Frequently Asked Questions on the No Child Left Behind Consolidated Application FAQ NCLB. Illinois State Board of Education

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1 Frequently Asked Questions on the No Child Left Behind Consolidated Application FAQ NCLB Illinois State Board of Education

2 How do I add a new school onto targeting step 4? If information is incorrect in the application, such as if the District opened, closed or consolidated schools, that cannot be changed on the current application. The District should make changes to the entity profile system (EPS) available on IWAS and follow the procedures within the CDS CODES: GUIDELINES AND PROCEDURES FOR CHANGES document which is available at: In addition to following the procedures within that document, an should be sent to Janet Allison at so that the change can be made in the IWAS system. In order for the change to take effect prior to July 1, the District should notify ISBE by the procedures above as soon as possible in the preceding school year. Meanwhile, the District should make a note of the new school in the comments box but the school will not be listed for allocations until the system is updated and the district can then amend their application.

3 What is the essential difference between a Title I schoolwide program and a Title I targeted assistance program? A targeted assistance program employs staff paid with Title I funds to serve only those students who have been identified as being most at-risk of not meeting the State s challenging standards. Multiple measures of student academic achievement are used to determine which students are eligible to participate in the program. Services to eligible students may be provided in a pullout setting on a limited basis, or may be provided in the regular classroom. Schoolwide program schools use Title I funds to meet the needs of all students in the school, as determined through a comprehensive needs assessment. Individual students are not identified as eligible to participate. No distinctions are made between staff paid with Title I funds and staff who are not. All school staff are expected to direct their efforts toward upgrading the entire educational program and improving the achievement of all students, particularly those who are low achieving.

4 How is it determined which schools can be served? An LEA must rank all of its school attendance areas (the geographic area from which a public school draws its children) according to their percent of poverty. An LEA must use the same measure of poverty for: Identifying eligible school attendance areas. Determining the ranking of each area. Determining the allocation for each area. The LEA must select a poverty measure from the following options: Children ages 5-17 in poverty as counted in the most recent census data approved by the Secretary. Children eligible for free and reduced-priced lunches under the Richard B. Russell National School Lunch Act. Children in families receiving assistance under the State program funded under Title IV, Part A of the Social Security Act (Temporary Assistance for Needy Families). Children eligible to receive medical assistance under the Medicaid program. A composite of any of the above measures. An LEA must rank school attendance areas based on the percentage (not the number) of low-income children counted. After an LEA has ranked all of its school attendance areas by poverty, the LEA must first serve, in rank order of poverty, its areas above 75 percent poverty, including any middle schools or high schools. Only after an LEA has served all of its areas with a poverty rate above 75 percent may the LEA serve lower-ranked areas. The LEA has the option to (1) continue on with the district-wide ranking or (2) rank remaining areas by grade span groupings.

5 What is the 125 percent rule? If an LEA serves any areas or schools below 35 percent poverty, the LEA must allocate to all its participating areas or schools an amount for each low-income child in each participating school attendance area or school that is at least 125 percent of the LEA's allocation per low-income child. An LEA serving only areas or schools at or above 35 percent poverty must allocate funds in rank order, on the basis of the total number of low-income children in each area or school but is not required to allocate 125 percent of the LEA's allocation per low-income child. In determining what per-child amount to allocate, the LEA should bear in mind the purpose of such funding--to enable children who are most at risk of not meeting the State's challenging student academic achievement standards. The per-child allocation amount must be large enough to provide a reasonable assurance that a school can operate a Title I program of sufficient quality to achieve that purpose.

6 May an LEA reserve funds from its Part A allocation before distributing funds to school attendance areas? Yes. Before allocating funds, an LEA must reserve funds to-- Comparable services for Neglected and Delinquent and Homeless services. No more than 5% for financial incentives and rewards to attract and retain qualified and effective teachers who serve students in Title I schools identified for school improvement, corrective action, and restructuring, for the purpose of attracting and retaining qualified and effective teachers. An amount equal to 20% for choice-related transportation and supplemental educational services. Of this amount, 5 percent must support choice-related transportation, 5 percent must support providing supplemental educational services, and the remaining 10 percent may support the costs of providing either choice-related transportation or supplemental educational services. 10% for professional development if the LEA is in status. 1% for parent involvement (if the LEA that receives more than $500,000 under Title I, Part A, subpart 2). The LEA must distribute not less than 95 percent of the amount reserved for parent involvement to schools receiving Title I services. Administration for Part A programs for public and private school children. Conduct other authorized activities, such as preschool programs, summer school and intersession programs, additional professional development, school improvement, and coordinated services.

7 Is there a maximum amount that an LEA may reserve? No. An LEA must bear in mind, however, that the goal of Part A is to enable participating children to make adequate progress toward meeting the challenging student achievement standards that all children are expected to meet.

8 If an LEA doesn t spend all the money it was required to reserve for a specific purposes, may the LEA carry over those unspent funds and spend them in other ways? No. If an LEA is required to spend a specific amount of its Title I, Part A allocation in a given year for a particular purpose, the LEA must meet that obligation. If it does not do so in the year for which the funds were allocated, it must carry over the unspent funds and spend them for the specific purpose in the following year. For example, under section 1118(a)(3)(A) of Title I, an LEA with an allocation of over $500,000 must reserve at least one percent of its Title I, Part A allocation for parent involvement activities. The LEA does not have any flexibility to spend less. Any funds that the LEA reserved for parent involvement in SY , but did not use that year, must be carried over into SY and used for parent involvement activities. These carryover funds may not be used for other Title I purposes. In addition to the funds carried over for parent involvement activities, the LEA must also reserve 1 percent from its SY Title I, Part A allocation for parent involvement activities

9 Does an LEA include funds carried over from the previous fiscal year in the current year s allocation base to determine statutory reservations? No. Title I of the ESEA requires an LEA to reserve certain percentages of its Title I allocation for specific purposes. For example, under section 1118(a)(3), an LEA must generally reserve at least one percent of its allocation for parent involvement activities. The base for calculating any of the reserves required under Title I is only the current year amount allocated to the LEA for Title I, Part A under Subpart 2, plus any funds transferred into Title I, Part A under the authority in Title VI, Part A, Subpart 2. The LEA would not include carryover funds from the preceding year when determining current-year reservations.

10 How does an LEA handle Title I, Part A funds that are carried over when allocating funds to school attendance areas? Although an LEA may not use carryover funds to provide services in an ineligible Title I school, an LEA has considerable discretion in handling carryover funds. Some of these options include: Adding carryover funds to the LEA's current-year allocation and distributing them to participating areas and schools in accordance with allocation procedures that ensure equitable participation of private school children. Allocating to schools with the highest concentrations of poverty in the LEA, thus providing a higher per-pupil amount to those schools, ensuring equitable participation of private school children. Providing additional funds to any of the activities supported by the reservations outlined in of the Title I regulations. (Note that if an LEA adds carryover funds to a reservation to which equitable services apply (e.g., parental involvement), the LEA must also calculate and provide equitable services from the carryover funds.)

11 How does the carryover provision apply to equitable services to private school children? If equitable services for private school students was provided, any carryover funds previously targeted to provide equitable services would be considered additional funds for the entire Title I program in the subsequent year and would be part of the LEA s Title I resource base in the next year. Those funds would be used, along with any other carryover funds, for serving both public and private school students on an equitable basis. Example: private school students did not fully participate in the Federal program in the first year, even though an equitable program was planned and offered for those students. If equitable services were not provided, these carryover funds would be in addition to funds that the LEA would otherwise be required to use to provide equitable services for private school students out of the LEA s current-year allocation. Example: there was a delay by an LEA in implementing an equitable program for private school children because of consultation and notification issues between private school officials and the LEA. As a result, the LEA could not spend all the funds it had available for providing equitable services to private school children and needed to carry over those funds and use them to provide services to private school children in the following year. Under either situation, the LEA retains control of the Federal funds carried over into the following year. No funds are provided directly to private schools.

12 How do private school students and schools participate in the ESEA consolidated plan? The Elementary and Secondary Education Act (ESEA), as reauthorized by the No Child Left Behind Act of 2001 (NCLB), provides educational services and benefits to private school students and educational personnel, including those in religiously affiliated schools. These services are targeted for students and educators and not for the private schools as a whole. The reauthorized ESEA requires the equitable participation of private school students and educational personnel in some of its major programs.

13 What does equitable participation mean? Governed by the uniform provisions in Title IX of ESEA, sections ( LEAs are required to make educational services available to eligible private school students and educational personnel, as long as these services are provided in the same grade-span as the services provided to public school children. These educational services and other benefits must be comparable to the services and other benefits provided to public school students and educational personnel participating in the program and address their needs under the program. The services are to be provided in a timely manner. Private schools are not required to accept the educational services.

14 How does an LEA ensure equitable participation? An LEA must consult with private schools to assess, address, and evaluate the needs of private school students and educators; spend an equal amount of funds per student to provide services; provide private school students and educators with an opportunity to participate in activities equivalent to the opportunity provided to public school students and educators; and offer services that are secular, neutral, and nonideological.

15 How should a district collect poverty data on private school children? Section 1120(c)(1) of the Title I statute and (2) of the regulations allow a district to calculate the number of children who are from low-income families and attend private schools in several ways. Descriptions of the different allowable methods can be found in the federal non-regulatory guidance ( Using the same measure of poverty that is used by the district to gather low-income information for public school students is the most equitable approach. In most cases, that measurement is qualification for participation in the Free or Reduced-Price Lunch program.

16 How should eligible non-public schools be contacted? On at least an annual basis, a district must contact officials of private schools serving children who reside in the district regardless of whether the private school those children attend is located in the district. The district may choose to extend an invitation to officials of the private schools and convene a meeting at which district officials explain the intent of Title I and the roles of public and private school officials, and to provide opportunities for private school officials to ask questions. Alternatively, a district may choose to send an offer of participation and consultation by return receipt mail.

17 What should a district do if the private schools do not respond or spend the money? The return receipt can serve as evidence that a private school received an offer of participation in Title I services, and may thus facilitate a district's attempts to gather information from private schools within the established "reasonable deadline" for response. Keep a record when contacting the private schools and establish reasonable deadlines for response to contact.

18 Are only private school children from lowincome families eligible for Title I services? No. Although the number of low-income students attending private schools and residing in a public school attendance area is the source of funding for private school student Title I services, student eligibility for Title I services for private school children is determined by (1) residence in a participating public school attendance area, and (2) educational need. Poverty is not a criterion that can be used for selection of eligible students for participation in the Title I program.

19 When a child who is most at risk of failing resides in a Title I attendance area in one district and attends a private school in another district, which district is responsible for serving the child? Section (b)(1)(i) of the Title I regulations defines Title I-eligible private school children as those who reside in participating public school attendance areas of the district, regardless of whether the private school they attend is located in the district. Thus, the district in which the child resides is responsible for providing services to the child, but may arrange to have services provided by another district and reimburse that district for costs.

20 Once participants are selected, how is it determined what Title I services are to be provided? A district, in consultation with appropriate private school officials, determines the appropriate Title I services based on the needs of the private school students. Title I services may be provided in subject areas or at grade levels that are different from those provided public school students, as long as these services are provided in the same grade-span as the services provided to public school children. These services must hold reasonable promise that the academic performance of private school participants will improve.

21 What types of services are available for private school participants? Services for participating private school children include, but are not limited to, the following: Instructional services provided by public school employees or third-party contractors. Extended-day services. Family literacy programs. Counseling programs. Computer-assisted instruction (CAI). Home tutoring. Instruction using take-home computers.

22 May a district use the private school's assessment data to determine progress of the district's Title I program? Yes. Officials of the private schools may provide the district with the assessment data on Title I participants that the private school has collected as part of its testing program. However, private school officials are not obligated to do this, and refusal by private school officials to provide these data does not release the district from its obligation to provide services and assess the progress of the private school participants in the Title I program.

23 What is required to assess the progress of the private school participants in the Title I program? An LEA must annually assess the progress of the Title I program toward enabling private school Title I participants to meet the agreed-upon standards. Every year the district and private school officials must consult on what constitutes annual progress for the Title I program. If the Title I program for the private school participants does not make the expected annual progress, the district must annually make modifications to the Title I program, including the professional development, and parent involvement programs. Therefore, the results of the assessments should be available to the private school officials in a timely manner, before the Title I program for the following school year is finalized.

24 May Title I funds be used to assess private school children? Yes. Title I funds may be used to assess private school children if the assessment is used only for Title I purposes. To the extent, however, that an assessment is conducted for other purposes, it may not be paid for from Title I funds. If private school children, in general, are included in the State assessment, Title I funds may not be used to pay for the assessment of those private school children participating in Title I.

25 Who has control of the funds? The LEA maintains control of the federal funds used to provide services under the grant programs funded through the No Child Left Behind Act. It also maintains title to materials, equipment, and property purchased with those funds. LEAs may allow the private schools to keep the items from year to year, in accordance to approved ongoing activities, so long as records are maintained. No check should ever be written to the nonpublic school.

26 What kinds of costs can be included in the 5% administration costs line? General admin cost could include: coordinator costs, support staff costs, audit costs (all prorated for this program only) and a cost allocation plan should be on file at the LEA to show how the proration was determined. Other allowable costs might include administrative supplies and equipment for administration.

27 Can federal funds be used to host and/or attend a meeting or conference? Yes. Federal grant funds may be used to host and/or attend a meeting or conference if doing so is: A. Consistent with its approved application or plan; B. For purposes that are directly relevant to the program and the operation of the grant, such as for conveying technical information related to the objectives of the grant; and C. Reasonable and necessary to achieve the goals and objectives of the approved grant.

28 Are meals disallowed from Title I? Even for parent meetings? May Title I professional development funds be used for meals at workshops and conferences? A grantee hosting a meeting or conference may NOT use grant funds to pay for food for attendees UNLESS doing so is necessary to accomplish legitimate meeting or conference business. If food is provided, auditors will scrutinize the agenda, documentation, and question the necessity of food purchase and its direct relationship to achieving the goals and objectives of the meeting.

29 Should homeless students be offered Title I services even if the building they are attending does not receive Title I funds? Children and youth who are homeless are automatically eligible for Title I, Part A, services, whether or not they reside in a Title I attendance area or meet the academic standards required of other children for eligibility. According to Title I, Part A, LEAs must reserve (or set aside) such funds as are necessary to provide comparable services to homeless children who are not attending Title I schools. [ 1113(c)(3)] When determining appropriate expenditures for the funds set aside for homeless students, it is important to note that comparable services do not mean services that are necessarily identical to other Title I, Part A, services, since LEAs may use reserved funds to provide homeless students with services that are not ordinarily provided to other Title I students and that are not available from other sources.

30 What does shall reserve such funds as are necessary to provide services to homeless children and that these services must be comparable to the services the district provides to children in Title I, Part A schools mean? Method #1: Identify homeless students needs, and fund accordingly. Method #2: Obtain count of homeless students, and multiply by Title I, Part A per-pupil allocation. Method #3: Reserve an amount of funds greater than or equal to the amount of your McKinney-Vento subgrant request. Method #4: Reserve a specific percentage based on your district s poverty level or total Title I, Part A allocation.

31 What if we do not have any homeless students? An LEA must reserve funds for homeless students since these students may arrive at any time. Homeless students are often difficult to identify for many reasons and often go unnoticed by school personnel. Students and parents may try to hide their situation because they are embarrassed by their homelessness. In addition, the fear of having children taken away often prevents families from informing school officials of their living circumstances. Unaccompanied youth may not report their homeless status for fear of being returned to unsafe family environments. Children and youth who are not enrolled in school and who are not living in shelters are even more invisible to schools and their communities.

32 What should Title IIA funds be used for? After conducting its needs assessment, the LEA must target Title IIA funds to schools that (1) have the lowest proportion of highly qualified teachers, (2) have the largest average class size, or (3) are identified for school improvement under Section 1116(b) of Title I, Part A [Section 2122 (b)(3)]. In addition, in considering its best use of Title II, Part A funds, an LEA should consider whether to target Title II, Part A funds to help it meet its responsibilities under Title I. These include providing assurances that the LEA will: (1) work in consultation with schools as the schools develop and implement their plans or activities under Section 1119 [Section 1112(c)(1)(H)]; (2) comply with the requirements of Section 1119 regarding the qualifications of teachers and paraprofessionals and professional development [Section 1112(c)(1)(I)]; and (3) ensure, through incentives for voluntary transfers, professional development, recruitment programs, or other effective strategies, that low-income students and minority students are not taught at higher rates than other students by unqualified, out-of-field, or inexperienced teachers [Section 1112(c)(1)(L)].

33 What does a Title IIA needs assessment look like? The purpose of the needs assessment is to determine the needs of the LEA s teaching force in order to be able to have all students meet challenging State content and academic achievement standards. An LEA may want to use information such as student achievement data, information about numbers of teachers (disaggregated by subject taught and grade level) who lack full teacher certification or licensure, assessments by administrators and mentor teachers who evaluate teacher and student performance, and teacher self-evaluations. The LEA must carry out the needs assessment with the involvement of the district s teachers, including those in schools receiving assistance under the Title I, Part A program. The LEA uses the results of this assessment to plan its Title II, Part A activities, keeping in mind its student achievement goals and its plan for ensuring that all teachers in core academic areas meet the highly qualified requirements.

34 For what activities may an LEA use Title II, Part A funds? 1. Developing and implementing mechanisms to assist schools to effectively recruit and retain highly qualified teachers, principals, and specialists in core academic areas, 2. Developing and implementing strategies and activities to recruit, hire, and retain highly qualified teachers and principals. 3. Providing professional development activities that improve the knowledge of teachers and principals and, in appropriate cases, paraprofessionals, in content knowledge and classroom practices 4. Providing professional development activities that improve the knowledge of teachers and principals and, in appropriate cases, paraprofessionals, regarding effective instructional practices 5. Developing and implementing initiatives to promote retention of highly qualified teachers and principals, particularly in schools with a high percentage of low-achieving students 6. Carrying out programs and activities that are designed to improve the quality of the teaching force, such as innovative professional development programs 7. Carrying out professional development programs that are designed to improve the quality of principals and superintendents, including the development and support of academies to help them become outstanding managers and educational leaders. 8. Hiring highly qualified teachers in order to reduce class size, particularly in the early grades. 9. Carrying out teacher advancement initiatives that promote professional growth and emphasize multiple career paths (such as paths to becoming a mentor teacher, career teacher, or exemplary teacher) and pay differentiation.

35 Is it acceptable for the private school to pay their teachers a stipend if they attend professional development on their own time under Title II teacher quality? Title II, Part A funds may be used to pay for stipends for private school teachers, as reasonable and necessary. For example, if the professional development activity is conducted during after-school hours or in the summer, stipends may be needed to compensate teachers for their participation outside their regular employment hours. Stipends for private school teachers must be available on the same basis as those for public school teachers and the stipends must be paid directly to the private school teachers for their own use, and not to the private school.

36 Must a district complete a Title I District Plan and submit it to IIRC in order to receive any funding? Yes, the Title I plan needs to be approved by both your local school board and the State Board of Education before your NCLB application can be read and approved.

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