Module 4: Migrant Education Program Subgrant Procedures

1. Module 4: Migrant Education Program Subgrant Procedures New Directors’ Orientation Tutorial

2. Table of Contents

3. Getting Started In This Section Tutorial Objectives How to Use the Tutorial Icons to Guide You Key Readings and Resources

4. Tutorial Objectives Module 4 will enable new state directors to • understand which entities are eligible for state migrant education program (MEP) subgrants, • understand the responsibilities of state education agencies (SEAs) for establishing subgrant procedures, • understand common approaches to determining subgrant amounts, • make subgrant determinations, and • refine your subgrant process with actionable milestones.

5. How to Use the Tutorial For optimal benefit from the tutorial, you should • allow sufficient time to read the slides, reflect on the information, and complete all activities on the slides or on the Quick Resource and Reflection Sheets (QRRS) that can be downloaded as worksheets; • read each slide, as well as the information referenced in the slides; • engage with the “What Do You Think?” slides to facilitate interaction with the information (Answers will be provided directly following each of these slides.);

6. How to Use the Tutorial For optimal benefit from the tutorial, you should (continued) • pause to reflect on your state program at the “Check-in” slides (A QRRS document will typically accompany these.); • complete the “Pop Quiz!” slides to reinforce key concepts; • review your state’s MEP documents and reports as directed; • develop an action plan using the worksheets provided; • add actionable items to your MEP planning calendar (See QRRS 14.2.); and • contact your OME Program Officer for follow-up questions.

7. Icons to Guide You The following icons will guide you in making the best use of this tutorial: What Do You Think? Check-in Pop Quiz! Quick Reference and Reflection Sheet (QRRS) Action Planning Calendar Item

8. Key Readings and Resources You should have these documents readily available while completing the module, as the module will refer to these documents for more complete information on various topics. • MEP Guidance on Education of Migratory Children under Title I, Part C of the Elementary and Secondary Education Act of 1965, Chapter XI – State Administration • Your state Consolidated State Application (CSA) • Your state Comprehensive Needs Assessment (CNA) • Your state Service Delivery Plan (SDP) • Your state law and/or policies related to subgranting

9. Migrant Education Subgrant Overview In This Section Overview MEP Subgrant Eligibility Local Operating Agencies State Subgrant Requirements State Director Responsibilities

10. Overview The MEP is designed to supplement the educational services that districts provide to eligible migrant children. One way of doing this is by subgranting MEP funds to districts or toother entities that can provide direct services to migrant children. Issues migrant children face that can affect their ability to do well in school. • Educational interruptions • Low household income • Cultural & language barriers • Social & community isolation • Health-related problems

11. Overview SEAs may choose to deliver MEP services directly, or through a subgrant process to eligible LOAs. • A subgrant is an award of financial assistance, in the form of money, made under a grant by a grantee (the SEA) to an eligible subgrantee (the LOA). Section 1302 of the ESEA, as amended EDGAR - § 76.770 and 80.3

12. Overview • Whether the SEA chooses to deliver MEP services directly or through LOAs, the SEA remains responsible for the overall administration and operation of the MEP in the state. • The SEA must ensure that LOAs receiving subgrants comply with all applicable statutory and regulatory requirements. • The SEA has the sole authority for determining which LOAs receive subgrant awards. • No LOA is entitled to receive an MEP subgrant. Section 1302 of the ESEA, as amended EDGAR- § 76.770 and 80.3

13. Migrant Education Program Subgrant Eligibility Eligible LOAs are defined as: • Local education agencies (LEAs), • Public or nonprofit private agencies, or • The SEA, if the SEA operates the MEP directly. Section 1309(1) of the ESEA, as amended EDGAR § 77.1

14. What Do You Think? • What are the advantages/disadvantages of having few/many subgrantees in your state? Consider: • The size of MEP staff at the SEA. • How the migrant child population is distributed in your state.

15. What Do You Think? – Reflection What are the advantages/disadvantages of having few/many subgrants in your state?

16. Local Operating Agencies • In some states the LEA operates as the LOA. • In some cases, two or more LEAs or other entities may partner to form an LOA to provide services to migrant children across multiple districts. • In some states, institutions of higher education and non-profit entities may provide services and/or ID&R across multiple districts. • In some states with small migrant child populations or with migrant families that remain in the state for short periods (reducing the time services are needed), the state may opt to provide services directly.

17. State Subgrant Requirements States must have a plan on file with ED (contained within their Consolidated State Applications) describing how: • The SEA will determine the amount of any subgrants they will award to LOAs, taking into consideration: • The numbers of migrant children, • The needs of migrant children, • Priority for Services (PFS) migrant children, and • The availability of funds from other federal, state, and local programs. Section 1304(b)(5) of the ESEA, as amended

18. State Director Responsibilities The state MEP director is responsible for ensuring that the SEA has: • Established procedures to determine which, if any, entities are eligible to receive a subgrant; and • Taken steps to ensure that LOAs comply with all applicable statutory and regulatory requirements.

19. State Director Responsibilities When deciding which LOAs will deliver services to migrant children most efficiently and effectively, the state director will need to consider: • CNA results; • Types of services necessary to address the needs of migrant children, including the needs of PFS children; and • The capacity of the LOA to provide services.

20. State Director Responsibilities • The state director should be familiar with common MEP subgrant approaches and the state’s policies regarding subgrants. • States may have specific requirements related to the process by which funds are awarded; therefore, it is important to ensure that the SEA administration and budget officers understand the intent of, and legislative requirements for, MEP subgranting.

21. Check-in What policies are in place in your state for the MEP subgrant process? • See QRRS 4.1 – State MEP Subgrant Process

22. Factors for Determining Subgrant Amounts In This Section Factors for Determining Subgrant Amounts Factor 1: Number of Migrant Children Factor 2: Needs of Migrant Children Factor 3: Priority for Services Requirement Factor 4: Availability of Funds from Other Programs Other Factors Types of Programs Subgranted to Local Operating Agencies

23. Factors for Determining Subgrant Amounts There are four factors that the SEA must consider when determining the amount of asubgrant: • Numbers of migrant children; • Needs of migrant children; • Statutory priority to serve children who are failing, or most at risk of failing, to meet the state’s challenging academic content standards, and whose education has been interrupted during the regular school year; and • Availability of funds from federal, state, and local programs.

24. Factor 1: Number of Migrant Children SEAs must consider the number of migrant children in the area to be served when determining amounts for subgrants, but have considerable latitude in deciding how to include this factor in the subgrant process. SEAs may consider the number of migrant children who: • Reside, or are expected to reside, in the project area and/or • Are served by, or are expected to be served by, the project.

25. Factor 1: Number of Migrant Children For example, the SEA might implement a weighted scale based on: • The number of eligible migrant children who reside, or are expected to reside, in the project area; • The number of students who are served by, or will be served by a project; • The number of students who are/will be served relative to the total number of eligible migrant children who reside, or are expected to reside, in the project area; • A combination of 1-3; or • Other ways of considering the number of migrant children in the project area.

26. Factor 2: Needs of Migrant Children Consistent with the CNA process, the SEA will identify the needs of migrant children and develop an SDP to address those needs. The SEA is required to consider these needs in determining the amount of subgrants. However, the SEA: • Is not required to take into account all of the identified needs of migrant children in its subgrant process, and • May choose to fund a project that proposes to address additional needs of migrant children (needs that were not identified in the statewide CNA, but which were identified in a particular project area)—if services are not available from another funding source.

27. Factor 2: Needs of Migrant Children In addition to understanding the needs identified in the statewide CNA and the strategies for delivering services as outlined in the SDP, the SEA will benefit from having a clear understanding of the effectiveness of the programs (impact on migrant children’s educational outcomes). This will help SEAs prioritize and consider ongoing needs when determining future subgrant amounts.

28. Factor 3: Priority for Services (PFS) The SEA must consider the PFS requirement when determining the amount of a subgrant. Students who are eligible for PFS are those migrant children who are: • Failing, or most at risk of failing, to meet the state's challenging state academic content standards and challenging state student academic achievement standards and • Whose education has been interrupted during the regular school year. Section 1304(d) of the ESEA, as amended

29. Factor 4: Availability of Funds from Other Programs In determining the amount of a subgrant, the SEA must consider the availability of other funds that an LOA may leverage to provide services to migrant children. The SEA may: • Examine the funding levels of programs that the LOA implements and that are available to migrant children, or • Evaluate the availability of other federal, state, or local funds by collecting data on per-pupil expenditures.

30. Check In There are four requirements that the SEA must consider when determining the amount of subgrants. How is your state factoring in the four requirements to determine subgrants in your state? • See QRRS 4.2 – Addressing the Four Required Factors

31. Additional Factors In addition to the four required factors, the SEA may also consider additional factors when determining amounts for subgrants, such as: • Nature, scope, and cost of the projects to be implemented and • State CNA and SDP priorities.

32. What Do You Think? What are some of the factors, other than the four required factors, you might include when considering subgrant amount determinations?

33. What Do You Think? – Reflection In addition to the four factors required for making subgrant amount determinations, consider the nature and scope of the project, migratory patterns, and how MEP funds can be maximized. • Nature and scope of the projects to be funded • How many migrant students will be served during the regular school year and/or summer session? • How many staff members will be required to implement the project, and how much professional development will staff need? • What local resources will be leveraged to provide services to migrant children in the project area?

34. What Do You Think? – Reflection • Migratory patterns • Are migrant families frequently moving in and out of the state or within the state? • What districts or regions are migrant families moving to/from and when? • Project costs • Are costs associated with operating the project necessary, reasonable, and allocable? • What percentage of the project funds are dedicated to administrative functions and overhead that are not really needed versus providing services to migrant children?

35. Types of Programs Subgranted to Local Operating Agencies Examples of the type of programs that might be subgranted to LOAs to address the needs of migrant children in the areas the LOAs serve include: • Academic programs to meet state academic standards, • Health programs, • Preschool programs, • Parental involvement, • Summer school programs, • Supplemental services for secondary education (e.g., secondary credit accrual, dropout prevention, alternative education programs), and • Information dissemination activities (e.g., assist migrant families in understanding services and resources available).

36. Approaches to Subgrants In This Section • Determining Amounts Available for Migrant Education Program Subgrants • Subgrant Funding Approaches • Formula Approach • Proposal and Negotiation Approach • Combination Approach

37. Determining Fund Amounts Available for Migrant Education Program Subgrants When determining the amount of funds available for subgrants, the SEA should consider • Current FY MEP grant award (+), • Set aside for general state administration (up to 1%) (-), • Carryover funds from previous grant award (+), and • Unique SEA program function costs (-).

38. Subgrants – Funding Approaches As previously discussed, the SEA has flexibility in how the four required factors will influence the subgrant process. Similarly, the SEA has flexibility in identifying how funding amounts will be determined. The most common approaches are: • Formula, • Proposal and negotiation, • A combination of formula/proposal and negotiation, or • Another reasonable alternative process.

39. Formula Approach In the formula approach, the SEA determines the amount of MEP funds available for award to each eligible LOA by: • Using quantitative data to generate a total number of points for each LOA. • The proportion of an LOA’s points of the grand total of points is used to determine the amount of funds the SEA will award to each LOA. • In the formula approach, the SEA typically applies weights to each factor, so some factors will produce a higher number of “points”. • While the four required factors must be included in the formula, the SEA has flexibility in determining what data will be used for calculating these factors and how much weight each factor will receive.

40. Example Formula Approach An example of a state migrant formula allocation worksheet reflecting formula factors, sources of data, and possible weighting of factors * For example purposes only.

41. Example Formula Approach Many SEAs use the total number of eligible migrant children as part of their Numbers of Migrant Children factor. In the example on Slide 40: • The count of total eligible migrant children is taken from Category 1 and Category 2 Child Counts data and • Is given a fairly heavy weight as a starting base for funding projects.

42. Example Formula Approach The SEA has flexibility in deciding which Migrant Student Needs to factor in when determining subgrant amounts. Additionally, the SEA can decide to weigh some needs more than others. Some considerations reflected in the example on Slide 40 include: • Gaps in services identified in the SDP, • Changes in migrant children populations (demographic data), • Changes in proficiency on state or other assessments scores, and • Whether academic needs are statewide or limited to specific areas.

43. Example Formula Approach When considering how the Needs of Migrant Children factor will be used in determining subgrant amounts, the SEA may choose to count a migrant child: • Only once regardless of the number of times she/he fits into a needs category (unduplicated counts), or • Each each time she/he fits into a needs category. • For example, Juan is counted a total of three times because he fits three separate needs categories: he is considered limited English proficient (LEP), he is below proficient in reading, and he is below proficient in math. • If the SEA allows children to be counted for each need category, then the number in the Needs of Migrant Children factor could potentially exceed the Number of Migrant Children factor.

44. Example Formula Approach In some cases, the Priority for Services (PFS) factor might overlap with the Needs of Migrant Children factor. • For example, a child might be considered PFS based on the fact that he/she has experienced an educational interruption during the regular school year, and scored less than proficient on the state mathematics assessment. If less than proficient scores on the mathematics assessment is also one of the Needs of Migrant Children, then the child would be counted under both factors. • Because of the high risk of failure of PFS students, SEAs may choose to allow this overlap in numbers for purposes of determining subgrant amounts.

45. Example Formula Approach When considering the Availability of Other Funds, the SEA may choose to: • Examine the funding levels of programs that the LOA implements and that are available to migrant children, or • Evaluate the availability of other federal, state, or local funds by collecting data on per-pupil expenditures.

46. Example Formula Approach Spreadsheet Below is a spreadsheet reflecting the application of weighting from the example worksheet shown on Slide 40.

47. Proposal and Negotiation Approach In the proposal and negotiation approach, the SEA: • Defines how the four required factors and any additional factors will be applied in the subgrant process, • Reviews a description of the proposed activities and the budget request submitted by a LOA, and • Determines the final subgrant amounts based on the quality of the proposal and any negotiated adjustments.

48. Proposal and Negotiation Approach The proposal and negotiation approach differs from the formula approach in that the SEA has not established (by formula) a predetermined amount that each eligible LOA may receive. Rather, in this approach: • The SEA establishes a Request for Proposals (RFP) or application process. • The proposal and negotiation may result in more than one entity submitting a proposal to serve the same district or area, or might allow for consortia to submit proposals to serve children across multiple districts or areas.

49. Proposal and Negotiation Approach • The SEA may contact the LOA to negotiate changes to the proposal/application, such as: • Revisions to strengthen proposed services to migrant children, • Requesting addition of services, or • Budget adjustments.

50. Combination Approach As the name suggests, the combination approach will involve the SEA using a two-pronged approach to award MEP funds to LOAs: • The SEA may establish a base amount by formula for which all eligible LOAs apply through the application process. • The SEA may apply weights to each factor, as described in the formula approach on slides 39-46. • The SEA may negotiate final subgrant amounts with each LOA based on the quality of the applications submitted. • For example, the SEA may apply bonus points for addressing certain high priority issues or subtract points for services not included.