Under Title I of the Elementary and Secondary Education Act (ESEA), as amended by the Every Student Succeeds Act (ESSA), local educational agencies (LEAs) are required to provide services for public school students and eligible nonpublic school students. In particular, Sections 1117 of Title I, Part A, and Title VII, Part F, require a participating LEA to provide eligible children attending nonpublic elementary and secondary schools, their teachers, and their families with Title IA, Title IIA, and Title IVA services or other benefits that are equitable with those provided to eligible public school children, their teachers, and their families. Eligible nonpublic school students are those students who would be eligible to receive Title IA and Title IVA services from the district if they were attending public schools.
Elements of the Consultation Process
The consultation process between public and nonpublic school officials regarding Title IA, Title IIA, and Title IVA services is extremely important. Timely and meaningful consultation must occur between the LEA and nonpublic school officials prior to any decision that affects the opportunities of eligible nonpublic school children, teachers, and other educational personnel to participate in the Title IA, Title IIA, and Title IVA programs. The LEA can use this
sample letter to reach out to nonpublic schools to initiate a conversation.
THE LEA, DURING THE CONSULTATION PROCESS, SHOULD:
- Set up a timeline with nonpublic school officials for future meetings and for frequent visits by the LEA
- Plan for multiple meetings
- Gather input from private school representatives
- Have an agenda for each meeting
- Keep written notes and share with private school officials
- Maintain meaningful written assurance
- Plan to conduct full school year programming
The LEA, in working with the nonpublic schools, must be sure to cover all of the consultation topics listed on the
Consultation Participation Form (43-20) that is used to document consultations with each nonpublic school.
Nonpublic School Enrollment Data
Please use the
Nonpublic School Enrollment 2017-18 datain consultations with nonpublic schools for purposes of FY19 ESEA Title IA, Title IIA, and Title IVA. Each worksheet in the Excel workbook has its own instructions, but in general keep these points in mind:
- The data offered here are self-reported by the nonpublic schools who have registered with ISBE. Schools were asked to do this last Fall; there is a high likelihood of some errors, so data checks during consultation is strongly advised.
- The data here do not represent all possible students from the district being served in nonpublic schools. They only represent data from nonpublic schools that choose to become registered with ISBE. Districts must still be alert to the possible presence of non-registered schools with which a consultation should be done. Students at non-registered nonpublic schools are eligible for ESEA services. So the first consultation question might be “Can we confirm that the nonpublic students at this school really belong to this public school district?”
- The data here give raw numbers of students. The consultation process should include a confirmation that the students are resident in the school district and a determination as to whether any of the students are low income.
- Lastly, there must be a connection between a nonpublic school student and a public school with an ESEA Title IA and Title IVA program, so the third consultation issue would be which public schools the nonpublic school students would have attended.
Provide Equitable Services and Equitable Share of Funds
The Title IA, Title IIA, and Title IVA programs provide supplemental instructional or other services so that all children have a fair, equal, and significant opportunity to obtain a high-quality education. The amount of Title IA, Title IIA, and Title IVA funds allocated to each participating public school attendance area is determined solely on the basis of the total number of low-income students (both public and nonpublic school students) residing in each area. Expenditures for nonpublic school students in each area generally are determined based on the proportion of students from low-income families residing in that area who attend nonpublic school.
Once the participating public school attendance areas have been established for Title I services (see “Determining Educational Need and Participation” below for more information), an LEA then calculates the per-pupil allocation for each participating public school attendance area. Then, based on the total number of children from low-income families residing in each attendance area attending public and nonpublic schools, the LEA calculates the total amount of funds for each area. From this amount, the LEA reserves an amount of funds for the nonpublic school children (equal to the per pupil allocation multiplied by the number of low-income nonpublic school students in the area) to provide equitable services to eligible nonpublic school children. Remember, the LEA should never directly pay the nonpublic school or the nonpublic school officials for services or supplies.
Determining Educational Need and Participation
To be eligible for Title IA services, a nonpublic school child must reside in a participating public school attendance area.
To be eligible for Title IIA and Title IVA services, a nonpublic school child must be housed within the public school’s boundaries. The total enrollment of the nonpublic school is used regardless of where the students would go to public school.
All students must meet the requirements of Title IA, Title IIA, and Title IVA, which requires the LEA to use multiple, educationally related, objective criteria in selecting children to participate in the Title IA, Title IIA, and Title IVA programs.
What is a participating public school attendance area?
A participating public school attendance area is one in which Title IA, Title IIA, and Title IVA money is used to provide services to children. For example, if Illinois District 1 receives Title I money and uses that money at Washington Elementary but not Lincoln Elementary, then eligible nonpublic school children residing in Washington Elementary attendance area would be eligible to receive services. Those nonpublic school children who reside in Lincoln Elementary attendance area would not be eligible since the public school is not using Title IA, Title IIA, and Title IVA funds in that school.
Eligible status children
Some children may be identified as eligible solely by virtue of their status:
- Homeless children
- Children who have been enrolled for 2 years in Head Start
- Children enrolled in the Even Start program
- Children enrolled in Early Reading First
- Children enrolled in Title I preschool program
- Children enrolled in the Migrant education program
Staffing and Servicing the Private School Program
Title I funds are expended to implement academic research-based programs that help students improve their academic achievement in the regular nonpublic school classrooms in core academic subject areas.
Types of Services
- Instructional services
- Extended day services
- Family literacy programs
- Counseling programs
- Computer assisted instruction
- Home tutoring
- Instruction using take home computers
- Professional development targeted to help teachers better teach at-risk students
Title I programs must not be staffed exclusively with paraprofessionals. Paraprofessionals must be under the direct and immediate supervision of highly qualified teachers. Paraprofessionals must not determine the program of services; only highly qualified teachers can determine the program of services.
Third Party Providers
Title IA, Title IIA, and Title IVA services to nonpublic school children may be provided under contract with a third party provider chosen by the district. A third party provider may be a public or private agency, organization or institution that is independent of the nonpublic school and of any religious organization in the provisions of those services. The contract needs to specify the deliverables (instructional time, academic subject areas, assessment, number of students, etc.). LEAs should choose a third party provider that would attract specialists in nonpublic school programs. Actual costs must be divided by number of months services are provided and multiple services must be broken out clearly or separately contracted.
Public school students who participate in Title IA, Title IIA, and Title IVA programs must be held to the same challenging content and student achievement standards that a state expects all public school students to meet. Nonpublic school students who participate in Title IA, Title IIA, and Title IVA programs must also be held to high standards, although these students may not be expected to meet the same standards the state expects public school students to meet. Benchmarks for success are needed to help determine the effectiveness of a program.
In addition to evaluating students, the nonpublic school Title IA, Title IIA, and Title IVA programs must be evaluated. Every year the LEA and nonpublic school officials must consult to determine what constitutes annual progress for the Title IA, Title IIA, and Title IVA programs. This may be determined by instructional method, grade level, school, or other appropriate basis. Results should be used to modify future programming. An LEA must annually assess the progress of the Title IA, Title IIA, and Title IVA programs toward enabling nonpublic school Title I participants to meet agreed-upon standards (which should be determined during consultation).
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