1. Equitable Services to Non-public Schools
2016 ESEA Directors Institute
August 23, 2016

2. Bridgett Carwile Regional Consultant Division of Consolidated Planning & Monitoring (615)

3. Session Overview Equitable service requirements across all programs
Discuss timely and meaningful consultation
Intent to Participate form and the Private School Survey forms: what they do and where they are in ePlan
Fiscal considerations to keep in mind when providing services to non-public students and teachers
An overview of allowable activities for Titles I, II, and III
The complaint process available to non-public schools
Required documentation to be maintained by the LEA
Let’s start by looking at the agenda for this webinar. First we will review the process for getting your ITP forms out to private schools, then we’ll discuss transferring all of that data onto your private school surveys. Next we will walk through how to navigate in ePlan to find those documents and how to upload that the PSS back into ePlan once you have populated it. Lastly we will review why it is so important to get this information for each private school as it relates to Title I equitable services and set asides.

4. Equitable Service Requirements

5. What is equitable participation?
Required by sections 1120 and of NCLB
LEAs must provide equitable services and benefits to eligible private school students, teachers, other educational personnel, and parents.
Applies to select formula and competitive grant programs
As we said earlier, since the initial passage of the Elementary and Secondary Education Act of 1965 (ESEA), private school students and teachers have been eligible to participate in certain federal education programs.

6. Affected Programs Formula Grants: Title I, Part A Title I, Part C
Title II, Part A
Title III, Part A
Competitive/Discretionary Grants:
Title II, B (Math and Science Partnerships)
Title IV, Part B (21st Century Community Learning Centers)
Federal guidance states that LEA’s are required provide services to eligible students in non-public schools. In order to implement those services we must collect enrollment data from ALL non-public schools throughout the state. Although for pro-fit schools may not participate, we still need enrollment data for those schools. If a school is non profit private institution, they may participate and must be given that opportunity to do on an annual basis.

7. Who is Eligible for services?
Title I:
Students who:
Reside in a Title I participating attendance area
Attend a non-public school
Are identified as failing or at risk of failing
Title II:
Teachers working in non-public schools within the LEA boundaries
Title III:
Teachers working in non-public schools within the LEA boundaries who provide instruction to English learners
English learners attending non-public schools within the LEA, meeting eligibility requirements for services
Poverty is not a factor in determining eligibility
Eligible students qualify for Title I equitable services if they live in a Title I school zone and are at risk for failure in core subject areas. Eligibility should be determined using several multiple measures. The most popular ones are the ones listed hear, but those don’t have to be the only measures. I have known others to use parent questionnaires as part of the measurable criteria. During consultation LEA’s should discuss and come to an agreement with private school officials as to what the criteria for eligibility should be

8. Services are Equitable when LEAs…
2/21/2012
Services are Equitable when LEAs…
Assess, address, and evaluate the needs of non-public school students, teachers, and parents
Provide non-public school students and teachers with an opportunity to participate in activities equivalent to the opportunity provided to public school students and teachers
Services are equitable when they assess the needs of the students teachers and parents, address those needs through provision of services and then through evaluating those needs of the private school students, teachers and parents, changes are made to better serve are all parties involved. Services are equitable when they provide equitable opportunities for participation for private school students and teachers and if the services begin at the same time as the public schools start. Now that does not mean private school doors have to open the same exact day as public schools. We know start dates may vary. However, by the time school opens for public schools, private school officials should have been consulted and start dates and times should have been agreed upon. So if private school officials want to start their programs as early as the first day of school, LEA’s should be able to accommodate that and if they want to start after Labor, LEA’s should be able to accommodate that as well.

9. Services are Equitable when LEAs…
2/21/2012
Services are Equitable when LEAs…
Begin services with non-public school students at the same time as public school students
Spend equal amount of funds to serve similar public and non-public school students
Services are equitable when they assess the needs of the students teachers and parents, address those needs through provision of services and then through evaluating those needs of the private school students, teachers and parents, changes are made to better serve are all parties involved. Services are equitable when they provide equitable opportunities for participation for private school students and teachers and if the services begin at the same time as the public schools start. Now that does not mean private school doors have to open the same exact day as public schools. We know start dates may vary. However, by the time school opens for public schools, private school officials should have been consulted and start dates and times should have been agreed upon. So if private school officials want to start their programs as early as the first day of school, LEA’s should be able to accommodate that and if they want to start after Labor, LEA’s should be able to accommodate that as well.

10. Consultation

11. Regulatory Requirements of Consultation
Title I requires timely and meaningful consultation between the LEA and private school officials prior to any decision that affects the opportunities of eligible private school children, families, and teachers to participate in Title I programs, and shall continue throughout the implementation and assessment of activities.

12. Regulatory Requirements of Consultation
“Timely” consultation means
BEFORE any decisions are made by the LEA
“Meaningful” consultation means
Genuine opportunities for parties to express their views
Views are heard and seriously considered
An opportunity for discussion—not a unilateral decision
LEA has final decision regarding instructional services to be offered.

13. Regulatory Requirements of Consultation
Consultations must address the following for eligible private school children:
How LEAs will identify needs
What services LEAs will offer
How and when LEAs make decisions about the delivery of services
How, where, and by whom LEAs will provide services
How LEAs assess the academic services to private school children, and how LEAs use the results to improve Title I services

14. Example Timeline for LEA Consultation with Private Schools
Month
LEA Activity
Legal Basis
November/December in preparation for the next school year
Obtain complete list of all private schools who are residents of the LEA
LEA uses list to ask all private school officials if they want their eligible students to participate in Title I the next school year
December/March in preparation for the next school year
Obtain from principals or a central office serving a group of private schools poverty data (as appropriate)
Private school students from low-income families who live in Title I participating public school attendance areas generate funds for instructional purposes

15. Statement of Affirmation
Title I § requires that each LEA must obtain a written affirmation signed by the official of each participating private school, or a representative of those schools, that the required consultation process has occurred.
A signature on an affirmation form signifies that the private school official is satisfied that an equitable program has been designed to meet student needs and has a reasonable promise of being effectively implemented.

16. Intent to Participate Form
Collects enrollment data from all private schools; both non-profit and for-profit
Indicates which non-profit private schools will be participating in federal programs during the following year
Independent home schools do not complete an Intent to Participate form
The state provides that opportunity by sending out the Intent to Participate form every year. This is an avenue for collecting pertinent data such as enrollment information, whether a school is for profit or non-profit as well as which non profit schools want to participate and which programs they would like to participate such as Title I, Title IIA, etc. Independent homeschools do not have to complete the ITP form. Those are home schools that are registered only with their local districts. But if a homeschool is registered with the State, as a private school, it is deemed a private school and must fill out an ITP form.

17. Intent to Participate Form: Distribution
Distribute to all private schools in your district.
Use the Tennessee non-public schools list.
Use registered mail to document contact with each private school.
Attempt more than one form of communication.
(return receipt)
Non-registered mail
Fax
Refer to forms on ePlan for current deadlines.
Non public schools MUST be sent an itp form, even if they indicated last year that they never plan to participate and that you should never contact them ever again. The school may feel that way, but The law says otherwise, therefore districts must send the ITP forms out annually. On the hyperlink provided on the page is a list of nonpublic schools for each LEA that has private school in their area. This is the same list that your private school surveys were derived from. It is a bit more detailed in that there are addresses and telephone numbers for schools on your survey. This list is in an excel format , so if you would like to do a custom sort by your district’s name, to only get a list for private schools in your district, it is totally doable. When it comes to mailing out the ITP form, It is suggested that those forms are mailed via certified mail, but I would like to further suggest that LEA’s reach out to private schools in several ways. Forms can be ed, but I would make sure to attach a return receipt. A third means of getting those forms to schools could be faxing it and using the transmittal confirmation as proof of distribution. Please make sure you have contacted all of the schools in your districts and collected ITP forms for those schools by Friday, January 30. I do know that there are some schools that you will not be able to get a form back from. In that event please have documentation of at least three attempts to retrieve the form.

18. Intent to Participate Information on ePlan
From there, you would select ESEA Private schools information and documents.

19. Intent to Participate Information on ePlan
then, you should see the intent to participate link. And when you click on that link, you will be able to retrieve the most current version of the ITP form for the school year. Then just send that form to all of the private schools on in your area.

20. Intent to Participate Form
then, you should see the intent to participate link. And when you click on that link, you will be able to retrieve the most current version of the ITP form for the school year. Then just send that form to all of the private schools on in your area.

21. Intent to Participate Form
then, you should see the intent to participate link. And when you click on that link, you will be able to retrieve the most current version of the ITP form for the school year. Then just send that form to all of the private schools on in your area.

22. Intent to Participate Form
*if box is checked, fill out number of LEP students.
then, you should see the intent to participate link. And when you click on that link, you will be able to retrieve the most current version of the ITP form for the school year. Then just send that form to all of the private schools on in your area.

23. Private School Surveys
Which brings us to the private school surveys

24. Reporting Intent to Participate Data
LEAs should submit the enrollment and participation data collected from private schools using the Private School Survey.
The Private School Survey is located on ePlan in the district LEA Document Library.
Surveys should be uploaded to ePlan in late January of each year.
Refer to survey for actual deadline
You can find the survey for your district in your LEA Document library and we will take a little ePlan field trip to show where that lives momentarily. Before we do so, please make every effort to collect all of the ITP forms in your district by January 30, because the surveys are due to the TDOE by the following Friday, February 6

25. Locating the Survey on ePlan
Next, scroll down to Non-public / private school documents and select the ESEA private schools information and documents folder

26. The Private School Survey
You can find the survey for your district in your LEA Document library and we will take a little ePlan field trip to show where that lives momentarily. Before we do so, please make every effort to collect all of the ITP forms in your district by January 30, because the surveys are due to the TDOE by the following Friday, February 6

27. Upload the Completed Document
Click on “Edit Documents” to the right of “Private Schools Participation Form (completed).”
It is actually the tab directly underneath where you found the template. To upload the documents click on the edit documents button that is circled on the screen.
If “Edit Documents” does not appear, contact the ePlan Help-Line at (615)

28. Upload the Completed Document
The name of the document will appear under “Documents/Links” section.
The trash can icon can be used to remove an unwanted upload to replace with a corrected upload.
Once you have saved it, then you will see the your saved document should show up in the “update documents and links” If you have to make changes for any reason, can delete your copy and upload corrects versions as many times as you like, but I suggest changing the name of the document so that you remember which version was your last version, maybe adding a date, or revision number to keep track of changes that you may have made.

29. Checking the Document Upload
The name of the document and the upload history will appear on the main page of the LEA Document Library.
Once you have uploaded your document, it will appear in your LEA document Library and the history of your last update will appear beside it. So, you are done with that portion. But . . .

30. Fiscal Considerations
Which brings us to the private school surveys

31. Fiscal Considerations
Funds for non-public services are generated based on the number of low-income, non-public school students residing in Title I participating attendance areas.

32. Fiscal Considerations
Funds taken as district-level set asides, in some cases, must be shared equitably with eligible non-public students.
Parental involvement
Additional instructional initiatives
Professional development
Before and after school programs
ESL services
Other instructional initiatives

33. Fiscal Considerations
LEAs are required to complete the Title I Equitable Services Worksheet to determine allocations. This worksheet is located under “Related Documents” in the Consolidated Funding Application on ePlan.

34. Fiscal Considerations
IMPORTANT:
Non-public low income student data determines the amount of money available for non-public services.
However, services are provided to eligible students who are failing or at-risk of failing, regardless of economic status.

35. Fiscal Considerations
LEAs maintain control of funds and are responsible for providing services.
Equipment purchased remains the property of the LEA and must be properly tracked and maintained by the LEA.
Equipment, materials, and supplies may only be used by participating Title I students.

36. Allowable Activities
Which brings us to the private school surveys

37. Allowable Activities: Title I
Instruction outside the regular classroom
Extended learning time (before and after school and in the summer)
Family literacy programs
Early childhood education programs
Counseling
Home tutoring
Instruction using take-home computers
Computer-assisted instruction
Combinations of services listed above

38. Allowable Activities: Title I Parent Involvement
An LEA must provide equitable services to parents of private school participants from the funds set aside for this purpose.
Activities for the parents of private school participants must be planned and implemented after meaningful consultation with private school officials and parents.

39. Allowable Activities: Title I Parent Involvement
Activities that LEAs can provide parents that will assist private school students in achieving high academic standards include a written agreement between the LEA and parents of private school participants regarding the responsibilities of the LEA and parents in:
the Title I program,
parent meetings,
student academic progress,
parent teacher conferences, and
parent education.

40. Allowable Activities: Title II
Professional development activities may include:
improving the knowledge of teachers, principals, and other educational personnel 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 on how to teach students with different needs, including students with disabilities or limited English proficiency, and gifted and talented students.

41. Allowable Activities: Title II
Additional professional development activities include:
training on methods to improve student behavior, identifying early and appropriate interventions, and involving parents more effectively in their children’s education;
leadership development and management training to improve the quality of principals and superintendents; and
training in the use of data and assessments to improve instruction and student activities.

42. Allowable Activities: Title III
Supplemental tutoring for ELs before and after school
Professional development for teachers provide instruction to ELs
Summer school programs for ELs
Administration of English language proficiency assessments (supplemental)
Supplemental instructional materials and supplies for use by ELs

43. Complaint Process

44. Complaint Process Components
A private school official has a right to complain to the state educational agency (SEA) if the LEA did not:
engage in a timely and meaningful consultation process; or
give due consideration to the views of the private school officials.
Any dispute regarding the accuracy of low-income data for private school students also can be the subject of a complaint.
The SEA has complaint procedures in place and will resolve the complaint.

45. Documentation

46. Documentation LEA must retain documentation to show staff:
informed non-public school officials of available federal programs;
engaged in timely and meaningful consultation;
allocated sufficient funds for non-public schools;
identified non-public school needs;
provided equitable services and benefits;
evaluated programs for effectiveness; and
adequately addressed problems and complaints.

47. Questions

49. Notifications can also be submitted electronically at:
FRAUD, WASTE, or ABUSE
Citizens and agencies are encouraged to report fraud, waste, or abuse in State and Local government.
NOTICE: This agency is a recipient of taxpayer funding. If you observe an agency director or employee engaging in any activity which you consider to be illegal, improper or wasteful, please call the state Comptroller’s toll-free Hotline:
Notifications can also be submitted electronically at: