PSRC Federal Programs Guidance

Title I is committed to enhancing the academic performance of all students so they may be successful and productive members of society. This is accomplished through intensive staff development and support of visionary programs designed to sustain a learning environment which addresses the varying needs of students. Schools develop their goals that address student needs based on frequent assessments.

• Professional development opportunities that will assist school personnel in developing the skills and capacities necessary for student success.

• Supplemental instruction in reading, writing, and mathematics to assist students in gaining the knowledge and skills that will enable them to be successful in the work force or higher education.

• Support, resources, and educational opportunities for parents to become active, involved participants in their child’s education.

• Coordination between other school programs, civic organizations, and community agencies to ensure that children and families receive necessary health and social services.

• Technical support to the Computer Assisted Instructional Component of the Title I program.

Title I schools must adhere to federal regulations detailed in the ESSA.

The purpose of this title is to provide all children with significant opportunity to receive a fair, equitable, and high-quality education, and to close educational achievement gaps.

1. School Attendance Areas: A district must rank order all of its school attendance areas based on the percent of low income children. The district must serve, in rank order of poverty, its schools above 75% poverty. ESSA 1113(a)(6) outlines an exception to these ranking and serving rules. Districts with a total enrollment of less than 1,000 children are not subject to ranking and serving requirements, including the 75% rule. Then the district has the option to (a) continue on with the district-wide ranking or (b) rank remaining schools by grade span grouping. There is an exception to the ranking rule; a district may lower the poverty threshold to 50% for high schools. Districts are not required to serve high schools above 50% poverty, it is optional. If a district elects to use the exception, all high schools at or above 50% poverty must be served before elementary and middle schools with less than 75% poverty.

2. Allocations: A district must allocate Title I, Part A funds to participating schools based on Title I, Part A allocation procedures. Districts serving any school below 35% low-income must allocate Title I, Part A funds to participating schools based on a minimum per pupil amount using the 125% rule.

3. Children from Local Institutions for Neglected Children: A district must set aside funds for the educational needs of children in local institutions for neglected children. Funds for service to the institution should be put in the district set-aside before funds are allocated to schools.

4. Homeless Children: Districts must provide services for homeless children who attend Title I and non-Title I schools, including providing educationally related support services to children in shelters. The services in non-Title I schools must be comparable to those provided to children in Title I schools. A district must reserve “such funds as may be necessary” (see ESSA 1113(c)(3)(A)), to serve homeless children attending both Title I and non-Title I schools (regardless of receiving a McKinney-Vento Homeless Assistance Grant). Funds must be reserved even if all schools in the district are Title I schools. The reserved funds must address the educational needs of the homeless students and must take into account homeless students enrolled in private schools, institutions for neglected children, and local institutions for delinquent youths.

5. Private School Children: A district must provide eligible private school children, their families and teachers with Title I, Part A educational services that are equitable to those provided to eligible public school children, their families, and teachers. These services must be determined in consultation with private school officials. See the services to eligible private school children section for more information on how Title I, Part A funds are used to provide equitable services to eligible private school children.

6. Preschool Programs: Preschool programs supported by Title I, Part A funds must comply with Head Start performance standards unless the preschool program is based on the Even Start model. See the preschool section for more information on how Title I, Part A funds are used to serve preschool programs.

7. Parent and Family Engagement: A district with an allocation over $500,000 must reserve and spend at least 1% of its allocation in the district set-asides for parent and family engagement activities and must distribute 90% of that 1% to Title I schools. A proportionate amount of the private school allocation must be used for parent and family engagement for parents of participating private school students. A written parent and family engagement policy at the district level must be developed jointly, agreed upon, and distributed to parents of participating children. The parent and family engagement policy must include:

   • Overall expectations for parent and family engagement;

   • Components for building capacity for more effective parent and family engagement; and

   • An annual evaluation of the content and effectiveness of the parent and family engagement activities in increasing participation of parents and whether there are barriers to greater participation.

8. Paraeducators: Districts must ensure that all paraeducators working in a program supported with Title I funds meet one of the following requirements as outlined in ESSA 1111(g)(2)(J) and (M):

   • Completed at least 2 years of study at an institution of higher education;

   • Obtained an associate’s (or higher) degree; OR

   • Met a rigorous standard of quality and can demonstrate, through a formal State or local academic assessment – knowledge of, and the ability to assist in instructing, reading, writing, and mathematics; or knowledge of, and the ability to assist in instructing, reading readiness, writing readiness, and mathematics readiness, as appropriate.

9. Maintenance of Fiscal Effort: A district may receive Title I, Part A funds for any fiscal year only if either its combined fiscal effort per student or the aggregate expenditures of the district and the state with respect to the provision of free public education by the district for the preceding fiscal year is not less than 90% of the combined fiscal effort or aggregate expenditures for the second preceding fiscal year.

10. Comparability: A district must meet the comparability requirement as follows: A district may receive Title I, Part A funds only if it uses state and local funds to provide services in Title I, Part A schools that are at least comparable to the services provided in schools that are not receiving Title I, Part A funds.

11. Supplement versus Supplant: A district may use Title I, Part A funds only to supplement the funds that would, in the absence of Title I, Part A funds, be made available from non-federal sources for the education of children participating in Title I, Part A programs. In no case may Title I, Part A funds be used to supplant, or take the place of, funds from non-federal sources. ESSA 1118(b)(2) changed the way that districts demonstrate compliance with the Supplement not Supplant requirement. The LEA must demonstrate that the methodology in which state and local funds are distributed to each school receiving Title I funds ensures that the schools receive all of the state and local funds they would otherwise receive if they were not receiving Title I funds. Funds must be distributed in a Title I neutral manner; the LEA cannot determine the amount of state and local funds allocated to a school based on the school’s Title I allocation. The Supplement Not Supplant Methodology must be updated annually and kept on file at the district office. Currently there are no federal regulations or guidelines regarding the revised Supplement Not Supplant test. A possible method of evaluation could include:

    • Examine how the district distributes state and local funds/resources to schools.

    • Verify the distribution method does not take away from state and local funds/resources from Title I schools because they participate in the program.

    • Verify the district followed its distribution process so that Title I schools received all of the state and local funds/resources they would have received if not participating in Title I.

District-level expenditures are evaluated on a purchase by purchase basis. District-level expenditures remain subject to the three presumptions of supplanting in place prior to ESSA. Under these assumptions a Title I supplanting violation is presumed if Title I, Part A funds are used for:

11. • An activity required by federal, state, or local law;

    • An activity paid for using state or local funds in the prior year; or

    • The same services for Title I students that non-Title I students receive through state and local funding.

12. Carryover Funds: For districts with Title I, Part A allocations of $50,000 or more, carryover funds on September 30 are limited to no more than 15%. A state education agency (SEA) may grant a one-time waiver of the percentage limitation during a three-year period upon written request of a district if it determines the request is reasonable and necessary or if supplemental appropriations become available. A school district that is interested in obtaining a waiver of the carryover limitation in section 1127(a) so that it may carry over more than 15% of its Title I, Part A, Subpart 2 allocation must apply to its SEA in accordance with the SEA’s regular procedures for granting a waiver of the carryover limitation.

13. Transferability of Funds: A district may transfer up to 100% of funds from other federal programs (Title II, Part A; and Title II, Part D) into Title I, Part A. A district may not transfer Title I, Part A funds into other federal programs.

14. Records: Records must be maintained at both the school and district level for the current year and three (3) prior years. Best practice is to maintain records for the current year and five (5) prior years.

Definition: A school with at least 40% low-income is eligible to plan and implement a schoolwide program (SWP). A schoolwide program must upgrade the entire educational program in the school in order to raise academic achievement for all students.

An LEA may operate a schoolwide program in a school with less than 40% poverty in order to allow the LEA to implement interventions aligned with turnaround principles or an intervention that is based on the needs of the school’s students.

Schoolwide program checklist:

Is based on one year of planning and is built on schoolwide reform strategies, rather than on separate add-on services.

Provides flexibility in spending federal, state, and local funds as long as the school engages in strategies that increase the amount and quality of learning time and help provide a high-quality curriculum for all children, according to a comprehensive school improvement plan or a SWP plan to help children meet North Carolina’s standards.

Focuses on results. The flexibility in the use of funds must result in increased achievement by student populations (economically disadvantaged, racial and ethnic groups, students with disabilities and students with limited English proficiency).

Meets at least one of the following qualifications:

1. A Title I school with 40 percent or more of its students living in poverty, regardless of the grades it serves.

2. A Tier I or Tier II school in a state that requested and received a waiver through the School Improvement Grant (SIG) program that received funds to implement one of the SIG intervention models.

3. A Title I school under 40% poverty that receives a state waiver or was served the previous school year as a schoolwide program and the LEA wishes to continue services for a school that dipped below 40% poverty using the grandfather clause.

SCHOOLWIDE PROGRAM PLAN CORE COMPONENTS

There are three core components required by statute for effective implementation of a schoolwide program (SWP): conducting a comprehensive needs assessment, preparing a comprehensive schoolwide plan, and annually reviewing and revising, as necessary, the schoolwide plan. Each component must be described in the SWP plan.

Title I regulations require that a school operating a schoolwide program annually evaluate the implementation of, and results achieved by, the program. The evaluation must determine whether the program was effective in increasing the achievement of students in meeting the challenging state standards, particularly those students who had been furthest from achieving the standards. The school must revise its plan as necessary based on the results of the evaluation to ensure the continuous improvement of student achievement. The intent of the evaluation is to determine if strategies are contributing to improvement in student achievement or increases in other activities like parent and family engagement or high quality professional development that lead to increases in student achievement.

The school must decide whether the review will be conducted internally (by school staff) or externally (by a person or persons outside of the school such as district staff, regional educational laboratory, institution of higher education or any technical assistance provider). The decision should be made collaboratively between schools and their districts. Districts and schools are strongly encouraged to use outside reviewers when possible but at least every couple of years.

The annual evaluation examines whether the schoolwide program is being effectively implemented and whether the implementation is improving student achievement. The annual review should not only address student achievement but also teacher quality, parent and family engagement, coordination of funds and other components that directly and indirectly affect achievement. The annual review is designed to reveal areas of strength within the program and areas that need revision in order to better position the school to continue making academic improvement.