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"Give me six hours to chop down a tree and I will spend the first four sharpening the axe.”
― Abraham Lincoln
The importance of honing our skills and fully utilizing the resources available to us cannot be overstated. We must dedicate time to refining our abilities and preparing ourselves for challenges.
By investing in our personal and professional development, we equip ourselves to tackle any obstacle with confidence. Preparation is not merely a step in the process – it is the foundation upon which all achievement is built.
 Participants at the federal education programs training in Lexington received valuable information on program requirements. Photo by Erin Sudduth, Sept. 10, 2024.
Statewide Federal Programs Training Summary
The Kentucky Department of Education (KDE) hosted a statewide federal programs training on Sept. 10-12 at the Central Bank Center in Lexington.
Federal program coordinators, finance officers and superintendents from more than 100 districts received timely updates from Bonnie Graham and Kelly Christiansen from The Bruman Group. The Bruman Group (formerly Brustein & Manasevit) is a legal firm that is nationally recognized for its federal grants management and education regulatory and legislative practice.
Graham and Christiansen shared information regarding recent updates to the Uniform Grant Guidance (UGG) and Education Department General Administrative Regulations (EDGAR), procurement, American Rescue Plan Act Elementary and Secondary School Emergency Relief (ARP ESSER) closeout and several other topics. Attendees asked questions surrounding procurement, purchases made through educational cooperatives and the date of obligation for services provided through a contractor. The training ended with tips to help districts prepare for audits.
Thank you to everyone who submitted suggested topics prior to the training, joined us in Lexington and provided valuable feedback!
In Case You Missed It: Avoid Handing Direct Title I Funding or Equipment Ownership to Private Schools
In June 2022, ESEANow (then known as Title1Admin) featured an article titled, “Avoid Handing Direct Title I Funding or Equipment Ownership to Private Schools” that highlighted the requirement for the district to maintain control of funds generated for equitable services as well as items purchased with those funds. Revisiting this article at the beginning of the school year can provide helpful reminders to districts as they begin providing services to participating 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.
A lack of timely spending of funds reserved for equitable services is sometimes a finding during monitoring. In interviews with district staff, Title I staff may hear that the private schools have not spent down “their money.” This opens the door for us to have an important conversation about a mindset shift. Funds reserved as a proportionate share to administer equitable services, as well as the title to equipment, materials and property purchased, don’t belong to the private school and must maintain their identity and control and the district level per Section 1117(d)(1) of the Every Student Succeeds Act (ESSA).
The LEA and participating private schools determine what services to provide during the initial consultation meeting. This may include one-on-one tutoring, counseling programs, expanded learning time or professional development (see question C-15 of the Equitable Services Non-Regulatory Guidance for additional services available to participating private school students).
The LEA is responsible for arranging and providing services, whether through district staff or a third-party contractor. The LEA cannot hand over the money to the private school to purchase these services. Similarly, the LEA must order any supplies for the private school; the private school cannot order materials or resources since this would create an obligation to pay and private schools have no authority to obligate public funds.
The LEA retains ownership to any non-consumable supplies (computing devices, books and resources), equipment and property. 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 (see question C-26).
Reviewing expenditures to ensure the timely spending of funds should be part of the ongoing consultation meetings between the district and private school. If funds are not being spent timely, both parties should discuss the cause. For example, if the consultation agreement includes a plan to hire a certified teacher to provide after-school tutoring for participating students but the district has not been able to fill the position, it may be necessary to re-evaluate the plan and make adjustments to ensure funds are spent.
There are instances in which action by private school officials is necessary for the district to obligate funds. For example, the teacher of participating students may need to provide the district with information in order to register for an approved conference. The LEA may impose reasonable deadlines on private school officials to ensure the obligation of funds requirement is met (see question B-31). These deadlines should be clearly communicated with private school officials.
Principal's Perspective: Discussing the Compact at Elementary Conferences
Obtaining signatures on school-family compacts is likely embedded into your beginning of the year registration activities. But too often, those compacts get signed and filed away, and never referred to again. Parents, students and teachers can all benefit from periodically revisiting the commitments made at the start of the school year.
ESSA 1116(d)(2)(a) requires that the school-family compact be discussed as it relates to the individual child’s achievement during at least one elementary parent-teacher conference each year to help parents connect their home responsibilities to their child's academic progress. For example, if a student is struggling with reading, conference time is an ideal opportunity to revisit the compact. This opens the door for a conversation with the family to ensure all parties are meeting the agreed-open responsibilities in the compact to ensure the student’s academic success. Teachers might ask whether additional support at home is needed to meet reading goals and fulfill the commitments outlined in the compact.
Failure to discuss the school-family compact during the individual elementary students’ parent-teacher conferences is a common finding during consolidated monitoring visits. This noncompliance may be due to a misunderstanding of the purpose of the discussion. Simply sharing the compact with parents and obtaining signatures is not sufficient to meet the requirement. The compact must be incorporated into the discussion of the progress for each individual student.
A lack of proper documentation supporting how the compact was discussed could also result in a finding. Consider implementing one or more of the following recommended methods of documentation:
- Develop a checklist or agenda for parent conferences to document individual discussions of the student-family compact in relation to each student’s academic achievement.
- Add a checkbox to a conference night sign in sheet for parents to verify the compact was discussed in relation to their child’s achievement is another way to document that this requirement has been met.
- Save documentation, such as staff meeting minutes and email reminders outlining how the compact should be discussed during conferences.
Notably, discussing school-family compacts at individual conferences is only a requirement at the elementary level. However, ESSA still requires that schools demonstrate various opportunities for communication between school staff and parents through frequent reports to parents on their children’s progress.
Open Title I, Part A Projects and Associated Deadlines
Please review the table below and make note of the approaching deadlines regarding the obligation and expenditure of funds from all open Title I, Part A projects.
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Fiscal Year (FY)
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Period of Award
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85% Obligation
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All Funds Spent or Encumbered
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Final Federal Cash Request
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FY2023
(Project 310J)
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July 1, 2022 - June 30, 2025
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Sept. 30, 2023
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June 30, 2025
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TBD
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FY2024
(Project 310K)
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July 1, 2023 - Sept. 30, 2025
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Sept. 30, 2024
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Sept. 30, 2025
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Nov. 14, 2025
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FY2025
(Project 310L)
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July 1, 2024 - Sept. 30, 2026
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Sept. 30, 2025
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Sept. 30, 2026
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Nov. 13, 2026
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