Title I Part A Schoolwide Flexibility The New Day is here! The use of flexibility for Title I Part A Schoolwide building is available for ALL schoolwide buildings to implement. The NEW DAY has arrived! “Who is in the room?” Find out who is included in your audience. Adjust time to meet the needs of those present.

Every Student Succeeds Act of 2015 (ESSA), Section 1001. Intent and Purpose “The purpose of this title is to provide all children significant opportunity to receive a fair, equitable, and high-quality education and to close educational achievement gaps.” Every Student Succeeds Act of 2015 (ESSA), Section 1001. Statement of Purpose The guiding principle in using flexibility is that strategies and activities supported through the use of these funds MUST meet the intent and purpose of ESEA Title I Part A as reauthorized in the Every Student Succeeds Act- ESSA.

Keeping the intent and purpose before us… What do we need to consider? Have we conducted our Comprehensive Needs Assessment with fidelity? Have we identified our needs and what we will do to help meet educational the needs of our students? Have we identified how we will provide supplemental support for those students who are most in need? Have we identified strategies and activities that help close any identified achievement gaps? Have we discussed the funding streams we will use to support these strategies and activities? Questions to consider as you make plans to implement flexibility to ensure that the intent and purpose of Title I Part A is preserved. Has the process we use served us well? If yes, you may only need to implement new flexibility in very select ways. (If it ain’t broke….” Are there ways the flexibility WILL help us? What about the test of supplement not supplant– Part II of presentation. Discuss each question – table talk or large group.

(Turn and Talk) What expenditures have been “unallowable” in the past? What are some of the reasons the items were unallowable? Has EVERYTHING changed? A major compliance area has been to ensure that funds were spent to supplement NOT supplant other funds. What items have been unallowed in the past? What make them unallowable? Have YOU had any items disallowed? SHARE--What were they and why? Much has changed BUT some things remain the same.

Uniform Grant Guidance Factors affecting allowability of costs. Costs must meet general criteria in order to be allowable under Federal awards. § 200.403 Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. § 200.405 (a) A cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received. The Uniform Grant Guidance (UGG) / EDGAR continue to provides “guard rail” guidance in areas we are familiar with including: Allowability is determined through an expenditure being… Reasonable / Necessary Allocable An item is “allocable” if it fall within the parameters of the funding source. I.e. Title I teacher. This expense may not however be allowed if it is not in the school improvement plan.

Uniform Grant Guidance Factors affecting allowability of costs. § 200.407 Prior written approval (prior approval) Under any given Federal award, the reasonableness and allocability of certain items of costs may be difficult to determine. In order to avoid subsequent disallowance or dispute based on unreasonableness or nonallocability, the non-Federal entity may seek the prior written approval of the cognizant agency for indirect costs or the Federal awarding agency in advance of the incurrence of special or unusual costs. Prior written approval should include the timeframe or scope of the agreement. The absence of prior written approval on any element of cost will not, in itself, affect the reasonableness or allocability of that element, unless prior approval is specifically required for allowability as described under certain circumstances. Prior Approval is still in effect. This helps ensure that a requested expenditure is allowable before funds are expended.

Now… the fun part! In spite of rules and regulations that still remain when using Federal Funds, the new flexibility that has been provided for schools implementing Title I Part a Schoolwide Flexibility and with ESSA new flexibility for ALL Title I programs opens up new opportunities for schools. So now… “The fun part!” What can we do now, that we could not do before?!

Staffing Support Examples: Additional classroom in a grade to reduce class size with special math expertise that will be shared with colleagues during PLC time. A sixth grade teacher What staffing ideas do you have or what changes might your school and district consider to help provide all children significant opportunity to receive a fair, equitable, and high-quality education and to close educational achievement gaps? Staffing is one place schools may exercise flexibility. What are ways your school might use flexibility in staffing to ensure that the INTENT AND PURPOSE of Title I is met? -- Discuss.

Curriculum Support Examples: Stipends for classroom teachers for participation in math curriculum study to align school standards with State standards. Tier 1 instructional materials. What curriculum ideas do you have or what changes might your school and district consider to help provide all children significant opportunity to receive a fair, equitable, and high-quality education and to close educational achievement gaps? Curriculum is one place schools may exercise flexibility. What are ways your school might use flexibility in the area of curriculum to ensure that the INTENT AND PURPOSE of Title I is met? Discuss--

School Improvement and Assessment Support Examples: Support School Improvement requirements. Site license for “Online Testing Program” to prepare students. NWEA for all students. What school improvement and assessment ideas do you have or what changes might your school and district consider to help provide all children significant opportunity to receive a fair, equitable, and high-quality education and to close educational achievement gaps? School Improvement and Assessment are areas schools may exercise flexibility. What are ways your school might use flexibility in school improvement to ensure that the INTENT AND PURPOSE of Title I is met? What are ways your school might use flexibility in school assessment to ensure that the INTENT AND PURPOSE of Title I is met? Discuss— SHARE LIST OF ACTIVITIES FROM NEW GUIDANCE. Discuss–

? (Turn and Talk) Challenges… Opportunities… Questions… What challenges do you foresee? What help do you need to overcome the challenges? What new opportunities do you foresee? What questions do you have?

What does this mean for us now? Write down 3 things you will do when you return to your district as you move toward implementing Title I Part A Schoolwide Flexibility to help ensure successful implementation and outcomes. (Who do you need to contact? What do you need to check? How do you want to plan? Other?) 1. 2. 3. To help ensure that a more flexible use of funds yields positive student achievement, closing of achievement gaps, and the providing of a “well-rounded” “high-quality” education for students– what are your next steps? What do you need to do when you return to your school/district? Who do you need to talk to and share this information? What data do you need to collect? What do you need to consider? Has your current process worked to achieve your goals? Gather…Plan…Implement…Evaluate…

NEXT… Supplement not Supplant

Supplement Not Supplant Legislation and Guidance Update Every Student Succeeds Act (ESSA) Supplement Not Supplant Legislation and Guidance Update Proposed Guidance U.S. Department of Education published a draft notice outlining its suggested requirements surrounding the “Supplement, not Supplant” requirement of Every Student Succeeds Act (ESSA). Emphasize the fact that this guidance is still PROPOSED. The fact sheet can be found on the USED we site: Entitled “Fact –Sheet- Supplement-not supplant-under-Title-I”

“Supplement/Supplant” Rule Every Student Succeeds Act (ESSA) “Supplement/Supplant” Rule The “New” Supplement/Supplant rule is only used for Title I funds. (Title I, Part A, Title I, Part C, etc.) All other Title funds will continue to apply the currently used supplement not supplant rule. The new rule takes effect in 2019/2020, until then districts must use the present Supplement/Supplant rule. Stress this is for all the Title I parts only.

Language of the Statute Every Student Succeeds Act (ESSA) Language of the Statute The proposed regulation reiterates that Title I, Part A funds may only be used to supplement and not supplant (take the place of State and local dollars). New prohibition for all Title I programs: An LEA may not be required to identify an individual cost or service as supplemental (in the Title I program).

Demonstrating Compliance Every Student Succeeds Act (ESSA) Demonstrating Compliance Annually, an LEA must publish its methodology in a way that parents and the public can understand. They must submit their methodology to the State for approval. LEAs must demonstrate annually to the SEA that each Title I, Part A school receives at least as much funding as it would if it were not a Title I school. Parents and public understanding is important, easy non educational lingo and simple math formula that is designed in easy to follow steps.

Every Student Succeeds Act (ESSA) 3 Methodologies to Choose From Method 1: Weighted Student funding formula Method 2: Formula for staff position and non- personnel resources Method 3: State developed Example on next slide

Every Student Succeeds Act (ESSA) Option 4: Special Rule A methodology selected by the district that ensures the per-pupil funding in each Title I school is at least as much as the average per-pupil funding in non-Title I schools within the district. A district methodology must be submitted and approved by the State. Concern comes from the fact we have over 900 districts.

Every Student Succeeds Act (ESSA) Timeline By Dec 10, 2017 an LEA must file with the State either its methodology for the 2018-19 school year, or its plan for implementing its new methodology for the 2019-20 school year. This date will be final…..failure to comply could me a loss of federal funds… ALL FEDERAL FUNDS

Supplement Not Supplant Rules… What does this mean for us now? What does this mean for us in the future? For your consideration… With whom do you need to share this information? What additional information do you think you need in preparation of and planning for increased flexibility across ALL Title I programs? What stakeholder input will be helpful in identifying ways to implement the flexibly effectively? What else do we need to think about in our district and schools?

Stay Tuned! Questions? Contact the Office of Field Services. Remember, the comment period for Supplement not Supplant Guidance is still underway. Stay Tuned! October 12, 2016 Questions? Contact the Office of Field Services. 517.373.4004 Link to the full text of the proposed regulations. www.ed.gov/news/press-releases/fact-sheet-supplement-not-supplant-under-title-i-every-student-succeeds-act