and state funds cannot replace the cake or frosting, BUT • Categorical federal and state funds can provide an additional resource.

13. Analogy • For example, classroom text books (cake) are a district responsibility, BUT • The extra leveled books (for Title I or III students) can be considered an additional resource.

14. Analogy • Curriculum development is a district responsibility, BUT • Professional development on teaching strategies can be considered an additional resource.

15. Analogy • Classroom teachers are a district responsibility, BUT • A Reading Recovery teacher may be considered an additional resource.

16. Analogy • For example, when the Title I computer wears out and must be replaced or repaired, Title I categorical funds may pay the cost.

17. Staffing Example - Director The director of state and federal program position is split-funded between state funds and federal categorical funds. • 50% of salary for administrative oversight of district responsibilities and • 25% of salary for administrative oversight of Title I, Part A and • 25% to provide professional development for Title II, Part A activities Time logs must be kept to ensure that Title I and Title II funded time is used for allowable program activities.

18. Staffing Example - Principal EDGAR Federal Regulations do not allow payment of a part of a building principal’s salary out of Title I, Part A unless:

19. Staffing Example - Principal • Documentation exists from Local School Board Action, which shows that the position as a principal is not full time And

20. Staffing Example - Principal • Documentation exists which states what part of the day is designated for Title I activity • a reasonable time when the principal is not available as a principal to talk with students, parents, etc., because he/she is working on Title I activities (perhaps a separate office) And

21. Staffing Example - Principal • Documentation exists that includes a time log of all activities charged to Title I and is maintained for single audit purposes, OR A stipend may be paid, to a principal for Title I, Part A duties beyond the contract day/year. Time logs must be kept to ensure that only Title I activities are conducted during this time period.

22. SCENARIOS • Audience participation • Read scenario on screen • Discuss with partner • Hold up supplement or supplant card

23. SCENARIOS A superintendent wants to fund full-day kindergarten in all elementary buildings. Title I, Part A funds would be used for half of each kindergarten teacher’s salary and benefits in Title I buildings (additional time). Non-Title I buildings would be funded by general funds. Is this supplement or supplant?

24. SCENARIOS A superintendent wants to fund extended-day kindergarten in the Title I elementary buildings. Title I, Part A funds would be used for half of each kindergarten teacher’s salary and benefits (additional time). Only Title I eligible children would attend the extended day program. Is this supplement or supplant?

25. SCENARIOS Title II, Part A funds are being used for class-size reduction in second grade. The class-size reduction is needed to meet a contractual responsibility. Is using Title II, Part A funds supplement or supplant?

26. SCENARIOS A high school counselor is fully funded by Section 31a. The counselor works on scheduling, goal setting, college applications with all students and is the MEAP coordinator for the district. Is this supplement or supplant?

27. SCENARIOS A district has hired a teacher with Title III funds. She is teaching 5 classes of English at the high school. All of the students in these classes are limited English proficient. This class counts toward graduation for these students. Is this supplement or supplant?