Title I Schoolwide Programs: From Intent to Implementation

Office of Title I New Jersey Department of Education

February 26, 2014

Agenda

Welcome and Introductions (Karen Campbell, Director)

Title I-Historical Background, Facts and Myths (Anthony Wright, Title I Program Specialist)

Federal Requirements (Karen Campbell)

Schoolwide Program Design (Anthony Wright)

Fiscal Accountability (Anthony Hearn, Title I Fiscal Specialist)

Title I- The Purpose

Established in 1965 as part of the War on Poverty

Largest federal elementary and secondary education program

Provides supplemental funds for students in schools with concentrations of low-income students to have an equal opportunity to achieve levels of proficiency.

Scope of Title I-Nationwide

2011-2012 School Year*

Over 23 million students served

Federal allocation of over $14 billion

Over 66,000 schools serving more than 23 million students

*US Department of Ed-Data Express (http://eddataexpress.ed.gov/index.cfm)

Scope of Title I in New Jersey

2011-2012 School Year Allocation of $302,805,798 388, 681 students served

Over 7,000 in Nonpublic schools Supplemented instructional programs in English

Language Arts, Mathematics, Science, Social Students and CTE

Provided support services: guidance, medical, dental, eye care

*US Department of Ed-Data Express (http://eddataexpress.ed.gov/index.cfm)

The Need for Title I-The Gaps

Gaps in equity-Low-income students do not have access to equitable levels of:

Funding Highly effective teachers and leadersEarly learning opportunitiesInstructional resources, including technologySafe and secure schools

The Need for Title I- The Gaps

The opportunity gap :

High school graduation rate of low-income students63%

College attendance rate of low-income students29%

College completion rate of low-income students9%

Title I, Part A: Intent and Purpose

8

Public Law 107-110 Section 1111-1127 : Improving the Academic Achievement of the Disadvantaged

Improving Basic Programs Operated by Local Education Agencies (LEA) provides supplemental funding to state and LEAs for resources to help schools with high concentrations of students from low-income families provide a high quality education that will enable all children to meet the state’s student performance standards.

Transition From Targeted Assistance to Schoolwide

Title I funds “target” lowest-performing students.

Entrance and exit criteria based on multiple, objective, and uniform criteria● Children who have the

greatest academic need receive Title I services

● Districts may need to prioritize the student selection to provide a meaningful program

Title I funds upgrade school’s educational program to meet the state’s academic standards.

40 percent of students must be from low-income families.

A comprehensive needs assessment must be conducted.

The school must engage its stakeholder group when developing the schoolwide plan

TARGETED ASSISTANCE (TA)ESEA §1115

SCHOOLWIDE (SW)ESEA §1114

Purpose of Title I Schoolwide Programs

34 CFR 200.25

“[t]he purpose of a schoolwide program is to improve

academic achievement throughout a school so that

all students, particularly the lowest-achieving

students, demonstrate proficiency related to the

State's academic standards . . .”

Why Schoolwide Programs?

Research shows that schools with high poverty,

student needs are more widespread throughout

the school population as opposed to

concentrating on a select group of ”targeted”

and/or intended beneficiaries.

Why Schoolwide?

Incorporate reform strategies into overall instructional program Improving academic achievement of lowest-performing students

while upgrading the educational program of the entire school Services benefit ALL students

more service delivery options for Title I and other federal program services.

Title I students are not singled out. Student needs met more effectively. Federal program resources are available to all students. greater staffing flexibility. Professional development extended to all staff.

Going Schoolwide…

Does not result in schools receiving additional Title I funds.

Does enable schools to utilize their Title I funds more flexibly than is permitted in a targeted assistance program

Must meet all the intents and purposes of the Title I legislation

Going Schoolwide . . .

Requirements:

• One year of planning (may be waived if the school had previously been operating under a strategic plan or improvement plan that addresses the entire school)

• Stakeholder engagement

• Title I Schoolwide Plan which describes the planned changes in the school and explains how the school will address the components of a Schoolwide program

FEDERAL REQUIREMENTS

10 Components of a Schoolwide Program

ESEA §1114(b)(1)(B)1. Comprehensive Needs Assessment2. Increased Parental Involvement3. Schoolwide Reform Strategies4. Transition of Preschool Children5. Highly Qualified Teachers6. Teacher Decisions Regarding Assessment7. Professional Development8. Assistance To At-risk Students9. Recruitment And Retention of Highly Qualified Teachers10. Coordination and Integration of Services & Programs

Title I Schoolwide: The Process

Stakeholder EngagementESEA §1114(b)(2)(B)(ii)

• The schoolwide plan must be developed with the involvement of parents and other stakeholders.

• To gain final approval to operate a Title I Schoolwide program, schools must document the stakeholder engagement process.

Title I Schoolwide: The Process

Schoolwide PlanESEA §1114(b)(2)(A)

•Reflects 10 components of a schoolwide programs

•Updated annually

• Submitted with district’s ESEA-NCLB Consolidated

Application

Title I Schoolwide: The Process

Title I Schoolwide PlanESEA §1114(b)(2)(A)

Must include the following three elements:

1. A description of how the school will implement the ten mandatory schoolwide program components

2. A description of how the school will use resources from Title I and other resources to implement those components

3. A list of federal, state, and local programs that will be consolidated in the schoolwide program (if applicable).

Schoolwide Programs

ESEA § 1114 & 34 CFR §§200.25-200.29

Authorizes a school to consolidate its federal, state, and local funds to upgrade the entire educational program within the school.

School NOT required to identify or “target” certain children for services based upon multiple, educationally-related criteria.

Schoolwide Programs

ESEA § 1114 & 34 CFR §§200.25-200.29

As a result, in a schoolwide setting- federal, state, and

local resources should be used collaboratively to ensure

that ALL students have the opportunity to meet the

state’s academic standards.

SCHOOLWIDE PROGRAM DESIGN

Developing and Implementing a Schoolwide Program

ESEA § 1114 & 34 CFR §§200.25-200.29

A schoolwide program consists of the following three core elements:

1. A Comprehensive Needs Assessment;

2. Comprehensive Plan; and

3. Evaluation

Comprehensive Needs Assessment

ESEA §1114(b)(1)(A)

The comprehensive needs assessment MUST be based

on academic achievement information about All

students in the school( all subpopulations, i.e. students

with disabilities, economically disadvantaged, and

Limited English Proficient)

Comprehensive Needs Assessment

ESEA §1114(b)(1)(A)

The needs assessment MUST clearly identify the

school’s strength’s and challenges in key areas that

impact/affect student achievement

Comprehensive Needs Assessment

ESEA §1114(b)(1)(A)

The comprehensive needs assessment MUST be based

on academic achievement information about All

students in the school( all subpopulations, i.e. students

with disabilities, economically disadvantaged, and

Limited English Proficient)

Comprehensive Needs Assessment

ESEA §1114(b)(1)(A)

The needs assessment MUST be developed with the involvement of the people who will carry out the schoolwide program.

School MUST document how the needs assessment was carried out, to include the results obtained.

Comprehensive Needs Assessment

Description of Priority Problems and Interventions to Address Them (Example from 2013-2013 Plan)

Describe the root causes of the problem. School’s response: The school serves a high percentage of

minority students and closing the achievement gap and reaching the %90 target requires long term commitment and hard work.

NJDOE’s response: Having a specific demographic of students in your school is not a root cause. Revise this response to indicate the academic barriers that result in an achievement gap.

ROOT CAUSE OF PRIORITY PROBLEM: SERVING HIGH PERCENTAGE OF MINORITY STUDENTS AND CLOSING THE ACHIEVEMENT GAP AND REACHING OUT THE %90 TARGET REQUIRES LONG TERM COMMITMENT AND HARD WORK.

How can being a minority be a Cause? Surprisingly, No one told them!

Needs Assessment

Example from 2013-2014 Plan:

How does the school address the needs of homeless students?

• School’s response: N/A

• NJDOE’s response: Clarify how the school determines that it does not enroll any students experiencing homelessness.

Needs Assessment Process

Example from 2013-2014 Plan

Description of Priority Problems and Interventions to Address Them

• School’s response: Name of priority problem: Common Core State Standards for English Language Arts

NJDOE’s response: Specify what aspect of ELA common core implementation presents a problem

• School’s response: Name of priority problem: Literacy

NJDOE’s response: Specify what aspect of literacy presents a problem.

Comprehensive Plan

Schoolwide Reform StrategiesESEA § 1114(b)(1)(B)

Provide all students in the school the opportunity to meet the state’s proficient and advanced levels of student academic achievement

Use effective methods and instructional strategies that are grounded in scientifically based research

Strengthen the core academic program in the school

Comprehensive Plan

Schoolwide Program ComponentsESEA §1114(b)(I)(B)

Schoolwide programs MUST contain the following program components:1.Schoolwide Reform Strategies;2.Instruction by Highly Qualified Teachers;3.Family and Community Engagement; and4.Additional Support(s)

Comprehensive Plan

Schoolwide Reform Strategies: Standards for identifying effective approaches

Schools operating schoolwide programs should implore reform strategies grounded in scientifically based research (SBR)

These approaches (SBR) are likely to have a positive impact on student achievement

Comprehensive Plan

Example from 2013-2014 Plan

Schoolwide Reform Strategies-Name of Strategy

School’s response: Professional Development in Mathematics focused on alignment with new Common Core Standards

NJDOE response: Please specify what type of PD/intervention. As described, this is a mandated activity vs. a reform strategy.

Comprehensive Plan

Step 1-School collects data that gives a complete, accurate picture of the current state of the school.

Step 2-School community analyzes data to determine and prioritize needs.

Step 3- After prioritizing needs, school writes goal statements to address prioritized needs.

Step 4- School develops potential strategies to achieve stated goals.

Schoolwide Reform Strategies: Integrating scientifically based research strategies step-by-step

Schoolwide Reform Strategies: Integrating scientifically based research strategies step-by-step (cont’d)

Step 5- School begins topical literature review, identifying research base of potential strategies.

Step 6- School uses abstracts to determine if the research addresses the theoretical bases of a program or practice; issues of implementation; and evidence of the effects of that program or practice on student achievement.

Step 7- If the examination of the abstracts reveal to relevant to the needs of the individual school(s), the study should be further examined in full detail.

Step 9- School must determine if the examined research is of high quality, replicable, and relevant.

Schoolwide Reform Strategies: Essential QuestionsIs there a theoretical base for the practice or program being considered?

What are the ideas behind this practice or program?

What are its guiding principles?

How does it work? Why does it work?

Is there a clear, non-technical description of the central idea and goals of the practice or program?

Is there a clear description of the instructional activities that are central to this program or practice?

Is the practice clearly tied to an established learning theory (i.e., language acquisition, child development)?

Questions about the theoretical base

Judging quality of the theoretical base

Schoolwide Reform Strategies: Essential QuestionsIs there evidence that this practice or program has been successfully implemented and has produced positive outcomes in a variety of situations? Has it been successful in a

context similar to that of the school considering this practice?

Has the program or practice been widely used?

Where is the reform likely to work?

Under what circumstances is it most effective?

How many schools have used this practice or program?

Did the schools using it fully implement the practice or program?

In what settings has it been implemented?

Has improved student achievement been convincingly demonstrated in a variety of settings?

Questions about implementation and replicability

Judging quality of implementation and replicability

Schoolwide Component- Evaluation34 CFR § 200.26 (C)

A school operating a schoolwide program must—(1) Annually evaluate the implementation of, and results achieved by,

the schoolwide program, using data from the State's annual assessments and other indicators of academic achievement;

(2) Determine whether the schoolwide program has been effective in increasing the achievement of students in meeting the State's academic standards, particularly for those students who had been furthest from achieving the standards; and

(3) Revise the plan, as necessary, based on the results of the evaluation, to ensure continuous improvement of students in the schoolwide program.

Schoolwide Component- Evaluation34 CFR § 200.26 (C)

http://link.brightcove.com/services/player/bcpid24557258001

Schoolwide Program Evaluation

Example from 2013-2014 Plan

What were the staff’s perceptions of the plan? School’s response: The staff was very supportive. They

became familiar with the plan and implemented the best practices.

NJDOE’s response: Expand this response to include the measurement instrument the school used to determine that staff were supportive about implementing the program.

Schoolwide Program Evaluation

Example from 2013-2014 Plan

State Assessments-Partially Proficient: Describe why the interventions did or did not result in proficiency.

School’s response: Students did not reach proficiency, however growth was demonstrated.

NJDOE response: In the past (2011-2012), data was provided. Please provide 2012-2013 data that supports growth was demonstrated. Note: In the 2014-2015 plan, this evaluation requires formative data on the impact of each specific intervention.

Fiscal Accountability for Schoolwide Programs

Schoolwide Programs Approval on a school by school basis

Same fiscal rules apply in OMB A-87, Attachment B

MUST have approved plan that addresses all schoolwide issues

Time sheets are required (except in a blended resource fund, e.g., Fund 15 for Abbott districts)

Key questions to be addressed: Do the activities budgeted support the intent of the law?

[Federal Register: July 2, 2004 (Volume 69, Number 127)]Are supplemental services provided to the students enrolled

in the school?

Use of Funds

A school operating a schoolwide program does not have to: (1)

show that Federal funds used with the school are paying for

additional services that would not otherwise be provided; (2)

demonstrate that Federal funds are used only for specific target

populations; or (3) separately track Federal program funds once

they reach the school.

Use of Funds

A schoolwide program school must use Title I funds only to

supplement the amount of funds that would, in the absence of

the Title I funds, be made available from non-Federal sources for

that school, including funds needed to provide services that are

required by law for children with disabilities and children with

limited English proficiency. [Section 1114(a)(2)]

Use of Funds

Supplement vs. Supplant for Schoolwide ProgramsOMB Circular A-87

All children in the building may participate in activities funded with Title I Part A funds (consistent with the schoolwide program plan) and the school does not need to demonstrate that those activities are supplemental to ones that would otherwise be provided by the school. In instances where a school operating a schoolwide program does not

consolidate its Title I Part A funds with other Federal, State, and local funds, the school and district must account for and track the Title I Part A funds separately, identifying the activities that the Part A funds support; and

A district must be able to show its method for allocating state and local funds is neutral with regard to Title I funds and does NOT reduce state and local allocations in light of its Title I Part A funds

Supplement vs. Supplant for Schoolwide Programs

Example If School A would normally receive $1,000,000 of state and local funds under the school district’s regular allocation procedures, the district could not reduce School A’s state and local allocation because it also receives Title I funds.

For example, if the school receives $200,000 of Title I funds, reducing the school’s state and local allocation by $200,000 to $800,000 would violate the “supplemental funds” test.

Fiscal News from Washington

New Haven Audit Report from Office of Inspector General

Supplanting in a Schoolwide Program

http://www.ed.gov/about/offices/list/oig/auditreports/a02f0005.pdf

Fiscal News from Washington

Policy Letter 4/15/1998 (G-2608)

Request to have Title I partially fund the expansion of an innovative laptop computer classroom and at-home computer initiative through a leasing contract. Title I funds, in combination with other funding sources, should not be used to provide services to children not eligible for Title I assistance; this would result in supplanting state and local funds and is not permissible.If the LEA was a schoolwide program district, this approach would generally be allowed as long as it meets full schoolwide plan objectives.

Fiscal News from Washington

Policy Letter 11/18/1999 (G-2633)

Request to use Title I funds to support college awareness presentations is allowable if provided to only Title I identified students.

If such presentations are given in a schoolwide program, they can be funded by Title I for all students

Fiscal Options In New Jersey

Two Options

Consolidate Funds

Not Consolidate

Consolidation of Funds

Financial Implications

Schools do not have to associate each expenditure with individual funding sources, but districts still need to list by function and object code how Title I funds are being utilized.

Thusly, combining programmatic flexibility at the school level with fiscal accountability at the district level.

Districts must be able to show that Title I, Part A schools received at least as much state and local resources as non-Title I schools.

Title I Schoolwide: Requirements

Monitoring Implications

The district musty be able to demonstrate that the intent and purposes of the Federal programs whose funds are met at each schoolwide school using funding consolidation.

• The district must meet the reasonable and necessary test as articulated in OMB A-87 circular at each schoolwide school using funding flexibility.

• Districts must show that schoolwide schools using this flexibility received at least as much state and local resources as non- Title I schools.

• Districts must continue to maintain inventories and track time and effort for all federally funded staff.

Title I Schoolwide: Requirements

Necessary and Reasonable StandardOMB Circular A-87

In a schoolwide program, Title I funds may only be for expenditures that are necessary and reasonable to achieve the legislative and regulatory requirements as articulated in the schoolwide plan.

OMB Circular A-87 clarifies that “ [t]o be allowable under Federal awards, costs must…[b]e necessary and reasonable for proper and efficient performance and administration of Federal awards.”(http://www.whitehouse.gov/omb/circulars a087_2004#c)

The use of Title I funds for activities not included in the schoolwide plan are not allowable, and are therefore subject to recovery

Helpful Questions to Ask When Analyzing Costs

Is the proposed cost consistent with federal cost principles? OMB A-87, Attachment B

Is the proposed cost allowable under the relevant program? (Title I, IDEA, etc)

Is the proposed cost consistent with an approved program plan and budget? (EWEG)

Is the proposed cost consistent with program specific fiscal rules? (Supplement not Supplant)

Is the proposed cost consistent with EDGAR?

Fiscal News from Washington

City of Detroit and Parent Involvement Fund2005

Disallowed Charges for Entertainment, Promotional Items and Public Relations

Need to be necessary, reasonable, allocable and documented

Disallowed items include advertising for an event and live musical entertainment at parent volunteer function

http://www.ed.gov/about/offices/list/oig/auditreports/a05f0018.pdf

Fiscal News from Washington

City of Detroit -Revisit in 2008

Over $131 Million in 2005 and $126 Million in 2006 No Time Sheets – Almost $50 Million Teaching non-Title I students – even though most of Detroit is schoolwide

some schools are not (no plan submitted) and OIG looked to these schools and found staff being funded that were teaching non-Title I identified students. Detroit argued they could have been schoolwide if they did a plan and the OIG rejected this argument

Over $21 M for adjusting entries for employees that were charged to other programs and then charged to Title I

Gift cards they could not show got to students $150,000 for martial arts training

Fiscal News from Washington

Philadelphia

• Findings totaling $138,376,068• Unsupported Salaries (some direct and some thru

adjusting entries)• School Police paid from Title I Funds• Supplanting (moving company, etc)• No backup for School Choice Charges of $1.3M• Weak internal controls

Fiscal News from Washington

Maryland-Title I ARRA Funds

• Findings totaling $540,013• $8,736 in gifts to staff• $4,352 in Dinner Cruises in Baltimore Harbor• Lack of Receipts for Expenses• $200,323 in Unsupported Title I and IDEA Salaries• 3,922 Tablets with no controls over them or applications that

are downloaded (Items against policy – 22%)

What Happens When Federal $$$ Are Misspent??????

Accountability. Efficiency. Effectiveness. Oversight

US Dept. of EducationOffice of Inspector General

Former Charles County Public Schools Title I Coordinator Sentenced (Maryland).

The former Title I coordinator was sentenced to serve 27 months in prison and 36 months of supervised release. She was also ordered to pay more than $115,300 in restitution for theft. The former official used Title I grant funds to purchase technology items for herself, family, and friends, including computers, video games consoles, portable media players, tablet computers, and televisions.

US Dept. of EducationOffice of Inspector General

Sandra Campbell, 57 a former Detroit Public Schools contract accountant and school board candidate, and her daughter, Domonique Campbell, 38, a Detroit Public Schools teacher, were convicted today by a federal jury in Detroit on charges of program fraud conspiracy, money laundering conspiracy, and tax charges following a five-week jury trial, United States Attorney Barbara L. McQuade announced today. The jury returned its verdict after only one-and-a-half hours of deliberations.

McQuade was joined in the announcement by FBI Special Agent in Charge Robert D. Foley, III and Special Agent in Charge, Erick Martinez, Internal Revenue Service, Criminal Investigation.

The evidence presented at trial established that between 2004 and 2008, Sandra Campbell and Domonique Campbell obtained in excess of $530,000 from the Detroit Public Schools through a fraudulent scheme in which orders were placed with the Campbells’ sham company for books and educational materials never provided to the schools. Sandra Campbell and Domonique Campbell conspired to launder the fraud proceeds and to defraud the Internal Revenue Service and failed to report the money they fraudulently obtained from the Detroit Public Schools as income on their tax returns.

United States Attorney Barbara L. McQuade said, “Anyone who considers stealing from our school children should take note that we are scrutinizing records and conduct, and will prosecute wrongdoers.”

Web Site Resources

“Designing Schoolwide Programs” addresses the program requirements: http://www.nj.gov/education/title1/leg/

“Schoolwide Programs” addresses the general schoolwide requirements: http://www2.ed.gov/legislation/ESEA/Title_I/swpguide.html

“Title I Fiscal Issues” addresses consolidating funds in schoolwide programs:

http://www2.ed.gov/programs/titleiparta/fiscalguid.pdf US Dept. of Education http://www2.ed.gov/policy/elsec/leg/esea02/pg2.html http://www2.ed.gov/legislation/ESEA/Title_I/swpguide.html

Next Steps: Required Stakeholder Engagement Documentation

DUE to the NJDOE Friday, April 4, 2014 Complete a thorough engagement of the school/district’s stakeholder group in

planning to implement Title I schoolwide programs;

Samples of communication distributed to schools on the Title I schoolwide program requirements or charts demonstrating how Title I schoolwide requirements align with intended goals, objectives and needs of intended schools;

Evidence of communications with schools on consolidating and using funds with other federal, state, and local funds in a Title I schoolwide program, to include identifying fiscal and accounting barriers to combining/blending said funds;

Evidence of technical assistance provided by stakeholder group in support of the district’s and schools’ capacity to plan and implement Title I schoolwide programs, and

Evidence of notices, agendas, schedules, meeting minutes, relevant handouts the district has provided to help schools build capacity to plan and implement Title I schoolwide programs.

CONTACT US…

The Office of Title I

609-943-4283

titleone@doe.state.nj.us