January 2026

Volume 10, Issue 1

"What gets measured gets improved."

― Peter Drucker

As we reach the midpoint of the school year, it’s the perfect time to pause and take a pulse check.

This edition of our newsletter is designed to get you thinking. Are your plans and expenditures truly aligned with the needs of your students? Has your district made the most of its Title I resources to support equitable learning opportunities?

This moment of reflection isn’t just about compliance –  it’s about ensuring that every decision we make continues to move us toward meaningful impact. Let’s use this time to evaluate progress, adjust strategies and set the stage for a strong finish to the year.

Time and Effort – Semi-annual Certification

Time and effort reporting must be maintained for all employees who are paid fully or partly from Title I funds (or any federal funding source). This applies to staff at the district and school level paid completely or partially from Title I funds.

Uniform Grant Guidance states that salaries and wages of employees who work on federal programs may be paid with federal funds as long as appropriate time distribution records are maintained (see 2 CFR 200.430(g)(1)). These records are often referred to as “time and effort” records. Time and effort records must reflect an after-the-fact distribution of the actual activity of the employee. Maintaining accurate time and effort documentation helps ensure the allowability of personnel charges.

Districts have some flexibility in time and effort reporting. Internal controls for time and effort reporting, such as documented policies and procedures, must be developed and consistently applied. The type of time and effort documentation an employee must maintain depends on the number of cost objectives on which that employee works.

The key to determining whether an employee is working on a single cost objective is whether the employee’s salary and wages can be supported in full from each of the federal awards on which the employee is working, or from the federal award alone if the employee’s salary also is paid with non-federal funds. The January 2025 Title I newsletter, February 2025 Title I newsletter and February 2025 Title I webinar provide a detailed review of time and effort requirements and cost objectives.

The focus during January is on district and school personnel who work solely on a single cost objective. A single cost objective can be, for example, a single function, a single grant or a single activity. These employees are either paid fully with Title I, Part A funds or paid from multiple funding sources for a single function/activity that could be supported in full by Title I, Part A funds. Employees paid with federal funds who work on a single cost objective must certify that they worked solely on that cost objective for the period covered.

The Kentucky Department of Education (KDE) provides an example of a strong internal control for staff working from a single cost objective in the form of a “semi-annual certification.” This certification example indicates the period covered by the certification and is signed by the employee and the supervisor who has first-hand knowledge of the work performed. A sample semi-annual certification is located in the Title I, Part A Sample Documents folder.

Semi-annual certification forms are completed twice a year and must be signed by the employee and their supervisor who has knowledge of the work performed. For the period worked July 1-Dec. 31, forms are signed in January, and for the period worked Jan. 1-June 30, forms are signed in July.

Bottom Line: If your time and effort internal controls include collecting semi-annual certifications for staff with a single cost objective, now is the time to collect signatures for the period from July 1-Dec. 31.

Pulse Check: Spend Down of FY26 Funds

While the Title I, Part A grant has a 27-month life, certain Title I, Part A set-asides should be spent during the school year for which they are appropriated to meet the needs of current students and families.

• Homeless set-aside funds should serve students currently identified as homeless at Title I and non-Title I schools.
• Equitable services funds for private schools must be used this year to support identified students.
• Parent and family engagement funds also need to be spent within the same school year to serve the current families at each school.

As we reach the midpoint of 2025–2026, now is the perfect time to meet with your finance officer for a quick review of your FY26 (310M) projects. Are you on track to spend these identified categories of funds by May? If not, collaborate with your homeless liaison, your principals and, if applicable, private schools to ensure plans are in place. If any of these funds were carried over from the previous school year, be sure to check that they have been spent on their original purpose.

Proactive planning helps avoid common monitoring findings and ensures Title I funds are used effectively and timely to support students and families.

Tip: Review the Principal’s Perspective article in this issue with your principals to involve them in their own evaluation of timely spending.

Principal's Perspective: Pulse Check – Spend Down of PFE Funds

Submitted by Denise Harover, Title I, Part A Consultant

The Every Student Succeeds Act (ESSA) requires districts with a Title I, Part A allocation greater than $500,000 to reserve at least 1% of its total allocation for parent and family engagement. From that reservation, at least 90% of those funds must be distributed to Title I schools to support programming for parents (with priority given to high-need schools). These funds for parent and family engagement must be spent in the school year for which they are appropriated to serve the needs of those families.

January is a great time to check in with your district Title I coordinator about your school’s parent and family engagement fund spend down. It is important to schedule your spending, making sure you have documentation for the events that have already taken place and that you have funds remaining for the activities you have planned for parent and family engagement in the spring. Be sure to consult with your district Title I coordinator to ask any questions you may have about events you are planning.

At this point you have probably received input from parents about the types of workshops and events they want to see provided by the school. Take the lead and start talking about these events with teachers and leaders in your building. Think about the resources you will need to make them a success, keeping in mind that all items purchased must be allowable. The school and the district must make sure spending supports student academic success and meets the program intent. The Title I Part A Parent and Family Engagement Program and Allowable Uses of Funds is a great one-page resource to use for planning your parent and family engagement events.

Consultation with your Title I coordinator should be ongoing to allow for program adjustment as it is needed. Your coordinator can help you make sure the activities and events you are planning align with the narratives and spending that have been added to the Title I, Part A application. If significant changes are made to what will take place at the school for parent and family engagement events, the coordinator may make revisions at any point during the year through the Grant Management Application and Planning (GMAP) system.

It is highly recommended that districts have a process to regularly align GMAP and actual spending in Enterprise ERP (EERP). This helps to ensure your parent and family activities are compliant and meet the intent of the parent and family engagement program. KDE recommends aligning GMAP and EERP at least quarterly.

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.

In This Issue

• Reminder: Tentative Hold Harmless Rates
• Time and Effort– Semi-annual Certification
• Pulse Check: Spend Down of FY26 funds
• In Case You Missed It – Ongoing Consultation with Private Schools
• New Resource Available on the Foster Care Webpage
• Principal’s Perspective: Pulse Check – Spend Down of PFE funds
• Coordinator’s Year at a Glance

Reminder: Tentative Hold Harmless Rates

Be on the lookout for an explanation of tentative census poverty data and tentative hold harmless rates, which is usually released in January.  

The hold harmless rates are set by the U.S. Department of Education and based on the tentative poverty percentages derived from U.S. Census Bureau data. Please note that tentative poverty percentages provided by the Census Bureau are not reflective of data available to the district or the Kentucky Department of Education (KDE), such as free- and reduced-price lunch data. 

Districts can multiply the hold harmless rate by the current year’s Title I, Part A allocation to produce an estimate of their 2026-2027 school year Title I, Part A allocation for planning purposes.

An in-depth review of hold harmless rates is available in the December webinar available on KDE’s Title I, Part A Documents and Resources webpage. 

For more information, contact your Title I, Part A consultant.

New Resource Available on KDE Foster Care Webpage

In order to help guide districts and local child welfare agencies, a sample student school re-entry plan checklist is now available on the Kentucky Department of Education's (KDE's) Foster Care webpage. This resource will help ensure that all relevant and appropriate parties can meaningfully participate in the planning of the student’s transition back into a traditional public-school setting.

Districts are not required to use this checklist but it can be used when a student is undergoing the school re-entry process following expulsion, out-of-state care, returning from a residential facility, homeschooling or home-hospitalization.

In Case You Missed It – Ongoing Consultation with Private Schools

ESEA Now, a publication containing resources related to educational programs in the Elementary and Secondary Education Act (ESEA), published an article on Oct. 16 called “Ongoing consultation necessary to effectively provide equitable services.”

Under ESEA, districts must engage in timely and meaningful consultation with private school officials to provide equitable services under Title I. This is not a one-time requirement; consultation should continue throughout the year.

Key steps mentioned in the article include:

• Assess needs collaboratively and revisit plans regularly.
• Evaluate implementation through site visits and resource reviews.
• Document efforts including meeting agendas, signed affirmations, and progress measures for monitoring and audits.

The mid-year point is an opportune time to check in with the private schools currently being served out of the FY26 project. Continuous collaboration ensures programs meet student and educator needs effectively.

Coordinator's Year at a Glance – Suggested Tasks for January

– Utilize the Hold Harmless Notification from KDE for planning purposes for the upcoming school year.

– Establish a plan and timeline for working with other federal programs in the district to coordinate the consolidated application in the next year.

– Contact private school officials to set the consultation calendar for the upcoming application and school year.

Monthly Title I Webinar

The December webinar and accompanying PowerPoint are available on the Title I, Part A Documents and Resources webpage. During the webinar, information centered around preparing for tentative census poverty and hold harmless data.

The January webinar will be held at 10 a.m. ET Jan. 29. A reminder email will be sent before the webinar.

We value your feedback and would like to learn more about what is helpful and what you would like to see more of in the monthly webinars. Anonymous feedback and topic suggestions may be submitted through the optional Title I Monthly Webinar Feedback Survey. The feedback will be used to help ensure the monthly webinars meet your needs.

CONTACTS

Title I District Consultant List