BUREAU OF FEDERAL EDUCATIONAL PROGRAMS
CONFERENCE CALL REGARDING THE IMPLEMENTATION OF TITLE I, PART A PROGRAMS IN PRIVATE SCHOOLS 
May 31, 2012 9:00AM - 10:00AM
Conference Call Notes

NOTES	
Welcome and Introductions

	Good morning. Today we will be discussing the implementation of Title I, Part A programs in private schools 
On the Topic of: Choosing a Service Delivery Model

FDOE Staff Present:  Anna Moore, Audrey Obinyan, Sally Hugo, Tony Graham, Justin Donald, Sandra Lesley, Eric Gaines, Brittney Rucker, Cynthia Milton, and Ashley Scott. 	
Roll Call 	We will have a password at the end of the call to document participation in this call. 	
Overview of Agenda

	Today we will provide technical assistance and guidance on the several different service delivery models that may be used when providing services to students enrolled in private schools. We will also discuss the documentation that should be maintained to demonstrate compliance and strategies for monitoring student progress.  	

	
During meaningful consultation, LEAs discuss all of the key elements of the program and the evaluation of services that allow equitable participation of private school students, their parents, and teachers in Title I programs. The key elements are related to the instructional services, professional development, and parental involvement. We will be discussing several different ways that services may be provided to participating students. Keep in mind, the LEA is responsible for providing services not money. 

LEAs and private school officials should consider the specific needs of the students when making decisions regarding the specific program delivery methods. Options include the following: 
	
Design of the Program	After consultation with appropriate private school officials, the LEA must design a Title I program that meets the needs of private school participants.  The LEA is responsible for planning, designing, and implementing the Title I program and may not delegate that responsibility to the private schools or their officials.

Consistent with §1115(c) of the Title I statute, the LEA provides a Title I program to private school children, using methods and instructional strategies for improving academic achievement that have been shown to be effective through scientifically based research.  The LEA must also give primary consideration to providing extended learning time and a high-quality curriculum.

Based on the needs of the children to be served, the LEA must provide an instructional program that not only supplements but also is well coordinated with the instruction that the private school children are receiving in their regular classrooms.  Services for participating private school children include, but are not limited to, the following:
•	Instructional services provided by public school employees or third-party contractors.
•	Extended-day services.
•	Family literacy programs. 
•	Counseling programs.
•	Computer-assisted instruction (CAI).
•	Home tutoring.
•	Instruction using take–home computers.

Keep in mind, the Title I program should be designed to help the children meet challenging academic standards and complement classroom instruction. Title I services for private school participants may be provided at various locations, including the private school, neutral sites, or public schools.  LEA officials must consult with private school officials before any decision is made about the location of Title I services.  If appropriate space is available, the least disruptive and least expensive location will be the private school that the participating children attend. 	
Service Delivery Models: Extended Learning Time

	Extended Learning Time may include before or after school and may include Saturday or summer sessions. Generally, small group or individual tutoring is provided to participating students. The length of the sessions varies among districts and schools. Keep in mind that services are not limited to only one subject.

Time after school is prime time for the implementation of programs to complement, enhance, and enrich what happens during the regular school day. Effective extended school day and after-school programs must address the specific academic needs for the participating students. 

• Title I Before/After School Programs – Providing a Title I paid after school program is an opportune way to utilize the additional funds without hiring additional permanent staff. The LEA may employee public school staff to work in the after school program. Private school staff may be hired; however, the LEA must ensure that the Title I services are provided at a time when the employee is not being paid by the private school.  A Title I after school program is going to look different in each LEA and private school; however, the following components should be a part of all Title I-funded programs:

•	The program’s main focus should be to raise the academic achievement of participating students.
•	Teachers should employ research-proven strategies (i.e., use different modes and methods of instruction, provide an environment rich in print, provide exposure to a variety of texts).
•	Group sizes should be kept small. The smaller the group size, the bigger impact Title I services will have on each student.
•	Services for students should be individualized as much as possible.
•	Student assessment and reporting the results of these assessments, including identifying the progress of the child in the program to parents should be included in the after school program.

Title I Summer School Programs – Providing a Title I paid summer school program is again an opportune way to utilize the additional funds without hiring additional permanent staff. Schools can use existing staff to work in the summer school program. 

Advantages:
•	After-school programs also can help to improve the academic performance of participating children. After-school programs allow them to focus attention on areas in which they are having
difficulties. 
•	Before/after-school programs keep children of all ages safe and out of trouble. 
•	After-school programs also contribute to raising children's self-confidence as well as academic performance. Children who participate in after-school programs develop better social skills and learn to handle conflicts in more socially acceptable ways. 
Disadvantages: 
•	Some students may not be able to attend due to other after school commitments. 	
Service Delivery Models: Pull-Out or Push-In	Several LEAs implement pull-out or push-in programs where either the students are pulled-out of the regular classroom or a Title I teacher comes into the classroom to provide small group instruction. This model could be an effective model for instruction. 

Pull-Out Instructional Model
In a pull-out model, the Title I teacher instructs students outside of the private school regular classroom in a Title I classroom. This model of instruction is best for beginning and intermediate students, enabling the teacher to provide intensive instruction that builds the skills and confidence of the students. This is similar to the old Chapter 1 program.  It is recommended that students be pulled for instruction during a time of the day when students are working independently (such as centers time or independent activities). The LEA may not pull student out during a time when core instruction taking place.

Scheduling seems to be the hardest part of this program since services may not replace the core instruction provided by the private school classroom teacher and may not take place during a time when the child is missing core instruction in another subject. This could be similar to intervention programs provided in public schools (the “iii”). The Title I teacher may provide small group reteaching of skills or strategies that the child may need additional help grasping. For this to be an effective model, the Title I teacher and the  private school classroom teacher should spend some time planning together to ensure that services are appropriate for the needs of the child. 

•	Advantages: intensive instruction, all materials can be maintained and controlled by the LEA as they are all placed in one room.
•	Disadvantages: wasted transition time traveling to the Title I classroom

Push-In (AKA Plug-In)  Instructional Model
In a push-in model, the Title I teacher instructs students within the general education classroom. This model includes instructing small groups of students during independent work/center time. This model is most effective when co-planning with the classroom teacher takes place on a regular basis.
•	Advantages: eliminate the transition time concerns in the pull-out model, may increase coordination with regular classroom curriculum since the Title I teacher actually observes the instruction, 
•	Disadvantages: Difficult to only serve the specific participating students, the teacher must travel with all of the supplies and instructional materials needed to implement the program, limited space within the regular classroom, distractions from other students, 

LEAs and Title I teachers must use caution when implementing the push-in model of instruction. The services, materials, and supplies are only available for participating students. The Title I teacher may not co-teach, provide supervision of the all of the students, or substitute for the classroom teacher. 
Time allotted for pull-out or push-in instruction varies by district and school. Most are 30 minutes two to three times per week and depend on the funds available. Achievement data should be used to make instructional placement decisions for the students. Teachers should analyze these data points when developing their schedules:
•	Number of students at specific levels  
•	Number of students at specific grade levels 
•	Achievement data and specific academic needs of the students	
Service Delivery Models: Computer Assisted Instruction	Computer assisted instruction (CAI) is one of the instructional delivery methods that may be used to provide services to students enrolled in private schools. Programs range from tutoring, drill and practice, to interactive web-based lessons. Instruction may be provided at the school, in other locations (libraries, community centers) or a home. Virtual school and course recovery would not be appropriate since this type of instruction is the core instruction. Title I instruction may be provided via distance learning technology--a two-way interactive television, voice and data network. Instruction is provided through an add-on (after school) or limited pull-out model. Instructors must meet the highly qualified and background screening requirements.

Title I, Part A funds may be used to pay the cost of the computers and licensing of the software. This would be considered part of the  instructional costs. The LEA would be responsible for the supervision of students while working on the computers, reviewing student performance data, and making modifications to the program as needed. Reasonable installation costs are allowable under certain circumstances it the following  conditions are met: 
•	The installation is necessary in order for the Title I program to operate; 
•	The cost is related solely to the CAI program and does not otherwise correct a deficiency in the facility; 
•	The installation does not result in any improvement to the private school facilities other than the electrical wiring related to the Title I computer(s); and 
•	The representatives of the private school agree either to reimburse the Title I program for the residual value of the wiring (the installation cost minus depreciation), or to have the LEA remove the wiring if the CAI program is terminated at the site.

No Title I, Part A funds may be used for repairs, minor remodeling, or construction of private school facilities. 

The cost of technicians who perform non-instructional duties such as operating and maintaining CAI equipment and keeping order in the Title I, Part A CAI classroom are considered administrative costs. The LEA may hire a non-highly qualified paraprofessional to work in the Title I computer lab as long as this individual only provides non-instructional support (such as monitoring of behavior, operation of the equipment, printing reports, etc.). A non-highly qualified paraprofessional may not provide instructional support to participating students. Whether employees should be considered instructional personnel or non-instructional technicians depends on the functions performed by the employees, in addition to their job titles, job description, or classifications. 

Things to keep in mind: 
•	Services may only be provided for eligible participating students;
•	Instruction must supplement the core instruction provided at the private school ;
•	Computers should be kept secure and only provide the CAI program agreed upon during consultation;
•	The LEA may not install software on the private school’s network for use by the Title I students;
•	All equipment should be clearly labeled as property of the LEA;
•	If the computers are no longer needed for the Title I program at the private school, they should be removed; 	
Service Delivery Models: Counseling	The Non-Regulatory Guidance does indicate that counseling services may be provided for participating students in private school. The services must be designed to help the student meet high academic achievement standards. 

We are not aware of any LEAs in Florida providing this service, but private school officials should be made aware of this option.  For example, if a participating Title I student suddenly experiences a life-changing event (death of a parent, serious illness, etc.) and this difficulty has negatively impacted their academic performance, then counseling services may be appropriate for the child.

Services of a behavioral specialist may be appropriate for some students. This may also be a time when IDEA and Title I work together to meet the needs of the child. The evaluation of these services must be based on the academic achievement of the children participating. Since it would be hard to evaluate these services in relation to academic achievement, it may not be a wise option.	
Parental Involvement and Professional Development

	We have received many questions about the type of services available for private school teacher and parents of participating children. The services must be discussed during consultation and designed with the specific needs of the children. 

It is not the responsibility of the Title I program to help private school teachers become better teachers or highly qualified or even certified. The LEA’s only responsibility is to provide professional development to assist the teacher in better meeting the needs of the participating children. The same applies to the parental involvement activities. These activities should be designed based on the academic needs of the participating students. Both of these activities should be supported by data and answer the following questions: 

Qualifying Question	
Yes	
No	

1.	Is the content of this activity different from the content of the instruction provided at the school (i.e. math tutoring-math training)? 	

2.	Will the activity benefit the teacher personally (college courses, become highly qualified, etc.)?	

3.	Is the activity linked to the instruction being provided in the Title I program (i.e. reading training)? 	

4.	Will the activity help the teacher provide better instruction for all students? 	

5.	Is the activity based on the academic needs of the participating children and supported by achievement data?	

6.	Is the activity for all of the teachers at the private school?	

7.	Was the selection of the activity based solely upon a request made by private school officials?	

8.	Is the cost higher than what the LEA would pay for the same program for public school teachers?	

9.	Does the activity have a religious/non-secular basis?	

If you can answer “yes” to any of these questions, then the activity is not allowable with Title I, Part A funds. The following situations may be used as examples: 
•	Training in differentiated instruction: Not allowable—DI is a way to teach and will help the teacher implement small group instruction and differentiation for all students in the classroom. (Question 4 and 5)
•	Attendance at the International Reading Association Conference: Not allowable—IRA conferences provide a multitude of reading sessions that may or may not be specifically linked to the instruction being provided or the achievement data of participating students (Questions 5)
•	In November, the private school requested to send 3 teachers to the technology conference: Not allowable—The activity should have been discussed during the consultation process and not just a request of the private school and improving the ability of the teacher to integrate/use technology will benefit the teacher personally or all of his/her students. (Questions 2, 4, and 7)
•	Teachers have requested to attend a math training and the LEA will pay $8000 for an eight-hour event—Not allowable since the cost is not reasonable. The LEA would not pay this cost for a training designed for a few teachers. Just because a private school generates $1000 for professional development or parental involvement does not mean that the LEA should pay this full amount for one activity. (Question 8)
•	The private school is purchasing a new reading curriculum and would like specific training on the implementation of the new program: Not allowable—the activity would benefit all of the children in the classroom. (Question 6)

Similar questions can be used to determine if activities are allowable for parental involvement. 	
Personnel Issues	Section 1120(d)(2) of the statute requires that Title I services be provided by either an employee of a public agency (LEA) or through a contract by the public agency (LEA) with an individual, association, agency, or organization.   These employees, individuals, associations, agencies, or organizations must be independent of the private school and any religious organization in the provision of those services and such employment or contract must be under the control and supervision of the public agency (LEA).  An LEA may provide Title I services directly or indirectly through contracts with public and private agencies, organizations, and institutions so long as those entities are independent of the private school and of any religious organization in the provision of those services.  The services may be provided in a private school under the same conditions, and subject to the same limitations, as if the LEA provided the services. Teachers and paraprofessionals who provide Title I services to private school participants and are employees of an LEA must meet the qualification requirements within the timeframes specified in §1119 of the statute, including the provisions to be highly qualified. The highly qualified personnel requirements only apply to those teachers and paraprofessionals who are directly employed by the LEA.

The LEA may hire a private school teacher to provide Title I services to private school participants; however, the LEA must ensure that the services take place at a time when the employee is not being paid by the private school. The private school teacher can only be employed for Title I purposes outside of the time he or she is employed by the private school and the private school teacher must be under the direct supervision of the LEA with respect to all Title I activities. 

Paraprofessionals providing instructional support must work under the direct supervision of a public school teacher (see §1119(g)(2)(G) and (g)(3)(A) of Title I).  A paraprofessional works under the direct supervision of a teacher if (1) the teacher prepares the lessons and plans the instructional support activities that the paraprofessional carries out, and (2) the paraprofessional works in close and frequent proximity to the teacher.  USED has defined “close and frequent proximity” as in the same building. As a result, a Title I program for private school participants staffed entirely by paraprofessionals is not permitted.   Title I-paid paraprofessionals may not work under the supervision of private school teachers. 

The LEA must maintain control of the employees hired to provide the services. This is evident in personnel records, hiring, payroll, leave (sick and/or annual), supervision, evaluations, etc. The LEA must conduct the evaluations of there own personnel. Just as you would not expect the principal of a private school to conduct the evaluation of a teacher employed to teach in a regular public school, the private school officials should not evaluate the LEA’s personnel. 

Roll Call 	Email BFEP@fldoe.org with the password “Summertime” in the subject line.