Private Schools 101: A Timeline for Planning, Serving, and Assessing a New Private School Program 2014 Annual GCEL Conference February 26-26, 2014 Savannah, GA Riverfront Marriott

Presenters Elaine Dawsey Georgia Department of Education Title I Education Program Specialist (478) Marijo Pitts-Sheffield Georgia Department of Education Title I Education Program Specialist (912)

Workshop Purpose To offer centralized guidance and support to district and private school officials working with Title I programs To ensure uniformity in the implementation of the Title I Private School Provisions in ESEA –Consultation –Identifying eligible participants –Ensuring equitable participation of private school students –Ensuring equitable participation of private school teachers and families of Title I participants –Ensuring equitable set-asides 3

Guidance 4

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. 5

Guidance Section 1120 of the Title I Part A ESEA requires a participating district to provide eligible children attending private elementary and secondary schools, their teachers, and their families with Title I services or other benefits that are equitable to those provided to eligible public school children, their teachers, and their families. 6

Guidance Title I, Part A funds 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 Title l students as determined in consultation. 7

Guidance Federal programs with equitable participation requirements: Title I, Part A – Improving Basic Provisions Title I, Part B – Even Start Family Literacy 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 II, Part D – Enhancing Education Through Technology Title III, Part A – Language Instruction for Limited English Proficient and Immigrant Students (ESOL) Title IV, Part B – 21 st Century Community Districting Centers 8

Guidance Who is responsible for planning and designing services for eligible private school students? Through the consultation process, the district must design a program that meets the needs of the private school and its students. The district is responsible for planning, designing and implementing the Title I program and SHALL NOT delegate that responsibility to the private school. 9

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 during the design and development of the district’s program for eligible private school children. 10

Roles and Responsibilities Private School Officials: 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 be used for identification or services. Poverty is used only to determine funding allocation. 11

Roles and Responsibilities Private School Officials: Suggest ideas, program designs, and modifications that meet the needs of their eligible children, their teachers, and their families. Provide a dedicated space for instruction, if appropriate. Collaborate with the district officials to ensure Title I funds are only used to purchase materials and equipment to meet the needs of participating private school students. Ensure non-Title I private school students do not use materials and equipment purchased with Title I funds. These guidelines are discussed and documented at a consultation meeting with private school officials. 12

Equipment Use for Participating Private Schools Section 1120(d)(1) of the ESEA requires that the control of the Title I funds, and the ownership of the materials and equipment, purchased with Title I funds for private schools shall be in the LEA, and the LEA shall administer the funds, materials, equipment and property. This is an LEA responsibility rather than the responsibility of the private school. 13

Equipment Use for Participating Private Schools District Officials will: complete the requisitions forms for ordering materials and/or equipment. have the materials and equipment delivered to the LEA. sign for the delivery of the materials and/or equipment. label the equipment as Title I to include the fiscal year of purchase and property of the respective school district. deliver the materials and/or equipment to the private school. store materials and equipment in a secure location when not in use. 14

Equipment Use for Participating Private Schools District Officials will: maintain an inventory of all materials, equipment, and property purchased with Title I funds for use with eligible Title I students at private schools. The inventory shall contain the same requirements for any equipment purchased with Title I, Part A funds. – These requirements are: a description of the equipment, serial number, funding source, acquisition date and unit costs, location, use of equipment, current condition, date of disposal or transfer if applicable, and date inventory was completed. 15

Equipment Use for Participating Private Schools Inventory must be updated as equipment items are purged or new purchases are made. Equipment items purchased with federal funds are to be identified and physically marked as such. Adequate safeguards must be in place related to the loss, damage, or theft of the equipment. Any loss, damage, or theft should be investigated and fully documented. Adequate maintenance procedures should be implemented to keep the equipment in good condition. A physical inventory of equipment items must be taken and the results reconciled with the inventory records at least once every two years. 16

Equipment Use for Participating Private Schools The GaDOE shall require: All LEAs serving private school children to implement adequate procedures and internal controls to account for the location, custody, and security of materials, equipment, and property purchased with Title I funds for private school use. These procedures must include the proper labeling of materials and equipment purchased with Title I funds, policies and procedures to ensure that private school officials do not use these materials and equipment with ineligible children, and disposal procedures. 17

Consultation 18

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. 19

Consultation Timely and Meaningful Consultation To ensure timely and meaningful consultation, the district must consult with private school officials prior to the district making any decision that affects the opportunities of any private school children to participate in programs. Requirements in ESEA Section 1120(b) and regulations 20

Consultation Regulatory Requirements for Consultation How the district will identify the needs of eligible private school children What services the district will offer to eligible private school children How, where and by whom the district will provide services to eligible private school children? How the district will assess academically the services provided and how the district will use the results of that assessment to improve services [Sec.1120(b)(1) ESEA] 21

Consultation Regulatory Requirements for Consultation The size and scope of the equitable services that the district will provide to eligible private school children and the proportion of its Title I funds that the district will allocate and reserve The method, or sources of data, the district will use to determine private school children from low-income families residing in participating public school attendance areas How and when the district will make decisions about the delivery of services 22

Consultation Regulatory Requirements for Consultation How the district will involve families in the Title I program What professional development activities the district will offer to the private school teachers of Title I participants NOTE: If the district disagrees with the views of the private school official on the provision of services through a contract, district officials must provide in writing to the private school officials an analysis of the reasons why the district has chosen not to use a contractor. 23

Consultation Consultation Steps: In the fall, the district contacts private school officials with children who reside in the district boundaries regardless of private school location and have a written returned receipt verifying that contact was made. District provides the Intent to Participate Form to the private school who must complete and return it if they are interested in participation in the following school year. District convenes a meeting to discuss needs and service options. –Phone conversations and letters are not adequate. District must obtain a written affirmation from private school officials stating that timely and meaningful consultation occurred. District must keep documentation on file for review during cross functional monitoring. 24

Documenting Consultation Retain documentation that shows the District: Informed private school officials of available federal programs Engaged in timely and meaningful consultation Identified private schools’ needs Allocated sufficient funds for private schools Provided equitable services and benefits Evaluated programs and services for effectiveness Adequately addressed problems and complaints 25

Consultation Sample Documentation Initial consultation Agendas Sign-in sheets Supporting documentation (most current DE 1111 Forms, letters mailed with return receipts, responses from private schools) On-going meaningful and timely consultations Agendas Sign-in sheets Minutes Complaints and/or problems documents Consultation affirmation form, signed Equitable services affirmation form, signed 26

Consultation Disagreements and Complaints Consultation does not guarantee that private school officials will agree with the district’s decisions regarding Title I services. Private school officials may not be satisfied that their views were adequately considered during the process of initia l consultation. District must develop procedures that will address any private school complaints. 27

Consultation Disagreements and Complaints It is the district’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 district 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 education agency (SEA) and the district must forward any relevant documentation about the dispute to the SEA. 28

EXAMPLE OF A TIMELINE FOR DISTRICT CONSULTATION WITH PRIVATE SCHOOL OFFICIALS (21 month cycle) 29

Timeline for Consultation October (month 1) Start planning for the next year’s consultation cycle –Obtain complete list of all private schools with students who are residents of the LEA Most current DE1111 forms submitted to district by private schools 30

Timeline for Consultation October (month 1) continued Start planning for the next year’s consultation cycle –The LEA must send an letter to all private schools with students who are residents of the LEA inviting them to participate in the Title I program Invitations must be postmarked three weeks prior to consultation meeting and must include the date, time, and location of the meeting 31

Timeline for Consultation November/December (month 2/3) Meet with private school officials to review timeline and consultation process Establish a consultation calendar and procedures for collecting poverty data (i.e., data on low-income families) B-4. How does a district collect poverty data on private school children? 1. Using the same measure of poverty. If available, an LEA should use the same measure of poverty used to count public school children, e.g., free and reduced price meals data. Private School Non-regulatory Guidance, October 17,

Timeline for Consultation November/December (month 2/3) continued Procedures for Collection of Poverty Data Collected by: –Principal of private schools, or –Central office official representing a group of private schools Collection of Poverty Data –Conduct a survey of private school parents, asking for income data, addresses, grade levels of children, etc. –Utilize alternative poverty data, i.e. scholarships, Temporary Aid to Needy Families (TANF), Medicaid, etc. –Or, decide, through consultation, to use proportionality 33

Timeline for Consultation The following individual consultation meetings will result in the development of an LEA written plan to serve eligible students, their teachers and their parents in each participating private schools. Each individual participating private school plan must include all the components of a targeted assistance program. 34

Timeline for Consultation January/February (month 4/5) Review poverty data collected Review amount of funds available for services Discuss pooling option Determine the multiple, educationally-related, objective criteria to be used to select eligible students (educationally needy students who reside in Title I attendance areas) in consultation with private school officials 35

Timeline for Consultation January/February (month 4/5) continued Review of options for service providers Additional teachers Tutors Summer school 3rd party vendors. If chosen, begin the district’s procurement process Verify or decide on dates for future meetings-develop a calendar 36

Timeline for Consultation March/April (month 6/7) Obtain from private school officials lists of names, addresses, and grades of private school students who meet the multiple, educationally-related, objective criteria to select eligible students for Title I service Rank the students by greatest need for service by subject area From these lists, select for Title I services for those students most at-risk of failing, as decided in consultation 37

Timeline for Consultation March/April (month 6/7) continued Discuss how the Title I program will be evaluated –What standards and assessment will be used (pre and post assessments) –What goals, assessments and criteria will be used to measure the effectiveness of : –Instructional Programs –Parental Involvement –Professional Learning 38

Timeline for Consultation May/June (months 8/9) Finalize the designs of the Title I programs; ensure materials have been ordered Ensure LEA personnel who are providing Title I services are in place and service start date is firm Finalize professional development programs and activities for private school teachers –Establish a calendar for next year’s professional learning activities 39

Timeline for Consultation May/June (months 8/9) continued Finalize parental involvement programs and activities for parents of participants –Establish a calendar for next year’s parental involvement activities Provide on-going consultation affirmation form for signatures Provide equitable services affirmation form for signatures 40

Timeline for Consultation July (month 10) Ensure private school materials have arrived, added to the inventory and are delivered to the appropriate location 41

Timeline for Consultation August/September (months 11/12) Inform private school officials of the readiness of Title I program services for private school participants Begin Title I services for students identified the previous spring as participants and provide private school officials with student names, services to be provided, and name(s) of Title I teachers Obtain a list of newly enrolled students who meet eligibility criteria. Consult with private school officials on how new students might be accommodated in the program 42

Timeline for Consultation August/September (months 11/12) continued Initiate professional development and parental involvement activities based on previous spring’s consultation Review criteria to be used for evaluation of the effectiveness of the Title I program including the following areas: academic, parent involvement, and professional development 43

Timeline for Consultation August/September (months 11/12) continued Conduct academic pre-assessments Host Title I parent information meeting for participating parents Complete a Parent Compact (optional) 44

Timeline for Consultation October (Month 1) –Begin the new initial consultation cycle for the next fiscal year 45

Timeline for Consultation October/November/December/January/February/ March (months13/14/15/16/17/18) Meet with private school officials periodically to determine if program is operating smoothly and effectively Meet with Title I teacher(s) periodically to determine if program is operating smoothly and effectively Make on-going adjustments to ensure student needs are being met Monitor implementation of the parental involvement component of the program 46

Timeline for Consultation October/November/December/January/February /March (months13/14/15/16/17/18) continued Monitor implementation of the professional development component of the program Ensure conferences are occurring between the Title I teacher and the private school teacher(s) of participating students Ensure conferences are occurring between the Title I teacher and the parents of the participating students 47

Timeline for Consultation October/November/December/January/February /March (months13/14/15/16/17/18) continued Conduct Title I teacher observations periodically to verify effectiveness of teaching skills and instruction Conduct on-site visits for periodic physical inventories of equipment(at least once every two years) 48

Timeline for Consultation April/May (month 19/20) Complete parent survey Gather documentation to evaluate the effectiveness of the Title I program based on the criteria established at the beginning of the school year in the areas of academic, parental involvement, and professional learning Evaluate the effectiveness of the Title I program Based on the evaluation of the Title I program, determine adjustments and program changes to improve the Title I program 49

Timeline for Consultation April/May (month 19/20) continued Attach Private School documentation to the Consolidated Application no later than June 30 1.Affirmation of Consultation signed by private school official for each private school served 2.Affirmation of Equitable Services signed by private school official for each private school served 50

Timeline for Consultation April/May (month 19/20) continued 3.Evaluation of the Title I Private School Program The annual evaluation of the private school program should include goals written in measurable terms, summary evaluation of each goal, and an overall narrative summarizing the progress made and identifying adjustments or changes to the private school program that will be made for the upcoming year. –Areas to be included in evaluation o Student academic achievement o Parental involvement o Professional Development o Additional goals based on the Title I Program design 51

Timeline for Consultation April/May (month 19/20) continued 3.Evaluation of the Title I Private School Program The district may create their own evaluation instrument (a sample format will be provided but the format is not required) Sample Private School Evaluation optional format Programs/Pages/Title-I-Worksheets.aspx In addition to the required areas of evaluation, the final evaluation must include –the dates of the consultation meetings –a dated final narrative that reviews the effectiveness of the program and identifies modifications for the upcoming school year with signatures of the Title I Director and the Private School Administrator 52

Timeline for Consultation April/May (month 19/20) continued Note: The FY13 Title I conference session and PowerPoint, Serving and Assessing the Private School Program provides additional detailed information related to evaluation of the private school program. 53

ALLOCATION OF TITLE I FUNDS 54

Allocation of Title I Funds There are two ways in which private schools participate in Title I programs. Through … Per Pupil Allocation of Title I Funds Equitable Participation in Programs Control of Title I funds and title to materials, equipment, and property purchased with such funds shall be in a public agency. [ESEA, §1120 (d): Public Control of Funds] 55

Allocation of Title I Funds Determining Private School Allocations Eligible Students are: –Private school students from low-income families who reside in Title I participating public school attendance areas 56

Allocation of Title I Funds Per Pupil Allocation (PPA) Private school students from low-income families who reside in Title I participating public school attendance areas Multiply the number of private school poverty students by the participating public school per pupil allocation Funds are used for instructional activities 57

Allocation of Title I Funds Equitable Participation An equitable proportional amount is available to participating private schools for: Instruction Professional Learning Parental Involvement 58

Allocation of Title I Funds Equitable Participation An equitable proportional amount goes to private school if districtwide activities are set-aside in the following areas: Instruction Summer School After School Professional Learning Academic Coaches Districtwide professional learning activities Highly Qualified Professional Learning Parental Involvement 59 [34 CFR sec (a)(2)(i)(A)]

Allocation of Title I Funds Equitable Service does not apply to the following set–asides: Required Flexible Learning Programs set-asides Additional Priority, Focus and Alert Schools set-asides NCLB Choice Transportation set-asides Homeless set-aside Neglected and Delinquent set-aside Pre-School set-asides Administrative set-asides 60

Allocation of Title I Funds Calculating Equitable Participation Determine the number of private school students from low-income families who reside in Title I participating public school attendance areas Multiply the percentage of eligible private school students by the district set-aside; and Determine the services to be provided based on the equitable dollar amount 61

62 Allocation of Title I Funds Use of Funds for Equitable Services Instructional –Services to Eligible Participating Students Instructional Support – materials District Paid Instructional Staff – tutors, small group instruction Parental Involvement –Services to Parents of Eligible Participating Students

63 Allocation of Title I Funds Use of Funds for Equitable Services Professional Learning –Training for private school teachers of eligible participating students –Not for district paid teachers of eligible participating students –Arranged by the district through consultation with private school officials – Private schools cannot arrange for professional learning and then submit for reimbursement –Reimbursement for substitutes is not an allowable expenditure

64 Allocation of Title I Funds Use of Funds for Equitable Services Reminder –Private schools are not to be reimbursed for services and materials provided. The district is responsible for private school program implementation.

ENSURING EQUITABLE PARTICIPATION 65

Ensuring Equitable Participation To ensure equitable participation, the district or other entity receiving federal financial assistance must: –Assess, address, and evaluate the needs of private school students and teachers through consultation; –Determine amount of funds per student Provide private school students and teachers with an opportunity to participate in activities equivalent to the opportunity provided to public school students and teachers; and Offer services that are secular, neutral and non-ideological. 66

Ensuring Equitable Participation Services are equitable, if the district— Addresses and assesses the specific needs and educational progress of eligible private school children on a comparable basis as public school children; Meets the equal expenditure requirements for instructional programs, and professional development and parental involvement activities; Provides private school children with an opportunity to excel and achieve equitable to the opportunity provided to public school children; and Provides promise of private school children reaching high levels of academic achievement. 67

Samples 68

69 Worksheets Private School Per Pupil Allocation (PPA) Worksheet -Embedded in Consolidated Application Private School Equitable Participation Worksheet -Attached to the Consolidated Application

Title I Program Specialist Contact Information AreaNameOffice Telephone 1Robyn Planchard(404) 2Randy Phillips(770) 3Anthony Threat(706) 4Evelyn Maddox(404) 5Judy Alger(229) 6Grace 7Jimmy Everson(229) 8Marijo Pitts-Sheffield(912) 9Kathy Pruett(706) 10Elaine Dawsey(478) 11Olufunke Osunkoyo(678) 12Bobby Trawick(229) 70

Presenters Elaine Dawsey Georgia Department of Education Title I Education Program Specialist (478) Marijo Pitts-Sheffield Georgia Department of Education Title I Education Program Specialist (912)