Comprehensive School Reform Program

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Guidance on the Comprehensive School Reform Program
Updated August 2002
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F. State Awards to LEAs

F-1. What entities are eligible to apply to an SEA for CSR funds?

LEAs and consortia of LEAs are eligible to apply to their SEA on a competitive basis as follows -

  • CSR funds appropriated under the Title I, Part F authority: Only LEAs or consortia of LEAs with schools that are eligible for funds under Part A of Title I may apply for CSR funds appropriated under Title I, Part F. The funds must be used to support CSR activities in Title-I eligible schools.

  • CSR funds appropriated under the FIE authority: Any LEA or consortium may apply for CSR funds appropriated under FIE authority, whether or not the schools that would receive support are eligible for Title I, Part A funds.

F-2. How does an LEA apply to its SEA for CSR funds?

Application options for LEAs applying for CSR funds are contingent upon the process the State uses to apply for CSR funds from the Department -

(a) If an SEA applies to the Department for CSR funds through use of a consolidated State application, it may -

  • require its LEAs seeking CSR funds to apply as part of a consolidated local application; or

  • permit its LEAs to apply using either an individual program application or as part of a consolidated local application.

However, the SEA may not require its LEAs to complete an individual program application when applying for CSR funds.

(b)If an SEA applies to the Department for CSR funds through an individual program application, it must -

  • permit its LEAs to apply for a CSR subgrant through an individual program application or as part of a consolidated local application. (See section 9305 of the ESEA.)

F-3. What priorities and considerations must an SEA address in designing its LEA application?

In awarding competitive subgrants, the SEA must develop criteria for judging the quality of an applicant's comprehensive school reform proposal. The criteria should be designed to ensure that funded proposals are likely to be successfully implemented and improve the academic achievement of all students in core academic subjects in the participating schools. Strong applications will reflect the spirit and intent of the CSR legislation, which is to empower schools to design and implement their own comprehensive plan for improvement. This plan must address the eleven discrete components, each of which has a strong effect on school functioning, but do so in a manner that results in the whole being greater than the sum of its parts. The comprehensive integration of the components is crucial. (See B-1 and Appendix B [[downloadable files] MS WORD (45K) | PDF (154K)].)

Required priority for subgrants under Part F of Title I:

In awarding subgrants under Title I, Part F, an SEA must give priority to LEAs or consortia that -

(1) plan to use CSR funds in schools identified as being in need of improvement or corrective action under section 1116(c) of the ESEA;
and
(2) demonstrate a commitment to assist these schools with budget allocation, professional development, and other strategies necessary to ensure that the comprehensive school reforms are properly implemented and sustained, such as providing assistance with school needs assessments and planning processes, decentralized decision making, or the reallocation of financial or other resources.

To meet this priority, an LEA or a consortium of LEAs must target schools that are in need of improvement or corrective action and must agree to assist those schools using the strategies necessary to ensure that their reforms are properly implemented. An SEA may comply with this legislative requirement by giving a competitive preference (i.e., additional points in a competition) to LEAs that submit proposals that meet both of the priority conditions.

Because of the strong and specific emphasis in the CSR legislation on assisting schools identified as in need of improvement or corrective action, an SEA may also establish an absolute priority that restricts all awards under Title I, Part F to LEAs that meet the priority conditions.

Considerations under either CSR authority

In awarding CSR subgrants under either authority, an SEA must also take into consideration the equitable distribution of subgrants to different geographic regions within the State, including urban and rural areas, and to schools serving elementary and secondary students.

F-4. May a State establish priorities in addition to those that are required?

A State may establish other priorities as a part of its overall school reform strategy and to further the purposes of the CSR program. For example, a State may give preference to applications that demonstrate an alignment with State or Federal reform priorities in core academic areas. Such priorities should be designed to give schools or programs a competitive edge in the subgrant selection process rather than entirely precluding non-priority programs or schools. For example, in awarding CSR funds, a State may give a competitive priority to schools at a particular grade level, such as elementary, middle, or high schools, but may not entirely exclude schools at other grade levels.

An SEA may also give a competitive preference to LEAs that would use funds appropriated under the FIE authority in Title I-eligible schools. Congress appropriated CSR funds under the FIE authority for the purpose of making other schools eligible for support; therefore, an SEA may not establish an absolute priority that would limit eligibility for FIE support to only Title I schools.

Because the legislation expressly permits their use, an SEA may not establish an absolute priority that prevents schools seeking to implement a locally developed model from receiving CSR support.

F-5. Do SEAs have flexibility regarding the timing of their subgrant competitions?

Yes. Fiscal year 2002 CSR funds will be available for obligation by an SEA or LEA through September 30, 2004. Accordingly, an SEA may decide to delay its competition until it believes that most eligible schools have had sufficient time to determine their needs and design their comprehensive school reform programs. However, this strategy provides LEAs with less time to obligate funds. An SEA could also run separate competitions, awarding a portion of its funds soon after the State receives them and reserving the remaining funds for LEAs with schools that need additional time to design a comprehensive program to meet their needs.

F-6. What key issues must an LEA address in applying for CSR funding?

Individual LEA applications for CSR funds must contain the following information -

  1. Identification of the schools to be assisted and the costs of the program

    The applicant must identify which of its eligible schools plan to implement a comprehensive school reform program and the projected costs of such a program.

    Although LEAs or a consortium of LEAs may apply for CSR funds on behalf of one or more schools, the merit of each school's comprehensive design must be evaluated for funding independently of the others contained in the same application.

  2. Description of the reform to be implemented

    The applicant must describe the comprehensive school reform program that each eligible school would implement. The LEA must demonstrate that each school has woven scientifically based research, effective practice, and proven methods into an integrated, comprehensive program that addresses the eleven components described in B-1. Among other requirements, the program must employ proven strategies and methods for student learning, teaching, and school management that are based on scientifically based research and effective practices and have been replicated successfully in schools. In addition, the overall program must have been found, through scientifically based research, to significantly improve the academic achievement of students participating in such a program, or there must be strong evidence that the program will accomplish these results.

  3. Description of LEA support

    The LEA must describe how it will provide the technical assistance and support that is essential for the effective implementation of comprehensive school reform programs in its schools. (See H-4 and H-5.)

  4. Evaluation strategies

    The applicant must describe how it will evaluate the implementation of comprehensive school reform programs in its schools and measure the results achieved in improving student academic achievement for all students in participating schools.

  5. Additional information

    Each LEA application must also include the following:

    (a) the amount of CSR funding, if any, requested for LEA administration, technical assistance, and evaluation activities (in addition to that requested for school-level activities) and an explanation of how those funds will be used (See E-4, F-7, and F-16.);

    (b) a description of the steps the LEA proposes to take to overcome barriers to equitable program participation, as required under section 427 of the General Education Provisions Act;

    (c) the general assurances in section 9306 of the ESEA;

    (d) an assurance that CSR funds will be used only to supplement, and not supplant, Federal, State, and local funds a school would otherwise receive; and

    (e) the lower-tier certification covering lobbying and debarment/suspension under 34 CFR Parts 82 and 85.

F-7. What is the minimum amount of CSR funding that an SEA may provide to an LEA or consortium?

Each award that an SEA makes must be of sufficient size and scope to support the initial cost of implementing the comprehensive school reforms selected or developed by each school that receives assistance.

At a minimum, the SEA must award at least $50,000 for each participating school, or for each participating consortium of small schools. The SEA must renew the initial award that an LEA or consortium receives for two additional one-year grant periods if the school or schools are making substantial progress in the implementation of their reform program.

An SEA may not simply provide all successful applicants with a minimum award of $50,000 for each participating school if that amount is insufficient to enable each school to meet the purposes of the CSR program. In many instances, the amount of funding that a school will need to support the successful implementation of comprehensive school reforms will be greater than $50,000 annually over the three- year funding period.

In addition to providing an LEA or a consortium of LEAs with funds to support school-level activities, the SEA may provide an LEA funds to support reasonable and necessary costs that an LEA may incur for administrative expenses, technical assistance, and evaluation activities. The LEA may not deduct funds to meet these expenses from a school's allocation. As a part of the application process, the LEA must provide an explanation of how those funds will be used. (See E-4, F-6, and F-16.)

F-8. What is a consortium of small schools?

The CSR legislation defines a consortium of small schools as one serving a total of not more than 500 students.

F-9. How does the legislative requirement for a minimum award of $50,000 per school apply to a consortium of small schools?

If an SEA provides CSR support to a consortium of small schools, the $50,000 annual minimum award applies to the consortium rather than to each school in the consortium.

An individual school that applies for and receives CSR funds through its LEA--regardless of its size--must receive at least $50,000 annually for up to three years.

F-10. May a consortium of LEAs apply for CSR funds?

Yes. Consistent with the Education Department General Administrative Regulations (EDGAR) requirements, two or more LEAs may apply to their SEA as a consortium. To receive funds authorized under Title I, Part F, each LEA within the consortium must apply on behalf of schools that are eligible to receive funds under Title I, Part A and otherwise meet the funding criteria. An LEA consortium applying for funds made available under the FIE authority may use those funds to support comprehensive school reforms in both Title I-eligible and non Title I-eligible schools.

F-11. If a consortium of LEAs is funded, must each participating school within the consortium receive a minimum award of $50,000 annually?

The SEA must award at least $50,000 annually to each school in an LEA consortium unless the consortium is applying on behalf of small schools and the total number of students served by the consortium does not exceed 500 students. (See F-8 and F-9.)

F-12. May an SEA award funds to some, but not all, of the schools that an LEA or consortium of LEAs has included in its CSR application?

Yes. Although an SEA may choose to fund all of the schools for which an LEA or consortium of LEAs has requested funds, it may also decide to fund some and not others. The SEA must independently evaluate the quality of each school's comprehensive reform proposal and its likelihood of success.

F-13. May an SEA use CSR funds to support planning activities in schools that have not yet designed their comprehensive reform program?

No. CSR funds are intended to assist schools that have already undergone the planning necessary for successful implementation of a comprehensive school reform program. An LEA's application for CSR funds must describe, among other things, the comprehensive school reforms based on scientifically based research and effective practices that the schools will implement. A CSR-funded school may, however, use its funds to enhance and strengthen the various components of its program or to better integrate those components.

F-14. Should CSR funds be used to support schools that are already implementing a comprehensive school reform program?

No. Schools already engaged in comprehensive reform may not receive CSR funds. CSR funds support schools that have completed all of the required preliminary steps and are ready to begin implementing a comprehensive school reform program. Schools that have previously engaged in only piecemeal attempts at reform-e.g., rewriting curriculum or increasing professional development-without integrating those strategies into a comprehensive design, but are now ready to take a whole-school approach, are eligible for CSR funds. (See G-1.)

F-15. If an LEA submits virtually identical applications to an SEA on behalf of different schools, should the SEA consider such proposals for funding?

LEAs are responsible for ensuring that each school develops a unique program, based on each school's needs assessment, an analysis of those needs, and the goals developed as a result of that analysis. The eleven CSR components must be integrated and addressed coherently. A "one size fits all" proposal is not likely to address adequately the individual needs of each qualifying school. SEAs must evaluate the merit of each school's comprehensive design independently of any others contained in the same application.

F-16. May an LEA or consortium use CSR funds to cover administrative costs, technical assistance, and evaluation activities?

LEAs and consortia that receive CSR support must receive awards that are of sufficient size and scope to support the initial costs of implementing CSR activities in the participating schools. The award may not be less than $50,000 annually for each participating school, with the exception of a consortium of small schools, which may receive the $50,000 minimum for the consortium as a whole. An LEA may not deduct from these award amounts funds for administrative costs, technical assistance, or evaluation.

SEAs may provide LEAs with additional CSR funding (i.e., funding beyond the amounts referenced in the preceding paragraph) to support reasonable and necessary expenses for administration, technical assistance, and evaluation activities. (See E-4 and F-6.)

F-17. Are public charter schools eligible to participate in the CSR program?

If a charter school is an LEA, it may apply to the State for CSR funds on the same basis as other LEAs in the State. (See F-1.) If a charter school is not an LEA, it may receive support only through an LEA that applies on its behalf.

F-18. What are the implications for CSR awards of the charter school provisions in section 5206 of the reauthorized ESEA?

Section 5206 of the ESEA requires that public charter schools be permitted to compete for CSR funds on an equal footing with other public schools and LEAs. States may not create competitive preferences or absolute priorities for the purpose of excluding charter schools from competing for CSR funds and may not discriminate against these schools in awarding funds simply because of their charter school status. States and districts should use a clearly defined process and criteria to determine which schools--including charter schools and other public schools--are most deserving of CSR support. The criteria should distinguish among CSR applicants on the basis of a particular school's need for reform and the quality of the proposed program.

F-19. Are private school children eligible to participate in the CSR program?

No. There is no provision in the CSR legislation for providing services to private school children. The CSR program is specifically designed to stimulate comprehensive reform of a school's entire operation. Generally, services for private school children under Federal education programs must be provided by employees who are under public supervision and control, and must benefit private school children and their teachers directly, not the private school in general.

F-20. Are Bureau of Indian Affairs (BIA)-funded schools eligible to compete for CSR funds?

Yes. The Department allocates CSR funds each year to the Bureau of Indian Affairs (BIA). The BIA then makes competitive subgrants to BIA-funded schools. BIA-funded schools that meet the definition of an LEA as defined in section 9101(26) of the ESEA are also eligible to apply to the State for CSR funds. However, although these schools may participate in both the BIA and SEA competitions, they may not receive CSR funds from both sources.

F-21. On what basis does an SEA award continuation funding to subgrantees?

The decision to continue CSR funding beyond the initial year is based on the SEA's determination that the participating school has made substantial progress in the implementation of reforms. The Department strongly recommends that a State fund continuation awards only after it has determined that schools have made progress in implementing their CSR plans and achieving their benchmarks. Possible indicators of implementation progress include measures of the school staff's awareness of and involvement in the reform; the amount and quality of professional development; or the degree to which the reform plan is being implemented in every classroom. SEAs should develop clear and consistent criteria by which they make this determination.

F-22. If an SEA determines that a CSR school is not making substantial implementation progress, what becomes of the school's subgrant funds?

If an SEA determines that a school is not making substantial progress and decides not to award the school a second or third year of its subgrant, the SEA must use the funds to establish new CSR programs (if the SEA can fund these new programs for a full three years) or to support comprehensive school reform activities at other existing CSR sites.


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Last Modified: 12/03/2004