Georgia Department of Education Private School Consultation and Program Coordination (Title I, Part A; Title II, Part A; Title I, Part C; Title III and ESOL) Providing Equitable Services to Eligible Private School Children Marijo Georgia Department of Education 2016 GCEL, Inc., Conference February 22-24, 2016

DISTRICT EFFECTIVENESS SCHOOL IMPROVEMENT & DISTRICT EFFECTIVENESS Marijo

Presenters Marijo Pitts-Sheffield Elaine Dawsey Georgia Department of Education Title I Education Program Specialist mpitts@doe.k12.ga.us (912) 269-1216 Elaine Dawsey edawsey@doe.k12.ga.us (478) 971-0114 Marijo

Presenters Sharon Brown John Wight Georgia Department of Education Title II-A Education Specialist shbrown@doe.k12.ga.us (404) 561-4888 John Wight Title I, Part C – Education of Migratory Children jwight@doe.k12.ga.us (404) 463-1857 Marijo

Presenters Tammie Smith Georgia Department of Education Title III and ESOL- Education Specialist tsmith@doe.k12.ga.us (678) 794-3667 Marijo

Workshop Purpose To ensure uniformity in the implementation of the Title I Private School Provisions in ESEA: Private school consultation and program coordination with applicable Federal programs Overview of regulatory guidance relative to private school consultation Roles and responsibilities of district and participating private schools Consultation process with private school staff Review of a timeline for private school consultation Marijo

Guidance Marijo

Guidance The Elementary and Secondary Education Act of 1965 (ESEA) provides benefits to private school students, teachers and other education personnel, including those in religiously affiliated schools. Marijo

11/11/2018 Guidance ESEA requires a participating district to provide eligible children attending private elementary and secondary schools, their teachers, and their families with Title I, Part A, Title II, Part A, Title I, Part C, Title III and ESOL services or other benefits that are equitable to those provided to eligible public school children, their teachers, and their families. Marijo Dr. John D. Barge, State School Superintendent June, 2011

Guidance Title I, Part A, Title II, Part A, Title I, Part C, Title III and ESOL are aimed at children who are at-risk of failing to meet the State’s student academic achievement standards or other more appropriate standards for private school students as determined in consultation. Marijo

Guidance Federal programs with equitable participation requirements: Title I, Part A – Improving The Academic Achievement of the Disadvantaged Title I, Part C – Education of Migratory Children Title II, Part A – Teacher and Principal Quality Title II, Part B – Mathematics and Science Partnership Title III, Part A – Language Instruction for Limited English Proficient and Immigrant Students (ESOL) Title IV, Part B – 21st Century Community Learning Centers Marijo

Guidance Who is responsible for planning and designing services for eligible private school students? Through the consultation process, the district must design a coordinated Federal program with services that meet the needs of the private school and its students The LEA is responsible for planning, designing and implementing the Federal program and shall not delegate that responsibility to the private school Marijo

Roles and Responsibilities District officials will: Provide educational services or other benefits on an equitable basis, and in a timely manner to eligible children who are enrolled in private elementary and secondary schools Ensure that teachers and families of participating private school children participate on a basis equitable to the participation of teachers and families of public school children receiving these services Consult with appropriate officials of private schools and coordinate the design and development of the LEA’s federal programs plan that is appropriate for eligible private school children, their teachers and their parents Marijo

Roles and Responsibilities Private school officials will: Participate in consultation sessions Provide list of addresses and grade levels of low-income families Provide list of names, addresses, and grade levels of children who meet the multiple, educationally- related, objective criteria for participation eligibility Ensure that poverty is not to be used for identification or services. Poverty is used only to determine the Title I funding allocation Marijo

Roles and Responsibilities Private school officials will: Suggest ideas, program designs, and modifications that meet the needs of their eligible children, their teachers, and their families Provide a dedicated space, if appropriate Marijo

Consultation Marijo

Consultation What is Consultation? It is planning discussions between public and private school officials It provides a genuine opportunity for all parties to express their views and to have those views considered Successful consultation establishes positive and productive working relationships Marijo

Consultation Timely and Meaningful Consultation: To ensure timely and meaningful consultation, the district must consult with private school officials prior to the LEA making any decision that affects the opportunities of any private school children, their parents or the staff to participate in programs [Requirements in ESEA Section 1120(b) and 200.63 regulations] Marijo

Consultation Regulatory requirements for consultation include eight topics that must be included: How the LEA will identify the needs of eligible private school children. Will the LEA use test scores? If so, from which tests? Will teacher recommendations be acceptable? What services the LEA will offer to eligible private school children. Will the LEA pay for tutoring? Before-school or afterschool services? Supplemental instruction during the school day? How and when the LEA will make decisions about the delivery of services. What is the LEA’s decision-making process? Is there a contracting process, and if so, what’s the timeline? When will the private schools know what to expect? Marijo

Consultation Regulatory requirements for consultation include eight topics that must be included con’t: How, where and by whom the LEA will provide services to eligible private school children. Will the LEA pay for a highly qualified teacher to provide services? Or is the LEA likely to rely on third- party contractors? Will services be provided on the schools’ campus? Is so, where? Will students receive services in person or via computer? Individually or in groups? What will services look like? How the LEA will assess academically the services provided and how the district will use the results of that assessment to improve services. How will the LEA determine whether the services improved student achievement? Based on that information, what is the LEA’s decision-making process? For example, what will be the achievement goals, and if those goals aren’t reached, what are the options to change the services? Marijo

Consultation Regulatory requirements for consultation include eight topics that must be included con’t: The size and scope of the equitable services that the LEA will provide to eligible private school children and the proportion of its Title I funds that the LEA allocate and reserve. What can the available funds purchase in terms of services? Will students receive an hour of instruction a week, or an hour a year? Are equitable service available for parental involvement or professional learning? How will these be delivered? The method, or sources of data, the LEA will use to determine private school children from low-income families residing in participating public school attendance areas. Do the private schools collect poverty data? If not, would they be willing to have families fill out a school lunch application? What exactly will be done to determine if there are eligible students in each school? [ Marijo

Consultation Regulatory requirements for consultation include eight topics that must be included con’t: The services the LEA will provide to teachers and families of participating private school children. What will the LEA be offering to the teachers of served students? What family involvement strategies will be used? NOTE: If the district disagrees with the views of the private school official on the provision of services through a contract, the district officials will provide a written explanation and an analysis to the private school officials of the reasons why the district has chosen not to use a contractor. Marijo

Consultation Consultation Steps: In OCTOBER, the LEA must use the US postal service to contact private school officials with children who reside in the LEA boundaries regardless of private school location and have a written returned receipt verifying that contact was made The invitation must include the date, time, and place of consultation meeting (mail invitation at least three weeks prior to proposed meeting date) LEA provides the Intent to Participate form to the private school who must complete and return the form

Consultation Consultation Steps (continued): Title II, Part A, Title I, Part C and Title III only require notifications to private schools located within the geographical boundaries of the LEA A current list of private schools is housed on the Georgia Department of Education’s website and will be used during monitoring to check for compliance https://app3.doe.k12.ga.us/ows bin/owa/psc_pack_mainmenu.pvsch_list_public?p_sort=1

Consultation Consultation Steps (continued): LEA must convene a meeting to discuss needs and service options for applicable federal programs Phone conversations and letters are not adequate LEA must obtain a written affirmation from private school officials stating that timely and meaningful consultation occurred LEA must maintain documentation on file for each applicable federal program for review during cross functional monitoring (dated agendas and sign-in sheets) Marijo

Consultation Retain documentation that shows the LEA: Informed private school officials of available federal programs Engaged in timely and meaningful consultation Identified private schools’ needs Allocated sufficient funds for services to private schools Provided equitable services and benefits Evaluated programs and services for effectiveness Adequately addressed problems and complaints Marijo

Consultation Sample Documentation: Initial consultation Agendas Sign-in sheets Supporting documentation (DE 1111 Forms, letters mailed with return receipts, responses from private schools) On-going meaningful and timely consultations Minutes

Consultation Sample Documentation: Complaints and/or problems documents Consultation Affirmation form, signed Title I Equitable Services Affirmation form, signed

Consultation Disagreements and Complaints: Consultation does not guarantee that private school officials will agree with the LEA’s decisions regarding federal program services Private school officials may not be satisfied that their views were adequately considered during the process of initial consultation LEA must develop procedures that will address any private school complaints

Consultation Disagreements and Complaints: It is the LEA’s responsibility to inform private school officials of their right to complain and the procedure to follow in filing a complaint If private schools believe that the LEA did not engage in a timely and meaningful consultation process or did not consider their views, a complaint may be filed The complaint goes to the state educational agency (SEA) and the LEA must forward any relevant documentation about the dispute to the SEA

Private School Worksheets for Title I PPA Calculations: Private School Per Pupil Allocation (PPA) Worksheet PPA funds can only be used for instructional purposes Worksheet is embedded in Consolidated Application under School Allocation Tab Refer to next slide for screen shot of worksheet

Private School Worksheets for Title I PPA Calculations:

Private School Worksheets for Title I Equitable Services Calculations: Private School Equitable Participation Worksheet Equitable services is base on the LEA’s set asides for instruction, professional learning and parental involvement activities Services can only be provided in the areas in which they are generated Worksheet is embedded in Consolidated Application under Data Collection Tab Refer to next slide for screen shot of worksheet

Private School Worksheets for Title I Equitable Services Calculations:

SEE HANDOUT FOR EXAMPLE OF A TIMELINE FOR DISTRICT FEDERAL PROGRAM COORDINATION AND CONSULTATION WITH PRIVATE SCHOOL OFFICIALS

Marijo Pitts-Sheffield Title I, Part A Staff Area Name Office Telephone Email 1 Robyn Planchard (404) 985-3808 rplanchard@doe.k12.ga.us 2 Sherri Minshew TBD 3 Anthony Threat (706) 615-0367 anthony.threat@doe.k12.ga.us 4 Evelyn Maddox (404) 975-3145 emaddox@doe.k12.ga.us 5 Judy Alger (229) 321-9305 julager@doe.k12.ga.us 6 Grace McElveen (912) 334-0802 gmcelveen@doe.k12.ga.us 7 Jimmy Everson (229) 723-2664 jeverson@doe.k12.ga.us 8 Marijo Pitts-Sheffield (912) 269-1216 mpitts@doe.k12.ga.us 9 Kathy Pruett (706) 540-8959 kpruett@doe.k12.ga.us 10 Elaine Dawsey (478) 971-0114 edawsey@doe.k12.ga.us 11 Olufunke Osunkoya (678) 704-3557 oosunkoya@doe.k12.ga.us 12 Bobby Trawick (229) 246-1976 btrawick@doe.k12.ga.us 13 Ken Banter (478) 960-2255 kbanter@doe.k12.ga.us 14 Tammy Wilkes (478) 237-2873 twilkes@doe.k12.ga.us Email Talking Points:

Title II, Part A Sharon

Title II, Part A Title II, Part A has requirements similar to those of Title I, Part A for the invitation to participate and consultation. The major differences are related to the location of the private school, purpose and use of funds.

Title II, Part A SEC. 2101. PURPOSE. The purpose of this part is to provide grants to state educational agencies, local educational agencies, state agencies for higher education, and eligible partnerships in order to — (1) increase student academic achievement through strategies such as improving teacher and principal quality and increasing the number of highly qualified teachers in the classroom and highly qualified principals and assistant principals in schools; and (2) hold local educational agencies and schools accountable for improvements in student academic achievement. We will begin by reviewing the purpose of Title II, Part A. What is the purpose of the Title II, Part A program? 1. Increasing student achievement Improving quality of teachers and leaders Increase the number of HiQ teachers 2. Holding LEAs accountable for student achievement Remember: Title I focuses directly on student learners in order to increase student achievement, while the primary focus of Title II, Part A is on the teachers and leaders who serve them.

Title II, Part A – Private Schools Equitable Participation Section 9501 of the ESEA requires the LEA to set aside Title II, Part A funds for professional development for private school teachers and other appropriate staff at an amount equal to that set aside for public school teachers and staff on a per‐pupil basis, taking into account the number and educational needs of the children to be served. Federal law requires that private school teachers have the opportunity to participate in Title II, Part A just as public school teachers. We will go into detail later in the presentation as to what are allowable activities, who is allowed to participate, and the required reporting of enrollment data to the LEA. Note: Section 9501 8501 of the ESEA ESSA

Title II, Part A – Private Schools Invitation to Participate The Elementary and Secondary Education Act requires that public LEAs contact appropriate officials of all private schools within the geographic boundaries of the LEA annually to determine if they want their teachers to participate in the Improving Teacher Quality State Grants program, regardless of whether or not those officials have recently indicated any interest in program participation. A current list of Private Schools is housed on the Georgia Department of Education’s website and will be used during monitoring to check for compliance. https://app3.doe.k12.ga.us/ows-bin/owa/psc_pack_mainmenu.pvsch_list_public?p_sort=1 The LEA boundaries refer to the area from which the LEA draws its residence students. The DOE website with the list of private schools is, hopefully, updated annually. It is the official list from which Title II, Part A monitors for compliance. Click on the link and show the website. The Private Schools should ensure that they are on the DOE’s list. The LEA will use the list as well as local knowledge of LEAs in its boundaries to send out invitations for participation.

Title II, Part A – Private Schools Private School Elects to Participate The private school is responsible for Submission of needs assessment Plan for implementation including plan for measuring effectiveness and budget Participation in ongoing consultation Providing K-12 enrollment data to LEA Obtaining prior approval for PL activities (noted in plans or budget) Providing required documentation of implementation of PL activities The LEA will inform private schools of their obligations. It is important that the private schools are aware and have systems in place to meet the obligations.

Title II, Part A – Private Schools Use of Funds As with any professional development activity that the LEA carries out for public school teachers, activities supported with Title II, Part A funds that benefit private school teachers must meet the requirements of the statute. Activities to be carried out for private school personnel must be based on the prioritized needs and a review of scientifically based research. The activities are expected to improve student academic achievement.

Title II, Part A – Private Schools Use of Funds - Title II, Part A Non-Regulatory Guidance Professional development activities may include: Improving the knowledge in one or more of the core academic subjects and in effective instructional teaching strategies, methods, and skills; Training in effectively integrating technology into curricula and instruction; Training in how to teach students with different needs, including students with disabilities or limited English proficiency, and gifted and talented students; Training in methods of improving student behavior, identifying early and appropriate interventions, and involving parents more effectively in their children’s education; and Leadership development and management training to improve the quality of principals and superintendents.

Title II, Part A – Private Schools Internal Controls The LEA must have written procedures for ensuring invitation, consultation, and provision of equitable services to private school within a district’s geographic boundaries. The LEA must have written procedures to ensure that costs are allowable, reasonable, necessary, and managed in a manner that minimizes costs to the federal award. No reimbursements directly to private schools.   LEAs are required to have a number of internal controls including some that relate to private schools. It is recommended that private schools establish their own internal controls related to the use of Title II, Part A funds for PL. §200.403(a) - Costs must meet the following general criteria in order to be allowable under Federal awards: (a) necessary, reasonable, and allocable §200.404 - A cost is reasonable if, in its nature and amount, it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost. §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.

Title II, Part A – Private Schools Professional Development Activities and Private Schools Title IX, Part E Non-Regulatory Guidance Reimbursement checks from the LEA are payable to the individual teacher/administrator for completion of professional learning and/or related travel. Checks for stipends earned are paid directly to teachers. Private schools participating in the shared services supported with Title II, Part A funds of any LEA must provide the collaborating public LEA with W-9 information upon request. This is related to stipends earned and not applicable for reimbursement of travel related expenses. There are no exceptions to the guidance on the flow of funds to private school staff. Whoever is on the bill is the one who gets reimbursed. If the PL requires registration, the documentation shows that the teacher paid the documentation. If the PL requires travel, the teacher’s name should be on the hotel receipt, etc. What do you do if you are traveling in a group and the principal pays the bills for everyone? Who gets reimbursed? What if you planned PL at the Private School and later realized you could have used IIA funds? Can you still use IIA funds

Title II, Part A – Private Schools Documentation Required for Approval and Reimbursement of Expenses Evidence of prior approval by LEA Receipts (registration, hotel, gasoline) Agendas (If agenda includes concurrent sessions, attendee must indicate which sessions were attended.) Evidence of direct payment by eligible participant to be reimbursed Evidence of receipt of contracted services

Title II, Part A – Private Schools Common Findings Unallowable expenditures No prior approval Inadequate documentation Not reasonable and necessary

Title II, Part A – Private Schools Resources Sample consultation letters, private school worksheet, and sample private school plans can be found on the Title II, Part A resources page on the DOE website. http://www.gadoe.org/School-Improvement/Teacher-and-Leader-Effectiveness/Pages/IIA-Resources.aspx The LEA is provided with sample consultation letters and should follow the recommended timeline for the invitation to consult. It is recommended that the LEA develop a timeline for collaboration with private schools to ensure quality communication and effectiveness of the use of funds. The private school should respond to the invitation to consult in a timely manner and actively participate in all consultations.

Title II, Part A Staff Julie Noland jnoland@doe.k12.ga.us Program Manager Email Julie Noland jnoland@doe.k12.ga.us Specialists Carly Ambler cambler@doe.k12.ga.us Saralyn Barkley sbarkley@doe.k12.ga.us Sharon Brown shbrown@doe.k12.ga.us Pam Daniels pdaniels@doe.k12.ga.us Greg Petersen gpetersen@doe.k12.ga.us Terri Still tstill@doe.k12.ga.us Elizabeth Zipperer ezipperer@doe.k12.ga.us Talking Points: 11/11/2018

Title I, Part C Education of Migratory Children

Purpose of Title I, Part C The purpose of Title I, Part C in Georgia (and the United States) is to ensure that migratory children fully benefit from the same free public education provided to all children and that the unmet education-related needs resulting from their migratory lifestyle are met. 11/11/2018

Title I, Part C Staff John Wight, Program Manager jwight@doe.k12.ga.us; (404) 463-1857 Margarita Munoz, Region 1 Coordinator mmunoz@doe.k12.ga..us; (404) 272-8762 Israel Cortez, Region 2 Coordinator jcortez@doe.k12.ga.us; 404-272-8780 Talking Points:

Title I, Part C Follow similar steps to Title I, Part A The Department identifies eligible children and notifies districts; parents are aware of Title I, Part C eligibility before the schools… in many instances Needs assessment; consultation with school; options for services are explained If needed, supplemental services are provided by the district where the child resides/attends school or the Title I, Part C Consortium at Abraham Baldwin Agricultural College (ABAC)

Title III and ESOL

Title III and ESOL Staff Cori Alston Title III and ESOL Program Manager calston@doe.k12.ga.us (404) 656-2067 Dr. Jacqueline Ellis ESOL Professional Learning/ State Rules jellis@doe.k12.ga.us (404) 463-1858 Dr. Meg Baker Regional Program Specialist - North Georgia RESAs mbaker@doe.k12.ga.us (678) 794-3695 CLIP/Budgets: North Region Tammie Smith Regional Program Specialist - South Georgia RESAs tsmith@doe.k12.ga.us (678) 794-3667 CLIP/Budgets: South Region Amy Lacher Program Specialist - Middle Georgia RESAs alacher@doe.k12.ga.us (404) 463-1074 CLIP/Budgets: Mid Region Talking Points:

Title III and ESOL Resources Georgia Department of Education ESOL Guidance http://www.gadoe.org/Curriculum-Instruction-and- Assessment/Curriculum-and-Instruction/Documents/ESOL/2015- 2016%20ESOL%20Title%20III%20Resource%20Guide%20web.pdf Title III Services for Private School Students http://www.gadoe.org/Curriculum-Instruction-and- Assessment/Curriculum-and Instruction/Documents/ESOL/TITLE%20III%20DIRECTORS%20CONFE RENCE/Private%20Schools%20and%20Title%20III%20Services.pdf

Common Private School Findings Unallowable expenditures No prior approval Inadequate documentation Expenditures not reasonable and necessary Equitable participation calculated incorrectly Use of multiple selection criteria to determine rank order of private school students served

Internal Controls The LEA must have written procedures for ensuring invitation, consultation, and provision of equitable services to private school students. The LEA must have written procedures to ensure that costs are allowable, reasonable, necessary, and managed in a manner that minimizes costs to the federal award. No reimbursements directly to private schools.   LEAs are required to have a number of internal controls including some that relate to private schools. It is recommended that private schools establish their own internal controls related to the use of Title II, Part A funds for PL. §200.403(a) - Costs must meet the following general criteria in order to be allowable under Federal awards: (a) necessary, reasonable, and allocable §200.404 - A cost is reasonable if, in its nature and amount, it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost. §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.

Georgia Department of Education Private School Consultation and Program Coordination (Title I, Part A; Title II, Part A; Title I, Part C; Title III and ESOL) Providing Equitable Services to Eligible Private School Children Marijo Georgia Department of Education 2016 GCEL, Inc., Conference February 22-24, 2016