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"Good order is the foundation of all things."
― Edmund Burke
When it comes to Title I, Part A programs, strong implementation starts with strong systems. Whether it's safeguarding purchased assets or conducting regular self-assessments, the success of federally funded programs depends on clear, consistent procedures.
In this edition, we’re highlighting the importance of internal controls – from inventory management to monitoring tools – that help ensure compliance and, more importantly, support meaningful outcomes for students. Tight processes are not just about following rules, they’re about maximizing resources and strengthening program integrity.
Safeguarding Assets Purchased with Title I Funds
Ensuring the proper use and protection of federal funds is a key responsibility of all districts receiving Title I, Part A allocations. According to 2 CFR 200.302(b)(4), each non-federal entity is required to maintain a financial management system that provides effective control and accountability over all funds, property and other assets, ensuring they are used only for their intended authorized purposes.
To comply with this requirement, districts must establish and implement internal procedures that demonstrate clear oversight of Title I, Part A expenditures for the district, its schools and any participating nonpublic schools receiving equitable services. Some common examples of effective internal controls include maintaining accurate inventories and clearly tagging or labeling purchased items.
Tangible personal property having a useful life of more than one year and a per-unit acquisition cost which equals or exceeds the lesser of the capitalization level established by the district for financial statement purposes or $10,000 is considered equipment and must be inventoried. 2 CFR 200.313(d) specifies the following information that must be included on equipment inventory:
- A description of the equipment (the type and model)
- A serial number, identification number or model number
- Funding source, Federal Award Identification Number (FAIN) and percentage (who holds title) under which the equipment was acquired. The grant award year also should be included.
- Vendor
- Acquisition date (delivery date)
- Unit cost (not total cost)
- Location (school and location within the school [library, classroom 200, etc.])
- Use of the equipment (Title I classroom, Title I afterschool program, Title I administration)
- The condition of the equipment (new, good, fair, poor)
- The date the information was reported on the inventory
- Information regarding the transfer, replacement or disposition of equipment (date of disposal, sale price of equipment)
In the event of any loss, damage or suspected theft of equipment, districts are required to investigate the incident. If the situation affects the program, it must also be reported to the Kentucky Department of Education (KDE), as stated in 2 CFR 200.313(d)(3).
Most assets purchased with Title I funds fall below the equipment threshold but are still considered valuable and must be protected from loss, damage or theft. Even if an item isn’t tracked in the official equipment inventory, districts are still expected to have a control system in place to safeguard it. Consider the following questions when determining which items to safeguard:
- Will the item last longer than one year?
- If damaged, would the item be repaired?
- Is the item easily lost or stolen?
- Is the item considered valuable?
KDE recommends districts investigate instances of loss, damage or suspected theft of valuable items not meeting the equipment threshold.
For more information and practical tools, districts can refer to the Safeguarding Assets Purchased with Title I Funds guidance document. This resource can serve as a starting point for developing or refining your district’s own internal procedures for asset management and protection. In case you missed it, check out the July 2025 Title I Webinar for more on recent updates to the safeguarding assets resource.
By maintaining robust controls and clear procedures, districts help ensure that federal funds are used effectively and that the resources purchased truly benefit the students they are meant to serve.
Principal's Perspective: Celebrations vs. Engagement: Understanding the Difference Between Holiday Parties and Title I Activities
Submitted by Denise Harover, Title I, Part A Consultant
As we are getting settled into the school year, we are approaching the time for many exciting classroom celebrations. Kids love classroom celebrations with treats and decorations, and parents love to volunteer to bring snacks and interact with the students. As we prepare for these occasions where many parents will be in our schools, we need to be mindful of the difference between celebrations and Title I parent and family engagement activities.
Title I parent and family engagement activities are federally funded and should be intentionally designed to build partnerships between families and schools. They should support student learning and academic success by providing activities that teach parents how to reinforce learning at home.
If books or manipulatives are provided to parents, strategies of how to use these items also should be given to families. For example, a math night might include interactive stations where parents learn how to use a simple deck of cards to build math fluency. Families could then take a deck of cards along with instructions and strategies to continue the learning while at home. Activities learned at the event also could be extended into future homework assignments.
Title I parent and family engagement activities require planning and should be designed to engage students as well as parents in hands-on learning activities. There should be a specific focus, and the planned activities should be designed with that focus in mind.
You want to make sure the event is documented with parent invitations and ways they were notified the event would be taking place. You also should keep sign-in sheets to document the attendance at the event and evaluate the activities by asking for parental feedback and ideas for improvement.
We can still celebrate with seasonal celebrations and have fun while learning. We just need to keep in mind our schoolwide goals and remember to keep our federally funded Title I efforts focused and impactful for the students, parents and the school.
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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FY2024
(Project 310K)
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July 1, 2023 - June 30, 2026
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Sept. 30, 2024
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June 30, 2026
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Aug. 31, 2026
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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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FY2026 (Project 310M)
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July 1, 2025 - Sept. 30, 2027
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Sept. 30, 2026
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Sept. 30, 2027
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Nov. 12, 2027
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