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“Winter is the season of recovery and preparation.”
- Paul Theroux
And somehow, just like that, winter has come. May this holiday season be a time of rest and recovery, a season of renewal and preparation for the road ahead. We wish you a safe, healthy and peaceful holiday!
Spending of Parent and Family Engagement and Private School Services Funds
December is a great time to review district- and school-level spending for parent and family engagement and private school services.
Districts with a Title I, Part A allocation of $500,000 or more are required to reserve at least 1% of funds for parent and family engagement under ESSA 1116(3)(A). Question D-13 of the Title I Fiscal Issues Non-Regulatory Guidance states that if a district is required to spend a specific amount of its Title I, Part A allocation in a given year for a particular purpose, the district must meet that obligation. If it does not do so in the year for which funds were allocated, it must carry over the unspent funds and spend them for the specific purpose in the following year. Simply put, funds reserved for parent and family engagement cannot be redistributed for other purposes.
Parent and family engagement funds carried over do not affect the amount of money the district is required to reserve for parent and family engagement in the following year (see question D-16). The 1% reservation for parent and family engagement must be met regardless of any carryover funds a district may have.
ESSA 1117(a)(4)(B) states that funds allocated for educational services and other benefits to eligible private school children shall be obligated in the fiscal year for which the funds are received by the agency. The amount of funds generated for providing services to private school students is calculated to ensure equity between public and private schools and cannot be altered. Districts may not decrease the amount of funds generated by private schools to account for carryover funds.
Funds in these categories should be spent in the school year for which they are appropriated in order to serve the students and families present within the district and private school that year. Stopping mid-year to evaluate spending in each of these categories and revising plans, if necessary, to ensure the funds are spent down by the end of the school year is a beneficial activity for coordinators in this season.
Private School Cost of Equitable Services Administration Reminder
Don’t forget, if a district reserves funds for the salary and benefits of a Title I coordinator to support the administration of services at private schools, administrative costs for the provision of equitable services must be paid from the funds reserved for non-public schools. Since this reduces the amount available for direct services, an LEA must discuss this reservation during consultation with non-public school officials.
A district must charge administrative costs when a Title I, Part A-paid staff member oversees all or a portion of equitable services during their Title I-paid time. In this case, the person would be paid an amount from the equitable service reservation that is proportionate to the amount of time they spend providing such oversight, including consultation meetings, visits to the school to observe program implementation, etc.
The reason for this is equitability. The private school allocation is calculated off the top of the total Title I, Part A award, which effectively creates two “pots” of money – one for the district and public schools and another for private school services.
Expenses related to overseeing equitable services at the private school should be taken from the private school monies. If a coordinator is paid 100% from Title I, Part A district set-aside funds but spends 10% of their time overseeing equitable services, that means funds intended for the district and public schools are being used for private school students. In order for this scenario to be equitable, 10% of the coordinator’s salary should be charged to the private school budget for the administrative cost of equitable services.
The need for this reservation depends on staff member’s duties during their Title I-paid time. Consider a Title I coordinator paid 40% from Title I and 60% general funds who spends 10% of their time administering the equitable services. In this instance, the requirement for charging administrative costs would depend from where that portion of time is paid.
If time paid for equitable services administration is paid from Title I, that portion of the person’s salary must be charged to the equitable services reservation. If time paid for equitable services administration is paid from general funds rather than Title I, there is no equitability issue as no Title I funds intended for public schools are being used for students at the private school. If equitable services administration is being paid from general funds, the district may charge a proportionate amount to the equitable services reservation, however, it is not required.
The May Title I Webinar covers additional guidance regarding the charge of administrative costs for the oversight of equitable services.
Monitoring Update
Consolidated monitoring notifications were sent to 10 districts. Monitoring will begin in January 2021.
The district consolidated monitoring checklist, the schoolwide program consolidated monitoring checklist and the targeted assistance program consolidated monitoring checklist are used in the consolidated monitoring process to evaluate compliance and effectiveness of Title I, Part A activities.
Additionally, 10 districts were notified of their selection for Title I desk monitoring. These districts have been submitting evidence and Kentucky Department of Education Title I consultants soon will begin reviewing the documentation. The desk monitoring checklist is used in the desk monitoring process for the evaluation of Title I, Part A activities.
Whether selected for monitoring or not, Title I coordinators can use these checklists to self-assess and monitor their programs and ensure they are keeping documentation to address each of the monitoring indicators.
Coordinator's Year at a Glance - Suggested Tasks for December
The day-to-day activities and many hats you wear may make it challenging to keep up with tasks in the Title I world, especially as this school year progresses differently from any other school year you have had. As a reminder, the following activities should be taking place sometime this month:
- Monitor implementation of schoolwide parent and family engagement activities.
- Ensure that methodology regarding supplement, not supplant, is on file at the district, if applicable.
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