1. FY14 Title I Summit July 24, 2013 WELCOME FY2014 Federal Programs Information Sessions “Commitment to Excellence for Student Success”

2. Title I 101 FY14 Title I Summit July 24, 2013 Andrea Fairries-Moore Assistant Superintendent for Administrative Services Afairries-moore@atlanta.k12.ga.us

3. Intent of Title I The intent of Title I is to ensure that all children have a fair, equal, and significant opportunity to obtain a high- quality education Title I provides funds to improve achievement of the lowest-achieving students – those who are failing, or are most at-risk of failing, to meet State academic achievement standards – enrolled in high-poverty schools

4. Targeted Assistance Programs Schools that are ineligible for a schoolwide program (Section 1114) Less than 40 percent poverty Less than the district poverty average Schools that choose not to operate a schoolwide program Schools that operate targeted assistance programs must: Rank list students using multiple academic criteria Limit the expenditures only to identified students (activities, teachers, parent)

5. Schoolwide Programs Section 1114 of Title I of the ESEA allows a school in which 40 percent or more of its students are from low-income families to use its Title I funds, along with other Federal, State, and local funds, to operate a schoolwide program to upgrade the entire educational program in the school to improve the academic performance of all students, particularly the lowest-achieving students. [Section 1114(a)(1)]

6. Determining Title I Eligibility The local educational agencies (LEAs) must identify eligible Title l school attendance areas and schools and allocate funds to those attendance areas and schools based on the requirement in Title l, part A, section 1113 of the Elementary and Secondary Education Act of 1965 (ESEA)

7. Definitions What is an Eligible Attendance Area?  It is an attendance area that qualifies for Title I services based on its ranking according to poverty data  LEA must rank all of its school attendance areas (the geographic area from which a public school draws its children) according to their percent of poverty

8. Requirements An LEA must use the same measure of poverty for:  Identifying eligible school attendance areas  Determining the ranking of each area  Determining the allocation for each area

9. Poverty Measure The LEA must select a poverty measure from the following five options: 1.Children ages 5-17 in poverty as counted in the most recent census data approved by the Secretary 2.Children eligible for free and reduced-priced meals under the Richard B. Russell National School Lunch Act 3.Children in families receiving assistance under the State program funded under Title IV, Part A of the Social Security Act, Temporary Assistance for Needy Families (TANF) 4.Children eligible to receive medical assistance under the Medicaid program 5.A composite of any of the above measures

10. Poverty Measure *In order for LEAs to arrive at an accurate number, An LEA must rank school attendance areas based on the percentage (not the number) of low-income children counted

11. For Schools Using the Community Eligibility Option Community Eligibility Option: Guidance and Procedures for Selection Healthy, Hunger-Free Kids Act of 2010 (Act) The Healthy, Hunger-Free Kids Act of 2010 (Act) and the National School Lunch Program now includes a new universal meal program, the Community Eligibility Option The Community Eligibility Option permits eligible schools to provide meal service to all students at no charge, regardless of economic status

12. Implementation of the Community Eligibility Option Implementation began in the 2011–2012 school year in local educational agencies (LEAs) in Illinois, Kentucky, and Michigan In the 2012–2013 school year, the USDA selected the District of Columbia, New York, Ohio, and West Virginia In the 2013–2014 school year Georgia is one of four states to be selected The option will be available to all LEAs in the 2014– 2015 school year

13. Community Eligibility Option Uses only direct certification data, such as data from the Supplemental Nutrition Assistance Program (SNAP) or Temporary Assistance for Needy Families (TANF) program to determine the federal cash reimbursement provided by USDA Will not rely on annual household applications that are generally used to determine eligibility for free or reduced meals (FRM)

14. Community Eligibility Option A school is eligible for the Community Eligibility Option if at least 40 percent of its students are certified for free meals through means other than FRM applications (for example, students directly certified through Supplemental Nutrition Assistance Program (SNAP) Note: The 40 percent threshold may be determined school-by-school, by a group of schools with the LEA, or in the aggregate for the entire LEA. A percentage of 39.98 percent does NOT meet the threshold

15. Community Eligibility Option To account for low-income families not reflected in the direct certification data, USDA will set meal reimbursement levels for Community Eligibility Option schools by multiplying the percentage of students identified through the direct certification data by a multiplier established in the Act (initially, the multiplier is 1.6) Note: The law states that the multiplier is 1.6 through school year 2013-2014 (July 1, 2013, through June 30, 2014). After that time, Food and Nutrition Services (FNS) is permitted to change the multiplier to a number between 1.3 and 1.6 for any given fiscal year within the original four year timeframe. Otherwise, schools electing CEO will keep the same multiplier for an entire four-year cycle and do not have to implement changes to the multiplier until the next cycle if the CEO is elected again

16. Impact on Title I, Part A LEAs must rank its schools based on the percentage of economically disadvantaged students in each school to determine a school’s eligibility to receive Title I funds and to allocate funds to selected schools. (Section 1113 of the ESEA) States and LEAs that receive funding under Title I must assess and report annually on the extent to which students are making progress toward meeting state academic achievement standards in reading or language arts and in mathematics. (Section 1113 of the ESEA)

17. Impact on Title I, Part A Section 1113 of the ESEA States and LEAs must measure and report publicly on the progress of all students and of students in various subgroups, including students who are economically disadvantaged. (Section 1113 of the ESEA) LEAs must hold schools accountable for the achievement of subgroups. (section 1116 of the ESEA or under ESEA flexibility for those states with an approved ESEA flexibility request) To meet the requirements of ESEA, an LEA must have school-level data on individual economically disadvantaged students. In Georgia, information from the National School Lunch Program has been the source of data used to identify those students

18. CEO Guidance Issues under the Community Eligibility Option: If a school within a district using the CEO Option does not qualify for the CEO option, those schools will continue to use the FRM applications for free or reduced meals (FRM). In this case, a school will still continue to use the FRM application counts to determine a schools Title I allocation For the purposes of Food and Nutrition Services (FNS), the identified student percentage must be established using the identified students and students enrolled with access to the program no later than April 1st of the prior year For the purposes of Title I, Part A ), the identified student percentage must be established using the identified students and students enrolled with access to the program no later than October FTE count date of the prior year

19. Annual Determination of the Eligibility of a CEO School for Title I Funds LEA must assume that the percentage of economically disadvantaged students in the school is proportionate to the percentage of meals for which that CEO school is reimbursed by the USDA for the same school year Because CEO schools may conduct direct certification yearly, if data show an increase in the percentage of enrolled students eligible for direct certification, and the school therefore receives a higher level of reimbursement from USDA, then the figures used for Title I purposes would be adjusted accordingly

20. New Attendance Area Determination Worksheet A new attendance area determination worksheet has been created for LEAs to use in FY14. This worksheet will replace the current document found in the consolidated application

21. Example Within-District Title I Allocations for a Local Educational Agency with a Combination of Community Eligibility Schools and Other Schools * The number of students may be determined once every four years for Community Eligibility Option schools. Moreover, the poverty data used will likely differ from other schools. For the Community Eligibility Option schools, the poverty data would be, for example, direct certification (e.g., SNAP or TANF) collected at least every four years times the multiplier. For other schools, the poverty data might be from FRM applications collected every year or a combination of direct certification and FRM applications collected every four years. ** The multiplier applies only to a Community Eligibility Option school. *** For a Community Eligibility Option school, the Column 6 figure is equal to the lesser of (1) Column 4 x Column 5 or (2) Column 3. In other words, this number may not exceed the school’s total enrollment. For the other schools, the Column 6 figure is equal to Column 4. ****Column 6 / Column 3. *****Column 8 x Column 6 (Note: Monroe is ineligible for Title I funds because its poverty percentage is below both the LEA’s average and 35 percent.) Column 1Column 2Column 3Column 4Column 5Column 6Column 7Column 8Column 9 School Community Eligibility Option School (Y/N) Enrollment - PreK Economically- Disadvantaged Students Identified by Data for School Lunch Program* Minus Pre-K Multiplier** Number Used to Determine Percentage of Meals Paid by USDA*** Percentage of Economically- Disadvantaged Students for Title I Allocations**** Per-Pupil Amount Used by LEA Title I Allocation***** LincolnY4254001.6425100%$500$212,500 WashingtonN500475N/A47595%$500237,500 AdamsY6003501.656093%$500280,000 JeffersonN450400N/A40089%$450180,000 MadisonN400200N/A20050%$45090,000 MonroeN500100N/A10020%N/A0 TotalN/A2,875N/A 2,16071%N/A$1,000,000

22. For Schools Using the FRM Applications Information collected to determine School attendance area Enrollment Data School Enrollment Data, October 2013 Student Enrollment by Grade Level (Pre-K-12), October 2, 2013 Enrollment by Grade Level Pre-K Enrollment, October 2013 Poverty Data Free or Reduced-Priced Meals Per School, October 2, 2013 Free or Reduced Price Meals Eligibility Pre-K Free and Reduced-Priced Meals, October 2013Free or Reduced Price Meals Eligibility

23. Rank Order LEAs must annually, rank without regard to grade spans. Eligible school attendance areas in which the concentration of children from low-income families that exceeds 75 percent from highest to lowest according to the percentage of children from low-income families LEAs must serve eligible school attendance areas in rank order LEAs may either rank schools district wide or by grade span grouping

24. Rank Order After an LEA has ranked all of its school attendance areas by poverty, the LEA must first serve, in rank order of poverty, its schools above 75 percent poverty, including any middle schools or high schools Only after an LEA has served all of its schools with a poverty rate above 75 percent may the LEA serve lower-ranked Schools (Districts must not select schools below the district average unless the school has a poverty percentage of 35 percent or higher)

25. Allocating Title I Funds to Participating Areas and Schools An LEA must allocate Part A funds to participating school attendance areas or schools, in rank order, based on the total number of children from low- income families in each area or school An LEA is not required to allocate the same per-child amount to each area or school However, the LEA must allocate a higher per-child amount to areas or schools with higher poverty rates than it allocates to areas or schools with lower poverty rates

26. How to Determine if a Cost is Allowable Federal Cost Principles A-21 Educational Institutions A-87 State, Local, Indian Tribal Governments Basic Guidelines of Cost Principles All costs must be: Necessary Reasonable Allowable under the relevant program

27. How to Determine if a Cost is Allowable How will this activity/expenditure impact the academic achievement of the most academically at-risk students in this school? (Intent) Is the activity/expenditure reasonable and/or necessary? How is this activity/expenditure funded in non-Title I schools in the district? Is this activity/expenditure required under local, state, or some other federal law? How will this activity/expenditure build capacity within the parent to assist in his/her child’s education?

28. Federal Cost Principles (Items of Cost Examples) Advertising & Public Relations Costs Generally not allowable except as specified in OMB Circular A-87, Attachment B Alcohol Not allowable Entertainment Amusement or social activities not allowable Fines and Penalties Not allowable

29. Federal Cost Principles (Items of Cost Examples) Salaries and Wages Allowable if proper time distribution records are maintained If an employee is paid with federal funds, then that employee must work on that specific federal program/cost objective Allowable based on FTE and QBE staffing Class size reduction Academic Coaches Tutors Paraprofessional Positions

30. Federal Cost Principles (Items of Cost Examples) Travel Expenses Transportation, lodging, mileage, parking, and meals are allowable with certain restrictions Prior approval is required Must be in Title I Plans/align to academic needs Must be specified in budget Title I funds cannot be used to pay stipends for mileage Training Professional development is allowable Prior approval is required Must be in Title I Plans/align to academic needs Must be specified in budget

31. Federal Cost Principles (Items of Cost Examples) Allowable Conferences Related to the core curriculum subjects, focused on the needs of the most at-risk students, specifically related to the Title I program and not to the general needs of the district or school, and reasonable and necessary. Prior approval is required Must be in Title I Plans/align to academic needs Must be specified in budget Not allowable RTI IB Leadership Assessment

32. Federal Cost Principles (Items of Cost Examples) Incentives, T-shirts, etc. Not Allowable -Title I funds may not be used to purchase incentives or T-shirts for students or staff Snacks for students Not Allowable Title I funds may not be used to purchase snacks for students Food may only be purchased with Title I funds when it is tied to a planned parent involvement activity that is designed to build capacity in the parent to assist in his/her child’s education and when the activity is tied to a normal meal time (Meals are not allowed)

33. Federal Cost Principles (Items of Cost Examples) Equipment Allowable - the district, however, must determine that: 1)the equipment is reasonable and necessary to effectively operate its Title I programs; 2)existing equipment it already has will not be sufficient; and 3)the costs are reasonable Federal Guidelines and Procedures Manual FY2014 (Page 75) Any equipment purchased with Title I, Part A funds must be used to implement instructional programs for Title I eligible students. Title I equipment/laptops cannot be purchased for nor utilized by employees for personal use. Any equipment purchased with Title I funds must be used in the classroom for instructional purposes only.

34. Supplement Not Supplant A State educational agency or local educational agency shall use Federal funds received under this part only to supplement the funds that would, in the absence of such Federal funds, be made available from non-Federal sources for the education of pupils participating in programs assisted under this part, and not to supplant such funds [Title I, Part A Section 1120 A (b)]

35. Supplement Not Supplant The Words Defined Supplement – To fill in what is lacking…….. Supplant – Replace Roget’s II – The New Thesaurus ©1988 Houghton Mifflin Co.

36. Supplement Not Supplant Definition of Supplanting Substituting or replacing funds from non-Federal sources (State/local) for existing or previously- existing instructional programs or non- instructional services Substituting or replacing funds from other Federal/State funds required by law for specific categories of students (e.g., Special Education) State/local funds must be used for all activities that are the district’s responsibility

37. Supplement Not Supplant A-133 Compliance Supplement presumes supplanting in three situations 1.Used federal funds to provide services the LEA is required to make available under other federal, state or local laws 2.Used federal funds to provide services the LEA provided with state or local funds in prior year 3.Used Title I, Part A to provide the same services to Title I students that the LEA or SEA provides with state or local funds to nonparticipating students

38. Supplement Not Supplant What is “District Responsibility”? Defined as the requirements for operating a school under State and local laws/policy. This includes categories such as, but not limited to: Basic education classroom teacher salaries Support personnel salaries Administrator salaries Basic classroom supplies and materials Operation and maintenance Transportation

39. A-133 Compliance Supplement Presume supplanting occurred if federal funds were used to provide services that: 1.Were required to be made available under other federal, state, or local laws; Example: States, districts, and schools are required to provide special education services according to a students IEP. A supplanting violation will be presumed if the LEA uses Title I or Title III funds to provide these services 2.Provided with non-federal funds in the prior year; Example: If an LEA used state or local funds to support an after- school reading program during school year 2012-2013, a supplanting violation will be presumed if the LEA uses federal funds to support the same program during the year 2013-2014

40. Contracted Services District level Title I funds cannot be used to pay contracts for services rendered for non-district level activities If all schools are not involved, then you circumvent the ranking order for individual eligible schools and. skew the Title I per pupil allocation Contracts may be initiated by the individual schools, but must be associated with direct instruction, improvement of academic achievement of Title I students, and/or professional development of Title I teachers

41. Staffing Semi-Annual Certification Per OMB Circular A-87, Attachment B, Paragraph 8.h.3-Where employees are expected to work solely on a single Federal award or cost objective, charges for their salaries and wages will be supported by periodic certifications that the employees worked solely on that program for the period covered by the certification These certifications will be prepared at least semi-annually and will be signed by the employee or supervisory official having firsthand knowledge of the work performed by the employee This is an after-the-fact certification of time worked; therefore, it should be signed and dated after the end of the time period. Federal Guidelines and Procedures Manual FY2014 (Page 88)

42. Staffing Class-size Reductions Title I and Title II teachers are earned based on class-sized reduction and can only be implemented after state maximum class size requirements are met. Prior to reducing class size with Title I funds, the following must take place: receipt of FTE per grade level and the staffing of teachers including EIP based on FTE and QBE requirements The supplement/Supplant guidance prevents the usage of federal funds for class size reduction without meeting set class size (QBE) requirements first. In addition, class size reduction supported with Title II funds must be listed as a priority need as assessed by annual needs assessment and listed as a strategy in the System Implementation Plan (SIP) and applicable School Improvement Plan APS board approved addition teachers this year, which must be taken into consideration prior to approving class-size reduction teachers

43. Staffing Instructional Coaches Funded from school level federal funds Roles and Responsibilities Conducts informal classroom observations and provides feedback to teachers and assists with the development of new teachers Models lessons and provides opportunities for teachers to watch and learn new strategies or instructional practices Facilitates professional learning communities and assists teachers with collaborative lesson planning Conducts analysis of formative and summative student data and recommends modifications to instruction Uses observation and achievement data to identify professional development needs and designs and delivers site based professional learning

44. Staffing Parent Liaison Funded from school level federal funds (Full Time or Part-Time) Roles and Responsibilities Meets with the PTA and Title I Committee to develop a yearly plan for outreach activities to increase family and community partnership with the school Develops programs and activities designed to engage families in improving student achievement. Plans these in collaboration with an action team of families, teachers, parent organizations, business- community partners, and the principal Produces publications to provide information regarding school events to staff, the community and parents Helps to recruit partners to become part of the district’s family involvement program

45. To Report Fraud, Waste, or Abuse Anyone suspecting fraud, waste or abuse involving Department of Education funds or programs should call or write the Inspector General's Hotline (choose the method of contact which best suits you): Send an email message to oig.hotline@ed.gov Call the OIG Hotline's toll free number 1-800-MIS-USED. The Hotline's operating hours are Monday, Wednesday and Friday 9:00 AM until 11:00 AM, Eastern Time; Tuesday and Thursday, 1:00 PM until 3:00 PM, Eastern Time except for holidays.

46. Title I 101