1. Office of Field Services Ensuring Equitable Services for School Children Attending Private Non-Profit Schools Office of Field Services

2. Katie Doerr Parker Gayle Green Yvonne W. Mayfield Field Services Consultants Office of Field Services www.michigan.gov/ofs

5. Reference Materials The following handouts are available on MDE’s website, www.michigan.gov/ofs: Ensuring Equitable Services for Private Non- Profit School Children -  Power Point  Overview Technical Assistance Packet – Working with Private Schools  Allocation Worksheets  Non-Regulatory Guidance  Private School Questions and Answers  Equitable Worksheet

6. Reference Materials Technical Assistance Packets –  Title I, Part A  Title I, Part C  Title II, Part A  Title III, Part A

7. REQUIREMENTS

8. Equitable Services Requirement- District Responsibility Equitable Participation in:  Title I, Part A Improving the Academic Achievement of the Disadvantaged  Title I, Part C Migrant Education  Title II, Part ATeacher & Principal Training & Recruiting  Title III, Part A Language Acquisition Program (English Learners and Immigrant Students)

9. Equitable Services Requirement In order to meet Equitable Services requirements, a Local Educational Entity (LEA) must annually notify all private, non- profit schools within its boundaries and outside of district if resident students attend, of eligibility for equitable participation with Title programs

10. Equitable Services Requirement Low-income parents with private school children are included in census poverty counts that generate funds the Local Educational Agencies (LEAs) use for Title I services

11. Equitable Services Requirement Child Benefit Theory This theory was developed to comply with the Constitutional prohibition against Federal funding to private schools. No funds go directly to private schools. Under the Child Benefit Theory, Title I services – Benefit the individual child, not the private school Are provided by the LEA, not the private school

12. Equitable Services Requirements  In order to meet equitable services requirement, an LEA must:  Provide eligible private school children with an opportunity to participate;  Meet the equal expenditure requirements for instruction, professional development, and parent involvement;  Assess student needs and the effectiveness of the Title I program; and  Begin Title I programs at the same time as the Title I programs for public school children.

13. Equitable Services Requirement Program Responsibility  The LEA is responsible for designing and implementing Title I programs for its resident children who attend private schools, even those attending private schools located in other LEAs

14. Equitable Services Requirement Program Responsibility  The LEA is responsible for making program and budgetary decisions based on timely and meaningful consultation with the private school.

15. Consultation

16. Consultation Requirements What is Consultation? Consultation involves discussions between public and private school officials on key issues that affect the ability of eligible private school children to participate equitably in Title I programs

17. Consultation Requirements Consultation…  Must occur during the design, development, and implementation of the Title I programs  Must include meetings  Must occur prior to the LEA making any decisions  Must continue throughout implementation of programs  Must be documented (Reference the Private School Consultation Checklist)  Complete the process by May 1st

18. Consultation Requirements What topics must be addressed during consultation ?

19. Consultation Requirements At a minimum, consultation must address:  How the LEA will identify the needs of eligible children  What services the LEA will offer  How and when the LEA will make decisions  How, where, and by whom the LEA will provide services  How the LEA will assess the Title I program and use the results to improve Title I services

20. Consultation Requirements At a minimum, consultation must address:  The size and scope of the equitable services and the proportion of funds the LEA will allocate for services  Method or sources of data the LEA will use to determine the number of low-income students  Services the LEA will provide to teachers and families of participating children  Discussion of service delivery mechanism the LEA can use  A thorough consideration and analysis of the views of private school officials services through a contract with third-party provider

21. Consultation Requirements  Private school officials have the right to complain to the SEA for the following reasons:  The LEA did not engage in timely and meaningful consultation  The LEA did not give consideration to the views of private school officials  The LEA disputes the low-income data provided by private school officials The SEA resolves the complaint

22. Equitable Services for Teachers & Families Professional Development REQUIRED CONSULTATION TOPIC: LEA must consult with private school officials prior to the LEA designing and implementing professional development activities that increase the private school teachers ’ skills and knowledge on how to better instruct their students

23. Funding for Equitable Services

24. Funding for Equitable Services Collecting Poverty Data  An LEA may calculate the number of private school children* who are from low-income families and live in participating public school attendance areas in several ways:  Use same measure of poverty as for public school children. The majority of districts in Michigan use free and reduced price meals eligibility as its source of data  Use comparable poverty data from a survey and must extrapolate results if actual data are unavailable  Use comparable data from a different source  Use an equated measure *LEA must collect poverty data on their resident low- income children attending private schools in other LEAs.

25. Funding for Equitable Services Generating Funds for Instruction  Low-income public and private school children residing in the same Title I attendance areas generate the same per-pupil amount (PPA)  PPA x the number of low-income private school children residing in participating public school attendance areas = instructional funds for the Title I programs for eligible private school children

26. Funding for Equitable Services Generating Funds for Instruction Funds may be generated from multiple LEAs with students attending a private school or from multiple attendance areas within a district.

27. Funding for Equitable Services Generating Funds for Instruction  e complaint Eligible Public School Attendance Area (1) Grade Span Group (2) Percent Low- - Income (3) Amt. Per Low- Income Child (4) Public Low Income Count (5a) Section 31a Funding Per Child (5b) Public Amount (5c) Carryover and Parent Involvement Reservations (5d+5e+5f) Total Public Amount (5g) Private Low Income Count (5h) Private Amount (5i) School A K – 885%$7804600$358,800$23,000$381,80029$22,620 School BK – 879%$7805160$402,480$36,500$438,98000 School CK – 865%$7803750$492,500$13,000$305,50015$11,700

28. Funding for Equitable Services Generating Funds for Instruction Funds generated by low-income private school children who reside in Title I attendance areas must be used only for instructional services

29. Funding for Equitable Services Reservation of Funds If an LEA elects to reserve funds for district level instructional activities, such as summer school, for public school students, the LEA must also provide from those reserved funds equitable services to eligible private school children. These funds are in addition to per pupil funds designated for instructional services.

30. Title I Funds for Equitable Services District-Wide Instructional Activities Districtwide Instructional Program(s) Reservation (does not apply to preschool programs) in participating public school attendance areas: No. of private school children from low-income families divided by total no. of children, public and private, from low-income families equals proportion of reservation _______5,000____ ÷ ______10,000_______ = _____5%___ (Proportion of Reservation)__5% x _$50,000__Reservation = $___2,500 for Equitable Services

31. Funding for Equitable Services Carryover LEAs must consider the equitable services requirements when making any decision about the use of district reservations and carryover funds: Instructional Programs Professional Development Parent Involvement

32. Equitable Services for Children

33. Equitable Services for Children Selection of Students  Private school children who reside in Title I participating public school attendance areas AND are failing or most at risk of failing to meet student academic achievement standards  Homeless; 2 preceding years in Head Start; Great Start Preschool Program; Title I Preschool; Title I, Part C (Migrant Education)  Grades pre-K-2: selected solely on the basis of teacher judgment, interviews with parents, developmentally- appropriate criteria and local assessments  Grades 3 and above: selected using multiple written selection criteria  Poverty is NOT a criterion!

34. Equitable Services for Children Standards The LEA should use:  Standards that are aligned with the curriculum of the private school  Depending on the number of private schools, there may be more than one standard The State Educational Agency cannot impose standards, achievement levels, or assessments

35. Equitable Services for Children Types of Services for Children Equitable services for children must be designed as a Targeted Assistance Title program.

36. Equitable Services for Children Types of Services for Children  Direct instruction outside the regular classroom = pull out model  Tutoring  After- or before-school programs  Saturday programs

37. Equitable Services for Children Assessments  After consultation, LEA establishes the assessment it will use to measure the effectiveness against the agreed-upon standards  May use the State assessment or another assessment that is aligned to the agreed-upon standards, such as the assessment used in the private school  All participants are assessed annually, including children receiving nonacademic services

38. Equitable Services for Children Supplement, Not Supplant  The supplement, not supplant provision applies  Title I services must be in addition to, and cannot replace or supplant, services that would be provided by private schools to their private school participants

39. Equitable Services for Children Subject Areas and Grade Spans Title I services for private school children DO NOT need to be in the same subject areas or the same grade levels as Title I services for public school children. Needs of private school participants determine what Title I services are appropriate.

40. Equitable Services for Children Subject Areas and Grade Spans The providing LEA has the option of providing services for the private school within any grade of the public school’s grade span. Private school services do not have to be for the same grade levels as services at the public school, but they must be within the same grade span.

41. Equitable Services for Children Service Providers – LEA Employees  Provider of Title I services must be either an employee of the LEA or an employee of a third party under contract with the LEA  Private school teachers may be employed by both the private school and the LEA; however, they must be independent of the private school during the time they are employed by the LEA to provide Title I services

42. Equitable Services for Children Service Providers – LEA Employees Paraprofessionals must meet the paraprofessional qualification requirements, provide instructional support, and be under the direct supervision of and in close and frequent proximity to a highly qualified public school teacher Private school officials may not sign time and effort records Private school officials cannot establish requirements for LEA-employed teachers

43. Equitable Services for Children Materials and Equipment  Title I funds may only be used to meet the needs of participating children  Non-Title I private school children, nor non- Title I teachers and parents non-Title students may not use materials purchased with Title I funds  LEA must retain title to all materials purchased with Title I funds

44. Equitable Services for Children Materials and Equipment  All materials, etc., purchased with Title I funds must be labeled “Property of… School District” and placed in a secured location when not in use  Private school officials have no authority to obligate Federal funds  There must be an instructional program before the purchase of supplemental materials

45. Equitable Services for Teachers and Families

46. Equitable Services for Teachers & Families Requirements An LEA must provide equitable services to private school teachers and families of participating private school children from funds reserved for professional development (§1119) and parental involvement (§1118)

47. Equitable Services for Teachers & Families Use of Funds  The LEA must use these funds to provide equitable services to teachers and families of participants  There is no authority under Title I for an LEA to transfer these funds to instruction  If teachers or families of participating private school students do not have a need for equitable services, those funds are available to the LEA for other allowable uses

48. Title I Funds for Equitable Services District Professional Development Reservation Professional Development Reservation under Sec. 1119 of ESEA in participating public school attendance areas: No. of private school children from low-income families divided by total no. of children, public and private, from low-income families equals proportion of reservation ___5,000÷ _____100,000_______ = _____5%___ (Proportion of Reservation)__5 % x $360,000__Reservation = $__18,000 for Equitable Services

49. Title I Funds for Equitable Services District Parental Involvement Reservation Parental Involvement Reservation under Sec. 1118 of ESEA in participating public school attendance areas: No. of private school children from low-income families divided by total no. of children, public and private, from low-income families equals proportion of reservation ________5,000____ ÷ _____100,000_______ = _____5%___ (Proportion of Reservation)__5% x $60,000__Reservation = $__3,000__ for Equitable Services

50. Additional Programs

51. Equitable Services Title I, Part C Allocation Use the Title I, Part C Calculation of Private Schools’ Equitable Share screen to determine the appropriate per pupil amount for students eligible for Title I, Part C services. This is located on the OFS website under 2014-15 Consolidated Application Important Information. Services require consultation. Contact the Title I, C Consultant. www.michigan.gov/ofs

52. Equitable Services Title II, Part A Under Title II, Part A, LEAs are required to provide equitable services for private school teachers and other educational personnel only to the extent that they use the funds for professional development

53. Equitable Services Title II, Part A Amount of Title II Budgeted for PD Box C Current Title II, Part A AllocationBox B$715,604 Amount of Title II, Part A Budgeted for PDBox C$715,604 FY 2001 Eisenhower FundsBox D$96,822 Base AmountBox E$715,604 $715,604 Divided by Total Pupil Count of 18,691 = Current Per Pupil Amounts = $38.29 List of Private Schools within the LEA Boundary Private School Enrollments Private School Title II, Part A Allocations School A230$8,806.70 School B159$6,088.11 School C271$10,376.59 School D217$8,308.93 LEA Enrollment 17,814 (Box A)

54. Equitable Services Title II, Part A Transfer of Funds/Other Uses The amount of Title II, Part A that the district would use to calculate what is due to the private school would be the amount of the Eisenhower Grant:  If an LEA was putting all of it’s Title II, Part A funds into class size reduction, merit pay or bonuses  Transferring all of Title II, Part A into Title I, Part A. The amount of Title II, Part A that the district would use to calculate what is due to the private school would be the amount of the 2000 - 2001 Eisenhower Grant. This calculation would have to be done for the private school before budgeting other LEA uses of the funds.

55. Equitable Services Title III, Part A- Language Acquisition Program Participation is considered equitable if the LEA:  Assesses, addresses and evaluates the needs and progress of public and private school students and educational personnel on a comparable basis  Provides, in the aggregate, approximately the same amount of services to students and educational personnel with similar needs

56. Equitable Services Title III, Part A- Language Acquisition Programs  Spends an equal amount of funds to serve similar public and private school students and educational personnel  Provides both groups of students and educational personnel equal opportunities to participate in program activities Resource – Private School Participation Fact Sheet

57. Equitable Services Title III, Part A LEA (LEP) Enrollment 151 Current Title III, LEP Allocation Base = $15,100 Total enrollment for LEA & Private Schools (263) divided by the base amount = $57.42 List of Private Schools within the LEA Boundary Private School Enrollments Private School Title III, Part A (LEP) Allocations School A16$918.72 School B25$1,435.50 School C40$2,296.80 School D31$1,780.02

58. Evaluation

59. After consulting with private school officials, the LEA must establish standards it will use to measure the effectiveness of the Title I program as indicated by the academic achievement of its participants The MDE Program Evaluation Tool is a viable option for evaluating Title programs and services.

60. Evaluation Annual Progress  Every year, the LEA, after consulting with private school officials, must determine what constitutes acceptable annual progress for the Title I program  This decision must be made before Title I services begin  It’s not enough to just assess participants – the LEA must determine the effectiveness of the total program in raising academic achievement

61. Other Considerations

62. General Requirements Suggested Timeline  January/February  Mail letter (see sample of letter)  March  Conduct initial meeting (see sample of documentation)  Review demographics  Plan program  April - July  Await allocations  Meet to confirm  Submit application Provide consultation throughout the year

63. General Requirements Reminder -  Meetings and consultation must occur before district makes decisions  Consultation continues throughout implementation

64. Determining Private School Participation—Student Numbers Private School Students Residing Within District Boundaries (who attend a private school within or outside of district boundaries) Students Attending Private School Within District Boundaries (regardless of their residency) Title I, Part A Funding Generated By:  Low-income students who reside in a Title I school attendance area Students Eligible to be Served:  Identified by a Needs Assessment for achievement below standard and reside in a Title I school attendance area* Title I, Part C  Meet criteria for migrant?  Meet priority for services? Title II, Part A Title III, Part A  Meet criteria for ELs/Immigrant?  Completes Home Language Survey?

65. Allowable Uses of Funds for Private Non-Profit (PNP) Schools LEA for PNP SchoolsTitle I, Part ATitle I, Part CTitle II, Part ATitle III, Part A Salaries for PNP personnelNo Salaries of LEA staff who service PNP Yes Yes, if providing PDYes Substitutes for ANY reasonNo Stipends  Professional Development in core academic areas – secular content only  Reasonable & necessary  Outside of school day  Paid directly to teacher by LEA Yes Purchase of ComputersYes for Eligible students NoYes for Eligible students SuppliesYes, for Title I students Yes, for Migrant studentsYes for Professional Development Yes for Eligible students Class Size ReductionNo Support for PNP staff to become HQ No Yes for ESL/Bilingual Endorsement Professional DevelopmentYes, for helping Title I students Yes

66. What Happens When a PNP Closes or the Program Ends? If a program is terminated or if the private school closes, the non-consumable materials and equipment must be returned to the district

67. District Fiscal Responsibilities Write a check? NO! Generate a purchase order Pay for professional development registrations Pay wages of district employees who serve the private school Pay for services of third-party employees who serve the private schools (“purchased services”) YES!

68. Other Resources

69. Further Assistance  U.S. Department of Education  Guidance Documents  www.ed.gov/policy/elsec/guid/list.jhtml  Office of Nonpublic Education  www.ed.gov/about/offices/list/oii/nonpublic/index.html  Michigan Department of Education  Office of School Improvement, Field Services Unit  Technical Assistance packets on each grant source  Call your Field Services Consultant

70. Questions, Comments and Concerns Contact your Field Services Consultant:  Regions 1 - 5.........517-373-4004  Special Populations…….517-373-6066 Homeless, Migrant, Section 31a, Section 41, Title I, D and Title III  Finance………………….517-373-2519