1. Georgia Department of Education
Private School Consultation and Program Coordination (Title I, Part A; Title II, Part A; Title I, Part C; Title III and ESOL) Providing Equitable Services to Eligible Private School Children
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Georgia Department of Education
2016 GCEL, Inc., Conference
February 22-24, 2016

2. DISTRICT EFFECTIVENESS
SCHOOL IMPROVEMENT &
DISTRICT EFFECTIVENESS
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3. Presenters Marijo Pitts-Sheffield Elaine Dawsey
Georgia Department of Education
Title I Education Program Specialist
(912)
Elaine Dawsey
(478)
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4. Presenters Sharon Brown John Wight Georgia Department of Education
Title II-A Education Specialist
(404)
John Wight
Title I, Part C – Education of Migratory Children
(404)
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5. Presenters Tammie Smith Georgia Department of Education
Title III and ESOL- Education Specialist
(678)
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6. Workshop Purpose
To ensure uniformity in the implementation of the Title I Private School Provisions in ESEA:
Private school consultation and program coordination with applicable Federal programs
Overview of regulatory guidance relative to private school consultation
Roles and responsibilities of district and participating private schools
Consultation process with private school staff
Review of a timeline for private school consultation
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7. Guidance
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8. Guidance
The Elementary and Secondary Education Act of (ESEA) provides benefits to private school students, teachers and other education personnel, including those in religiously affiliated schools.
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9. 11/11/2018
Guidance
ESEA requires a participating district to provide eligible children attending private elementary and secondary schools, their teachers, and their families with Title I, Part A, Title II, Part A, Title I, Part C, Title III and ESOL services or other benefits that are equitable to those provided to eligible public school children, their teachers, and their families.
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Dr. John D. Barge, State School Superintendent June, 2011

10. Guidance
Title I, Part A, Title II, Part A, Title I, Part C, Title III and ESOL 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 students as determined in consultation.
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11. Guidance Federal programs with equitable participation requirements:
Title I, Part A – Improving The Academic Achievement of the Disadvantaged
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 III, Part A – Language Instruction for Limited English Proficient and Immigrant Students (ESOL)
Title IV, Part B – 21st Century Community Learning Centers
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12. Guidance
Who is responsible for planning and designing services for eligible private school students?
Through the consultation process, the district must design a coordinated Federal program with services that meet the needs of the private school and its students
The LEA is responsible for planning, designing and implementing the Federal program and shall not delegate that responsibility to the private school
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13. 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 and coordinate the design and development of the LEA’s federal programs plan that is appropriate for eligible private school children, their teachers and their parents
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14. Roles and Responsibilities
Private school officials will:
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 to be used for identification or services. Poverty is used only to determine the Title I funding allocation
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15. Roles and Responsibilities
Private school officials will:
Suggest ideas, program designs, and modifications that meet the needs of their eligible children, their teachers, and their families
Provide a dedicated space, if appropriate
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16. Consultation
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17. 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
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18. Consultation Timely and Meaningful Consultation:
To ensure timely and meaningful consultation, the district must consult with private school officials prior to the LEA making any decision that affects the opportunities of any private school children, their parents or the staff to participate in programs
[Requirements in ESEA Section 1120(b) and regulations]
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19. Consultation
Regulatory requirements for consultation include eight topics that must be included:
How the LEA will identify the needs of eligible private school children. Will the LEA use test scores? If so, from which tests? Will teacher recommendations be acceptable?
What services the LEA will offer to eligible private school children. Will the LEA pay for tutoring? Before-school or afterschool services? Supplemental instruction during the school day?
How and when the LEA will make decisions about the delivery of services. What is the LEA’s decision-making process? Is there a contracting process, and if so, what’s the timeline? When will the private schools know what to expect?
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20. Consultation
Regulatory requirements for consultation include eight topics that must be included con’t:
How, where and by whom the LEA will provide services to eligible private school children. Will the LEA pay for a highly qualified teacher to provide services? Or is the LEA likely to rely on third- party contractors? Will services be provided on the schools’ campus? Is so, where? Will students receive services in person or via computer? Individually or in groups? What will services look like?
How the LEA will assess academically the services provided and how the district will use the results of that assessment to improve services. How will the LEA determine whether the services improved student achievement? Based on that information, what is the LEA’s decision-making process? For example, what will be the achievement goals, and if those goals aren’t reached, what are the options to change the services?
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21. Consultation
Regulatory requirements for consultation include eight topics that must be included con’t:
The size and scope of the equitable services that the LEA will provide to eligible private school children and the proportion of its Title I funds that the LEA allocate and reserve. What can the available funds purchase in terms of services? Will students receive an hour of instruction a week, or an hour a year? Are equitable service available for parental involvement or professional learning? How will these be delivered?
The method, or sources of data, the LEA will use to determine private school children from low-income families residing in participating public school attendance areas. Do the private schools collect poverty data? If not, would they be willing to have families fill out a school lunch application? What exactly will be done to determine if there are eligible students in each school? [
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22. Consultation
Regulatory requirements for consultation include eight topics that must be included con’t:
The services the LEA will provide to teachers and families of participating private school children. What will the LEA be offering to the teachers of served students? What family involvement strategies will be used?
NOTE:
If the district disagrees with the views of the private school official on the provision of services through a contract, the district officials will provide a written explanation and an analysis to the private school officials of the reasons why the district has chosen not to use a contractor.
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23. Consultation Consultation Steps:
In OCTOBER, the LEA must use the US postal service to contact private school officials with children who reside in the LEA boundaries regardless of private school location and have a written returned receipt verifying that contact was made
The invitation must include the date, time, and place of consultation meeting (mail invitation at least three weeks prior to proposed meeting date)
LEA provides the Intent to Participate form to the private school who must complete and return the form

24. Consultation Consultation Steps (continued):
Title II, Part A, Title I, Part C and Title III only require notifications to private schools located within the geographical boundaries of the LEA
A current list of private schools is housed on the Georgia Department of Education’s website and will be used during monitoring to check for compliance bin/owa/psc_pack_mainmenu.pvsch_list_public?p_sort=1

25. Consultation Consultation Steps (continued):
LEA must convene a meeting to discuss needs and service options for applicable federal programs
Phone conversations and letters are not adequate
LEA must obtain a written affirmation from private school officials stating that timely and meaningful consultation occurred
LEA must maintain documentation on file for each applicable federal program for review during cross functional monitoring (dated agendas and sign-in sheets)
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26. Consultation Retain documentation that shows the LEA:
Informed private school officials of available federal programs
Engaged in timely and meaningful consultation
Identified private schools’ needs
Allocated sufficient funds for services to private schools
Provided equitable services and benefits
Evaluated programs and services for effectiveness
Adequately addressed problems and complaints
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27. Consultation Sample Documentation: Initial consultation Agendas
Sign-in sheets
Supporting documentation (DE 1111 Forms, letters mailed with return receipts, responses from private schools)
On-going meaningful and timely consultations
Minutes

28. Consultation Sample Documentation:
Complaints and/or problems documents
Consultation Affirmation form, signed
Title I Equitable Services Affirmation form, signed

29. Consultation Disagreements and Complaints:
Consultation does not guarantee that private school officials will agree with the LEA’s decisions regarding federal program services
Private school officials may not be satisfied that their views were adequately considered during the process of initial consultation
LEA must develop procedures that will address any private school complaints

30. Consultation Disagreements and Complaints:
It is the LEA’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 LEA 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 educational agency (SEA) and the LEA must forward any relevant documentation about the dispute to the SEA

31. Private School Worksheets for Title I PPA Calculations:
Private School Per Pupil Allocation (PPA) Worksheet
PPA funds can only be used for instructional purposes
Worksheet is embedded in Consolidated Application under School Allocation Tab
Refer to next slide for screen shot of worksheet

32. Private School Worksheets for Title I PPA Calculations:

33. Private School Worksheets for Title I Equitable Services Calculations:
Private School Equitable Participation Worksheet
Equitable services is base on the LEA’s set asides for instruction, professional learning and parental involvement activities
Services can only be provided in the areas in which they are generated
Worksheet is embedded in Consolidated Application under Data Collection Tab
Refer to next slide for screen shot of worksheet

34. Private School Worksheets for Title I Equitable Services Calculations:

35. SEE HANDOUT FOR EXAMPLE OF A TIMELINE FOR DISTRICT FEDERAL PROGRAM COORDINATION AND CONSULTATION WITH PRIVATE SCHOOL OFFICIALS

36. Marijo Pitts-Sheffield
Title I, Part A Staff
Area
Name
Office Telephone 1
Robyn Planchard
(404) 2
Sherri Minshew
TBD 3
Anthony Threat
(706) 4
Evelyn Maddox
(404) 5
Judy Alger
(229) 6
Grace McElveen
(912) 7
Jimmy Everson
(229) 8
Marijo Pitts-Sheffield
(912) 9
Kathy Pruett
(706) 10
Elaine Dawsey
(478) 11
Olufunke Osunkoya
(678) 12
Bobby Trawick
(229) 13
Ken Banter
(478) 14
Tammy Wilkes
(478)
Talking Points:

37. Title II, Part A
Sharon

38. Title II, Part A
Title II, Part A has requirements similar to those of Title I, Part A for the invitation to participate and consultation.
The major differences are related to the location of the private school, purpose and use of funds.

39. Title II, Part A SEC. 2101. PURPOSE.
The purpose of this part is to provide grants to state educational agencies, local educational agencies, state agencies for higher education, and eligible partnerships in order to —
(1) increase student academic achievement through strategies such as improving teacher and principal quality and increasing the number of highly qualified teachers in the classroom and highly qualified principals and assistant principals in schools; and
(2) hold local educational agencies and schools accountable for improvements in student academic achievement.
We will begin by reviewing the purpose of Title II, Part A.
What is the purpose of the Title II, Part A program?
1. Increasing student achievement
Improving quality of teachers and leaders
Increase the number of HiQ teachers
2. Holding LEAs accountable for student achievement
Remember: Title I focuses directly on student learners in order to increase student achievement, while the primary focus of Title II, Part A is on the teachers and leaders who serve them.

40. Title II, Part A – Private Schools
Equitable Participation
Section 9501 of the ESEA requires the LEA to set aside Title II, Part A funds for professional development for private school teachers and other appropriate staff at an amount equal to that set aside for public school teachers and staff on a per‐pupil basis, taking into account the number and educational needs of the children to be served.
Federal law requires that private school teachers have the opportunity to participate in Title II, Part A just as public school teachers. We will go into detail later in the presentation as to what are allowable activities, who is allowed to participate, and the required reporting of enrollment data to the LEA.
Note: Section of the ESEA ESSA

41. Title II, Part A – Private Schools
Invitation to Participate
The Elementary and Secondary Education Act requires that public LEAs contact appropriate officials of all private schools within the geographic boundaries of the LEA annually to determine if they want their teachers to participate in the Improving Teacher Quality State Grants program, regardless of whether or not those officials have recently indicated any interest in program participation.
A current list of Private Schools is housed on the Georgia Department of Education’s website and will be used during monitoring to check for compliance.
The LEA boundaries refer to the area from which the LEA draws its residence students.
The DOE website with the list of private schools is, hopefully, updated annually. It is the official list from which Title II, Part A
monitors for compliance. Click on the link and show the website. The Private Schools should ensure that they are on the
DOE’s list. The LEA will use the list as well as local knowledge of LEAs in its boundaries to send out invitations for participation.

42. Title II, Part A – Private Schools
Private School Elects to Participate
The private school is responsible for
Submission of needs assessment
Plan for implementation including plan for measuring effectiveness and budget
Participation in ongoing consultation
Providing K-12 enrollment data to LEA
Obtaining prior approval for PL activities (noted in plans or budget)
Providing required documentation of implementation of PL activities
The LEA will inform private schools of their obligations. It is important that the private schools are aware and have systems in place to meet the obligations.

43. Title II, Part A – Private Schools
Use of Funds
As with any professional development activity that the LEA carries out for public school teachers, activities supported with Title II, Part A funds that benefit private school teachers must meet the requirements of the statute.
Activities to be carried out for private school personnel must be based on the prioritized needs and a review of scientifically based research.
The activities are expected to improve student academic achievement.

44. Title II, Part A – Private Schools
Use of Funds - Title II, Part A Non-Regulatory Guidance
Professional development activities may include:
Improving the knowledge 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 in how to teach students with different needs, including students with disabilities or limited English proficiency, and gifted and talented students;
Training in methods of improving student behavior, identifying early and appropriate interventions, and involving parents more effectively in their children’s education; and
Leadership development and management training to improve the quality of principals and superintendents.

45. Title II, Part A – Private Schools
Internal Controls
The LEA must have written procedures for ensuring invitation, consultation, and provision of equitable services to private school within a district’s geographic boundaries.
The LEA must have written procedures to ensure that costs are allowable, reasonable, necessary, and managed in a manner that minimizes costs to the federal award.
No reimbursements directly to private schools.
LEAs are required to have a number of internal controls including some that relate to private schools.
It is recommended that private schools establish their own internal controls related to the use of Title II, Part A funds for PL.
§ (a) - Costs must meet the following general criteria in order to be allowable under Federal awards: (a) necessary, reasonable, and allocable
§ A cost is reasonable if, in its nature and amount, it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost.
§ (a) – A cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.

46. Title II, Part A – Private Schools
Professional Development Activities and Private Schools
Title IX, Part E Non-Regulatory Guidance
Reimbursement checks from the LEA are payable to the individual teacher/administrator for completion of professional learning and/or related travel. Checks for stipends earned are paid directly to teachers.
Private schools participating in the shared services supported with Title II, Part A funds of any LEA must provide the collaborating public LEA with W-9 information upon request. This is related to stipends earned and not applicable for reimbursement of travel related expenses.
There are no exceptions to the guidance on the flow of funds to private school staff.
Whoever is on the bill is the one who gets reimbursed.
If the PL requires registration, the documentation shows that the teacher paid the documentation.
If the PL requires travel, the teacher’s name should be on the hotel receipt, etc.
What do you do if you are traveling in a group and the principal pays the bills for everyone? Who gets reimbursed?
What if you planned PL at the Private School and later realized you could have used IIA funds? Can you still use IIA funds

47. Title II, Part A – Private Schools
Documentation Required for Approval and Reimbursement of Expenses
Evidence of prior approval by LEA
Receipts (registration, hotel, gasoline)
Agendas (If agenda includes concurrent sessions, attendee must indicate which sessions were attended.)
Evidence of direct payment by eligible participant to be reimbursed
Evidence of receipt of contracted services

48. Title II, Part A – Private Schools
Common Findings
Unallowable expenditures
No prior approval
Inadequate documentation
Not reasonable and necessary

49. Title II, Part A – Private Schools
Resources
Sample consultation letters, private school worksheet, and sample private school plans can be found on the Title II, Part A resources page on the DOE website.
The LEA is provided with sample consultation letters and should follow the recommended timeline for the invitation to consult.
It is recommended that the LEA develop a timeline for collaboration with private schools to ensure quality communication and
effectiveness of the use of funds.
The private school should respond to the invitation to consult in a timely manner and actively participate in all consultations.

50. Title II, Part A Staff Julie Noland jnoland@doe.k12.ga.us
Program Manager
Julie Noland
Specialists
Carly Ambler
Saralyn Barkley
Sharon Brown
Pam Daniels
Greg Petersen
Terri Still
Elizabeth Zipperer
Talking Points:
11/11/2018

51. Title I, Part C Education of Migratory Children

52. Purpose of Title I, Part C
The purpose of Title I, Part C in Georgia (and the United States) is to ensure that migratory children fully benefit from the same free public education provided to all children and that the unmet education-related needs resulting from their migratory lifestyle are met.
11/11/2018

53. Title I, Part C Staff John Wight, Program Manager
(404)
Margarita Munoz, Region 1 Coordinator
(404)
Israel Cortez, Region 2 Coordinator
Talking Points:

54. Title I, Part C Follow similar steps to Title I, Part A
The Department identifies eligible children and notifies districts; parents are aware of Title I, Part C eligibility before the schools… in many instances
Needs assessment; consultation with school; options for services are explained
If needed, supplemental services are provided by the district where the child resides/attends school or the Title I, Part C Consortium at Abraham Baldwin Agricultural College (ABAC)

55. Title III and ESOL

56. Title III and ESOL Staff
Cori Alston
Title III and ESOL Program Manager (404)
Dr. Jacqueline Ellis
ESOL Professional Learning/ State Rules
(404)
Dr. Meg Baker
Regional Program Specialist - North Georgia RESAs (678) CLIP/Budgets: North Region
Tammie Smith
Regional Program Specialist - South Georgia RESAs (678) CLIP/Budgets: South Region
Amy Lacher
Program Specialist - Middle Georgia RESAs (404) CLIP/Budgets: Mid Region
Talking Points:

57. Title III and ESOL Resources
Georgia Department of Education ESOL Guidance
Assessment/Curriculum-and-Instruction/Documents/ESOL/ %20ESOL%20Title%20III%20Resource%20Guide%20web.pdf
Title III Services for Private School Students
Assessment/Curriculum-and Instruction/Documents/ESOL/TITLE%20III%20DIRECTORS%20CONFE RENCE/Private%20Schools%20and%20Title%20III%20Services.pdf

58. Common Private School Findings
Unallowable expenditures
No prior approval
Inadequate documentation
Expenditures not reasonable and necessary
Equitable participation calculated incorrectly
Use of multiple selection criteria to determine rank order of private school students served

59. Internal Controls
The LEA must have written procedures for ensuring invitation, consultation, and provision of equitable services to private school students.
The LEA must have written procedures to ensure that costs are allowable, reasonable, necessary, and managed in a manner that minimizes costs to the federal award.
No reimbursements directly to private schools.
LEAs are required to have a number of internal controls including some that relate to private schools.
It is recommended that private schools establish their own internal controls related to the use of Title II, Part A funds for PL.
§ (a) - Costs must meet the following general criteria in order to be allowable under Federal awards: (a) necessary, reasonable, and allocable
§ A cost is reasonable if, in its nature and amount, it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost.
§ (a) – A cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received.

60. Georgia Department of Education
Private School Consultation and Program Coordination (Title I, Part A; Title II, Part A; Title I, Part C; Title III and ESOL) Providing Equitable Services to Eligible Private School Children
Marijo
Georgia Department of Education
2016 GCEL, Inc., Conference
February 22-24, 2016