Supplement Not SupplantNew ESSA Requirements

Title I, Part A

Introductions:

• Nathan Williamson (Director of Title Grants and Support )

• Adis Coulibaly (Assistant Director of Title Grants and Support)

Webinar Agenda

• Supplement not supplant changes under ESSA

• Methodology and examples

• Demonstration process

• Frequently asked questions

Reminder:

• Today’s webinar applies to the requirements under Title I, Part A only. The supplement, not supplant tests under other Title programs have not changed.

For additional information related to other programs, contact your Federal Grants Specialist or the reference document below.

https://www.doe.in.gov/grants/titlei/resources-pd-etc

Supplement Not Supplant Guidance Under ESSA

• ESEA Section 1118(b)(2)- Compliance

“[A] local educational agency shall demonstrate that a methodology used to allocate State and local funds to each school receiving assistance under [Title I, Part A] ensures that such school receives all of the State and local funds it would otherwise receive if it were not receiving assistance under [Title I, Part A]”

Supplement Not Supplant Guidance Under ESSA (continued)

• ESEA section 1118(b)(3) - SPECIAL RULE

No local educational agency shall be required to—

A. Identify that an individual cost or service supported under [Title I, Part A] is supplemental; or

B. Provide services under [Title I, Part A] through a particular instructional method or in a particular instructional setting in order to demonstrate such agency’s compliance with [the supplement not supplant requirement].

Changes to Supplement Not Supplant Under ESSA

• State and local fund focus: The SNS test under ESSA focuses on and requires demonstration of the LEA’s methodology used to allocate State and local (non-Federal) funds to each school receiving Title I assistance to ensure that it is receiving the same amount it would have regardless of whether the school received Title I assistance.

Changes to Supplement Not Supplant Under ESSA (continued)

• In other words, the updated SNS test reviews the manner in which LEAs allocate State and local funds to schools to ensure Title I schools receive all of the funds they would have received had they not participated in Title I.

• Shift from a Title I focus to a State and local focus.

NCLB: Use of Title I Funds

ESSA: Allocation of State and Local Funds

State and Local Funds90%

Federal Funds8%

Other2%

Local Education Agency (LEA) Funding

What is a “Methodology?”

• The term “methodology” refers to the manner in which State and local (non-federal) funds are allocated to schools.

• IDOE will recognize the following methodologies the LEAs may select from during the demonstration process:

• Distribution of State and Local (non-Federal) Resources Based on Projected Per-Pupil Expenditures (PPE)

• Distribution of State and local (non-Federal) resources based on the characteristics of the students (PPE);

• Distribution of State and local (non-Federal) resources based on staffing and supplies

• Distribution of State and local (non-Federal) resources based on a combined approach

• Other, as adopted by the LEA

Methodology Option: Based on Projected Per-Pupil Expenditures

• Example 1: Distribution of State and Local (non-Federal) Resources Based on Projected Per-Pupil Expenditures (PPE)

• In this example, the LEA is utilizing per-pupil expenditures as the foundation for planning a school’s allocation. The LEA needs to utilize the State/local figure only as a supplement not supplant test measured before Federal funding is allocated to schools.

• This methodology must be written with a focus on up-front allocations rather than after-the-fact expenditures.

• LEAs may consider using an estimated projection of Form 9 to supplement their methodology to demonstrate compliance.

Methodology Option: Based on Projected Per-Pupil Expenditures

• Although the methodology to allocate State and local funds to schools and the reporting of actual per-pupil expenditures for each school are related, they are distinguishable and serve different purposes.

• Actual per-pupil expenditures data represents a retrospective analysis of how much was spent by each school. The compliance demonstration for the supplement not supplant requirement is based on the methodology by which State and local funds are allocated to schools. It is designed to ensure Federal funds are not supplanting State and local funds at the point in which State and local funds are allocated to schools.

Methodology Example 1A

Methodology Example 1A

• Using Form 9, a comparison was made of the PPE between the Title 1 elementary ($6,584.08) against the PPE of the non-Title middle school ($7,716.35) and high school ($9,051.42).

• From the comparison, the PPE for the Title I elementary was less than the middle school and high school. In reviewing the expenditures by building, the average years of service for the Title I elementary teachers is 11.65 years, which is less than the average years of service for the middle school teachers of 11.73 years and the average years of service for the high school teachers of 13.87 years.

Methodology Example 1A

• An additional calculation indicated that the ratio of students to teachers at the Title I elementary is 15.56 students per teacher. At the middle school, the ratio is 17.38 students per teacher and the ratio at the high school is 13.79 students per teacher. The number at the high school shows that the number of class offerings is greater, thus reducing the student to teacher ratio.

• Another factor was that during the 2017 year, the Title I elementary did not have an Assistant Principal on staff, thus reducing the PPE. An Assistant Principal has been added to the staff for the 2018-2019 school year.

Methodology Example 1A

This methodology was found approvable for the following reasons:

• Differences in funding at schools with different grade spans is easily justified. The LEA has only one Title-served building, and it is at the elementary level.

• Rationale included justification for differences in funding (staffing, number of class offerings, etc.)

Methodology Example 1B

Methodology Example 1B

This methodology was found approvable for the following reasons:

• Six elementary schools (one of which is Title served) have PPEs within 10% of one another.

• The two middle schools as well as high school also fall within this range and additional justification or rationale is not needed.

• Provided an average PPE for each grade span with multiple schools (elementary, middle).

Methodology Option: Based on Staffing and Supplies

• Example 2: Distribution of State and Local (non-Federal) Resources Based on Staffing and Supplies

Assume:

a. 1 principal/school ($120,000)

b. 1 librarian/school ($65,000)

c. 2 guidance counselors/school ($65,000/counselor)

d. 1 teacher per 20 students ($65,000/teacher)

e. $825/student for instructional materials and supplies (including technology)

Methodology Example: Based on Staffing and Supplies

• This example allocates State and local funds to schools based on estimated average costs. In a school of 400 students, the LEA would allocate to the school $1,945,000 in State and local funds based on the following calculations:

Methodology Example 2

Methodology Example 2

Methodology Example 2

Methodology Example 2

This methodology was found approvable for the following reasons:

• Rationale included justification for differences in funding at the high school: CTE Programming, AP/Dual Credit programming causes increase in instructional materials and supplies. There are also additional staff (guidance counselors to assist with college & career).

• Rationale provided for staffing assignments based on number of students per building.

• Provided cost of instructional materials and supplies at each building.

Methodology Option: Based on Student Characteristics

• Example 3: Distribution of State and Local (non-Federal) Resources Based on Student Characteristics (Weighted Student Funding)

• Assume:• Base allocation per student ($7,000)

• Additional allocation per student from a low-income family ($250)

• Additional allocation per English learner ($500)

• Additional allocation per student with a disability ($1,500)

• Additional allocation per preschool student ($8,500)

Methodology Example: Based on Student Characteristics

• This example allocates State and local funds to schools based on a standard formula through which an LEA allocated dollar amounts based on objective student characteristics. In this example, in a school of 400 students, including 200 students from low-income families, 100 English learners, 50 student with disabilities, and 20 preschool students, the LEA would allocate to the school $3,145,000 in State and local funds based on the following calculations:

Methodology Option: Based on Combined Approach

• Example 4: Distribution of State and Local (non-Federal) Resources Based on a Combined Approach

• This form of equitable distribution includes characteristics of the two previous examples, distribution of State and local (non-Federal) resources based on the characteristics of the students and the staffing and supplies needs of the schools.

• Assume:• 1 principal/school ($100,000)

• 1 librarian/school ($55,000)

• 2 guidance counselors or social workers/school ($55,000/guidance counselor)

• Allocation/student ($5,000)

• Additional allocation/student from a low-income family ($250)

• Additional allocation/English learner ($500)

• Additional allocation/student with a disability ($1,500)

Methodology Example: Based on Combined Approach (cont.)

• In a school of 450 students, including 200 students from low-income families, 100 English learners, and 50 students with disabilities, the school would be expected to receive $2,690,000 in non-Federal resources based on the following calculation:

Category Calculation Amount

1 principal 1 x $100,000 $100,000

1 librarian 1 x $55,000 $55,000

2 guidance counselors 2 x $55,000 $110,000

Allocation/student 450 x $5,000 $2,250,000

Additional allocation/student from a low-income family 200 x $250 $50,000

Additional allocation/English learner 100 x $500 $50,000

Additional allocation/student with a disability 50 x $1,500 $75,000

Total $2,690,000

Methodology Option: Other, as Adopted by the LEA

• Example 5: Other, as Adopted by the LEA

• This form of equitable distribution does not necessarily fit within the parameters provided in the other examples; however, the LEA assures that this methodology is neutral in regard to the Title I, Part A status of each school.

• IDOE will support LEAs through the demonstration process if a methodology has not been previously formalized or does not fall within the options previously outlined

Exceptions to Methodology Requirements

• Considerations for Certain LEAs

If an LEA has

a. One school;

b. A grade span with a single school, all Title I schools, or all non-Title I schools (i.e., no methodology is required for the grade span); or

c. Only Title I schools,

Then that LEA need not comply with methodology requirements as outlined in ESEA section 1118(b)(2)

Demonstration Process – Frequency

• The LEA must be able to demonstrate compliance for the SNS methodology upon request through federal program monitoring

• If the LEA adopts or implements a revised methodology for allocating State and local (non-Federal) resources, then notification to IDOE is required (through the Title I grant) and local documentation must be kept of demonstration of compliance with the revised SNS methodology.

Demonstration Process - Substantive

• A substantive change may occur when an LEA shifts from one type of methodology to another. Minor changes to the value attached to a variable within the methodology are likely not considered substantive.

Demonstration Process

• IDOE is responsible for verifying that each LEA receiving Title I, Part A funds is in compliance with the SNS demonstration requirements under the ESSA.

• To ensure all LEAs in Indiana meet these requirements, each LEA is required to submit the following:

a) An assurance stating the LEA is in compliance with the provisions of section 1118(b) of the ESSA;

b) An indication of the type of methodology the LEA has adopted and is implementing in regard to the allocation of State and local (non-Federal) funds to all schools; and,

c) A narrative description of the methodology or a reference to the LEA’s Financial Transparency document in which the methodology is described.

Demonstration Process, cont.

• Upon adoption or implementation of a revised methodology, including any substantive changes to the methodology, it is incumbent upon the LEA to provide an updated description to IDOE; demonstration of compliance and the methodology should be kept onsite for monitoring purposes.

• In subsequent years after the initial demonstration, LEAs will be required to provide the current methodology with their Title I Basic grant indicating that no substantive changes have occurred.

Timeline

• LEAs must submit their methodology through the FY 20 Title I application by answering the question on the District Information page.

• The explanation must indicate the methodology type and include a narrative description.

• If an LEA is exempt from demonstrating methodology, the LEA must provide the rationale for exemption rather than the description.

• Title I applications are due July 1.

Frequently Asked Questions

• Q: Can we use our comparability submission to meet the SNS requirements?

• A: No, while comparability and supplement, not supplant requirements both examine how the LEA distributes State and local funds and/or resources to schools, they are separate tests and are intended to measure different aspects of the supplemental nature of Title I, Part A funds.

Frequently Asked Questions

• Q: Does the new application of supplement, not supplant under Title I, Part A apply to just schoolwide programs or to schools operating targeted assistance programs, as well?

• A: The rule applies to all LEAS receiving Title I, Part A funds, regardless of whether the school operates a schoolwide or targeted assistance program.

Frequently Asked Questions

• Q: Does an LEA have flexibility when developing its methodology for allocating State and local funds to schools?

• A:Yes, although many LEAs are likely to use an existing allocation methodology for purposes of demonstrating compliance (as long as its existing methodology is neutral with regard to Title I status). In developing a methodology, LEAs may (but are not required to) consider:

• Whether to use a singe districtwide methodology or a variable methodology/multiple methodologies based on grade band or school type;

• How the methodology may vary or scale based on student enrollment size; or• How the methodology may account for schools in need of additional funds to

serve high concentrations of children with disabilities, English learners, or other such groups of students the LEA determines require additional support.

Frequently Asked Questions

• Q: Does this provide the flexibility to use Title I funding on activities such as salaries for principals, general education teachers, Lau-required English learner teachers, students with disabilities teachers etc.?

• A: No. The local methodology must demonstrate how the LEA is providing enough State/local money to provide core educational services, such as general education teachers, English learner teachers, etc.

Questions regarding the SNS demonstration requirements, process, or timeline may be directed to:

Nathan Williamson Adis Coulibaly

Director of Title Grants and Support Assistant Director of Title Grants and Support

(317) 232-6671 | nwilliamson@doe.in.gov (317) 232-7179 | acoulibaly1@doe.in.gov