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“There is no greater joy, nor greater reward than to make a fundamental difference in someone’s life.”
– Mary Rose McGeady
As educators we strive to inspire, encourage and shape the future of our students. Many of our students face challenges outside of school that can negatively impact their educational stability and emotional well-being. Sometimes the adults at school can be their only source of support, encouragement and consistency. By keeping our students connected with school supports throughout the year, we can make that fundamental difference in their lives.
Train Staff to Spot Signs of Homelessness
The focus of the July newsletter is homelessness. Students experiencing homelessness often have difficulties with school attendance, behavior incidents and an increased dropout rate. Often the only stability and support these students have on a regular basis is found at school. Removing barriers these students may encounter is an essential step to their academic success, so it is imperative that Title I coordinators collaborate with the district’s homeless liaison.
704 KAR 7:090(2)(3)(g) and McKinney-Vento 11432(g)(6)(A)(ix) require district homeless liaisons to ensure school personnel receive professional development and support related to addressing the challenges students experiencing homelessness may face. It is important for all staff to be able to spot potential signs that a student may be homeless.
As you prepare for the upcoming school year, consider providing the homeless liaison resources and support in preparing for this training. Remember to think beyond the typical staff like office staff, counselors, family resource personnel, etc. Extend the training to teachers, cafeteria staff, bus drivers and others who also may have observation or conversation time with a student.
According to the McKinney-Vento Act, “homeless children and youths” are individuals who lack a fixed, regular and adequate nighttime residence. This definition includes children sharing housing due to economic hardship, living in motels, trailer parks, shelters or public/private places not designed for sleeping. Staff should be aware of the definition of homelessness as it relates to federal education.
Some signs of homelessness include poor health/nutrition, lack of transportation, attendance concerns, poor hygiene, social or behavioral concerns or even off-handed comments from the student. Any of these situations can affect the students’ ability to attend and succeed in school.
It is important to gather as much information as possible to determine if a student is experiencing homelessness. Some useful resources to aide this process include KDE’s Information for Students Experiencing Homelessness in Kentucky Schools, the National Center for Homeless Education’s Identifying Children and Youth in Homeless Situations and Determining Eligibility for McKinney-Vento Rights and Services
To plan for staff training in your district, see KDE’s Designing District Education for Homeless Children and Youth Professional Learning webinar. Additional support is offered by the National Center for Homeless Education's Homeless Liaison Toolkit (see chapter 12 for training resources).
All About the Homeless Set-Aside
Requirements
Section 1113(c)(3)(A) of the Every Student Succeeds Act (ESSA) requires all school districts to set aside funds to provide services for children experiencing homelessness. There is no specified amount that must be reserved, but the amount must be adequate to provide services to homeless students at all Title I and non-Title I schools.
Principals at all schools should be notified that funds are available for these students to use at any point during the school year. Homeless set-aside funds may not be held back for a “rainy day” fund and should be used to meet the needs of currently identified students. Non-Regulatory Guidance states that Title I, Part A funds must be used only as a last resort when funds or services are not available from other public or private sources. For example, services provided by a public health clinic should be exhausted before using Title I funds to provide the same services.
Determining the Amount
Using a needs assessment is recommended to help determine the needed amount and how the funds will be used. All student needs should be considered, such as educational support, mental health and social emotional support, health and dental care, basic needs and supplies and providing transportation to a student’s school of origin. Collaborate with the district’s homeless liaison to determine an amount that is appropriate to cover the services you will provide.
There is no specific method or formula that must be used to determine your homeless set-aside amount, but there are a few options that may be used. These include:
- Multiplying the number of identified homeless students by the Title I, Part A per-pupil allocations;
- Using historical homeless expenditure data as a guide to determine the amount;
- Reserving a percentage based on the district’s poverty level or the Title I, Part A allocation; or
- Identifying current student needs and funding them accordingly.
Narrative
The homeless set-aside must include a narrative describing the services that will be provided to homeless students. This narrative must include the methodology used to determine the set-aside amount and should include the number of students currently identified as homeless students. Consider any community partners or organizations that will be assisting in providing support and briefly describe services they will provide in the narrative.
Keep in Mind
Once funds have been reserved for homeless students, they must be used for the purpose of providing services to those students and the reservation amount may not be lowered.
It is also important to remember the majority of the funds reserved for the homeless set-aside should be spent during the year in which they are reserved, meeting the needs of current homeless students. Any unspent funds that are carried over to the next year must also be spent on students experiencing homelessness.
Failure to spend homeless set-aside funds in a timely fashion is a common finding during desk and consolidated monitoring. Implementing procedures for tracking the spending of funds with fidelity can help districts avoid these findings.
For questions concerning the homeless set-aside, please contact your district’s Title I Consultant or go to the “Help for Current Page” menu on the Title I, Part A District Set-Aside page in your GMAP application.
Homeless Spending – Title I, Part A and Gas Cards: What Districts Need to Know
Submitted by Jennifer White, KDE's Title I, Part A and homeless education consultant
Title I, Part A is designed to improve educational access and outcomes for students with the greatest needs, including those identified under the McKinney-Vento Homeless Assistance Act. For students facing housing instability, transportation challenges are often among the most significant barriers, directly impacting school attendance, participation and academic success.
Transportation barriers for students experiencing homelessness often require flexible, student-centered solutions. In situations where traditional transportation options are not feasible, using Title I, Part A funds to purchase gas cards can be an effective, allowable use of funds. Many gas stations offer cards that can only be used to purchase fuel. Gas cards or mileage reimbursement may be provided to parents, guardians or unaccompanied youth who are willing and able to transport themselves to school. When used appropriately, gas cards can help ensure students remain in their school of origin and continuity in education.
Districts should establish strong internal controls and accountability measures to prevent fraud, waste and abuse. Examples of internal controls that can help the district maintain accountability for the gas cards include, but are not limited, to:
- Documenting student eligibility and need.
- Clearly linking the support to academic participation.
- Maintaining distribution logs to document the recipient, amount and date of issue.
- Implementing safeguards such as tracking attendance to assess effectiveness.
- Avoid stockpiling gas cards; they should be used based on a demonstrated and immediate need for identified students.
- Limit the number of district staff who have access to the cards (e.g., perhaps only the homeless coordinator has access) and put a system of checks and balances in place to ensure proper oversight of who has access to the cards and how they are distributed.
District staff are encouraged to reach out to state coordinator Zach Stumbo for additional information regarding the transportation of homeless children and youth.
Principal’s Perspective: Funds Available to Support Homeless Students
All districts are required to reserve a portion of Title I, Part A funds to support students experiencing homelessness at Title I and non-Title I schools. These funds must be used for reasonable and necessary services and supports to assist homeless students in taking advantage of educational opportunities.
Title I, Part A funds must be used only as a last resort when funds or services are not available from other public or private sources. Internal supports are often available through the Family Resource Youth Services Center; many districts and schools work with community organizations and partners to help provide for these students. Keep outside supports in mind when determining the need to spend homeless set-aside funds.
Examples of Allowable Expenditures
Funds should be used to provide items and services that help homeless students succeed in their overall school experience. Common expenditures include, but are not limited, to:
- Tutoring and other academic supports such as extended learning time, to help students continue to meet academic expectations.
- Basic school supplies.
- Comprehensive supports such as mental health services or other medical and dental services.
- Technology supports such as computers, tablets and WiFi access may be allowable.
- Providing transportation support such as gas cards or public transportation tokens to get students to their school of origin.
- Meeting basic needs such as clothing, shoes and hygiene items to ensure students can participate more fully in school.
- Supports to help address chronic absenteeism.
- Parental supports and outreach specifically for the parents of homeless students.
Funds should be used to support the needs of students currently identified as experiencing homelessness as opposed to stocking up on supplies for future students.
Unallowable Uses of Funds
702 KAR 3:220 requires districts establish a process for waiving school fees for students who qualify for free or reduced-price lunch. This applies to charges required for participation in school-sponsored courses, activities, programs, events or services. Homeless students automatically qualify for free lunch and therefore qualify to have these fees waived.
Title I homeless set-aside funds are intended to provide supplemental services to homeless students. These students are already eligible to have the fees waived, therefore using federal funds to cover the fees would not be supplemental and thus unallowable. These fees include things like:
- Charges and deposits for use of school property such as locks, laboratory equipment or special supplies required for a particular class.
- Charges and deposits for uniforms or equipment related to intramural sports, music or fine arts programs.
- Charges for field trips, any portion of which falls within the school day.
- Graduation fees required for participation such as the cap and gown typically required for students to participate in the graduation ceremony.
Additional information on this regulation is available in KDE’s Frequently Asked Questions on Student Fee Waivers for McKinney-Vento. There are other unallowable uses of homeless funds beyond mandatory fees, including:
- Social field trips such as a senior class trip.
- Formal dresses or tuxedo rentals for prom.
The Bottom Line
If you have students experiencing homelessness, there may be funds available to help meet their needs. Reach out to your district Title I coordinator and homeless liaison to discuss how to meet the identified needs of homeless students in your school. There are expenses other than the ones listed in this article that may be allowable under certain circumstances and within specific parameters, upon approval from KDE.
Again, work with your district staff to determine allowability and they can direct any further questions to the district’s Title I consultant or KDE’s state homeless coordinator.
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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FY2025
(Project 310L)
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July 1, 2024 - June 30, 2027
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Sept. 30, 2025
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June 30, 2027
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TBD
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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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FY2027 (Project 310N)
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July 1, 2026 - Sept. 30, 2028
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Sept. 30, 2027
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Sept. 30, 2028
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TBD
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