Title I, Part A/LAP New Directors Workshop - Office of Superintendent of Public Instruction September 17, 2013 - OSPI

Title I, Part A/LAP
         New Directors Workshop

Office of Superintendent of Public Instruction
September 17, 2013

                                                 1

Learning Assistance Program (LAP)
          Requirements

                                    2

Change to LAP Law

• Engrossed Substitute Senate Bill (ESSB)
  5946 of 2013

• Under Chapter 28A.165 RCW and the
  Washington Administrative Code (WAC)
  392-162 (in process)

                                            3

NOTE

• For the 2013–14 school year, districts may
  continue LAP as it was implemented in the
  2012–13 LAP application.

• However, districts that select to do this must
  determine how they will implement the required
  changes made to LAP under ESSB 5946
  in school year 2014–15.

                                                   4

What are the important changes to LAP?

There are significant LAP changes resulting from
2013 legislation. They are:

   Districts are no longer required to submit a
    LAP application/plan or budget to the Office
    of Superintendent of Public Instruction (OSPI).

   Districts are no longer required to develop
    an Accelerated Learning Plan for identified
    LAP students.

                                                   5

LAP Requirements
• Each district must submit a LAP Assurance Form through the
  iGrants system in Form Package (FP) 218. FP 218 is available in
  iGrants and was due September 9, 2013. These assurances
  outline the end-of-year reporting that is now required under the
  new legislation.

• LAP must first focus on addressing the needs of students in
  kindergarten through fourth grade who are deficient in reading
  or reading readiness skills to improve reading literacy. (Districts
  must use intensive reading and literacy improvement strategies
  from a state menu of best practices in school year 2015–16 for
  schools where more than 40 percent of third grade students
  scored at basic or below basic.)

• LAP funds may be used to provide support services to students
  who demonstrate disruptive classroom behaviors.
                                                                        6

Five Percent
• Up to five percent of a district's LAP allocation
  may be used for development of partnerships
  with community-based organizations,
  educational service districts, and other local
  agencies to deliver academic and non-
  academic supports to participating students
  who are significantly at risk of not being
  successful in school, to reduce barriers to
  learning, increase student engagement, and
  enhance students' Readiness to Learn (RTL).
                                                      7

What stays the same?
• LAP remains supplemental to core instruction.

• LAP may be used to provide supplemental reading, writing,
  mathematics, and readiness interventions associated with
  these content areas.

• Districts may select the grades (K–12) to be served for basic
  LAP services.

• LAP may also support eleventh and twelfth grade students
  at risk of not meeting local and state graduation
  requirements.

                                                              8

What must a district do to access LAP
                funds?
• Contact your district business manager for the
  2013–14 LAP allocation amount.

• Districts must sign the Assurance Form found
  in iGrants, FP 218. FP 218 is available in
  iGrants and was due September 9, 2013.

• Districts must collect LAP individual student
  and program effectiveness data to report to
  OSPI.

                                                   9

Title I, Part A Program Models

• Targeted Assistance Model
• Schoolwide Model

                                         10

Title I, Part A Program Models

Targeted Assistance:
Provides supplemental services to “identified” children who are low-
achieving or at risk of low achievement.
                                       ESEA Section 1115, Targeted Assistance

Schoolwide:
Ensure all students, particularly those who are low-achieving, demonstrate
proficient and advanced level in the state achievement standards.
                                                 ESEA Section 1114, Schoolwide

                                                                            11

Service Delivery Model

 Supplemental/additional assistance to core instruction for eligible
  students, particularly addressing the needs of low-achieving children and
  those students at risk of not meeting the state’s academic achievement
  standards:
   In-class supplemental model (Push-in)
   Pull-out class model
   Before school/after school
   Saturday school
   Extended school year
   Summer school

                                                                          12

Targeted Assistance Program Model

• Program Focus - Supplemental assistance to core instruction in reading,
  language arts, and mathematics.
   – Supplemental services to identified children based on multiple,
      educational related, objective criteria established by the local
      educational agency and supplemented by the school (rank order list).
   – Based on comprehensive needs assessment.
   – Utilization of research-based strategies.
   – Focus on effective school and parent/community engagement.
   – Review program on an ongoing basis.

                                                                             13

Eight Components of Targeted Assistance
                   Program
The program model does not require a written plan, but must be based on the
evidence of the eight components of targeted assistance program which are:
1. Comprehensive needs assessment.
2. Ensure planning for low achieving students incorporated into current School
     Improvement Plan.
3. Methods and strategies are based on scientifically-based research.
4. Coordination and support to the general education program.
5. Provide instruction by highly-qualified teachers and paraprofessionals.
6. Provide opportunities for professional development.
7. Strategies to increase parent involvement.
8. Coordination of federal, state, and local services.

                                                                                 14

Schoolwide Program Model

A Title I, Part A school is eligible to become a
schoolwide program when the student poverty
level is at or above
40 percent:

 –A planning year is suggested prior to becoming a schoolwide
 program.
 –The plan must be developed in consultation with the district
 and its school support team, parents, and other technical
 assistance providers.
                                                            15

Schoolwide Program Focus

Program Focus - Supplemental assistance to
core instruction in reading, language arts, and
mathematics.
  –   Accountability for results
  –   Upgrade the entire educational program
  –   Utilization of research–based practices
  –   Effective school and parent/community engagement
  –   Review annually effectiveness of program

                                                         16

Developing Schoolwide Plan

The school must develop a comprehensive plan that includes reform
   strategies that describe how it will achieve the goals that have been
   identified from the results of the needs assessment:
   – Create a “school profile,” a data driven description of the school’s staff,
      community, programs, and mission, as well as student achievement
      data trends over time.
   – Identify strengths and improvement areas, using objective data and
      input from staff and community.
   – Identify highest priorities and determine which should be tackled first.
   – Identify effective strategies for achieving the needed changes.
   – Create an evaluation plan.

                                                                               17

The Ten Required Components of
                      Schoolwide Plan
1.   Comprehensive Needs Assessment.

2.   Schoolwide Reform Strategies.

3.   Instruction by highly qualified teachers.

4.   Professional development activities.

5.   Attract high-quality, highly qualified teachers.

6.   Strategies to increase parent involvement.

7.   Transition.

8.   Include teachers in assessment decisions.

9.   Strategies for additional assistance to students experiencing difficulties.

10. Coordinate and integrate Federal, State, and local services.

                                                                                   18

Title I, Part A
Parent Involvement

                     19

Parent Involvement

Key Requirements
• Accessibility
      Communication in General
        Provide information to parents of students participating in Title I,
          Part A programs in an easy to understand format and in a
          language they can understand.
      Other Languages
        Written translations of printed information must be provided to
          parents with limited English proficiency or orally in a language
          the parent can understand.
      Parent with Disabilities
        Districts must take the necessary steps to ensure that
          communication with parents with disabilities are as effective as
          with other parents.
                                                                                20

Parent Involvement

• Funding
 Districts receiving $500,000 or more in Title I, Part A funds must set
  aside, at minimum, one percent for parent involvement purposes.
  Ninety five percent of the district set-aside must be allocated to
  Title I, Part A buildings for building-level parent involvement.
 Districts with less than $500,000 must also provide parent
  involvement opportunities at the district and building levels.
 Districts must involve the parents in the allocation of funds the
  district has reserved for parent involvement activities, including
  promotion of parent literacy and developing parenting skills.

             [NCLB Section 1118(a)(3), Parent Involvement Guidance C-14]

                                                                       21

Parent Involvement
• District Level Parent Involvement Policy
  A written document (school board approved).
  Jointly developed and agreed upon with
   parents.
  Distributed to all parents of participating
   students, if applicable, in a format and language
   that parents can understand.
     • Describes elements of parent involvement activities
       that will be implemented at Title I, Part A schools.
     • Includes strategies on using parent input.
**   If the district already has a parent policy, it can be amended to   22

Parent Involvement
• School (Building) Level Parent Involvement
  Policy
  Written policy.
  Agreed upon by parents.
  Distributed to parents, and the local
   community, in a format and language, to the
   extent practicable, that parents can
   understand.
        • Describes the means for carrying out parent
          involvement activities at the building level.
        • Includes strategies in using parent input.
**    If the school has a parental involvement policy that applies to all
     parents, it may be amended to meet the requirements of Title I, Part
     A.                                                                     23

Parent Involvement
School Policy Requirements Continued…
• Provide timely information about programs.
• Involve parents in on-going, timely planning,
  review, and improvement of the school
  parental involvement policy and the joint
  development of the schoolwide program plan.
• Include a description and explanation of the
  curriculum in use at the school, the forms of
  academic assessment used to measure
  student progress, and the proficiency levels
  students are expected to meet.
                                              24

Parent Involvement
School-Parent Compact
 • Each Title I, Part A school shall jointly
   develop with parents, for all children served,
   a school-parent compact that outlines:
   How parents, the entire school staff, and
     students will share the responsibility for
     improved student academic achievement.
   The means by which the school and
     parents will build and develop a
     partnership to help children achieve the
     state’s high standards.                    25

District-Level
                    Parent Notification
• Written Parental Involvement Policy
   [Section 1116(a)(1)(C), (c)(1)(B)]
• Annual Report Cards
  [ESEA Section 1111(h)(1) and (2), Parent Involvement Guidance, B-5 (State) and C-7 (District)]
• Progress Review
  [ESEA Section 1116(a)(1)(C), (c)(1)(B) and (c)(6), Parent Involvement Guidance, B-7 (State) and
  C-20 (District)]

• Written Citizen Complaint Procedures
   [Chapter 392-168 WAC Special Services Programs-Citizen Complaint Procedures for Certain
   Categorical Federal Programs]

• Parents’ Right to Know-Teacher and Paraprofessional Qualifications
   [ESEA Section 1111(h)(6)(A) and (B)(i)]

                                                                                                    26

School (Building) Level Parent
                   Notification
• Written Parental Involvement Policy
  [ESEA Section 1118(a)(2) and (b)(1), Parent Involvement Guidance, C-3 and C–4 (district), and D-1
  (school)]

• Parents’ Right to Know
  – Student Achievement
  – Non-Highly Qualified Teacher(s)
 [Section 1111(h)(6)(B)(i), ESEA and Section 1111(h)(6)(B)(ii), ESEA.]

• School-Parent Compact
 [ESEA Section 1118(d)], Parent Involvement Guidance D-8]

• Individual Student Assessment
 [ESEA Section 1111(h)(6)(B)(i), Parent Involvement Guidance, D-10]

                                                                                                      27

Allowable Parent Involvement
               Activities
Allowable Parent Involvement Activities and Associated Costs under Title I,
Part A
• Pursuant to the mandates of Title I, Part A, Sec. 1118(e), districts
  shall provide a broad range of services to parents to help them
  more effectively support and assist their students to succeed in
  school.
• These services are reasonably broad in scope, but are generally
  linked to parent education and training, parent participation in
  school-related meetings, and parent inclusion in the education of
  their student(s).

                                                                              28

Allowable Parent Involvement
              Activities
•   The following list of allowable parent involvement activities (costs) is not
    complete, but is typical. These may be charged to Title I, Part A funds
    provided they have been determined to be reasonable, necessary, and
    allocable to Title I, Part A and do not supplant other funds.
      Transportation and child care costs, as needed, to facilitate parent attendance at
       meetings and training sessions.
      Meals or refreshments to accommodate parent attendance at parent involvement
       meetings and trainings that interrupt or conflict with family meals/schedules.
       Snacks may be provided as a means to encourage attendance at parent
       involvement events, but are only allowable to the extent that they are shown to
       increase participation. Title I, Part A funds may not be used to provide
       refreshments or snacks for staff meetings irrespective of a meeting’s purpose.
       Working meals for staff are allowable to the extent that they increase
       productiveness and no other scheduling option is viable.

                                                                                       29

Allowable Parent Involvement
                Activities
Continued…
     Registration and travel costs for parent representatives or committee
      members to attend in-state workshops and conferences that support
      parent education and involvement strategies to be shared with other
      parents.
     Translation and interpretation services for parents to have access to
      school related information in a format and language they can
      understand.
     Unavoidable facilities cost associated with the conduct of parent
      involvement activities.

** Note: Gifts and incentives are not allowable costs under Title I, Part A (WA
    State Constitution: Article 8, Section 5 and 7).

                                                                              30

Resources
• Guidance
  Parent Involvement Non-Regulatory Guidance
  Federal Programs Parent Involvement Requirements
• Samples
  WSSDA District Parent Involvement Policy Sample
  School Parent Involvement Policy Sample
  School-Parent Compact Sample
  District-School Requirements Side-by-Side
  District-School Key Parental Notifications
• Models
  National Network of Partnership Schools
  Family and Community Partnership-Federal Way
   Public Schools                                   31

Private School Requirements

                              32

Private School Participation

• If the Title I, Part A program is available to
  the public school district students and
  teachers, then the opportunity is available
  to private school students and teachers on
  an equitable basis.

   NCLB  Section 1120 – Participation of Students
    Enrolled in Private Schools
   34   CFR 200.62-67
                                                     33

Private School Requirements
• ESEA requires equitable services to eligible
  private school students and their parents and
  teachers.

• Consultation with private schools must occur
  before decisions are made about the services
  and programs to be offered.

• Needs of private school students, parents, and
  teachers are determined separately from
                                                  34

Consultation
• Consultation between the school district and
  private schools occurs during the design and
  development of the services.
    Must be timely and meaningful.
    Must take place on an annual basis, and be documented by
     the district: sign in sheets, agenda, written affirmation.
    Must continue throughout the year, to ensure the needs of
     private school students are being met.

                                                              35

Funding and Services
• Private School Allocation
     Generated  by the number of private school, low-
      income students residing in Title I, Part A-served
      public school attendance areas.

•   Eligible Private School Student
     Resides in a participating Title I, Part A public
      school attendance area.
     Selected on academic need. [34 CFR 200.62]

•   Title I, Part A Services                               36

Private School Participation
• Examples of Services
  Instructional services outside the regular classroom.
  Extended learning time (before/after school and in the summer).
  Family literacy programs.
  Counseling programs.
  Early childhood.
  Home tutoring.
  Computer-assisted instruction.
                                 [Non-Regulatory Guidance B37 & B38]

                                                                  37

Rules of Service Delivery
 All services are provided by and under the
  control and supervision of the school district.
 Services for private school children must begin
  at the same time as services for public school
  children.
                          [Non-Regulatory Guidance B39 & B40]

                                                           38

Rules of Service Delivery
 The school district maintains control of all
  materials, supplies, equipment, and property
  acquired with Title I, Part A funds for the
  benefit of eligible private school students.
                                    [34 CFR 200.67]

 Key word is services. No public funds are
  distributed to private schools, only services
  and materials.
                             [Non-Regulatory Guidance B-28]
                                                         39

Monitoring School Districts – Consolidated
            Program Review (CPR)

• School districts are monitored on a
  regular cycle and/or combination of “risk
  factors” to select school districts.

• 2013-14 School Year:
     Northwest ESD 189 (Anacortes)
     ESD 123 (Pasco)
     Seattle, Tacoma, Spokane, Evergreen (Clark County)
     Up to ten selected districts from throughout the
      state
                                                           40

Monitoring School Districts
• CPR Trainings
    Oct. 2, Northwest ESD 189
    Oct. 9, ESD 123
    Oct. 16, Webinar

• Monitoring conducted onsite or as a desk review.

• Move by the United States Department of Education for
  states to monitor for results.
    Evidence-based  or outcome based.
    Yes, the program is in compliance, but is it
     making a difference and is there data to             41

Allocations and Set-Asides

                             42

Title I, Part A Allocations

• Complex 4-Part Formula
    1. Basic
    2. Concentration
    3. Targeted
    4. Education Finance Incentive Grants (EFIG)
• Based on counts of students
     Poverty data from Census
     Children in neglected or delinquent institutions
     Children in foster care and in families receiving Temporary Assistance to
        Needy Families (TANF)
•   District 2013-14 allocations, calculations, and three years of history are
    available at http://www.k12.wa.us/SAFS/13budprp.asp

                                                                            43

School Allocations Overview
• Determine district set-asides.
• Determine individual school poverty rates.
• Determining which schools will be served:
  Ranking and serving rules
  125 percent rule
  Exceptions
• Distribute funds to schools.

                                               44

Ranking and Serving Rules

• Rank order all schools in the district by
  poverty percentage.
• Must serve all schools at or above 75
  percent poverty.
• Must serve other schools in rank order,
  from highest to lowest, all above district
  poverty average or 35 percent; or
• May serve other schools ranked in a grade
  span grouping.                               45

Ranking and Serving Rules (cont.)

• Schools served in rank order may be funded at different per pupil
  expenditures (PPEs) as long as each higher poverty school’s PPE is greater
  than or equal to next lower ranked school.
• Schools may be served down to 35 percent poverty or district-wide
  average poverty if less than 35 percent. Below 35 percent requires that
  every served school must have a PPE that is not less than 125 percent of
  the district-wide PPE (total district Title I, Part A allocation divided by total
  low income children = district-wide PPE).
• School PPE must be large enough to ensure that the school can operate a
  Title I, Part A program of sufficient quality to assist struggling students to
  meet academic achievement standards.

                                                                                 46

Special Rules

• Small districts may serve any school(s) if:
  Single attendance area (a one-school district or one school per
    grade span), or
  District enrollment of

District Set-Asides
•   Set-asides are amounts used at district level before allocating funds to schools;
    some are required, others are optional.
•   Required Set-Asides
     Parent Involvement: One percent of district’s allocation for districts receiving
        over $500,000 of which 95 percent must be allocated to schools.
     Homeless Children: Funds as are necessary to ensure that homeless students
        receive services that will enable them to be successful in school.
     Neglected Children: Funds needed for services to provide educationally-related
        support services to children in local institutions for neglected students.
     Private Schools: Funds reserved for educational services for eligible students
        attending private schools, within the district and outside of the district.

                                                                                    48

District Set-Asides (cont.)
• Optional Set-Asides
   Priority, Focus, and Emerging Title I, Part A Schools: District may
    reserve up to 20 percent of its Title I, Part A allocation to ensure that
    identified schools receive sufficient resources and support to
    implement interventions that are aligned with their improvement
    plans.
   Administration: Funds to cover costs of Title I, Part A program
    management, including budgeted indirect costs.
   Preschool Program(s).
   Professional Development.
   Parent Involvement activities that are in addition to the required set-
    aside.

                                                                                49

Supplement Not Supplant
            Presumption of Supplanting
• The district has used the Title I, Part A funds to
  provide services that the district was required
  to make available under federal, state, or local
  law.
• The district used Title I, Part A funds to
  provide services it provided with non-federal
  funds in the prior year(s).
• The district has used Title I, Part A funds to
  provide services for participating children that50

Supplement Not Supplant
• To rebut presumption show:
   Fiscal or programmatic documentation to confirm
    that, in the absence of federal funds, the
    staff/services in question would have been
    eliminated.
   State or local legislative action.
   Budget histories and information.

                                                      51

Grant Period

• Title I, Part A funds are “27 months” money.
• Federal FY 2013 funds:
   July 1, 2013 – September 30, 2014 (1st grant period).
   October 1, 2014 – September 30, 2015.
• No more than 15 percent of the Title I, Part A allocation
  may be carried forward to the next FY.
   States may approve an exception once every three
      years.
• States must return unobligated funds to the federal
  government.

                                                              52

Allowable Expenses
• All costs must be:
  Allowable under grant requirements.
  Necessary and reasonable.
  Allocable (proportionate to program).
  Legal under state and local law.
• OMB Circular A-87: State, Local and Indian
  Tribal Governments (2 CFR Part 225).
• OMB Circular A-133: Compliance Supplement.
                                           53

Fiscal: Three Key Requirements

•   A school district must:
     Maintain fiscal effort with state and local funds (Sections 1120A(a) and
        9521 of ESEA; 34 CFR 299.5).
     Provide services in its Title I, Part A schools with state and local funds that
        are at least comparable to services provided in its non-Title I, Part A
        schools (Section 1120A(c) and (d) of ESEA; 34 CFR 200.79).
     Use Title I, Part A funds to supplement, not supplant regular non-federal
        funds (Section 1120A (b) and (d) of ESEA; 34 CFR 200.79).
•   Maintenance of effort calculation done by OSPI, Apportionment and Financial
    Services using F-196 expenditure data. Failure to maintain effort in the prior
    year will result in a percentage reduction of new year ESEA grant allocations
    equal to the percentage by which district failed.

                                                                                   54

Time and Effort

• Time and effort reporting is required
  when any part of an individual’s salary is
  charged to a federal program.
  Single cost objective     Semi-annual
    certification.
  Multiple cost objectives Monthly
    time reports or Personnel Activity
    Reports (PARs).
• OMB Circular A-87.                           55

Title I, Part A Changes on the Horizon

 • Waiver of Title I, Part A 15% carryover funds limitation ends
   with school year 2012-13. (2012-13 carryover into 2013-14
   may exceed 15%)

 • United States Department of Education is considering
   changes to Title I, Part A comparability reporting –
   potentially eliminating comparison of school student-to-
   staff ratios for compliance and instead mandating
   comparability based on non-federal funding levels from
   school to school.

                                                                   56

Title I, Part A Changes on the
              Horizon

• The federal Office of Management and
  Budget released “Proposed OMB
  Uniform Guidance: Cost Principles,
  Audit, and Administrative Requirements
  for Federal Awards.” Frequently referred
  to as the Supercircular, many significant
  changes are proposed (particularly
  noteworthy are revised audit thresholds,
  time and effort documentation,              57

OSPI Title I/LAP Contacts

•   Title I, Part A/LAP Program Director
     – Gayle Pauley, gayle.pauley@k12.wa.us, 360.725.6100

   Title I, Part A/LAP Program Supervisors
    – Bill Paulson, bill.paulson@k12.wa.us, 360.725.6104
    – Jody Hess, jody.hess@k12.wa.us, 360.725.6171
    – John Pope, john.pope@k12.wa.us, 360.725.6172
    – Larry Fazzari, larry.fazzari@k12.wa.us, 360.725.6189
    – Mary Jo Johnson, maryjo.johnson@k12.wa.us, 360.725.6103
    – Penelope Mena, penelope.mena@k12.wa.us, 360.725.6069

   Title I, Part A/LAP Support Staff
    – Julie Chace, julie.chace@k12.wa.us, 360.725.6167
    – Tony May, tony.may@k12.wa.us, 360.725.6231                58