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

Providing Services to Eligible Private School Children


Contents


Introduction

The Title I program provides supplemental educational services for eligible public and private school students to assist those children in acquiring the knowledge and skills necessary to meet the challenging student performance standards that all children are expected to meet.

Section 1120 of Title I requires that an LEA provide eligible private school children with Title I educational services or other benefits that are equitable to those provided to eligible public school children. Title I services for eligible private school children must be developed in consultation with private school officials.

Consultation

Section 1120(b) requires that, to ensure timely and meaningful consultation, an LEA consult with appropriate private school officials during the design and development of the LEA's Part A programs, on such issues as the following:

Consultation must take place before an LEA makes any decisions that affect the opportunities of eligible private school children to participate in Title I programs. This includes decisions about reserving funds "off the top" of the LEA's allocation for LEA-wide activities before funds are allocated to participating areas and schools. In addition, because generation of funds and eligibility of private school children for services are dependent upon residence in a participating public school attendance area, an LEA must share the results of its selection process with private school officials early in the consultation process. Other information that must be provided in the consultation process includes the following data on each participating area: grade span, the number of low-income public and private school children residing in the area, and the per-pupil allocation of each public school participating area. (See Generating Funds for Services to Eligible Private School Children)

Consultation should include representatives of private schools and central administrative offices, if any. It would be helpful if private school officials make clear to the LEA which officials should be included in the consultation process, and what the roles of various individuals will be. It may be useful to include in the consultation process any third-party contractors providing Title I services for private school children.

A unilateral offer of services by an LEA with no opportunity for a discussion is not adequate consultation. Only after discussing all the facets of the provision of services does the LEA make the final decisions with respect to the Title I services to be provided to eligible private school children. If the LEA and private school officials cannot resolve an issue through consultation, the SEA may help the parties resolve the matter without requiring a formal complaint.


EXAMPLE:

Many LEAs provide advance notice of scheduled meetings through a published yearly calendar, letters, telephone calls, or a published notice. A letter of invitation explaining the intent of Title I (including the role of private school officials) is often the means LEAs use to inform private school officials about the Title I program and initiate the consultation process.


Ongoing coordination of services is essential in order to provide private school participants an optimal opportunity to reach challenging standards. Thus, it is very important that Title I teachers of private school participants and LEA officials consult with private school officials and instructional staff in order to coordinate Title I services with regular classroom instruction. These coordination activities should not take place during instructional time and may occur at a public or private school site, a neutral site, or by telephone.


EXAMPLE:

In one program the Title I teachers have a simple form for regular classroom teachers to complete periodically, informing the Title I teacher of the child's individual needs as well as subject content and skills being taught in the regular classroom. The Title I Classroom teachers send notes to the Title I teacher as necessary.


Generating Funds for Services to Eligible Private School Children

Under section 1113(c) of Title I, public school attendance areas are generally eligible to participate in Title I if the percentage of children from low-income families is at least as high as the percentage of children from low-income families in the LEA as a whole. An LEA ranks its eligible areas and selects, in rank order, those areas that the LEA will serve. For areas above 75 percent poverty, the LEA must serve them without regard to grade span; thus, high-poverty middle and high schools must be served. After an LEA has selected for services all areas above 75 percent poverty, the LEA may serve lower ranked areas by grade-span groupings. Thus, the LEA may decide to serve, for example, only elementary schools or a combination of elementary and middle schools, but not high schools.

In identifying and ranking eligible public school attendance areas, an LEA generally should, if possible, take into consideration data on the number of children from low-income families who reside in each area and attend private schools. For an LEA to include numbers of such children, however, would require adequate poverty data on private school children throughout the LEA. Because obtaining these data for the entire LEA may be extremely difficult, an LEA may identify and rank its eligible school attendance areas on the basis of children from low-income families attending public schools only.

Under section 1113(c) of Title I, an LEA must allocate funds to a participating public school attendance area or school on the basis of the total number of children from low-income families, including low-income children attending private schools. Thus, the LEA, in consultation with private school officials, must obtain the best available poverty data on private school children who reside in participating attendance areas. Because private school officials may have access to some sources of poverty information not easily accessible to public school officials, it is very important that public and private school officials cooperate in this effort.

Collecting Poverty Data on Private School Children

An LEA may use the following methods to obtain poverty data on private school children. Proportionality may be used only as a last resort and only for the 1995-96 school year.

1. Data from the same source. An LEA may use poverty data from the same source for both public and private school children, e.g., free and reduced-price lunch data.

2. Comparable data. If data from the same source are not available, an LEA may use poverty data for private school hildren that are from a different source than the data it uses for public school children as long as the income level for both sources is generally the same. For example, the LEA uses free or reduced-price lunch data but private school children do not participate in the free lunch program; however, private school officials are able to provide the LEA a count of children who would be eligible for free or reduced-price lunches using other sources of poverty data such as a survey of parents, Aid to Families with Dependent Children (AFDC), or tuition scholarship programs.

Some LEAs conduct a survey that requests comparable data on low-income families whose children attend private schools. The only information necessary for the LEA to include for private school children is (1) address, (2) grade level of each child, (3) size of the family, and (4) the income level of parents. An LEA is not required to have the names of the families.


EXAMPLE:

Surveys yielding good data have some common characteristics. The survey itself is simple and understood by parents, including parents with limited knowledge of English. Letter of explanation are sent to principals and meetings are held with them to explain the necessity and importance of the survey. Principals are encouraged to meet with the parents, then distribute the surveys. After a period of time has lapsed, during which the surveys should have been received, the principals begin to follow-up with those parents who have not returned them. Parents are assured that the completed individual survey forms will be kept in confidence at the private school.



EXAMPLE:

One school district finds that sensitive data, such as income level, are most easily collected when the families providing the data feel that their privacy is being protected. For this reason they use only a numbering system to identify the families, and do not require any names on the form. Each principal is given a copy of the form and instructed to number the forms and keep a log. They inform parents that their names will only be rematched to the numbers if they do not return the form (i.e., in order to contact them). Printed at the bottom of the form is "This form has been numbered to protect your privacy. Once we receive the information requested, any correlation of this number to your family's name will be kept in strict confidence."


3. Extrapolation from a representative sample of actual data. If complete actual data are not available under 1. or 2. above, an LEA may extrapolate the number of low-income private school children from actual data on a representative sample of private school children. The representative sample size should be large enough to reasonably conclude that the poverty estimate is accurate.

Column 1 Column 2 Column 3 Column 4 Column 5
Public School Attendance Area Number of Private School Children Resideing in each Attendance Area Number of Private School Children on Returned Surveys in each Attendance Area (Poor & Non-Poor) Number of Poor Private School Children on Returned Surveys in Each Attendance Area Extrapolated Number of Poor Private School Children in each Attendance Area
A 150 115 100 130
B 20 10 4 8

      Col. 5                    Col. 2                Col. 4 (Extrapolated poor) =  (Total private in area)  X (Poor on survey)                        -----------------------                        Col. 3 (Poor & Non-poor) 
4. Correlation of sources of poverty data. An LEA may obtain the number of poor private school children by correlating sources of data--that is, by determining the proportional relationship between two sources of data on public school children and applying that ratio to a known source of data on private school children. For example, AFDC in public schools is to free and reduced-price lunch in public schools as AFDC in private schools is to X (correlated free and reduced-price lunch in private schools).
          AFDC (public)                       AFDC(private) ------------------------------------    =    -------------- Free and reduced price lunch (public)         X (private) 
5. Proportionality. If there are no other adequate sources of data available to determine the number of poor private school children residing in each area, an LEA may use proportionality--that is, apply the poverty percentage of each participating public school attendance area to the number of private school children who reside in that area to obtain the number of poor private school children residing in each area. The LEA may use proportionality for the 1995-96 school year ONLY.

Allocating Title I Funds

Before allocating Title I funds to participating school attendance areas, an LEA reserves, off the top of its Title I allocation, funds needed, for example, to provide services to children in local institutions for neglected children, to meet the requirements for parental involvement, or to administer Title I programs for public and private school children, including any capital expenses not paid for from funds provided under section 1002(e) of Title I. Then, the LEA allocates funds to public school attendance areas, identified as eligible and selected to participate, in rank order of poverty on the basis of the total number of children--public and private--from low-income families residing in each area. Thus, unlike Chapter 1 under which funds were distributed on the basis of the numbers and needs of the children being served, Title I requires an LEA to allocate funds on the basis of all children from low-income families residing in participating areas. The LEA determines a per-pupil allocation (PPA) for each participating area and distributes that amount for each low-income child--public and private--residing in the area.

Public school attendance area Column A Per Pupil allocation (PPA) by area Column B Number of public school low-income children by area Column C Number of private school low-income children by area Column D Total allocation for each area [Col. A x (Col. B + C)] Column E Amount available for services to private school children (Col. A x Col. C)
A $800 500 130 $504,000 $104,300
B $700 300 8 $215,600 $5,600
C $600 200 3 $121,800 $1,800
D $500 400 17 $208,500 $ 8,500

To provide equitable services to eligible private school children, the LEA then reserves the amounts generated by poor private school children who reside in participating public school attendance areas. In consultation, the LEA and private school officials choose one, or a combination of, the following options for using the funds reserved for private school children:


EXAMPLE
Allocating Instructional Funds for Private School Children

Step 1: Multiply number of Poor Children By Public School PPA

          Two Private Schools              Five Public Attendance Areas   School #1          20 Poor                          A  20 x $400=$8000          20 Poor                          B  20 x $200=$4000            2 Poor                          C  13 x $200=$2600                                            (from School #2 below)                                         Non-Title I Public Attendance Areas School #2                                  13 Poor                           D    2 x $0=$0                                               (from School #1 above)          4 Poor                           E    4 x $0=$0  

Step 2: In Consultation, Determine Option For Using Funds

     Option A:     Combine Funds Allocated on the Basis of All Eligible Poor                    Private School Children for Eligible Educationally                    Needy Private School Children                              Pooling                     Private School #1 = $12,000                    Private School #2 = $ 2,600                                        -------                    Total for Title I Instruction for                    Eligible Chidren    $14,600         Option B:    Use Funds Allocated on the Basis of Poor Children Who                    Attend Individual Private Schools for Eligible                    Educationally Deprived Children in Each Individual                    Private School         Private School #1                         Private School #2
20 Low Income Residing in A = $8,000    13 Low Income Residing in C = $2,600 20 Low Income Residing in B = $4,000    04 Low Income Residing in E = $0,000 02 Low Income Residing in D = $0,000    ------------------------------------ ------------------------------------        Total for Eligible Private Total for Eligible Private                  School Children in #2   = $2,600 School Children in #1      = $12,000                                --------                            --------- 

Q1. When an LEA elects not to serve an eligible public school attendance area, as allowed in section 1113(b)(1)(C), what are the procedures under section 1113(b)(2) for serving the private school children who reside in that attendance area?

A. An LEA may elect not to serve ("skip") an eligible attendance area or school that has a higher percentage of children from low-income families if (1) the school meets the comparability requirements, (2) the school is receiving supplemental funds from other State or local sources that are spent according to the requirements of section 1114 or 1115, and (3) the funds expended from such other sources equal or exceed the amount that would be provided under Part A. Services for eligible private school children, however, must be determined without regard to whether any public school attendance areas are skipped.

In implementing this provision, therefore, an LEA must determine which school attendance areas would have received Title I funds absent any skipping and what the per-pupil allocations for those areas would have been. The LEA must then determine the amount of funds that would have been generated by low-income private school children residing in those school attendance areas. This amount is the amount available for serving eligible private school children in the LEA. If the LEA uses non-Title I funds to serve one or more of its higher-ranked school attendance areas, enabling the LEA to use Title I funds to serve additional lower-ranked areas, low-income private school children residing in those additional areas would not generate funds. If, however, the LEA decides under 200.11(a)(2)(ii)(A) of the Title I regulations to pool the funds generated by private school children, the LEA may provide services to eligible private school children residing in all the areas being served as well as in the areas that were skipped.

Q2. How are private school children to be identified as residing in a participating public school attendance area if an LEA is operating under an open enrollment, a desegregation, or a magnet plan?

A. As 200.10(b)(2) of the Title I regulations makes clear, if an LEA identifies a public school as eligible on the basis of enrollment, rather than because it serves an eligible school attendance area, the LEA must, in consultation with private school officials, determine an equitable way to identify eligible private school children. For example, the LEA may assign a private school child to the public school attendance area in which the child resides or to the public school that the child would have attended if not enrolled in a private school. Recognizing that many different enrollment plans exist, the Department is willing to assist an LEA in designing a reasonable approach that will allow for equitable services to be provided.

Q3. How does an LEA reserve funds for administering programs for private school children?

A. Consistent with its plan to enable children served by Title I to reach high standards, an LEA reserves the amount that is reasonable and necessary to administer programs for both public and private school children, including capital expenses needed to provide equitable services to eligible private school students that are not paid for with funds under section 1002(e) of Title I. The reservation for administration is taken "off the top" of the LEA's allocation (not just from the funds available for services to private school students), before funds are allocated to participating attendance areas for instructional services. The costs of administration, including the amount of capital expenses, may need to be adjusted after the LEA determines how many eligible private school children will be served. (See 200.27(c) of the Title I regulations.)

Q4. If an LEA, in consultation with private school officials, decides to pool funds generated by low-income children attending private schools, and later eligible low-achieving children in some schools choose not to participate in Title I programs, do the funds generated by poor children in these private schools remain in the pool?

A. Yes. An LEA allocates Title I funds to participating public school attendance areas using data it has obtained on the number of low-income children, both public and private, who reside in that public school area. Once funds are generated, if eligible low-achieving children in a particular private school do not wish to participate in Title I programs, any funds generated by low-income children in that private school remain in the pool.


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