"Sweet April showers do spring May flowers."
― Thomas Tusser
The culmination of all fruits of effort and labors of love are in full bloom in May. As you wrap up the school year, take time to really enjoy the positive outcomes that your students and school communities have displayed this year. Growth is beauty!
The Bruman Group Training Registration
The Kentucky Department of Education (KDE) is pleased to offer a statewide federal programs training at no cost to school districts on June 13-15 at the Central Bank Center in downtown Lexington. The same content is being offered three different days.
The training will be provided by The Bruman Group (formerly Brustein and Manasevit). This legal firm is nationally recognized for its federal grants management and education regulatory and legislative practice.
We strongly encourage the district superintendent, finance officer and federal program coordinator to attend. We will re-engage with some of the same topics from the fall 2022 training, but also will concentrate on new training needs that have emerged during monitoring.
To register for this training, please complete the Bruman Group Training registration form. Although registration will remain open until the training, space is limited, so please register early to secure a spot for your preferred date. Attendees must register individually.
Please mark your calendar for your first and second choice dates. We will follow up with all registrants in the coming weeks to confirm the day they have been scheduled for and provide additional details about the day.
If you indicated you would be interested in a hotel room, KDE will follow up with you individually (if we are able to provide them). If you need to change or cancel your registration, please contact Leslie Bridges.
Reviewing and Revising School Parent and Family Engagement Policies and Compacts
This is the time of year when many schools begin reviewing school policies and compacts and, if needed, making changes to those documents to meet the changing needs of the school. Schools should address any feedback received from families – either at the school or district level – on parent and family engagement practices. Sharing district-level feedback is essential to your principals in completing this activity.
Beyond that, you will want to share the Effective School Parent and Family Engagement Policy Checklist and Effective School-Family Compact Checklist to help schools ensure their documents meet the requirements of the Every Student Succeeds Act (ESSA). Information surrounding policy and compact requirements was covered in the March 2023 Title I webinar.
It is essential to remember that the policy should guide the parent and family engagement work at your schools and in your district. ESSA 1116(b)(1) requires school policies to describe the means for carrying out the requirements of ESSA 1116(c) – (f). A policy stating that the school will meet the requirements without a description of the specific activities and strategies the school will use would not be in compliance with ESSA. The policy should outline the strategies you will use to engage families. Your parent and family engagement funds should be used to accomplish the activities your school or district pledged to do in the policy.
Wrapping Up Equitable Services for Participating Private Schools
ESSA 1117(a)(4)(B) requires districts to obligate funds for equitable services in the fiscal year the funds are received by the local educational agency (LEA). This means there should be little to no carryover of equitable services funds at the end of the fiscal year.
Question B-27 of the Providing Equitable Services to Eligible Private School Children, Teachers, and Families Non-Regulatory Guidance lists the following scenarios in which an LEA may encounter carryover of funds for equitable services and how the funds could be used in each scenario:
- Equitable services for private school students are delayed due to natural disaster, delayed consultation, lack of qualified personnel or unexpected procurement challenges, resulting in an inability to provide equitable services or obligate funds by the end of the fiscal year. In this case, the U.S. Department of Education (USED) says the LEA must use funds to provide equitable services to eligible children in the affected schools the following year.
- A third-party equitable services provider contracted by the LEA submits an invoice for services in a private school for less than anticipated and late in the summer, limiting the LEA’s ability to responsibly obligate funds by the end of the fiscal year. In this case, the LEA must consult with private school officials and use the funds to provide equitable services to children in the affected private school the following year. However, if services are declined by private school officials, the LEA must add the funds to the proportional share for equitable services provided by other private schools. If there are no other participating private schools, the LEA can use the funds to provide Title I services to public school students.
In summary, the guiding rule is that equitable services funds must be spent in the fiscal year the funds are received by the LEA; any exceptions to this rule should be extremely rare. Although ongoing consultation should prevent funds from not being obligated in a timely manner, there are scenarios in which action by the private school is necessary for obligation to occur. The example given in Question B-31 of the non-regulatory guidance is teachers attending a professional development session. The guidance states that the LEA may establish a deadline by which the private school must obligate funds during the consultation process. If the deadline is not met and the private school has not discussed obstacles to meet the deadline during the consultation process, the LEA may consider the private school to have declined services.
As a reminder, private school officials do not have the authority to obligate or receive Title I, Part A funds (see Question C-26). ESSA 1117(d)(1) requires the LEA maintain control of all Title I funds, materials, equipment and property. This means that no Title I funds may be paid to a private school, including as reimbursement for allowable Title I expenditures.
The district should have a process in place for safeguarding assets purchased with Title I funds for use with participating private school students. This process will prevent loss, theft and damage, as well as ensure materials are not used for unauthorized purposes. For example, the district may work with the private school to create an inventory and determine where items such as technology devices will be housed during the summer. KDE’s Safeguarding Assets Purchased with Title I Funds can be used when developing the process.
House Bill 32 and Paraeducator Requirements
On March 22, Gov. Andy Beshear signed House Bill 32 into law. The bill amends KRS 161.011 to allow for the hiring of classified personnel without a high school diploma or equivalent if the district provides the employee the opportunity to obtain a high school equivalency diploma at no cost to the employee. It also allows licenses or credentials issued by a government entity to substitute for the requirement.
It is important to note that this does not negate the requirements for paraeducators (also called paraprofessionals) working in schools operating Title I schoolwide programs or paraeducators paid fully or in-part with Title I funds working in schools operating targeted assistance programs. ESSA 1111(g)(2)(J) requires all teachers and paraprofessionals working in a program supported with Title I funds to meet applicable state certification and licensure requirements.
34 CFR 200.58(b) states that all paraprofessionals providing instructional support services working in a program supported with Title I funds must have earned a secondary school diploma or its recognized equivalent. Additionally, paraprofessionals working in a program supported with Title I funds must meet the following educational requirements per 2 CFR 200.58(c):
- Completed at least two years of study at an institution of higher education;
- Obtained an associate (or higher) degree; or
- Met a rigorous standard of quality and can demonstrate, through a formal state or local academic assessment, knowledge of and the ability to assist in instructing, as appropriate:
- Reading/language arts, writing and mathematics; or
- Reading readiness, writing readiness and mathematics readiness.
The assessment used in Kentucky to demonstrate the abilities outlined in #3 above is the Kentucky Paraeducator Assessment (KPA). Additional information about the KPA is available on the Paraeducator Requirements in Title I Schools webpage.
The requirements for paraeducators also are outlined in Question B-1 of the Title I Paraprofessionals Non-Regulatory Guidance. Any paraeducator working in a program supported with Title I funds who has been hired since Jan. 8, 2002, must meet these requirements. Paraeducators hired prior to Jan. 8, 2002, were given until Jan. 8, 2006, to meet the requirements. 2 CFR 200.58(e) notes that paraprofessionals who only serve as translators or conduct parent and family engagement activities are not required to meet the additional educational requirements.
As a reminder, paraeducators provide instructional support services under the direct supervision of a certified teacher. Paraeducators should not be providing planned direct instruction or introducing students to new skills, concepts or academic content per Question A-2 of the non-regulatory guidance.
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