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Private School Services in NCLB

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 Private School Services in NCLB Powered By Docstoc
					Private School Services in
     NCLB Programs


           Rob Huffman
           Diane Lowery
     SD Department of Education
Private School Participation
   School Districts receiving federal
    financial assistance under NCLB
    programs are required to provide
    equitable services to eligible private
    school children, families, and teachers.
   This requirement applies to both ARRA
    Title I funds and the regular Title I
    allocation for 2009-10 as well as Titles
    IIA, IID, and IVA.
Eligible Private Schools
Must be
  • Non-Profit
  • State accredited elementary or secondary
   schools
Equitable Participation
   Services and other benefits must be
    comparable to the services and other
    benefits provided to public school
    children, families, and teachers
    participating in the program.
Do the services need to be the
same?
   No, if the needs of the private school
    students, families, and teachers are
    different from the public school, the
    district should develop a separate
    program.
District Responsibility

   Designing and implementing the programs
    for the private school students, families,
    and teachers.
   Services must be provided by an employee
    of the district or a 3rd party contractor.
    Services must be provided by a teacher
    who is highly qualified for the subjects and
    grades being taught.
   This responsibility can not be delegated to
    the private schools.
Control of Program & Funds
   The public schools must be in control of
    the program.
   No public funds are distributed to private
    schools.
   District provides services and materials
    to benefit students and their teachers
Services Provided
   Must be secular, neutral, and non-
    ideological

   Must supplement, and not supplant, the
    level of services provided.
Private School Consultation
   During the design and development of
    the programs.
   Before any decision is made that could
    affect the ability of the privates school
    students or teachers to receive benefits.
On Going
   Must continue throughout the year to
    ensure the needs of students and their
    teachers are met.
    • Phone calls, emails, onsite visits
Consultation Includes
   How the children’s needs will be
    identified
   What services will be offered
   How, Where and by whom the services
    will be provided
   Size and scope of the equitable services,
    & amount of funds available
Consultation       Continued

   How the services will be assessed &
    how the results will be used to improve
    services
   How and when the district will make
    decisions about the delivery of services
   Review the Complaint Process
Consultation        Continued


     District gives thorough consideration and
      analysis of the views of the private school
      officials on the provision of 3rd party
      contract services provider.
     If district disagrees with the views of the
      private school officials, the district must
      provide a written explanation of the reasons
      why it has chosen not to use a contractor.
Complaint Process
   If private school officials believe that
    timely and meaningful consultation has
    not occurred
    • Contact District Supt. or District Fed Programs
        Director to express and discuss concerns
    •   Each district is required to have a complaint
        policy applicable to federal programs and must
        disseminate the policy to private school officials
        and each family of children provided Title I
        services.
Complaint Not Resolved at
District Level
   1st Contact the Federal Programs staff
    at the SD DOE to mediate
   If not satisfactory resolved the private
    school has the right to file a formal
    written complaint with SD DOE
Formal Complaint to SD DOE
   A statement that the district has violated
    a requirement of the federal program
   The facts or basis of the complaint
   The name, address and signature of the
    complainant
What Documentation should
District Have?
   Representative of private schools were
    informed of availability of services
   The needs the private school students and
    teachers were identified as part of the district-
    wide need assessment
   Private school officials were consulted and
    provided an opportunity for input
Documentation              Continued

   The district designed a project that permits
    equitable participation
   District should maintain records of its efforts to
    resolve any complaints by private school
    officials
Consolidated Application
Programs
   Title I Part A
   Title I Part C Migrant
   Title II Part A Teacher Quality
   Title II part D Ed Tech
   Title III English Language Acquisition
   Title IV Safe and Drug Free
   Title V Innovative Programs
Which District is Responsible?
   Title I Part A
    • Each District is responsible for its own
      resident students
   Other Programs
    • District where the Private School is located
Remember Equitable Services
   Must be provided by employees of the
    District, or
   Independent 3rd Party Contractor
   Never give funds directly to a private
    school
District Administrative
Responsibilities
   Title to any equipment, supplies or
    materials remains with the District
    • Maintain inventory list & controls
    Ensure all services and equipment,
    supplies or materials are supplemental
    and not supplanting.
District Responsibilities
continued
   District must implement safeguards that
    equipment, supplies & materials
    • Used for secular, neutral and non-ideological
        activities
    •   Are supplemental
    •   Must be removed by district if not use
        appropriately
Title I Equitable Services
   Title I, Part A –
    • equitable based on resident low-income
      students residing in participating school
      attendance areas.
       •  amount per low-income student (public or private)
         must be the same within a school attendance area
       • Amount per low-income student may very between
         school attendance areas
Example - Private Allocation

   a LEA allocates
     • $1000 per poverty child to public School A
     • $800 per poverty child to public School B
     • School C is not receiving Title I Funds
    •   Any Private school poverty child residing in:
         • School A’s attendance area is allocated $1000
         • School B’s attendance area is allocated $800.
         • School C’s attendance area receive no allocation.
Title I Part A & Private School
Services
  • Resident district is responsible for providing
    services for its students, even if the students
    attend a private school in another district.
     • Resident district may contract with another district
       to provide services.
     • Must develop written agreement
Which Private students may
receive Title I services
   Must reside in a participating Title I school
    attendance area AND be failing or most at risk
    of failing
   Selected on the basis of multiple educational
    related criteria
   Poverty is NOT a criterion for services
Targeted Assistance
   Private school services must be
    Targeted Assistance
   Cannot operate a Title I schoolwide
    program in a private school.
Examples of Title I Services
   Instructional Services outside the regular
    classroom
   Before/After school and in summer
   Family Literacy
   Home Tutoring
   Computer-assisted instruction provided
    by the Title I teacher
Other Title I Requirements
   Equitable participation of private school
    teachers of Title I students in professional
    development activities
   Equitable participation of parents of Title I
    students in parental involvement activities
   Teachers providing Title I services must be
    HQT for subjects and grades
Off the Top Reservation for
District Level activities
   If the LEA reserves Title I funds for
    district level instructional programs -
   A proportional amount must go to
    nonpublic school services
    • Based on # of low income students in all
      participating Title I school attendance areas
Examples of District Level
Instructional Activities
   Summer school
   Professional development

District set asides for parental involvement are
  also subject to equitable participation for
  families of private school children receiving
  Title I services
Title I Part C Migrant
   Eligible children must meet the statutory
    definition of a migrant child
   Proportional share of total migrant
    children in district
Title III English Language
Acquisition
   Equitable Services for limited English
    proficient Children and their teachers to
    attain English proficiency

   Proportional share of LEP children in
    district
Title II Part A Services
   Requires equitable participation of
    private school teachers and other
    educational staff only to the extent the
    district uses its funds for professional
    development activities.
Title II Part A – Equitable
Funding
  • District where private school is located is
      responsible, regardless of the student’s
      resident district.
  •   Equitable amount based on the relative share
      of public and private student enrollments in
      the district; however,
Title II Part A Exception

  •   The district may reserve the funds the District uses for
      Class Size reduction and Teacher recruiting activities
      before calculating equitable share
  •   But, must provide at least as much as private school
      received for PD under the old Eisenhower Title II and
      CSR grant.
Title II Part A example
   Allocation                   $100,000
   Less Non PD Activities $60,000
   Professional development     $40,000
   Public enrollment 900
   Private Enrollment 100
   Private school share is 10% of $40,000
    or $40/student
Title II Part A Activities
   Participation in the District’s professional
    development
   Qualified District staff providing
    professional development for privates
    school teachers
   Third party services (conferences,
    contracted trainers)
Professional Development
   District must pay conference & travel fees
    directly, or reimburse teacher
   District may pay stipends directly to private
    school teachers
   District cannot pay for private school substitute
    teachers
   Do not give any funding to private school
Other Title Programs Equitable
Funding
   Title II Part D, Title IV, & Title V
    • Equitable amount based on the relative share
        of public and private student enrollments in
        the district
    •   District where private school is located is
        responsible, regardless of the student’s
        resident district.
Example
   Title IV allocation $10,000
   Public School Enrollment     900
   Private School Enrollment    100
   Total Enrollment is 1000
   10% is private school share or $10 per
    student
Transferability
   Must consult with the private school officials
    prior to making any decision that could affect
    their ability to benefit from programs
   Private school students and teachers receive
    equitable services under the same program
    where the District uses funds.
REAP
   Reserve the applicable funding that is
    generated by private school students
   REAP Flex eligible districts may use flexibility
    on behalf of private school students
   need not be expended under the same
    programs as funds for public school
Compliance Issues

   Public control of program
   Equitable services
   Computation of Title I funds for
    services
   Administration of the program for
    private school children
   Consultation requirements
USED Guidance
   Title I Services to Eligible Private
    School Children, Non-Regulatory
    Guidance, October 2003
   Equitable Services to Eligible Private
    School Students, Teachers, and Other
    Educational Personnel , Non-Regulatory
    Guidance, March 2009