1. PAPFC Annual Conference May 3-6, 2015 Presented By: Cindy Rhoads Division of Federal Programs Pennsylvania Department of Education

2.  To review the process for determining eligibility of schools for Title I at the district level to ensure the proper identification of Title I buildings.  To review the process of allocating Title I funds to eligible schools to ensure federal rules are followed.

3.  Based on census poverty figures from USDE (as well as neglected/foster and other low income indicators)  PDE provides “preliminary” Title I allocations to LEAs in the Spring preceeding the school year.  LEAs are responsible for allocating the school district’s Title I allocation to “eligible” Title I schools.

4.  Reserve funds “off the top” - ◦ District wide Title I purposes ◦ Meeting mandatory set-asides ◦ Administrative costs  Allocate Title I dollars to eligible schools for the Title I instructional program and nonpublic instructional program (if applicable)

6. “Required” Set Asides… LEAs “MUST” reserve funds for the following set asides – if applicable Parent Involvement** Neglected Allocation Non Highly Qualified Teachers 20% set aside for Priority/Focus Schools Homeless

7. Required Set Asides… 20 % School Intervention Set-Aside - Required for all Priority/Focus Schools - Meaningful interventions aligned with their Comprehensive plan - Any unused amounts may be rolled back in to the LEA’s regular Title I allocation - All Title I rules apply for the 20% set aside expenditures

8. Required Set Asides… Homeless LEAs are required to set aside funds to provide services to homeless students who do not attend Title I schools. No Minimum or Maximum set aside Exemptions: – If all buildings within LEA are Title I – Charter schools because there is only 1 building

9. Optional Set Asides Audit - Cost to conduct annual audit of federal programs Community Day Programs - Costs associated with providing Title I pre-school programs and services in a community based setting, such as community centers. Indirect Costs - Costs associated with implementing the Title I program that is not reflected in the program budget. Operations & Maintenance - Activities concerned with keeping the physical plant open, comfortable and safe for use, and keeping the grounds, buildings, and equipment in effective working condition and state of repair.

10. Optional set asides, cont…  **District Wide Professional Development - Costs for providing district-wide Title I professional development.  Pupil Transportation - Costs for providing transportation for extended day Title I programs.  Pre-School Programs - An LEA may reserve an amount from their total Title I allocation to operate an LEA-based Title I preschool program for eligible children in the district as a whole or for a portion of the district.

11. Optional Set Asides cont… Program Evaluation - Activities associated with the LEA evaluation of the effectiveness of federal programs – i.e., local assessments. Salary & Fringe Benefit Differentials - LEAs may reserve the difference in salary costs as it relates to the beginning step on a pay scale for an instructional teacher in a Title I school vs. a Title I teacher at the top of a pay scale. Summer & Intersession Programs - Costs associated to provide Title I summer school, extended day, or extended year programs. State & Federal Liaison - Costs associated with staff responsible for administering the Title I program in an LEA.

12. Optional set aside, cont… Administrative Costs - To cover costs of serving public & private school children (including excess capital costs for serving private school children). IMPORTANT: Any funds reserved for the following optional set asides must be reflected in the coordinating section of Title I budget. State & Federal Liaison Program Evaluation Audit Indirect Costs Administrative Costs

13. Equitable Nonpublic Share… If LEA reserves funds for district-wide activities for any of the following set asides – Summer school – Professional development – Parent involvement activities An equitable share must go to Nonpublic schools.

14. Keep in Mind…  If you are unsure of where to place an activity on the Reservation of Funds page, contact your Regional Coordinator for assistance.  Reserving funds off the top for required/optional activities will reduce the amount of Title I funds to be distributed to eligible (Title I) schools.  The ROF Worksheet in your Title I project is not the Budget section; You must still reflect set aside activities on the Title I budget pages. ◦ Or Title IIA budget pages if using IIA funds

15.  Selection of Schools Section of eGrant Application ◦ Series of worksheets to walk LEAs through the eligibility, selection and allocation process  Title I eligibility is based on low income percentages ◦ Rank Order (highest to lowest) ◦ % of Low income

16.  Three step process ◦ Determining which buildings are “eligible” ◦ Deciding which will be “served” ◦ Determine the amount of Title I funds each “served” building is allocated

17.  Determine data source for low income. ◦ Free/Reduced Price lunch participants (most common)  Use any date from school year – be consistent ◦ Temporary Aid for Needy Families (TANF) ◦ Census ◦ Community Eligibility Provision (CEP) ◦ Other

19.  eGrants calculates the % of low income for each building and displays the results in rank order from highest % of low income to lowest. ◦ Title I dollars must be allocated in this order  Highest poverty = highest per pupil amount  Using the results from this worksheet, an LEA may begin applying different eligibility criterisa to determine which method best meets the needs of your lowest achieving population.

20.  Any building with 75% or more low income population MUST be served, regardless of grade span.  After ALL buildings meeting this criteria are selected, remaining buildings may be eligible using the following parameters.

21. Title I Eligibility Rules ◦ Percentage by District Average  Example: If District Average of low income among all schools is 37%, then all schools 37% and above are eligible for Title I. The ones below 37% are not. ◦ Percentage by Grade Span – Using Grade Span Average  Example: If the low income average between all elementary buildings is 53.50%, then all elementary schools equal to or above 53.75% are eligible. The ones below are not.  Same rule is applied to middle school and high school(s). ◦ Percentage by Grade Span – Using District Average  Example: If the District average is 55%, then within each Grade Span, any building equal to or above is eligible

22. 35% Rule – All schools that are 35% low income (or higher) are eligible for Title I, regardless of grade span. All buildings must be served in rank order. Buildings cannot be skipped without justification and evidence of a district-funded program with the same intent as Title I. Title I Eligibility Rules (cont’d)

23. – Feeder Pattern (rarely used) – K-12 is always eligible if: District enrollment is less than 1000 Single attendance area (no overlapping grade spans between buildings) – ED FLEX Waivers Special Rule/Exceptions…

24. Allocating Title I Funds After determining which schools will be served with Title I, the LEA starts the process of allocating the Title I funds to the buildings. The next worksheet in the Selection of Schools section of eGrants walks the user through the process. Rules for allocating Title I funds:  Each low income child generates Title I dollars for the district. Title I building allocations are determined by calculating the number of low income students in the building by a low inocme per pupil amount (determined by the district).  Per pupil amounts may be different, but also must be highest in the highest poverty buildings and less than or equal to the preceeding building throughout the ranking list. Special Rule: If an LEA serves one or more buildings with less than 35% Low Income population:  125% of average per pupil amount to every low income child is required in all buildings  Last building served may receive less

25.  The amount of Title I funds displaying in eGrants for each building is the Title I allocation for that school.  LEA must maintain a Title I school level budget reflecting salary costs, materials, supplies, etc., relating to the Title I program/staff.  The Title I allocation for each school cannot be exceeded.  1% set aside for parent involvement should also be tracked in the building level budget.

26.  Procedures and fiscal controls need to be in place at the LEA level to ensure that Title I funds are allocated properly to the correct buildings.  Procedures and fiscal controls also need to be in place for determining allowable costs, time documentation, and ensuring the Title I allocations in eligible schools are not exceeded.

27. QUESTIONS