Corina Ene Director of Policy & Research Implementation

Office of Federal ProgramsTitles I, II, III, VI and X

Title I, Part AImproving the Academic Achievement of the

Disadvantaged

Title I, Part A Improving the Academic Achievement of the

DisadvantagedPROGRAM DESIGN: • To provide a funding source for school

districts and schools to supplement the local educational programs.

• To ensure that economically disadvantaged students are given the same opportunity to achieve state-defined academic standards.

Title I, Part AProgrammatic Alignment

Comprehensive District Academic Plan(CDAP)Site Plan (Targeted Assistance or Schoolwide

plans). New plans are submitted for approval once to OSDE through the Grants Management System (GMS), and updated them annually.

Grant Application and Budget (GMS)Expenditures (GMS)

Set asides-off the top of the total allocation• Homeless (1 % of the Current Year Allocation);• Priority, Focus or Targeted Intervention set asides are mandatory according

to the Sliding Scale Guidance. Use the latest designation list available (released in February 2014);

• Parental Involvement (1% of the Current Year Allocation if the district allocation is $500,000 or more. Only 5% of this 1% may be kept at the district level, the rest of 95% must be distributed to the sites);

• Private Schools Equitable Share Service Reservations (if applicable);• Administrative Costs have caps, based on the ADA :5% (if >1500 students),

7% (if 500 to 1500 students), 8% (if <500 students) of the Current Year Allocation. Function Codes 2330 and 2540 are used for these costs;

• IDC (Indirect Costs) reserved under function-object 5400-900• “Other” authorized activities- LEA must consult with teachers, principals,

parents of children in participating schools, and with private school officials to determine what reservations are needed. Keep agendas, sign-in sheets and minutes indicating the agreement during this consultation.

Supplement not Supplant• Is the basic principle of all federal programs;• Materials, property or personnel services paid with

Title I must be in addition to state requirements;• District representatives must know the accreditation

standards very well, to ensure the proposed Title I A personnel are supplemental;

• District representatives must have knowledge about the HQT and SPR systems, to ensure accurate correlation between these systems and the Consolidated Application.

Personnel paid with Title I A funds - Teachers

must be Highly Qualified in the subject matter;Have Title I assignments in the HQT system;If Title I assignments are new, update the 2014-

2015 contract to reflect this change;If there are other non-Title I responsibilities,

separate these responsibilities in the contract.

Personnel paid with Title I A funds -Paraprofessional

For the purposes of Title I, Part A, paraprofessionals are employees of an LEA who provide instructional support in a program supported with Title I funds;

Individuals who work only in non-instructional roles (such as food service, playground supervision, personal care services, and non-instructional computer assistance) are not considered to be paraprofessionals for Title I purposes;

must be Highly Qualified, and linked in the HQT system to a Highly Qualified teacher.

Personnel paid with Title I A funds – Superintendents

• Title I does not pay any part of the superintendent salary;

• Title I does not pay for superintendents’ stipends/extra duty payments for Federal Programs management for their district or other districts;

• Superintendents are on a 12 month state paid contract, therefore performing other duties during contractual hours is strictly prohibited.

Homeless set-aside under the new authority of Consolidated Appropriations Act, 2014

• If an LEA has homeless children and youth who attend non-Title I schools, a minimum of 1% of the Current Year Allocation is a required set-aside for educational services for Homeless students (books, supplies, activity fees, registration fees, etc.).

Homeless set-aside-continued The 2014 Consolidated Appropriations Act expands the use of Title I funds to support homeless children and youth for the following requirements under McKinney-Vento: a)Local homeless liaison’s salary; b)Transportation to and from the school of origin.

Homeless set-aside-continued

• An LEA may not use the set-aside reservation under ESEA section 1113(c)(3)(A) to pay for a homeless liaison or to provide transportation to the school of origin, but it may reserve additional Title I, Part A funds (above the 1%) for these purposes.

Homeless set-aside-continued

• The salary for a Homeless coordinator may be reserved in addition to the 1% reservation for student services;

• Transportation costs that may be charged to Title I are excess costs to transport a homeless child or youth to his or her school of origin, that are above what the LEA would otherwise provide to transport the student to his or her assigned school (such as bus passes, taxi fees, shuttles…).

Professional Development Activities

• (I) high quality, sustained, intensive, and classroom-focused in order to have a positive and lasting impact on classroom instruction and the teacher's performance in the classroom; and

• (II) are not 1-day or short-term workshops or conferences.” [NCLB law, Title IX, section 9101(34)(A)(v)]

Professional Development Activities

• However, participation in a short-term workshop or conference is only allowed to reinforce or lay the groundwork as part of a larger, systemic Professional Development plan;

• Keep agendas, sign-in sheets and minutes from the PD activities claimed from federal funds, for reimbursement.

Professional Development Materials

• Materials must be for allowable Professional Development activities under Title I A;

• Keep agendas, sign-in sheets and minutes from these PD activities.

Substitutes

• Title I, Part A funds may be used to pay for substitutes only to release teachers to participate in Title I A allowable professional development activities;

• Submit an agenda and the names of the teachers attending the event;

• Substitutes cannot be paid with federal funds for teachers attending PLCs during contractual hours.

Schoolwide Schools with the poverty level dropping below 40%

• The “Non-regulatory Guidance, LEA Identification and Selection of Eligible School Attendance Areas and Schools, and Allocation of their Title I Funds to those Areas and Schools” stipulates under the General Selection Requirements (5): “For one additional year only, [LEA has the discretion to] designate

and serve a school attendance area or school that is no longer eligible, but it was eligible and served in the preceding year”.

• Therefore, an LEA that wants to continue serving a school in a Schoolwide setting, even though the poverty level has dropped below 40%, may serve the school for one additional year only. If the poverty level comes back to 40% next year, then the school continues as a Schoolwide school, otherwise the school goes to a Targeted Assistance setting.

Interruption of Schoolwide school services for more than one year

• Section 34CFR200.26(c)(1) of the Code of Federal Regulation stipulates: “A school operating a Schoolwide school program must 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.”

• If the site was not served, the annual Schoolwide plan review could not be performed, the site was not in compliance with federal regulation, and therefore the school must go through the process of becoming Schoolwide again.

Schoolwide Plans in GMS for FY15

• Schoolwide plans can be uploaded in GMS starting with FY15;

• New Schoolwide plans will be submitted for OSDE approval;

• Existing Schoolwide plans can be updated and uploaded in GMS, without seeking approval from OSDE.

Food for meetings• In the past, schools have used Title I A funds to pay for refreshments as a

way to increase attendance at Title I A parent meetings. • Although there is no direct correlation between providing food for

parents and increasing the academic achievement of students, the Oklahoma State Department of Education (OSDE) extends the courtesy to Oklahoma schools for using part of the Parental Involvement portion of the Title I A funds to pay for light refreshments for educational parental involvement activities, as long as they are reasonable and necessary expenditures.

• The following are considered light refreshments: cheese and crackers, cookies, fruits, coffee/soft drinks, donuts/pastries.

• Districts are encouraged to use their activity accounts, partnership with community businesses, donations, etc. to pay for food for Title I parent meetings.

• Keep agendas, sign-in sheets and minutes from these educational Parental Involvement activities, with focus on Reading and Math.

Alcoholic Beverages

• The use of federal funds to pay for the cost of alcoholic beverages is strictly prohibited.

Furniture• Chapter I, Article V, Section 68, Items 7 and 12 of Oklahoma law

states that School Districts and Boards of Education shall:“7. Purchase, construct or rent, and operate and maintain, classrooms, libraries, auditoriums, gymnasiums, stadiums, recreation places and playgrounds, teacher ages, school bus garages, laboratories, administration buildings, and other schoolhouses and school buildings, and acquire sites and equipment therefor;”“12. Purchase necessary property, equipment, furniture, and supplies necessary to maintain and operate an adequate school system.”

• Purchasing furniture and storage furniture with federal funds would be supplanting, and therefore are not allowed from TIA funds;

Subscriptions

• Only for allowable activities under Title I A;• Only for 1-year agreements;• Invoices must indicate the length of the

contract;• Cannot be purchased at the end of the fiscal

year for the use in the next academic year.

Variance in the function/object codes

• On June 26, 2014 the State Board of Education approved no more than 25% variance for any function-object codes;

• Function codes 2330 (Admin Costs), 2540 (Central Services), 5400 (IDC) and object code 700 (property) do not allow any variances.

Unused Sick Leave

• OMB Circular A-87, Attachment B(8)(d)(3) states that unused sick leave (object codes 114 or 124) cannot be paid from federal awards as direct costs, but as indirect costs;

Transportation coding• If an LEA incurs bus transportation costs, the

following codes can be used for reimbursement from federal programs:bus driver salary (2720-100) gasoline (2740-623)• If the LEA uses its own bus, code 2720-442

(Equipment and Vehicle Lease Services) is not a correct code, since the LEA cannot lease the vehicle to itself.

Questions?Contacts:Ramona.Coats@sde.ok.gov – Assistant State Superintendent of Federal ProgramsGloria.Bayouth@sde.ok.gov – Executive Director of Federal ProgramsBo.Merritt@sde.ok.gov –Director of Titles I,II,VI & XCorina.Ene@sde.ok.gov–Director of Research and Policy ImplementationDaniel.Fryar@sde.ok.gov- Director of Finances