Title I and Homeless Education Webinar

1. Title I and Homeless EducationRegion 10 and THEO Webinar | January 15, 2015This presentation was developed by the Texas Homeless Education Office (THEO) The Texas McKinney-Vento Education for Homeless Children and Youths (EHCY) Program is sponsored by the Texas Education Agency (TEA), the Region 10 Education Service Center, and the Texas Homeless Education Office (THEO) at the Charles A. Dana Center at The University of Texas at Austin

2. Welcome Tim Stahlke Senior Program Coordinator Phone: 512/ 475-9709 tstahlke@austin.utexas.edu For more information, visit www.utdanacenter.org/theo or call toll free 800/ 446-3142

3. Session Overview • Use of Title I, Part A funds for serving homeless children • Use of Title I, Part A, Set-Aside funds for serving homeless children • New authority in the Consolidated Appropriations Act, 2014 regarding the use of fiscal year 2014 (FY 2014) Title I funds for serving homeless children • Q & A Texas Homeless Education Office | http://www.utdanacenter.org/theo

4. Title I Overview The underlying premise for services to children and youth experiencing homelessness in any school district or other LEA is: Any student who is homeless and attending any school in the district is eligible for Title I services. Texas Homeless Education Office | http://www.utdanacenter.org/theo

5. Title I Overview School districts and other LEAs provide services to students experiencing homelessness with Title I through two Title I funding streams: • Regular Title I, Part A, funds • Title I, Part A, Set-Aside funds Texas Homeless Education Office | http://www.utdanacenter.org/theo

6. Title I Overview For the purposes of our training today, we will use the following definitions for these two funding streams: • Regular Title I, Part A, funds- those funds that come to the district and are allocated to campuses (either through school-wide or targeted-assistance programs) or are reserved at the district level for district-wide activities Texas Homeless Education Office | http://www.utdanacenter.org/theo

7. Title I Overview • Title I, Part A, Set-Aside funds - those funds that are reserved, as required, under the ESEA Sec 1113(c)(3)(A) for services to homeless students that are not attending Title I-designated campuses that are comparable to the services received by homeless students attending a Title I-designated campus Texas Homeless Education Office | http://www.utdanacenter.org/theo

8. I. Regular Title I, Part A Funds The primary “vehicle” for serving homeless students on a Title I – designated campus is through the Campus Improvement Plan (CIP). • Each campus has a Campus Improvement Plan (CIP) that identifies services and activities to support children experiencing homelessness on the campus. • Each of those identified services and activities should receive adequate allocation of Title I funds. Texas Homeless Education Office | http://www.utdanacenter.org/theo

9. I. Regular Title I, Part A Funds • Consequently, homeless students should not have unmet needs on the campus due to the lack of funds. • Regular self-assessment and revisions to the CIP should take place in order to make sure that campuses are accurately and adequately assessing the needs of children in homeless situations that they serve. • An LEA may choose to provide services to homeless students that are not ordinarily available to other, non-homeless, Title I - eligible students as long as such services are not available from any other sources. Texas Homeless Education Office | http://www.utdanacenter.org/theo

10. I. Regular Title I, Part A Funds It is possible that situations could occur where there are a large number of high-need homeless students on a single campus and the designated Regular Title I funds could be exhausted before all the needs of homeless students on that campus could be met. This should be considered the exception, not the rule, for allocating funds to campuses to meet the needs of homeless students. Texas Homeless Education Office | http://www.utdanacenter.org/theo

11. I. Regular Title I, Part A Funds Title I funds may be used to pay for immunizations, emergency clothing, emergency medications, emergency food, medical screenings, eye exams/eyeglasses and other similar items for a STUDENT in a homeless situation • if the lack of these items presents a barrier to the student's ability to access education or inhibits the student's academic success; and • if the LEA documents the lack of local and community resources to be able to address the particular need identified. Texas Homeless Education Office | http://www.utdanacenter.org/theo

12. I. Regular Title I, Part A Funds Title I funds may be used to cover expenses that would allow a student experiencing homelessness to fully participate in school activities,IF the LEA provides documentation that no other local funds or community resources are available, by paying the fees for: • a medical examination/physical exam for a student to be eligible to participate in extracurricular sporting programs (football, track, volleyball, cheerleading, etc.); • the rental of a band instrument; and • the rental/purchase of athletic wear, such as a football helmet or gear, cleats, track shoes, or a cheerleading outfit. Texas Homeless Education Office | http://www.utdanacenter.org/theo

13. I. Regular Title I, Part A Funds The use of funds for these purposes is predicated on the fact that the student is entitled to full and equitable participation in school, and not necessarily based on whether or not the student gains academic credit from the activity in question. While funds MAY be used for these purposes for homeless students, this use should be measured. Districts should have a plan in place and resources available to provide these type of resources to any and all high-poverty students. Those resources should be explored and exhausted before Title I is used. Texas Homeless Education Office | http://www.utdanacenter.org/theo

14. I. Regular Title I, Part A Funds Title I funds may be used to pay the tuition or participation fees for academic services that are provided to eligible students by a third party in order to address academic deficiencies a student may have, such as an academic summer school camp or leadership enrichment program provided by a Boys and Girls Club. Texas Homeless Education Office | http://www.utdanacenter.org/theo

15. I. Regular Title I, Part A Funds The delivery of services paid for by Title I funds, such as academic tutoring, credit recovery, and other similar programs, may take place outside of the campus or LEA facilities, such as at a local domestic violence shelter. (These services DO NOT have to be school-based.) Texas Homeless Education Office | http://www.utdanacenter.org/theo

16. I. Regular Title I, Part A Funds Supplemental services that are provided to homeless students under Regular Title I funds DO NOT create a "comparable services" requirement for the LEA to serve other non-homeless Title I-eligible students in the same way.  In other words, a district may use Regular Title I funds to provide services to homeless students that are not provided to other, non-homeless students.(For example, a district may provide supplemental transportation with the use of Regular Title I funds to take homeless students home after after-school tutoring even if it does not ordinarily transport students home after tutoring.) Texas Homeless Education Office | http://www.utdanacenter.org/theo

17. I. Regular Title I, Part A Funds In addition to the use of Title I funds for services identified for homeless students in the CIP, homeless students are automatically eligible to receive all other Title I services provided on that campus to all other Title I – eligible students. Again, while allowable by statute, the need for a Title I campus to draw from the district Title I, Part A, Set-Asides to meet the needs of students on that campus should be largely unnecessary. Texas Homeless Education Office | http://www.utdanacenter.org/theo

18. II. Title I, Part A, Set-Asides LEAs must set aside funds as are necessary to provide services comparable to those provided to children in Title I schools to serve homeless children who do not attend participating schools. Title I, Part A, Set-Aside funds are intended to provide services to students on non-Title I campuses that are comparable to those services provided to students on an LEA’s Title I campuses. Texas Homeless Education Office | http://www.utdanacenter.org/theo

19. II. Title I, Part A, Set-Asides There is no formula or guidance in statute that indicates what the amount of the set-aside should be. The Texas Consolidated Application has a few requirements regarding the set-aside. Each LEA should have a rationale and justification for the amount it has designated for the set-aside. Texas Homeless Education Office | http://www.utdanacenter.org/theo

20. II. Title I, Part A, Set-Asides Federal guidance allows a district to also use Title I, Part A, Set-Aside funds to provide supplemental services to students in homeless situations on both Title I and non-Title I campuses that are not provided as part of the district Title I program (emergency food, clothing, etc.). However, as noted in the previous discussion, the need for a Title I campus to use Title I, Part A, Set-Asides to address the needs of homeless students should be largely unnecessary. Texas Homeless Education Office | http://www.utdanacenter.org/theo

21. II. Title I, Part A, Set-Asides All allowable expenditures under Regular Title I are also allowable under the Title I, Part A, Set-Asides, and vice-versa. Texas Homeless Education Office | http://www.utdanacenter.org/theo

22. II. Title I, Part A, Set-Asides Services that are provided under the Title I, Part A, Set-Asides by an LEA DO NOT create a "comparable services" requirement for the LEA to serve other homeless students in the same way.  Students served with set-aside funds may be served on a first-come, first served basis.  (If a homeless student requests assistance with the provision of the standard dress required for school attendance, and the district provides it, the district is not obligated to provide this service to all homeless students who request it.  The district may prioritize whom it serves or place a cap on the amount of funds it will expend for a given activity.) Texas Homeless Education Office | http://www.utdanacenter.org/theo

23. III. Consolidated Appropriations Act, 2014 The recent Consolidated Appropriations Act, 2014includes new authority for the use of Title I funds for fiscal year 2015, including roll-forward funds from this year (FY 2015, effective July 1, 2014) regarding: • the salary for the LEA designated homeless liaison; • providing school of origin transportation; and • the use of set-asides on non-Title I campuses. Texas Homeless Education Office | http://www.utdanacenter.org/theo

24. III. Consolidated Appropriations Act • Designated homeless liaison salaryAccording to the guidance released with the recent appropriations bill, regular Title I funds may be used to pay for up to 100% of the salary of an LEA's homeless liaison even if that person does not have any other Title I duties.If the homeless liaison is dedicated 50% as liaison and 50% as other Title I duties, 100% of the salary may come from Title I.If the liaison is 100% liaison, 100% of salary may come from Title I. Texas Homeless Education Office | http://www.utdanacenter.org/theo

25. III. Consolidated Appropriations Act Designated homeless liaison salaryIf the homeless liaison has other non-Title I duties, only the percentage of the time dedicated to homeless liaison duties may be paid for with Title I funds.If the liaison is 50% liaison, and 50% Assistant Principal at a campus, only 50% of the salary may come from Title I. Texas Homeless Education Office | http://www.utdanacenter.org/theo

26. III. Consolidated Appropriations Act • Providing school of origin transportationAccording to the guidance released with the recent appropriations bill, regular Title I funds may be used to pay for the incremental costs of transporting homeless students to and from their schools of origin.“Incremental costs” = excess costs of transportation Texas Homeless Education Office | http://www.utdanacenter.org/theo

27. III. Consolidated Appropriations Act • The use of set-asides on non-Title I campusesAccording to the guidance released with the recent appropriations bill, LEAs are given the option of creating an additional set-aside that can be used to serve homeless students on Title I campuses. This set-aside is optional, and does NOT replace the required set-aside for the use of Title I, Part A, Set-Asides for comparable services to students on non-Title I campuses. Texas Homeless Education Office | http://www.utdanacenter.org/theo

28. III. Consolidated Appropriations Act NOTE:According to the guidelines released with the recent appropriations bill, Title I, Part A, Set-Aside funds MAY NOT be used to pay for a homeless liaison's salary or the excess costs of school of origin transportation UNLESS the district can demonstrate that the requirement to provide comparable services to homeless services on all non-Title I campuses has been met.The use of funds for allowable salary and transportation services cannot supersede the need to provide services to eligible students. Texas Homeless Education Office | http://www.utdanacenter.org/theo

29. Texas Homeless Education Office | http://www.utdanacenter.org/theo

30. IV. Q & A Questions and (hopefully) Answers Texas Homeless Education Office | http://www.utdanacenter.org/theo

31. Challenges / Solutions -- Homelessness Nothing will work if YOU don’t work!