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Ensuring Equitable Services for Private Non-Profit School Children

Ensuring Equitable Services for Private Non-Profit School Children. Presenters. Linda Harrington Yvonne Mayfield Pat Meaux Field Services Consultants Office of School Improvement. Reference Materials. The following handouts are available on MDE’s website, www.michigan.gov/osi

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Ensuring Equitable Services for Private Non-Profit School Children

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  1. Ensuring Equitable Services for Private Non-ProfitSchool Children

  2. Presenters Linda Harrington Yvonne Mayfield Pat Meaux Field Services Consultants Office of School Improvement

  3. Reference Materials The following handouts are available on MDE’s website, www.michigan.gov/osi Ensuring Equitable Services for Private Non-Profit School Children - • Power Point • Overview Technical Assistance Packet – Working with Private Schools • Allocation Worksheets • Non-Regulatory Guidance • Private School Questions and Answers

  4. Reference Materials • Technical Assistance Packets – • Title I, Part A • Title I, Part C • Title II, Part A • Title II, Part D – (ARRA Recovery Funds only) • Title III, Part A • Title V, Part A –(Innovative Programs only for Small Rural School Achievement Program (SRSA) Districts)

  5. Requirements

  6. Equitable Services RequirementDistrict Responsibility Equitable Participation in: • Title I, Part A Improving the Academic Achievement of the Disadvantaged • Title I, Part C Migrant Education • Title II, Part A Teacher & Principal Training & Recruiting • Title II, Part D Enhancing Education Through Technology (ARRA Recovery Funds only) • Title III, Part A Language Instruction for Limited English Proficient and Immigrant Students • Title V, Part A Innovative Programs only for Small, Rural School Achievement Program (SRSA) Districts

  7. Equitable Services Requirement In order to meet Equitable Services requirements, a Local Educational Entity (LEA) must annually notify all private, non-profit schools within its boundaries and outside of district if resident students attend, of eligibility for equitable participation with Title programs

  8. Equitable Services Requirement Low-income parents with private school children are included in census poverty counts that generate funds the Local Educational Agencies (LEAs) use forTitle I services

  9. Equitable Services RequirementChild Benefit Theory This theory was developed to comply with the Constitutional prohibition against Federal funding to private schools. No funds go to private schools. Under the Child Benefit Theory, Title I services – • Benefit the individual child, not the private school • Are provided by the LEA, not the private school

  10. Equitable Services Requirement • In order to meet equitable services requirement, an LEA must: • Provide eligible private school children with an opportunity to participate; • Meet the equal expenditure requirements for instruction, professional development, and parent involvement; • Assess student needs and the effectiveness of the Title I program; and • Begin Title I programs at the same time as the Title I programs for public school children.

  11. Equitable Services Requirement Program Responsibility • The LEAis responsible for designing and implementingTitle I programs for its resident children who attend private schools, even those attending private schools located in other LEAs • Private school officials have no authority to make any decision

  12. Funding for Equitable Services

  13. An LEA may calculate the number of private school children* who are from low-income families and live in participating public school attendance areas in several ways: Use same measure of poverty as for public school children Use comparable poverty data from a survey and must extrapolate results if actual data are unavailable Use comparable data from a different source Use an equated measure * LEA must collect poverty data on their resident low-income children attending private schools in other LEAs Funding for Equitable ServicesCollecting Poverty Data

  14. Funding for Equitable ServicesGenerating Funds for Instruction • Low-income public and private school children residing in the same Title I attendance areas generate the same per-pupil amount (PPA) • PPA x the number of low-income private school children residing in participating public school attendance areas = instructional funds for the Title I programs for eligible private school children

  15. Funding for Equitable ServicesUse of Funds Funds generated by low-income private school children who reside in Title I attendance areas must be used only for instructional services

  16. Funding for Equitable ServicesReservation of Funds LEAs must provide equitable participation from funds reserved under §200.77 of the regulations for the purpose of district-wide instructional activities and/or programs* for elementary and secondary public school children * This requirement does not apply to reservations for program improvement required under section 1116 of ESEA, homeless, pre-K, neglected or delinquent programs

  17. Funding for Equitable ServicesCalculations for District-Wide Instructional Activities In participating public school attendance areas: # of private Total # of all school children public & private Proportion of from low- ÷ school children = reservation income families from low- income families Proportion of Amount of Amount of funds reservation x reservation =for equitable services** ** May be added to the instructional funds generated by low-income private school children

  18. Funding for Equitable Services Carryover LEAs must consider the equitable services requirements when making any decision about the use of carryover funds

  19. Equitable Services for Children

  20. Equitable Services for ChildrenSelection of Students • Private school children who reside in Title I participating public school attendance areas AND are failing or most at risk of failing to meet student academic achievement standards • Homeless; 2 preceding years in Head Start; Even Start; Early Reading First; Title I Preschool; Title I, Part C (Migrant Education) • Grades pre-K-2: selected solely on the basis of teacher judgment, interviews with parents, developmentally-appropriate criteria • Grades 3 and above: selected using multiple selection criteria • Poverty is NOT a criterion!

  21. Equitable Services for ChildrenStandards The LEA should use: • Standards that are aligned with the curriculum of the private school • Depending on the number of private schools, there may be more than one standard The State Educational Agency cannot impose standards, achievement levels, or assessments

  22. Equitable Services for ChildrenTypes of Services for Children • Direct instruction outside the regular classroom = pull out model • Tutoring • After- or before-school programs • Saturday programs • Summer school • Counseling • Computer assisted instruction (CAI)

  23. Equitable Services for ChildrenAssessments • After consultation, LEA establishes the assessment it will use to measure the effectiveness against the agreed-upon standards • May use the State assessment or another assessment that is aligned to the agreed-upon standards, such as the assessment used in the private school • All participants are assessed annually, including children receiving nonacademic services

  24. Equitable Services for ChildrenSupplement, Not Supplant • The supplement, not supplant provision applies • Title I services must be in addition to, and cannot replace or supplant, services that would be provided by private schools to their private school participants

  25. Equitable Services for ChildrenSubject Areas and Grade Spans Title I services for private school childrenDO NOT need to be in the same subject areas or the same grade levels as Title I services for public school children. Needs of private school participants determine what Title I services are appropriate. However, the Title I services must be in the same “grade span” as the Title I services for public school participants.

  26. Equitable Services for ChildrenService Providers – LEA Employees • Provider of Title I services must be either an employee of the LEA or an employee of a third party under contract with the LEA • Private school teachers may be employed by both the private school and the LEA; however, they must be independent of the private school during the time they are employed by the LEA to provide Title I services • LEA teachers providing Title I services must meet Highly Qualified Teacher (HQT) requirements

  27. Equitable Services for ChildrenService Providers – LEA Employees • Paraprofessionals must meet the paraprofessional qualification requirements, provide instructional support, and be under the direct supervision of and in close and frequent proximity to a highly qualified public school teacher • Private school officials may not sign time and effort records • Private school officials cannot establish requirements for LEA-employed teachers

  28. Equitable Services for ChildrenMaterials and Equipment • Title I funds may only be used to meet the needs of participating children • Non-Title I private school children may not use materials purchased with Title I funds • LEA must retain title to all materials purchased with Title I funds • All materials, etc., purchased with Title I funds must be labeled “Property of… School District” and placed in a secured location when not in use • Private school officials have no authority to obligate Federal funds

  29. Equitable Services for Teachers and Families

  30. Equitable Services for Teachers & FamiliesRequirements An LEA must provide equitable services to private school teachers and families of participating private school children from funds reserved for professional development (§1119) and parental involvement (§1118)

  31. Equitable Services for Teachers & FamiliesUse of Funds • The LEA must use these funds to provide equitable services to teachers and families of participants • There is no authority under Title I for an LEA to transfer these funds to instruction • Ifteachers or families of participating private schoolstudents do not have a need for equitable services, those funds are available to the LEA for other allowable uses

  32. Equitable Services for Teachers & Families Professional Development REQUIRED CONSULTATION TOPIC: LEA must consult with private school officials prior to the LEA designing and implementing professional development activities that increase the private school teachers’ skills and knowledge on how to better instruct their Title I children

  33. Equitable Services for Teachers & Families Example of Calculations In participating public school attendance areas: 5000 100,0005% (Private school (Total number of children from public & private (Proportion of low-income ÷ school children from = reservation) families) low-income families) 5% $360,000 $18,000 (Amount of LEA’s (Amount of (Proportion of § 1119 reservation* funds for reservation) x for professional = equitable development) services) * Must also include traditional professional development reservations

  34. Equitable Services for Teachers & Families Parental Involvement The LEA must consult with private school officials when designing and implementing parental involvement activities that assist parents in helping their children achieve high academic standards

  35. Equitable Services for Teachers & Families Example of Calculations In participating public school attendance areas: 5,000 100,0005% (Private school (Total number of public (Proportion children from ÷ & private school = of low-income children from low- reservation) families) income families) 5% $60,000 $3,000 (Totalamount of (Amount of (Proportion district’s reservation funds for of x for ALLparental = equitable reservation) involvement activities services) activities)

  36. Consultation

  37. Consultation RequirementsWhat is Consultation? Consultation involves discussions between public and private school officials on key issues that affect the ability of eligible private school children to participate equitably in Title I programs

  38. Consultation Requirements Consultation… • Must occur during the design, development, and implementation of the Title I programs • Must include meetings • Must occur prior to the LEA making any decisions • Must continue throughout implementation of programs • Must be documented

  39. Consultation Requirements What topics must be addressed during consultation?

  40. Consultation Requirements At a minimum, consultation must address: • How the LEA will identify the needs of eligible children • What services the LEA will offer • How and when the LEA will make decisions • How, where, and by whom the LEA will provide services • How the LEA will assess the Title I program and use the results to improve Title I services

  41. Consultation Requirements • The size and scope of the equitable services and the proportion of funds the LEA will allocate for services • Method or sources of data the LEA will use to determine the number of low-income students • Services the LEA will provide to teachers and families of participating children • Discussion of service delivery mechanism the LEA can use • A thorough consideration and analysis of the views of private school officials services through a contract with third-party provider

  42. Consultation Requirements • Private school officials have the right to complain to the SEA for the following reasons: • The LEA did not engage in timely and meaningful consultation • The LEA did not give consideration to the views of private school officials • The LEA disputes the low-income data provided by private school officials The SEA resolves the complaint

  43. Evaluation

  44. Evaluation After consulting with private school officials, the LEA must establish standards it will use to measure the effectiveness of the Title I program as indicated by the academic achievement of its participants

  45. EvaluationAnnual Progress • Every year, the LEA, after consulting with private school officials, must determine what constitutes acceptable annual progress for the Title I program • This decision must be made before Title I services begin • It’s not enough to just assess participants – the LEA must determine the effectiveness of the total program in raising academic achievement

  46. EvaluationProgram Modifications If the expected annual progress is not met, the LEA, after consultation, must review its program and determine those modifications it should make in order to improve the effectiveness of the Title I program in raising the academic achievement of private school participants

  47. Other Considerations

  48. General RequirementsSuggested Timeline • January/February • Mail letter (see sample of letter) • March • Conduct initial meeting (see sample of documentation) • Review demographics • Plan program • April - July • Await allocations • Meet to confirm • Submit application

  49. General Requirements • Meetings and consultation must occur before district makes decisions • Consultation continues throughout implementation

  50. Determining Private School Participation—Student Numbers

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