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The April newsletter is dedicated to questions that were raised during regional meetings.
Question 1: Can the Title I set-aside for homeless be used for preschool students? What about preschool students who are being home-schooled?
Answer: The Title I set-aside can be used to support homeless students enrolled in public preschool. For example, if your district has a preschool program, federal funds can be used to support the participation of the homeless students in that program. Districts that receive the McKinney-Vento grant may also use part of their grant funds for this purpose. A school's preschool program may use both McKinney-Vento and Title I set-aside funds to leverage funds to the maximum amount possible.
Since Kentucky provides for preschool for 4-year-old children based on income, schools would use the Title I set-aside differently for students who are 4 years old and those who are 3 years old.
Since districts receive state funds for 4-year-olds to participate in the preschool program (e.g., at-risk and/or disabilities), the district would need to consider the supplement-not-supplant requirement to make sure these state and local funds are not being replaced by Title I funds.
The district would be able to cover more of the costs affiliated with a homeless 3-year-old participating in the program with the Title I set-aside since the state does not provide funding for these students’ participation in preschool programs. The supplement-not-supplant requirement would need to be met for a 3-year-old in the preschool who is there in order to meet requirements under IDEA.
Districts cannot use the Title I homeless set-aside for home-schooled students, as home schools are considered private schools.
Question 2: If one school uses all Title I funds for staff and another school doesn’t use any for staff, will this cause the district to be unable to demonstrate comparability for the required comparability report?
Answer: Title I staff salaries should not affect comparability, because those paid with federal funds are excluded from staffing counts for comparability purposes. The comparability report instructions state the following about staff to be excluded:
The following instructional staff must be excluded for comparability purposes:
- Instructional staff paid from any federal funds, such as Title I-funded teachers and paraeducators/instructional assistants, Title II funded teachers to reduce class size, Title III funded staff, staff funded through IDEA, et cetera.
Question 3: Will adding another teacher or instructional staff member for a Comprehensive Support and Improvement (CSI) school for school improvement cause the district to be unable to demonstrate comparability for the required comparability report?
Answer: See the answer to the question above. If the staff member is hired with federal school improvement funds, the exclusion provision applies. Additional staff members hired through state or local funds might have some effect on comparability. Depending on the district, there may be options for how to assign schools into size groupings that might help alleviate any issues. Districts should consult with their KDE Title I consultants in these situations.
Question 4: On the GMAP application, are FTE and headcount supposed to match?
Answer: The Help for Current Page in GMAP states, “Headcounts and FTEs may not match.” In addition, if a headcount is reported the FTE must be greater than zero, and vice versa. For example, if one person is working half time, the reporting would be represented as follows:
Question 5: Can Title I pay for required textbooks?
Answer: Yes, if certain conditions are met. First, schools that operate schoolwide programs have flexibility in how they spend their Title I funds. The textbooks would have to address needs identified in the schools’ needs assessments and be documented in their CSIPs, and the purchase would have to be approved by their SBDM councils.
The supplanting test for Title I, Part A has changed from a focus on individual costs to a methodology (ESSA Section 1118). However, supplanting could still occur at the district level if the district purchased the textbooks using state and local funds for non-Title I schools and required Title I schools to use their Title I dollars to purchase the textbooks. In order to avoid supplanting, the district could 1) purchase the books for all schools using state and local funds or 2) allocate state and local funds to all schools in the district using a Title I-neutral methodology, ensuring all schools get all the state and local funds and staff they are due. Then the district would allocate Title I dollars to Title I schools according to rank and serve requirements. The schools’ SBDM councils could then use the Title I funds for the books or for other purchases.
Aside from concerns about supplanting, the expenditure would still have to be allowable. In evaluating whether the use of Title I funds is allowable, it is necessary to take into account the overall purpose of the Title I program, which is to improve the academic achievement of low-achieving students in schools with high concentrations of children from low-income households. The cost also must be reasonable.
Question 6: Can Title I now pay for required assessments (e.g., Star Math, Star Reading)?
Answer: See the answer to the previous question. There would be some additional concerns about the allowability of the purchase of assessments with Title I funds. Administering an assessment by itself does not improve the academic achievement of low-achieving students and would not be an allowable use of Title I funds. However, using the data from the assessment to improve instruction, identify students for supplementary tutoring and other strategies might improve academic achievement. The district would have to successfully justify and explain how the data from the assessment would be used to increase student learning.
Question 7: Do CSI schools have to follow maximum class sizes or can they allocate as they want?
Answer: Under KRS 160.346(7)(b), the authority of the school council granted under KRS 160.345 is transferred to the superintendent. Staffing requirements under KRS 157.360 do not change when the authority is transferred.
Question 8: When foster children are discussed in regard to Title I funding, does it only pertain when a district has a facility?
Answer: The Title I provisions for educational stability apply to all children in foster care enrolled in public schools in Kentucky, as defined within Title I as those ages 21 and under who are entitled to a free public education through grade 12. The non-regulatory guidance defines foster care as “24-hour substitute care for children placed away from their parents or guardians and for whom the child welfare agency has placement and care responsibility. This includes, but is not limited to, placements in foster family homes, foster homes of relatives, group homes, emergency shelters, residential facilities, child care institutions, and preadoptive homes.” Therefore, the Title I provisions need to be followed for all students in foster care enrolled in public schools in the district.
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