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“If you are going to achieve excellence in big things, you develop the habit in little matters. Excellence is not an exception; it is a prevailing attitude.”
– Charles R. Swindoll
August is here, which means we are back to our routines associated with the school year. What daily habits will you establish this year to maintain your programs with excellence?
Important Announcements from the Commissioner's Office
Several items related to Title I, Part A have appeared in recent emails from the commissioner’s office. The following are summaries of the announcements; links to the original messages also have been provided.
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Kentucky’s Every Student Succeeds Act (ESSA) Waiver Request Approved: The U.S. Department of Education (USED) has approved KDE’s request to waive program requirements under the Elementary and Secondary Education Act of 1965 (ESEA). This approval waives the requirement that limits KDE’s ability to grant to its local education agencies (LEAs) a waiver of the 15% Title I, Part A carryover limitation to once every three years for school year 2021-2022 Title I, Part A funds. The waiver also allows KDE to extend the period of availability of school year 2020-2021 (Project G) funds for Title I, Part A and several other programs until June 30, 2023. See the June 27, 2022, Commissioner’s Monday Message for the full article.
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Waiver Granted for Carryover Limitation of 2021-2022 School Year Title I, Part A (Project 310I) Funds: Due to impacts resulting from the COVID-19 pandemic, USED has granted KDE a waiver of the 15% carryover limitation requirement of section 1127(b) of the Every Student Succeeds Act. This approval allows KDE to grant a district’s carryover request more than once every three years. Districts that took the waiver within the previous three years could take it again if needed. Districts should be advised that if they take the waiver this year, they might not be able to take it again within the next few years. Any district wishing to request a carryover waiver for 2021-2022 funds may do so no later than Sept. 30, 2022, by following the instructions outlined in the June 27, 2022, Commissioner’s Monday Message.
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Title1Admin® Subscription for All Districts: KDE is providing every school district in the state with a subscription to Title1Admin for the 2022-2023 school year. District coordinators should have received an email from Theresa Harr of LRP Media Group regarding the licensure agreement and a staff access list spreadsheet, which must be returned to Theresa in order to begin receiving weekly emails and access the online resources. See the June 27, 2022, Commissioner’s Monday Message for the full article.
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Flexibility for Data Used to Rank and Serve Schools Under Title I, Part A Offered: ESSA 1113(a)(3) requires a district to rank all its schools according to their percentage of public school students from low-income families. To the extent that National School Lunch Program (NSLP) data from school year 2020-2021 and 2021-2022 are not available, districts may benefit from flexibility offered to determine within district allocations for Title I, Part A. For the 2022-2023 school year, districts have the flexibility to use data from the 2019-2020, 2020-2021 or 2021-2022 school years for the purposes of ranking and serving schools under Title I, Part A. See the July 5, 2022, Commissioner’s Special Tuesday Message for the full article.
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Registration Open for 2022 Continuous Improvement Summit: The annual Continuous Improvement Summit presented by KDE and Cognia™ is scheduled for Sept. 26-27 at the Central Bank Center in Lexington. Details about the summit and a registration link are available in the July 5, 2022, Commissioner’s Special Tuesday Message.
Avoid Handing Direct Title I Funding or Equipment Ownership to Private Schools
When providing equitable services to private schools under Title I, Part A, local educational agencies (LEAs) must refrain from disbursing funds or ownership of equipment directly into the hands of private school officials.
As the new school year approaches, the question of who controls the Title I, Part A resources directed toward private schools remains timely. The answer: Control of funds used in the provision of equitable services under Title I, Part A and the title to equipment, materials and property purchased with those funds must remain within a public agency (ESEA Section 1117(d)(1)).
While an LEA can provide services in instruction, evaluation, special education, counseling, mentoring and one-on-one tutoring to private schools, it cannot hand over the money to the private school to purchase these services. Likewise, computers, mobile educational technology, and radio and television materials can used in providing equitable services to private schools, but the public agency must retain ownership (ESEA Section 1117(a)(1)(A)).
Non-regulatory guidance emphasizes that private school officials have no authority to receive or obligate Title I funds and therefore, funds cannot be used to pay private schools, not even as a reimbursement.
If an LEA contracts with a third-party (including religious organizations) to provide equitable services, the LEA must still be the party to control funds and equipment, according to the guidance. While the non-regulatory guidance states LEAs may provide equitable services to religiously affiliated private schools, ESEA Section 1117(d)(2) requires providers of equitable services be independent of the religious organization or private school.
Brustein & Manasevit Training Registration
Registration for the statewide federal programs training provided by Brustein & Manasevit is still open. The training is being held Sept. 20-22 at the Central Bank Center in Lexington and is being provided at no cost to school districts. The same content is being provided each day, so attendees should select one day they plan to attend.
The training will benefit district staff who are responsible for oversight and administration of federal education programs and compliance with legal requirements. Superintendents, finance officers and federal programs coordinators are strongly encouraged to attend. Registration for the federal programs training is available online.
If you have registered for the training, you will receive an email in the next few weeks to confirm your training date and provide additional details. We also will be communicating with district staff who requested a hotel room.
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