1. 1 NonPublic School Services PAFPC 2012 Karl Streckewald DFP Non Public Manager (former) kstreckewa@pa.gov

2. 2 Nonpublic Consultation Title IA Title IIA (PD only – administered by the IU) Title IID (EETT – administered by the IU) Title IIIA (ELL, Imm)

3. 3 Nonpub funding is determined by: –Number of low-income students residing in eligible attendance areas Nonpub services are provided to: –Academically needy students The two groups may have common students, but are determined by two different criteria –There can be a different number of students in each group Title I Allocation

4. 4 Title I Eligibility Criteria At least two methods must be used to determine academic need Classroom grades Report card grades Skills checklists DIBELS Teacher recommendation Parent recommendation

5. Title III Allocation Based on number of ELLs and Immigrants the previous year Not all districts submit for Title III –$10,000 LEP minimum or join consortium –Significant increase for Immigrant numbers Additional nonpub numbers result in additional Title III funding for the LEA Consultation needs to take place –No Title III nonpub signoff…. yet 5

6. 6 Consultation Agendas may be combined (Titles I and III) SD officials may meet with several nonpubs together NP officials may meet with several SD officials at once Keep informal notes of consultation meetings “Timely and Meaningful” –Timely – Prior to decisions being made –Meaningful – wishes of nonpublic school officials are genuinely considered –RESULT – Title I program designed to meet the needs of the nonpublic students –LEA makes final decisions

7. 7 Documentation Copies of correspondence Log of contacts Parent Involvement documentation Professional Development documentation Inventory of Title I equipment Dated and signed affirmations Copies of expenditure documentation

8. 8 Program Design Pull-out program scheduled around regular reading/math classes Extended-day services Summer School Saturday programs Counseling (to promote academic success in reading, math language arts) Computer-Assisted Instruction Home Tutoring Take-home computers

9. 9 Program Design Cautions Push-in programs – not allowed –Teaching in the same room is not necessarily a push-in progam Computer-assisted Instruction –Program must be supervised by HQ teacher –Cannot be supervised by paraprofessional alone Take home computers –Train families and students in computer and software use

10. Program Design: Teachers Title I –Cannot send materials without a teacher Title III –Allowed to send materials without a teacher 10

11. 11 Assessing the program Agree in consultation to standards that are to be assessed Aligned with the nonpublic school curriculum –Aligned with state standards Decide what assessment will be used Decide what constitutes progress Assessment is done by Title I teachers and student results are provided to nonpublic personnel

12. 12 Professional Development Nonpublic schools get an equitable portion of the district set-aside for professional development –For nonpublic classroom teachers who have Title I students –To help nonpublic teachers better meet the needs of their Title I students Plan and review with –Teacher surveys –Student assessment results Activities should be ongoing Cannot be used to upgrade the instructional program in the regular classroom or to meet the needs of the general population

13. 13 Professional Development Activities may be provided by –LEA personnel –Third parties –Independent Education consultants Must be secular, neutral, non-ideological LEA approves the types of activities Funds cannot travel through the nonpublic school

14. 14 Non Public Timeline Nov - Dec: –Initiate contact –Interest survey –Data collection Dec – March –Obtain student data –Start of consultation –Examine NP needs April – June –Design final program –3 rd party contracts –Assess previous year’s program –Submit application July – Aug –Schedule/hire teachers, students, 3 rd party, facilities –Parent notification Sept: start NP services at same time as public services

15. 15 Types of Third-Party Agreements Inter-district agreement –Between LEAs –Includes IUs –Responsibility for students transfers Private company contract –Different rules due to California court case –Responsibility for students does not transfer

16. 16 Third-Party Agreements Consultation must include third-party option LEA has final say in using 3 rd party –The LEA must provide their reasons in writing –Includes both inter-district agreements and private vendors If Third-Party authorized to purchase equipment, supplies, etc., the sending LEA retains ownership –Add statement to contract –Tag clearly and permanently Don’t contract out consultation PD for third-party Title I teachers is administrative cost, not PD reserve

17. 17 Inter-district Agreements Agreement between LEAs –Includes districts and IUs Teachers and paras must be highly qualified Full allocation must transfer to the servicing LEA –Can be less if all 3 parties agree services are equitable May include regular nonpublic instructional funds and all relevant set-asides Responsibility transfers to the controlling entity

18. 18 Private Vendor Contracts Teachers and paras are not required to be highly qualified Responsibilities of LEA continue –Regular supervision –Approve all expenditures –Maintain responsibility for implementation and assessment of program

19. 19 Contract Construction: IDAs & Private Contractors Specify the instructional services to be delivered Parent involvement and professional development activities –Who provides –What activities will be Times and dates of delivery Start/end date of service Numbers of students – flexible Specify that services will be “secular, neutral and non- ideological” Include statement that contractor will comply with all Title I statutory and regulatory requirements

20. 20 Contract Construction – Both (cont.) Acknowledgement that LEA can withhold payments if requirements are not met Statement that the contract may be modified –For final allocation numbers Include date by which the LEA will inform the contractor of the funds available – final allocations –If there is a reauthorization of ESEA during the performance period of the contract Administrative costs come “off the top” –Added to Reservation of Funds Page/Budgeted on 2280 line

21. 21 Contract Construction – Private Contractor Name and compensation of each employee providing service Administrative costs spelled out Specify reports to be provided to LEA, i.e. progress of services, attendance records, assessment results Include definitions and uses for: –Instructional costs –Administrative costs –Professional Development costs –Parental Involvement

22. 22 Contract Construction – Private Contractor (cont.) Instructional costs –Teacher and instructional aide salaries –Teacher and instructional aide benefits –Instructional materials Books Computers & software Workbooks Supplies

23. 23 Contract Construction – Private Contractor (cont.) Parent Involvement costs - parent involvement activities for the parents of the nonpublic participating students –Parent Notification –Developing parent involvement policies –Developing parent compacts –Parent-teacher conferences –Student progress reports –Parent workshops

24. 24 Contract Construction – Private Contractor (cont.) Contractor oversight –Monthly unannounced visits –Regular reports on instructional services, professional development activities and parental involvement activities –Requests for documentation to support invoices Program assessment –Types of assessment to be used –What progress is expected –Format of assessment results –Date by which assessment results will be delivered to the LEA

25. 25 Contract Construction – Inter- district Agreements Statement that funds will change hands between LEAs Statement that responsibility for delivering the program transfers to the receiving LEA Servicing LEA (if an IU) should provide narrative of services to sending LEA for e-grant application purposes Servicing LEA should send relevant data to sending LEA

26. 26 Inter-district Agreements – Responsibilities of Sending LEAs Conduct consultation meetings Determine approximate available funds Provide servicing LEAs with approximate number of eligible students at each nonpublic school Design program based on needs of students in consultation with nonpublic schools Consult with nonpublic schools on program assessment

27. 27 Inter-district Agreements – Responsibilities of Servicing LEAs Attend consultation meetings, if invited, as an interested party Decide which LEA will send letters to parents inviting participation in Title I Prior to school year starting: –Sign inter-district agreements –Develop budget based on approximate available funds based on services agreed to –Hire teachers –Purchase materials –Inform nonpublic school of readiness of program

28. 28 Inter-district Agreements – Responsibilities of Servicing LEAs Begin program on time Supervise Title I teacher Monitor Title I program Assess program and share results with sending LEAs Share student assessment data with nonpublic schools and sending LEA

29. 29 Monitoring the Program Not a teacher evaluation Did the program start on time? (Beginning of school year?) Where is teaching taking place, i.e., outside regular classroom? What classes are taking place in the regular classroom? Are services being provided in areas that have been contracted for, i.e., reading, math, language arts? Did Title I teacher arrive on time, leave early, etc?

30. 30 Monitoring the Program (cont.) Have any professional development opportunities taken place? Have an parent involvement activities taken place? Are services being provided secular, neutral and non-ideological? Are all Title I equipment and/or materials tagged as the property of the LEA? Are Title I equipment and/or materials only available to the Title I students?

31. 31 Paying the Third Party Types of Contracts –Cost Reimbursement – LEA will reimburse the third party for actual costs incurred as part of providing services – must be used for private contractors Preferred by USDE –Fixed Fee – LEA is charged a specific amount to provide services (eg: $50,000 to provide services to 50 students) Most common

32. 32 Invoices – Cost Reimbursement Contract Actual costs incurred – expenditure summaries are not sufficient No equal distribution over 10-month period Review activity reports prior to paying Require supporting documentation –Canceled checks –Paid bills –Time & Attendance Records –Hours and frequency of services provided –Number of children served –Payroll data

33. 33 E-Grant applications Before beginning, collect the following: –Low-income student info Address Grade level By nonpublic school –Approximate number of eligible nonpublic students (may be based on prior year numbers) Address Grade Level By nonpublic school

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36. 36 Nonpublic Involvement List only NP schools that will receive Title I funds Click on INCOMPLETE under Selection of Schools Enter # of nonpublic low-income and # of participating student for each nonpublic school –Low-income numbers equals Selection of Schools-2 –Participating students equals Selection of Schools-4 Indicate who is providing service, place, and type of service by code Mark Selection of Schools Completed

37. 37 Nonpublic Assurances All assurances must be marked YES unless LEA and nonpublic have agreed to a different amount Give the amount that will go to this nonpublic school –If you have several nonpublic schools, you will have to divide the amount based on the per pupil allocation for each nonpublic student’s attendance area Click SAVE DATA

38. 38 Nonpublic Involvement (cont.) Give information on your inter-district agreement if applicable Give information on the timely and meaningful consultation that took place Indicate how eligibility will be determined Explain schedule of services Indicate how program will be assessed Indicate who is responsible for parent involvement activities Describe Professional Development activities (if set-aside)

39. 39 Budgeting Nonpublic Dollars Administrative costs must be recorded on the ROF page 1500 – Instruction Costs –Teacher & para salaries/benefits –Instructional materials/supplies/equipment –Include Summer School set-aside 2280 – Nonpublic Support Services 2270 - Professional Development 3300 – Parent Involvement

40. 40 Nonpublic Assurances Was NP school involved in the planning of: –Types of services –How, where, by whom services will be delivered –How eligibility is determined –Method to determine low income –Coordination with regular program

41. 41 Logging in to e-Grants Obtain a log-in and password –Contact DFP and/or E-grants Help Desk (717-783-6686) http://egrants.ed.state.pa.us/ “Division of Federal Programs” on blue navigation bar Log in Click on Title I School Districts will be displayed

42. 42 Signing Off an LEA Click on each district’s name Click on Selection of Schools – Step 3 –Total amounts to all district nonpublic schools –Per pupil amounts Click on Nonpublic Involvement Click on Completed under Selection of Schools –Portion of Total nonpublic funds for your school for each set- aside Click on Completed under Narratives Click on Incomplete under Agency Involvement –If all statements are correct, sign off –Contact LEA to tell them sign-off has been completed

43. 43 Further Resources DFP Regional Coordinator DFP Non Public Manager (vacant) –717 783 3381 USDE Non-regulatory Guidance: –Title I Services to Private School Children http://www2.ed.gov/programs/titleiparta/psguidance.dochttp://www2.ed.gov/programs/titleiparta/psguidance.doc –Title IX, Part E; Equitable Services: http://www2.ed.gov/policy/elsec/guid/equitablesergu idance.dochttp://www2.ed.gov/policy/elsec/guid/equitablesergu idance.doc