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NonPublic School Services

PAFPC 2012

Karl StreckewaldDFP Non Public Manager (former)

kstreckewa@pa.gov

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Nonpublic Consultation

• Title IA

• Title IIA (PD only – administered by the IU)

• Title IID (EETT – administered by the IU)

• Title IIIA (ELL, Imm)

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• 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

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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

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

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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

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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

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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

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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

Program Design: Teachers

• Title I– Cannot send materials without a teacher

• Title III– Allowed to send materials without a teacher

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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

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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

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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

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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– 3rd party contracts– Assess previous year’s program– Submit application

• July – Aug– Schedule/hire teachers, students, 3rd party, facilities– Parent notification

• Sept: start NP services at same time as public services

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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

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Third-Party Agreements• Consultation must include third-party option• LEA has final say in using 3rd 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

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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

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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

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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

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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

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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

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Contract Construction – Private Contractor (cont.)

• Instructional costs– Teacher and instructional aide salaries– Teacher and instructional aide benefits– Instructional materials

• Books• Computers & software• Workbooks• Supplies

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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

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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

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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

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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

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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

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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

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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?

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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?

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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

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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

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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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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

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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

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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)

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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

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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

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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

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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

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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.doc

– Title IX, Part E; Equitable Services:• http://www2.ed.gov/policy/elsec/guid/equitablesergu

idance.doc