1. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Supplement Not Supplant 13 th Annual Title Programs Conference June 15-19, 2015 Atlanta, Georgia

2. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Supplement Not Supplant Judy Alger Title I Education Program Specialist School Improvement Title Programs Division jualger@doe.k12.ga.us (229) 321-9305 Amy Lacher Education Program Specialist ESOL/Title III Consortium Monitor Curriculum and Instruction alacher@doe.k12.ga.us (404) 463-1074 Cathy Buescher Education Support Specialist School Improvement Outreach Programs Division Rural Education Achievement Program Title VI, Part B cbuesche@doe.k12.ga.us (229) 561-4499

3. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org 10/7/20153 SCHOOL IMPROVEMENT & DISTRICT EFFECTIVENESS

4. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Fiscal Requirements ESEA provides several fiscal requirements that are applicable to Title I, Part A LEAs must maintain the financial effort previously provided to Title I schools. LEAs may not use Title I funds to supplant or replace state or local funds. LEAs must provide services to Title I schools that are comparable to those of non-Title I schools.

5. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Supplement Not Supplant The Words Defined Supplement – To fill in what is lacking…….. Supplant – Replace Roget’s II – The New Thesaurus ©1988 Houghton Mifflin Co.

6. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Federal Definition Funds received under this part shall be used to supplement, and not supplant, non-federal funds that would otherwise be used for activities authorized under this part. Elementary and Secondary Education Act Section1120A(b)

7. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org In Other Words….. The district must ask? What would have happened in the absence of these federal funds: Title I funds? Would other monies from the state or local resources have been used to pay for the item or service? If so, and you used Title I monies for the item or service……..

8. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Supplement Not Supplant YOU HAVE JUST SUPPLANTED!

9. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Supplement Not Supplant All federal funds must be spent in ways that supplement, rather than take the place of state or local resources. But the statute varies from program to program. For example, Title I funds must be used to support activities that are supplemental to those required under state or local law. Title III funds must be used to supplement activities required under state, local or federal law….that is, Title III funds must be used to supplement activities required under Title I and other federal education programs. 10/7/20159

10. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Presumptions of Supplanting Clarification to the Supplement, not Supplant rule is provided in Uniform Administrative Grants Requirements for cost principles, and audit requirements for federal awards [2 C.F.R. Part 200.21, Appendix XI] Title I targeted assistance (TA) programs, and m ost programs operated at the district level, must reserve funds for services for students identified as most at-risk of failing to meet state achievement standards. Additionally, US ED guidance states that the Title I funds may not be used for activities that:

11. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Presumptions of Supplanting 1.the activities are required by local, state, or other federal law; 2.The activities were provided with non-federal funds to non-Title I students or in non-Title I schools that were provided with Title I, Part A funds for Title I students in Title I schools; or, 3.the activities were paid for in the prior year with non- federal funds. 10/7/201511

12. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Presumptions of Supplanting However, in Title I schoolwide (SW) programs do Title I’s three supplanting presumptions apply to schools operating SW programs? In January 2015, Kay Rigling, a Title I attorney in the U.S. Department of Education stated at the National Title I Conference stated: NO. If the three supplanting tests do not apply to SW, how can an LEA or Title I school judge the allowability of any particular expenditure? 10/7/201512

13. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Presumptions of Supplanting Guidelines to follow for SW Title I expenditures to determine supplanting: Articulate funds, strategies, and services in the schoolwide plan. In other words, the plan(s) drive the budget for Title I. SW Plans should specify which funds are being used to support the plan – whether Title I, Part A funds only, or other federal, state, and local funds, as well as, services and strategies it will use to raise the achievement among the lowest-performing students. Keep expenditures “instructional” in nature. Although SW schools are entitled to consolidate Title I, Part A monies with other federal funding streams, most LEAs in Georgia do not. “Instructional purposes” being used in the broadest sense. 10/7/201513

14. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Presumptions of Supplanting Using the parameters in Section 1001 of ESEA will assist LEAs in determing instructional activities: (1) ensuring that high-quality academic assessments, accountability systems, teacher preparation and training, curriculum, and instructional materials are aligned with challenging State academic standards so that students, teachers, parents, and administrators can measure progress against common expectations for student academic achievement (2) meeting the educational needs of low-achieving children in our Nation's highest-poverty schools, limited English proficient children, migratory children, children with disabilities, Indian children, neglected or delinquent children, and young children in need of reading assistance; 10/7/201514

15. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Presumptions of Supplanting (3) closing the achievement gap between high- and low-performing children, especially the achievement gaps between minority and nonminority students, and between disadvantaged children and their more advantaged peers; (4) holding schools, local educational agencies, and States accountable for improving the academic achievement of all students, and identifying and turning around low-performing schools that have failed to provide a high-quality education to their students, while providing alternatives to students in such schools to enable the students to receive a high-quality education; (5) distributing and targeting resources sufficiently to make a difference to local educational agencies and schools where needs are greatest; 10/7/201515

16. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Presumptions of Supplanting (6) improving and strengthening accountability, teaching, and learning by using State assessment systems designed to ensure that students are meeting challenging State academic achievement and content standards and increasing achievement overall, but especially for the disadvantaged; (7) providing greater decisionmaking authority and flexibility to schools and teachers in exchange for greater responsibility for student performance; (8) providing children an enriched and accelerated educational program, including the use of schoolwide programs or additional services that increase the amount and quality of instructional time; (9) promoting schoolwide reform and ensuring the access of children to effective, scientifically based instructional strategies and challenging academic content; 10/7/201516

17. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Presumptions of Supplanting (10) significantly elevating the quality of instruction by providing staff in participating schools with substantial opportunities for professional development; (11) coordinating services under all parts of this title with each other, with other educational services, and, to the extent feasible, with other agencies providing services to youth, children, and families; and (12) affording parents substantial and meaningful opportunities to participate in the education of their children. Adhere to the necessary and reasonable standard. This standard requires all expenditures of federal funds be necessary and reasonable for proper and efficient performance and administration of federal awards. 10/7/201517

18. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Presumptions of Supplanting In other words, all decisions affecting whether Title I funds are supplemental in a SW program must be necessary for it to function properly, and it must be clear to an objective observer why a decision is a good idea, considering the amount of money being spend, the needs of the program, and other relevant circumstance. This decision can hinge on individual circumstances therefore, what is reasonable for one LEAor school may not be reasonable for a different LEA or school or even other Title I schools within an LEA. Therefore, reasonable and necessary decisions can be tempered by: Grade levels Subject areas 10/7/201518

19. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Presumptions of Supplanting Amount of funds available What is the best use of those funds to educate students What is the best use of funds to train staff AND, most importantly, to be accountable to the public. 10/7/201519

20. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org 2 C.F.R. Part 200.21, Appendix XI Presume supplanting occurred if federal funds were used to provide services that: 1.Were required under other federal, state, or local laws Example: States, districts, and schools are required to provide special education services according to a students IEP. A supplanting violation will be presumed if the LEA uses Title I, Title III, or Title VI funds to provide these services.

21. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org 2 C.F.R. Part 200.21, Appendix XI 2. Were provided to participating children, if those same services were provided with non-federal funds to non-participating children. Example: In a targeted assistance school, a supplanting violation would be presumed if an LEA provides calculators to children participating in a math program for the non- Title I students but uses Title I, Part A funds to buy calculators for the Title I students.

22. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org 2 C.F.R. Part 200.21, Appendix XI 3. Provided with non-federal funds in the prior year Example: If an LEA used state or local funds to support an after-school reading program during school year 2014- 2015, a supplanting violation will be presumed if the LEA uses federal funds to support the same program during the year 2015-2016.

23. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Supplement Not Supplant May regular Title I, Part A funds be used to support activities that were previously supported with non-federal funds without violating the supplement, not supplant requirement? Not without a presumption of supplanting.

24. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Supplement Not Supplant Using Title I, Part A funds for an activity that an LEA provided in the prior year with non-federal funds generally leads to a presumption of supplanting. The presumption is that the LEA would have continued to use non-federal funds to fund the activity even if Title I, Part A funds were not available. Therefore, the use of Title I Part A funds for the activity is presumed to be supplanting.

25. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Summary: Preparing to Rebut Supplanting! The LEA must demonstrates it would not have provided services with non-federal funds if the federal funds were not available.

26. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Using Precipitous Decline to Rebut To rebut first the LEA eliminates the activity without taking into consideration whether or not Title I, Part A funds are available. The LEA documents this by fiscal and programmatic records This confirms that, in the absence of Title I, Part A funds, the activity would not be funded. The LEA now funds the activity with Title I, Part A.

27. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Using Precipitous Decline to Rebut The LEA maintains pertinent board minutes/approval on file. The LEA keeps a narrative explaining the situation of bugetary precipitous decline. Please note that such documentation must be contemporaneous with the LEA’s decision-making process; it is very difficult to rebut a presumption of supplanting after the fact.

28. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Using Precipitous Decline to Rebut If LEA documentation to rebut supplanting stands up to auditor/monitor scrutiny then: The activity, if consistent with Title I fiscal and programmatic requirements, is now allowable under Title I, Part A. This means, for instance, that a teacher formerly paid from non- federal funds is now allowable under Title I, Part A. On the other hand, if the LEA is unable to rebut the presumption of supplanting, it may not use Title I, Part A funds for an activity that it conducted the previous year with non-federal funds.

29. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Supplement Not Supplant - Title III States, districts, and schools are required to provide core language instruction educational programs and services for limited English proficient (LEP) students. A supplanting violation will be presumed if the LEA uses Title I, Title III, or any other federal funds to provide these services.

30. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Supplement Not Supplant - Title III This requirement is established based on Title VI of the Civil Rights Act of 1964, and its implementing regulations, as interpreted by the Supreme Court of the United States (including the Supreme Court’s ruling in Lau v. Nichols), and based on other significant case law.

31. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Supplement Not Supplant - Title III The use of state or LEA Title III funds to provide core language instruction educational programs, including providing for the salaries of teachers who provide those core services for LEP students, would violate the supplement not supplant provision.

32. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Supplement Not Supplant - Title III Any efforts by an LEA or school to reduce state and local funds expended to implement language instruction educational programs serving LEP students based on the receipt of federal Title III grant funds also violates the non-supplanting provision of Title III.

33. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org State’s Annual ELP Assessment Title III funds may not be used to pay for substitute teachers during test administration, for the scoring or reporting of ELP assessment results, for training incentives related to administering the ELP assessment, or for materials or equipment related to the administration of annual ELP assessments.

34. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org State’s Annual ELP Assessment The cost of administering assessments may not be paid with Title III funds because Title I already requires states to administer an annual ELP assessment to all LEP students.

35. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Schoolwide Consolidation of Funds An LEA that fully consolidates Title III funds with other state, local, and federal funds as part of a schoolwide program does not have to meet most of the statutory requirements of Title III, including the non-supplanting requirement.

36. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Schoolwide Consolidation of Funds However, each school must identify the specific programs being consolidated, and the amount each program contributes to the consolidation, and maintain records that demonstrate that the schoolwide program addresses the intent and purposes of each of the federal programs whose funds are being consolidated.

37. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Schoolwide Consolidation of Funds Each school operating a schoolwide program must receive all the state and local funds it would otherwise receive to operate its educational program in the absence of Title I, Part A or other federal education funds, “including funds needed to provide services that are required by law for…children with limited English proficiency.”

38. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Title III …may not supplant local, state or any other federal funding.

39. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Allowable Expenditures LEP and Immigrant Parental Involvement (Language and Culture) Supplemental Instructional Resources (related to ELs only) Supplemental Instructional Interventions (related to ELs only) Professional Learning (related to ELs only) Substitute Teachers for Professional Learning

40. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Immigrant Funding Title III Immigrant funds must be expended in direct support of immigrant students. Immigrant defined: Between the ages of 3 and 21 Not born in any of the 50 U.S. states; the District of Columbia; Puerto Rico Enrolled in a U.S. school for fewer than three (3) full academic years

41. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Immigrant Funding Note: Children born to U.S. service personnel stationed abroad are immigrants when they enter a U.S. school for the first time.

42. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Allowable Expenditures Immigrant Activities coordinated with community-based organizations, institutes of higher education, and private sector entities, to offer comprehensive community services.

43. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Title III Translation/ Interpretation Mandates of the Office for Civil Rights may not be funded through Title III LEP or Immigrant grants. Information provided to all parents must be provided to LEP and Immigrant parents in a language they can understand, to the extent practicable.

44. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Title III Translation/ Interpretation LEA Responsibilities: Registration PTA Open House Parent-Teacher conferences offered to all parents Parent meetings offered to all parents Day-to-day school-to-home communications Report Cards

45. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Title III Translation/ Interpretation LEA Responsibilities Student and/or Parent Handbooks RTI Meetings Tribunal IEP (IDEA)

46. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Title III Translation/ Interpretation Title III Allowable Expenditures Title III specific and/or required parent communications to share and discuss: ACCESS score reports English language proficiency levels Student’s progress toward English proficiency

47. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Title III Translation/ Interpretation Title III Allowable Expenditures Parent outreach, training, and literacy services to improve students’ English language skills and to assist parents in helping their children to achieve academically Parent outreach to share community resources and services (Immigrant)

48. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Title III Translation/ Interpretation If the service or resource was previously paid for through another source of funding…. If the service or resource is required under local, State, or another federal program….

49. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org You are Supplanting!

50. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Supplement Not Supplant Title VI, Part B Part B Rural Education Initiative Funds made available under subpart 1 or subpart 2 shall be used to supplement, and not supplant, any other federal, state or local education funds. Elementary and Secondary Education Act Section 6232

51. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Supplement Not Supplant Title VI, Part B Title VI, Part B Funds differs from other federal funds in that it must supplement other federal dollars. Title VI, Part B cannot fund an activity or budget item previously funded by another federal program if the other federal funds are still available. Title VI, Part B provides resources above all other resources.

52. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Supplement Not Supplant Title VI, Part B Title VI, Part B Federal State and Local

53. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Supplanting When Providing Response To Intervention (RTI) Services Tier I Universal Screening – Supplanting Occurs When: School staff involves Title I, Title III or Title VI staff in determining the assessment to be used to identify struggling students who may need specific intervention or involves them in conducting the screening. When Title I, Title III and Title VI funds or resources are used conduct screening for all students.

54. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Supplanting When Providing Response To Intervention (RTI) Services Tier II Needs-Based Learning When results of assessments and data indicate that a student needs an intervention to help with a targeted problem, increased monitoring such as formative assessments and analysis of student work is required.

55. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Supplanting When Providing Response To Intervention (RTI) Services Tier II Needs-Based Learning These interventions can be funded with Title I monies in schoolwide schools and sometimes Title I funds can be used in targeted assistance programs. These interventions can be funded with Title III monies for students identified to receive Title III services. These interventions can be funded with Title VI monies for students identified to receive Title VI services

56. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Supplanting When Providing Response To Intervention (RTI) Services Tier III SST Driven Learning Targeted students participate in learning that is in addition to Tier I and Tier II. Assessment and a student plan is individualized and formal monitoring procedures are implemented. Students in this category may need a referral to more specifically designed instructional program.

57. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Supplanting When Providing Response To Intervention (RTI) Services Tier III SST Driven Learning Title I funds may be used to monitor progress of identified Title I students in targeted assistance programs and may be used for all students in Title I schoolwide schools. Title III funds may be used to monitor progress of students identified for Title III service. Title VI funds may be used to monitor progress of students identified for Title VI service.

58. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Supplanting When Providing Response To Intervention (RTI) Services Tier IV Specifically Designed Learning Targeted students participate in a more prescribed and formal instructional process with a more specialized program. Title I funds may be used in conjunction with more specialized program funds. Title III and or Title VI funds may be used in conjunction with Title I funds or with other specialized program funds.

59. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Questions?

60. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Supplement Not Supplant May an LEA use Title I funds to pay for extended-day kindergarten costs for Title I eligible students, while parent contributions pay for non-Title students? A districtwide summer school serves Title I and non-Title I schools. Can Title I supplement the program for all the students? Does the supplement, not supplant requirement apply to indirect costs?

61. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Supplement Not Supplant A District with all Title I schoolwide schools is considering buying a software program called Leap Forward Learning. The Gifted Program Coordinator told the team about the program. All students can use and benefit from the program. Is buying the program supplanting?

62. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Supplement Not Supplant A District has all Title I schoolwide schools. The Gifted Coordinator wants Title I to fund individual “Advanced Program Workbooks” for the students in the gifted program. If Title I funds are used for the purchase, will the District be supplanting? Can Title I fund additional Title I Teachers to meet core subject needs for all Title I students including special education students?

63. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Supplement Not Supplant An LEA decided to buy workbooks for non-Title I students and in order to make the monies go further your district used Title I monies to supplement the purchase of the same notebooks for Title I students. Supplanting or not? An LEA decided to take a schoolwide trip and wants to pay for non-Title I students with district monies and Title I students with Title I monies. Supplanting or not? May Title I funds be used in a TA program to pay for Title I students’ participation in an extended- day kindergarten program?

64. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Supplement Not Supplant An LEA has hired a Director of Literacy as a K-12 administrative position. All the Title I schools in the LEA are K-5 targeted assistance schools. Thirty percent of the students in the LEA receive Title I services. May Title I pay for 30-percent of the Literacy Director salary? May an LEA use State and local funds to pay for non-Title I students’ participation in a full-day kindergarten, while Title I funds are used for Title I students?

65. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Supplement Not Supplant The principal in a schoolwide school decides to pay for all the school’s paper needs in the Title I budget. Is this supplanting? The principal in a schoolwide school decides to pay for report cards with Title I funds. Is this supplanting?

66. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Supplement Not Supplant A central office person has the responsibility of being curriculum director and Title I director. She is split funded. When she completes her log if she’s meeting with the language arts chair in a Title I school, she records the time on this task under Title I. When she’s meeting with the language arts chair at a non-Title I school, she records the time on this task as a part of her curriculum director duties. Is this supplanting?

67. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Supplement Not Supplant Title VI, Part B A district has three Title I schools. A reading coach is being funded at two of the three schools with Title I funds. The third school will fund a reading coach with Title VI, Part B funds. Supplementing? Supplanting?

68. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Supplement Not Supplant Title VI, Part B A district has three Title I schools and one non-Title I school. A reading coach is being funded at the three Title I schools with Title I funds. The non-Title I school will fund a reading coach with Title VI, Part B funds. Supplementing? Supplanting?

69. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Supplement Not Supplant Title VI, Part B All schools in the district are Title I schools. Title I is providing 2 supplemental computers in each classroom in each Title I school. Title VI, Part B is providing 1 computer in each classroom in each Title I school. Supplementing? Supplanting?

70. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Supplement Not Supplant Title VI, Part B All five schools in the district are Title I schools. Title I is providing 100 iPads in four schools and Title VI, Part B is providing 100 iPads in the fifth school. Supplementing? Supplanting?

71. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Supplement Not Supplant A district with all Title I schoolwide schools decides to fund all efforts to use the RTI Pyramid of Interventions activities with Title I funds. Is this supplanting? A district with some Title I schools and some non-Title I schools decides to fund 2 nd Tier and above RTI activities with Title I funds and non-Title I RTI interventions with state and local funds. Supplanting or not? 10/7/201571

72. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Supplement Not Supplant A district with all Title I schools paid for 2 nd Tier and above RTI activities with state and local funds last year. The district has decided to fund the activities with Title I funds this year. Supplanting or not? All schools in the district are schoolwide Title I schools. The district planning team decides to fund testing services to identify gifted students with Title I funds. Is this supplanting 10/7/201572

73. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Resources Title I Handbook Uniform Administrative Grants Requirements for cost principles, and audit requirements for federal awards [2 C.F.R. Part 200.21, Appendix XI], May 2015 U.S. ED Guidance Title I Fiscal Issues (February 2008), located at: http://www.ed.gov/programs/titleiparta/fiscalguid.doc http://www.ed.gov/programs/titleiparta/fiscalguid.doc ESEA Section 1120A Title I Web site.

74. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Resources U.S. ED Guidance Supplement Not Supplant Provision of Title III of the ESEA (October 2008), located at: http://www.ed.gov/programs/sfgp/legislation.html http://www.ed.gov/programs/sfgp/legislation.html Title I Fiscal Issues: Maintenance of Effort Comparability Supplement, Not Supplant Carryover Consolidating Funds in Schoolwide Programs Grantback Requirements Uniform Administrative Grants Requirements for cost principles, and audit requirements for federal awards [2 C.F.R. Part 200.21, Appendix XI], May 2015 Education Department General Administrative Regulations (EDGAR) ESEA Section 3115 (g)

75. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Title I, Part A Program Specialists’ Contact Information 10/7/201575 AreaName Office Telephone Email 1Robyn Planchard(404) 985-3808rplanchard@doe.k12.ga.us 2Randy Phillips(770) 221-5232rphillips@doe.k12.ga.us 3Anthony Threat(706) 615-0367anthony.threat@doe.k12.ga.us 4Evelyn Maddox(404) 975-3145emaddox@doe.k12.ga.us 5Judy Alger(229) 321-9305jualger@doe.k12.ga.us 6Grace McElveen(912) 334-0802gmcelveen@doe.k12.ga.us 7Jimmy Everson(229) 723-2664jeverson@doe.k12.ga.us

76. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Title I, Part A Program Specialists’ Contact Information 10/7/201576 AreaName Office Telephone Email 8Marijo Pitts-Sheffield(912) 269-1216mpitts@doe.k12.ga.us 9Kathy Pruett(706) 540-8959kpruett@doe.k12.ga.us 10Elaine Dawsey(478) 971-0114edawsey@doe.k12.ga.us 11Olufunke Osunkoya(678) 704-3557oosunkoya@doe.k12.ga.us 12Bobby Trawick(229) 246-1976btrawick@doe.k12.ga.us 13Ken Banter(478) 960-2255TBA 14Tammy Wilkes(478) 237-2873twilkes@doe.k12.ga.us

77. Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Richard Woods, Georgia’s School Superintendent “Educating Georgia’s Future” gadoe.org Supplement Not Supplant Judy Alger Title I Education Program Specialist School Improvement Title Programs Division jualger@doe.k12.ga.us (229) 321-9305 Amy Lacher Education Program Specialist ESOL/Title III Consortium Monitor Curriculum and Instruction alacher@doe.k12.ga.us (404) 463-1074 Cathy Buescher Education Support Specialist School Improvement Outreach Programs Division Rural Education Achievement Program Title VI, Part B cbuesche@doe.k12.ga.us (229) 561-4499