Policy Guidance for Title I, Part A: Improving Basic Programs Operated by Local Educational Agencies - April 1996
A r c h i v e d I n f o r m a t i o n
Targeted Assistance Schools
A targeted assistance school, primarily addressed in section 1115 of Title I, Part A, is one that receives Part A funds yet is ineligible or has chosen not to operate a Title I schoolwide program. The term "targeted assistance" signifies that the services are provided to a select group of children--those identified as failing, or most at risk of failing, to meet the State's challenging content and student performance standards--rather than for overall school improvement, as in schoolwide programs. Like schoolwide program schools, the goal of a targeted assistance school is to improve teaching and learning to enable Part A participants to meet the challenging State performance standards that all children are expected to master. To accomplish this goal, a targeted assistance program must be based on effective means for improving achievement of participating children; use effective instructional strategies that give primary consideration to extended-time strategies, provide accelerated, high-quality curricula, and minimize removing children from the regular classroom during regular school hours; coordinate with and support the regular education program; provide instruction by highly-qualified and trained professional staff; and implement strategies to increase parental involvement.
A targeted assistance school differs from a schoolwide program school in several significant respects:
- Part A funds may be used in targeted assistance schools only for programs that provide services to eligible children identified as having the greatest need for special assistance.
- Part A funds must be used for services that supplement, and do not supplant, the services that would be provided, in the absence of the Part A funds, from non-Federal sources.
- Records must be maintained that document that Part A funds are spent on activities and services for only Part A participating students.
One of the primary differences between schoolwide program schools and targeted assistance schools is the requirement that the latter may use Title I, Part A funds only for programs that provide services to eligible children identified as having the greatest need for special assistance. Targeted assistance schools, therefore, may not provide services to all children in the school or in particular grades.
In the new Title I, schools play the key role in selecting children to participate in Part A programs. No longer is there a requirement for a districtwide needs assessment in which children are selected on the basis of uniform criteria across the LEA as a whole. Rather, as described below, an LEA establishes multiple, educationally related, objective criteria to determine which children are eligible to participate in Part A. Each targeted assistance school may supplement these criteria and selects, from among its eligible children, those who are in greatest need for Part A assistance.
- Children eligible for Part A services must be from the following populations:
- Children not older than age 21 who are entitled to a free public education through grade 12.
- Children who are not yet at a grade level where the LEA provides free public education, yet are of an age at which they can benefit from an organized instructional program provided in a school or other educational setting.
- Eligible children are children who are failing, or most at risk of failing, to meet the State's challenging student performance standards.
- A targeted assistance school generally identifies eligible children within the school on the basis of multiple, educationally related, objective criteria established by the LEA and supplemented by the school.
- Children who are economically disadvantaged, children with disabilities, migrant children, and limited English proficient (LEP) children are eligible for Part A services on the same basis as other children that are selected for services. Thus, schools are no longer required to demonstrate that the needs of LEP students stem from educational deprivation and not solely from their limited English proficiency. Similarly, schools are no longer required to demonstrate that the needs of children with disabilities stem from educational deprivation and not solely from their disabilities.
- Children from preschool through grade two must be selected solely on the basis of such criteria as teacher judgment, interviews with parents, and developmentally appropriate measures that determine which children are failing, or most at risk of failing, to meet the State's challenging content and student performance standards.
Certain children are considered at risk of failing to meet the State's student performance standards and are thus eligible for Part A services by virtue of their status:
- Children who participated in a Head Start or Even Start program at any time in the two preceding years.
- Children who received services under a program for youth who are neglected, delinquent, or at risk of dropping out under Part D of Title I (or its predecessor authority) at any time in the two preceding years.
- Children in a local institution for neglected or delinquent children or attending a community day program.
- Homeless children attending any school in the LEA.
- From the universe of eligible children in a targeted assistance school, the school selects those children who have the greatest need for special assistance to receive Part A services. Because it is likely that a school will not have sufficient Part A resources to provide services to all eligible children, the school must obviously make some informed choices concerning which children to serve. These choices are difficult because they inevitably result in some children being selected before other children who may also have significant needs. School staff, in consultation with the LEA and based on a review of all the information available about the performance of eligible children, must use their best professional judgment in making these choices. It is not so simple as merely selecting a cut-off score on an assessment measure. School staff will necessarily need to balance the needs of different populations. For example, most schools will likely need to concentrate Part A resources in certain grades or in certain subjects to the exclusion of children in the grades or subjects not being served. Similarly, a school may decide that some children who are homeless have greater needs because, for instance, homeless children may likely face problems of attendance and homework completion due to recurrent moves and, therefore, may be at greater risk of failure than some other children who are not faced with the disruption associated with homelessness. Furthermore, schools and LEAs that focus strongly on family literacy, for example, may add the additional educationally-related criterion of the educational level of parents when selecting those children who are most in need of Part A assistance from the eligible pool of students to be served.
Other target populations, such as children with disabilities and LEP children, present similar choices. Those children are now eligible for Part A services on the same basis as other eligible children. However, they are also entitled to non-Part A services required by law because of their disability or their limited proficiency in English. A school may decide that the non-Part A services those children are receiving are sufficient to enable them to meet the State's challenging standards. However, children with disabilities or limited-English proficiency who are performing more poorly than other Title I-eligible children, even with the benefit of the non-Title I services they receive, may still be among those in greatest need and thus should receive Part A services also.
Q1. May an LEA and school use Part A funds to identify at-risk students?
A. No. It is the responsibility of the LEA and school to identify at-risk students from State or local sources. Once eligible children are identified, Part A funds may be used to identify those most in need or to identify their specific educational needs.
Q2. May a school provide services to particular children for less than a full school year?
A. A school may serve students who are in greatest need of assistance for only a particular skill for the period of time it takes the student to master the skill. In other words, if not necessary, a student need not be a participant for an entire school year.
Part A emphasizes the roles of the school, LEA, and SEA to create an environment of improved teaching and learning for all children, particularly those who are furthest from meeting the State's challenging content and performance standards. The key components contained in the Targeted Assistance Schools section of Title I, Part A reflect the focus of teaching and learning--coordinating students' educational programs and employing effective strategies for improving student achievement.
One of Title I's most significant changes brings Part a program decisions to the school level. Schools, in consultation with their districts, determine the uses of funds that best meet the needs of their students. The new Title I, Part A distributes funds to schools based on the number of children from low-income families in the school or school attendance area. The school then selects the children to serve, based on those who are most in need of service in the school and on the amount of funds available.
Each Title I targeted assistance school must work with its district to determine how to use its Part A funds in ways that make the most sense for its students. Bringing these decisions to the school level will transform Part A from a district-directed "one-size-fits-all" program to a significant resource for schools to use to meet the needs of their most at-risk students. For example, a school can take into consideration times that students participate in other activities and design a Part A program that optimally allows the students to participate in the regular program of instruction. Although LEAs establish general student eligibility criteria, the fact that schools may add school-level criteria and select those children in greatest need will ultimately result in varied Part A services from school to school. However, each of an LEA's twenty schools might add a set of supplemental, multiple, educationally-related objective criteria to select students in the school. Given that each of these schools could have different selection criteria, it is likely that many Title I schools in the LEA will offer different Part A services. For example, one school might offer reading services to the primary grades, another might offer reading to all grades and math in grades 4 through 6, while another might focus on reading along with an intensive professional development component.
Title I has a clear goal--enabling participating children to achieve to challenging State content and performance standards. To meet this goal, section 1115(c) requires that each targeted assistance program include certain components that research suggests are essential to any high-functioning program.
Under Section 1115(c), a targeted assistance program includes the following 8 components. It must--|
1. Use Part A resources to help participating children meet the State's student performance standards expected for all children.
In order to do this, programs must:
2. Be based on effective means for improving achievement of children.
3. Ensure that planning for participating students is incorporated into existing school planning.
4. Use effective instructional strategies that--
- Give primary consideration to providing extended learning time such as an extended school year, before- and after-school, and summer programs and opportunities.
- Help provide an accelerated, high-quality curriculum.
- Minimize removing children from the regular classroom during regular school hours for Part A instruction.
5. Coordinate with and support the regular education program, which may include--
- Counseling, mentoring, and other pupil services.
- College and career awareness and preparation.
- Services to prepare students for the transition from school to work.
- Services to assist preschool children's transition to elementary school.
6. Provide instruction by highly qualified staff.
7. Provide professional development opportunities with Part A resources, and other resources, to the extent feasible, for administrators, teachers, and other school staff who work with participating children.
8. Provide strategies to increase parental involvement, such as family literacy services.
Q3. Does Title I define "highly qualified staff?"
A. The Title I statute does not define "highly qualified staff." Nor does Title I require special certifications or degrees (with the exception of provisions related to instructional aides) for staff paid from Part A funds. The law's intent is for Part A participants to receive assistance from staff who have the knowledge and teaching skills that will enable participants to meet the challenging content and student performance standards that States set for all their students.
Each targeted assistance school must assist Part A participants in meeting the State's proficient and advanced levels of performance by--
- Coordinating Part A resources with other resources.
- Reviewing, on an ongoing basis, the progress of participants and revising the targeted assistance program, if necessary, to provide additional assistance to enable them to meet the State's challenging student performance standards.
Children with disabilities and LEP children are eligible for Part A services on the same basis as other children who are selected for services. However, they are also entitled to services required by law because of their disability or their limited proficiency in English. To avoid supplanting, a targeted assistance school may not use Part A funds to provide the level of services necessary to meet Federal, State, or local law requirements for limited-English-proficient children or children with disabilities. Part A funds may be used, however, to coordinate and supplement these services as well as to provide additional direct services to these children. In particular, there is no prohibition from providing Title I services in the same subject area in which a child is receiving special education services or services to address limited-English proficiency. For example, a special education student being provided with special education services in reading that are sufficient to meet the requirements of Part B of the Individuals with Disabilities Education Act (IDEA) may also be provided Part A services in reading if the school identifies the student as being in greatest need of assistance for meeting the State's challenging content and student performance standards. The non-Part A services alone, however, must be sufficient to meet the requirements of Part B of IDEA.
Examples of Title I-Funded Services for LEP Students:
- Title I funds are used to pay the salaries of instructional staff who work with those students having academic difficulties, including LEP students, as well as for native language instructional materials where the district's selected alternative language program only requires use of the English language as a means of instruction. Such staff includes additional ESL/bilingual teachers above and beyond what is paid for with Title VII funds and funds from comparable state programs, as well as other staff who work closely with the ESL bilingual teachers and regular classroom teachers.
- An LEA has a Title I-funded accelerated before- and after-school program for LEP students. One part of the program pairs high school and elementary school students for activities such as shared reading and writing time. Guided reading, math, and science activities and reinforcement of content concepts studied during the day are also an integral part of these sessions.
- An LEA uses Title I funds for an accelerate summer academic program for LEP students to build upon the skills that are developed during the school year in literacy and content mastery. One part of the program groups Title I-eligible LEP students by grade level and teams them with English-proficient Title I students. This gives the LEP students greater opportunity for English language usage. The content-based language instruction program is taught by a team of teachers--pairing a bilingual and non-bilingual staff member in each class. A variety of activities, such as field trips, are an integral part of the instructional program and provide opportunities to enrich language experiences.
Examples of Title I-Funded Services for Disabled Students:
- A teacher provides supplemental instructional assistance to disabled Title I students during their mainstreamed instructional activities. For example, for a disabled student who has been determined to be at-risk in language arts, the teacher provides assistance during the time the student is mainstreamed into language arts activities. This in-class teacher works with all children in the language arts class who are eligible and have been selected to receive Title I services. In this manner, there is maximum coordination with the regular classroom teacher since services are provided in the regular classroom and the disabled students are not segregated from non-disabled students when Title services are provided.
- A special education teacher is multiple-funded by special education funds and Title I funds in order to teach disabled students for a portion of the day and Title I students for a portion of the day. In the portion of the day during which the teacher works with Title I students, the teacher works with some of the disabled students who are eligible and have been selected to receive Title I services. In this manner, there is automatic coordination for those students in special education and Title I since the same teacher provides both services. This teacher also spends significant time with the regular teacher coordinating Title I and regular services for the non-disabled Title I students.
Migrant children are eligible for Part A services on the same basis as other children who are selected to receive services. However, when migrant children arrive at a school during the school year, they may often be unable to receive Part A services because the school has already allocated all its Part A funds. Because LEAs that currently receive migratory children normally do so on a regular basis, LEAs should plan for their arrival and consider their needs when planning, or helping schools to plan, Part A services. Adequate funds should be reserved so that migrant children, who are otherwise eligible for Part A services, receive services even if they arrive in the LEA well into the school year and remain for a limited period of time.
In meeting the needs of migrant children, States, LEAs, and targeted assistance schools have the flexibility under section 1306(b) of Title I, Part C to use Migrant Education Program (MEP) funds interchangeably with Part A funds. This flexibility can be exercised, however, only after MEP funds are first used to meet the identified needs of migrant students that--
- Result from the effects of their migrant lifestyle, or are needed to allow migrant students to participate effectively in school.
- Are not addressed by services provided under other programs, including programs under Title I, Part A.
If MEP funds remain after these unique needs have been met, the MEP funds may be used interchangeably with Part A funds to provide services that are determined to be necessary for the migrant children who are eligible under Part A. Section 1306 does not create a statutory priority to serve migrant children eligible for services under Part A ahead of other Part A-eligible children. Rather, section 1112(b)(8) of Part A makes clear that migrant children eligible for Part A services must be selected on the same basis as other children who are eligible to receive Part A services.
[Targeted Assistance Schools: Serving Students Who Participate in Educational Choice Programs]