Title III Requirements Gretchen Kroos, Title III Bilingual ESL Team Lead ESC Region 11, November 8, 2016

Title III, Part A English Language Acquisition, Language Enhancement, and Academic Achievement Act

Resources on http://www.esc11.net/Page/6068

Program Guidelines Program Specific Provisions and Assurances ESSA Guidance from USDE Sept. 2016

Title III, Part A Policy Guidance (older resource) Program Overview Funding and Fiscal Requirements Uses of Funds Assessment and Accountability Evaluation Participation of Students Attending PNP Schools

Title III FAQ Document (from January 2015 will be updated) Reimbursement of certification test fee Bilingual/ESL Certification Professional Development (PD) for LEAs with Bilingual exception or ESL waiver

Allowable Use of Funds Administrative Costs Bilingual/ESL Certification Professional Development Stipends Conferences

Reasonable and Necessary? Is activity tied to Comprehensive Needs Assessment? Is it supplemental? Is it in the Grant?

2014, 2015 and 2016 Annual Measurable Achievement Objectives Current status of AMAOs – still awaiting guidance from USDE on AMAO 1 and 2 standards Districts know if they met AMAO 3 – ELL Accountability by looked at their federal system safeguard reports

Title III and Private Non-Profit (PNP) Schools PNP Training PPT

PNP Resources soon available on Texas Gateway

NCLB Consolidated Application for Federal Funding For Title III, keep in mind that the LEA must consult with the private nonprofit (PNP) schools in its attendance area BEFORE completing the application (PS3106, Part 1 and Part 2). Consultation must be timely and meaningful regarding who will be served, how eligible students and teachers will be served, etc.

Supplement, Not Supplant Provision Funds for this program must be used to supplement (increase the level of services) and not supplant (replace) funds from other federal and nonfederal sources. Any program activity required by state law, SBOE rules, or local board policy may not be paid with these funds. State or local funds may not be decreased or diverted for other uses merely because of the availability of these funds. The LEA must maintain documentation that clearly demonstrates the supplementary nature of these funds.

NCLB Consolidated Application for Federal Funding What type of technical assistance is being provided to assist local educational agencies (LEAs) in regards to the NCLB Consolidated Application? What factors should LEAs consider when completing their local education plan (Part 6) of PS3106– Title III, Part A English Language Acquisition? Important Note: LEAs need to understand that their Title III Local LEA Plan should only include activities that are supplemental to state requirements and other federal program activities.

Title III, Part A – LEP (PS3106) Part 6: LEA Local Plan This will change for next year

Assessment & Accountability Under NCLB TELPAS and STAAR AMAOs ICRs Under ESSA Will still have accountability but falls under Title I Discussions/gathering feedback

Title III Accountability System under NCLB 2013 Title III Annual Measurable Achievement Objectives (AMAOs) November 2013 Title III Accountability System under NCLB Annual ELP Assessment: TELPAS AMAOs: LEA must meet all AMAO 1 Progress AMAO 2 Attainment AMAO 3 ELL Accountability (System Safeguards) Required Interventions: Based on number of consecutive years ‘Not Met’ We haven’t had AMAOs released in last 2 years. Were waiting for USDE to respond to TEA’s request to adjust standards based on the change to TELPAS in 2014. 11/17/201811/17/2018

2013 Title III Annual Measurable Achievement Objectives (AMAOs) November 2013 TELPAS (currently) Listening Speaking Reading Writing Language Domains Proficiency Levels For AMAOs 1 and 2, calculations are based on TELPAS Composite Ratings Beginning Intermediate Advanced Advanced High

AMAO 3 ELL Accountability 2013 Title III Annual Measurable Achievement Objectives (AMAOs) November 2013 AMAO 3 ELL Accountability AMAO 3 status is assigned based on LEA’s district-level Accountability (System Safeguards) status for its ELL student group. We will know more about this part of accountability when TEA releases State Plan in summer of 2017 11/17/201811/17/2018

Keep in Mind… Years as LEP Years in U.S. Schools Based on data LEA provides through PEIMS Considered for AMAO 2 (Title III) Count years as early as Pre-K Years in U.S. Schools Based on data LEA provides through TELPAS Considered for STAAR L (State) Count years as early as 1st Grade 11/17/201811/17/2018

Interventions for AMAOs for LEAs with ‘Not Met’ Status 2013 Title III Annual Measurable Achievement Objectives (AMAOs) November 2013 Interventions for AMAOs for LEAs with ‘Not Met’ Status LEA must carry out interventions if it has ‘Not Met’ one or more of the AMAOs: Year 1Parental Notification Year 2Parental Notification + CIP Year 3Parental Notification + Revised CIP Year 4Parental Notification + Revised CIP + Interventions as per TEA Year 5Parental Notification + Revised CIP + Interventions as per TEA Based on Consecutive Years

Coming soon! A series of online modules for administrators and educators is currently in development. The series provide the essential components necessary to provide an effective language instruction educational program for English language learners, as outlined in Title III, Part A, of the 2001 Elementary and Secondary Education Act.

Coming soon! An Educator Overview Guide to AMAOs is also currently in development. As a companion piece to the series of online modules, the guide will further support the LEA’s administration and instructional staff’s understanding of AMAOs and how to implement Title III program activities that assist their ELLs’ individual needs.

Title III, Part A: NCLB Compliance Report and Initial Compliance Review (ICR) Indicators

Initial Compliance Review (ICR) Crosswalk The Initial Compliance Review (ICR) is the first step in the compliance monitoring process. The ICR is an automated review of program-specific data indicators used to evaluate LEA compliance with federal program requirements. The ICR Crosswalk includes the indicators for the ESEA programs. It is posted on the NCLB Compliance Reporting page and updated annually around late spring.

Initial Compliance Review (ICR) Crosswalk

ICR Crosswalk and Title III, Part A Indicators The ICR Crosswalk includes the 12 indicators for Title III that correspond with the Title III program implementation questions in the NCLB Consolidated Compliance Report. Indicator Number Data Source (what the requirement is and cites the statute that requires it) ESEA Program Consolidated Compliance Report (cites location of indicator in PR3002) Met Standard (refer to Guide to Answering Program Implementation Questions)

PR3002 – Title III, Part A (Sample)

PR3002 Instructions

PR3002 Report Instructions

PR3002 Instructions (Part 11) Copyright © Texas Education Agency, 2015. All rights reserved.

2014-2015 Guide to Answering Program Implementation Questions Yes (documentation) N/A (explanation) No (explanation)

Teacher Fluency- Title III, Part A—LEP Did the LEA determine that all teachers in Title III language instructional programs for LEP children are fluent in both English and any other language used for instruction, including having written and oral communication skills? (ICR Indicator #45) N/A (explanation) The LEA did determine teachers were fluent in English and any other language used for instruction. No Yes (documentation) The LEA did not determine teachers were fluent in English and any other language used for instruction. Teacher Fluency- Title III, Part A—LEP The LEA had a language instructional program that used English and any other language for instruction (bilingual program). An LEA should only mark N/A if it is not required to provide a bilingual program (as per state requirements) or if the LEA has a bilingual exception for the 2014-2015 school year. Copyright © Texas Education Agency, 2015. All rights reserved.

Parental Outreach-Title III, Part A—LEP Did the LEA implement an effective means of outreach to parents of LEP/immigrant students to inform the parents of how they can be involved in the education of their children and be active participants in assisting their children to attain English proficiency, achieve at high levels in core academic subjects, and meet challenging State standards expected of all students? Parental Outreach-Title III, Part A—LEP (Note: Should even be supplemental to Title I, Part A) The LEA did implement an effective means of outreach to parents. The LEA did not implement an effective means of outreach to parents. It is highly unlikely that an LEA receiving Title III funds could justify a compliance status of N/A. N/A (explanation) Yes (documentation) No (ICR Indicator #46) Copyright © Texas Education Agency, 2015. All rights reserved.

Did the LEA conduct a timely and meaningful consultation with participating private nonprofit (PNP) school officials regarding the development and implementation of the Title III, Part A, program? (Consultation should have occurred before completing NCLB application.) (ICR Indicator #47) N/A (explanation) No Yes (documentation) Timely and Meaningful Consultation with PNP Officials Regarding Title III, Part A—LEP Program The LEA had participating private nonprofit schools with Title III, Part A-LEP program. The LEA did not have The LEA did not have a timely and meaningful consultation with PNP. The LEA did have a timely and meaningful consultation with PNP. Copyright © Texas Education Agency, 2015. All rights reserved.

Administrative Costs-Title III, Part A—LEP Did the LEA meet the statutory 2% limitation on administrative costs related to the implementation of the Title III, Part A—LEP Program? Administrative Costs-Title III, Part A—LEP The LEA had administrative costs. The LEA did not have administrative costs. N/A (explanation) The LEA met and adhered to the 2% statutory limitation. The LEA did not adhere to the 2% statutory limitation. No Yes (documentation) (ICR Indicator #48)

Administrative Costs (include direct and indirect costs)- When calculating administrative costs for the Title III, Part A—LEP program, did the LEA include all appropriate administrative costs, including both indirect costs and direct costs such as administrative salaries? Administrative Costs (include direct and indirect costs)- Title III, Part A—LEP The LEA had administrative costs. The LEA did not have administrative costs. N/A (explanation) The LEA did include both direct and indirect costs. The LEA did not include both direct and indirect costs. No Yes (documentation) (ICR Indicator #49)

Third-Party Contracts Title III, Part A—LEP Did the LEA require third-party contractor(s) associated with the Title III, Part A—LEP program to break out administrative costs, which were included in the 2% limit? Third-Party Contracts Title III, Part A—LEP The LEA had third-party contracts. The LEA did not have N/A (explanation) The LEA did require contractor to break out administrative costs. No Yes (documentation) (ICR Indicator #50) The LEA did not require contractor to break out administrative costs. Copyright © Texas Education Agency, 2015. All rights reserved.

Time and Effort Records for Split-Funded Staff with Did all Title III, Part A—LEP who were split-funded with other funds maintain appropriate time and effort records? Time and Effort Records for Split-Funded Staff with Title III, Part A—LEP Funds The LEA had Title III—LEP split-funded staff. The LEA did not have Title III—LEP split-funded staff. N/A (explanation) The LEA did maintain appropriate time & effort records. No Yes (documentation) (ICR Indicator #51) The LEA did not maintain appropriate time & effort records.

Did the LEA maintain control of Title III, Part A-LEP program funds being used to provide equitable services to private school ELL students and their teachers? (ICR Indicator #52) N/A (explanation) No Yes (documentation) Equitable Services to Private School ELL Students and their Teachers with Title III, Part A—LEP Program Funds The LEA had participating private nonprofit schools with Title III, Part A-LEP program. The LEA did not have The LEA did not maintain LEP program funds being used to provide equitable services to PNP schools. The LEA did maintain LEP program funds being used to provide equitable services to PNP schools.

Administrative Costs (include direct and indirect costs)- When calculating administrative costs for the Title III, Part A—Immigrant program, did the LEA include all appropriate administrative costs, including both indirect costs and direct costs such as administrative salaries? Administrative Costs (include direct and indirect costs)- Title III, Part A—Immigrant The LEA had administrative costs. The LEA did not have administrative costs. N/A (explanation) The LEA did include both direct and indirect costs. The LEA did not include both direct and indirect costs. No Yes (documentation) (ICR Indicator #54)

Time and Effort Records for Split-Funded Staff with Did all Title III, Part A—Immigrant staff who were split-funded with other funds maintain appropriate time and effort records? Time and Effort Records for Split-Funded Staff with Title III, Part A—Immigrant Funds The LEA had Title III split-funded staff. The LEA did not have N/A (explanation) The LEA did maintain appropriate time & effort records. No Yes (documentation) (ICR Indicator #56) The LEA did not maintain appropriate time & effort records.

Did the LEA maintain control of Title III, Part A—Immigrant program funds being used to provide equitable services to private school immigrant students and their teachers? (ICR Indicator #57) N/A (explanation) No Yes (documentation) Equitable Services to Private School (PNP) ELL Students and their Teachers with Title III, Part A—Immigrant Program Funds The LEA had participating PNP schools with Title III, Part A-Immigrant program. The LEA did not maintain Immigrant program funds being used to provide equitable services to PNP schools. The LEA did maintain Immigrant program funds being used to provide equitable services to PNP schools. The LEA did not have participating PNP schools with Title III, Part A- Immigrant program. Copyright © Texas Education Agency, 2015. All rights reserved.

Title III, Part A—Immigrant-funded Programs Did the LEA’s Title III, Part A—Immigrant-funded programs provide enhanced instructional opportunities for immigrant children and youth? Enhanced Instructional Opportunities for Private School (PNP) Immigrant students with Title III, Part A—Immigrant-funded Programs The LEA had participating PNP schools with Title III, Part A- Immigrant programs. The LEA did not have participating PNP schools with Title III, Part A- Immigrant programs. The LEA’s Immigrant-funded programs did provide enhanced instructional opportunities for PNP immigrant students. The LEA’s Immigrant-funded programs did not provide enhanced instructional opportunities for PNP immigrant students. N/A (explanation) Yes (documentation) No (explanation) Copyright © Texas Education Agency, 2015. All rights reserved.

Roundtable Discussion How are you utilizing your Title III funds? What are your parental engagement activities? How are your activities supplemental to our state required programs?

Questions? Contact information Gretchen Kroos 817-740-7630 gkroos@esc11.net