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

NOTES	
Welcome and Introductions

	Good morning. In our conference call this morning, we will provide LEAs technical assistance regarding instructional services to participating private schools. 

FDOE Staff Present:  Anna Moore and Sally Hugo	
Roll Call 	We will have a password at the end of the call to document participation in this call. 	
Overview of Agenda

	Today our technical assistance and guidance will focus on five common questions. We will discuss providing services with limited funding, providing services during core academic classes, using core academic textbooks for tutoring, the storage of such textbooks, and equitable shares for SES. 	

	Q. If an LEA has limited private school funding; can it use its allotment for Professional Development activities or Parental Involvement activities instead of instructional services?

A. If there is too little funding to provide an instructional program, it is acceptable to provide the following types of services instead.
1. Professional development services to the private school classroom teachers of the “eligible” children may be provided.  The professional development would need to be supplemental to what all teachers receive, and be specific to helping those teachers better meet the needs of their Title I eligible children.  The professional development could be provided either by an LEA employee, a consultant that the LEA would engage, or, if the LEA is already using a contractor, the contractor could engage the person who would provide the training.  The LEA would want to ensure that the consultant or contractor is qualified to provide this additional training in this area.

2. Parent involvement activities for the parents of the Title I eligible children may be provided that is supplemental to the parent involvement that the parents of all children receive and is designed to specifically address the needs of eligible students. Again, these activities could be provided either by a consultant that the LEA would engage, or, if the LEA is using a contractor, the contractor could engage the person who would provide the training.  Parents of the Title I eligible children could receive training that would assist their children with their school work at home. Title I funds could also be used for summer “book bags” of materials, etc. that the parents of eligible Title I children could use at home with their children over the summer.

In either case, the LEA should consult with the private school officials to determine what the evaluation would be to determine whether the activities provided by Title I have been effective in terms of making a difference for the Title I eligible children. Because the Title I eligible children are not receiving direct instructional services, the evaluation would look very different than it does for those private school children who receive Title I services in reading and/or math.

ED allowed some flexibility in this specific instance; however, this guidance is not intended to apply to every private school that an LEA may serve.
	
	Q. Is it appropriate to pull Title I eligible private school students out of a core class to provide services for another core subject area?  For example, if a child has a deficiency in math but a strength in reading, can an LEA pull that child out of reading (the strength) to provide services for math (the deficiency)?    

A. Section 1120A(b) indicates that an LEA may use Title I funds only to supplement and, to the extent practical, increase the level of funds that would, in the absence of Title I funds, be made available from non-Federal sources for the education of students participating in Title I programs.  In the case of a private school, the type of programs supported by Title I must supplement the educational services that the private school would provide to its students.  A private elementary school is responsible for providing instructional services to all its students, including those who participate in the Title I program. Consequently, in the example, it is required for a Title I student to receive the instructional reading services that all other children receive before Title I services can be provided.  In designing the Title I program to be provided for eligible private school children, the LEA should ensure that the Title I program is supplemental to the private school’s educational program. The other consideration is whether this practice of having a child miss instruction in one core subject in order to receive supplemental Title I services in another is educationally sound. The statute and regulations are very flexible in terms of allowing Title I services to be provided before school, after school, on weekends, or during the summer. The LEA should discuss all these options with private school officials during the consultation process.  

	Q.  Can a private school classroom teacher send their textbooks/materials with the Title I students for use by the Title I teacher in the Title I room (as a supplement or review of initial instruction) or must Title I purchase those exact textbooks/materials to use and to keep as property of Title I?  
A. Yes. The private school’s instructional materials may be used by the Title I instructor to provide Title I instruction to eligible students.  This practice helps to ensure that the students are receiving supplemental instruction that supports the instruction going on during the regular school day.
Q.  May the mentioned classroom materials be kept on the same shelf with the Title I Materials, as long as they are labeled as private school materials and all Title I materials are labeled as Title I materials, or do they each need to be kept on separate shelves/spaces (private school materials separated from Title I materials)? 
A. Yes. An LEA should label all Title I materials kept at the private school facility and ensure that the materials (as well as equipment and other supplies) are monitored and inventoried.  Separate shelves would be an ideal practice, however not always possible.

Q. What is the latest information on SES and how does it apply to the private school program?
A. The equitable share for SES is allocated in addition to the set-aside because the SES set-aside is reserved for Title I schools only [(see Section 1008.331, Florida Statutes) (2012)].  All other LEA-wide activities include the equitable share as part of the set-aside (see 34 C.F.R. § 200.65); thus, the total allocation for these activities is equal to the set-aside.

An equitable share must be reserved for SES activities and be clearly identified in the LEA’s budget. The equitable share is calculated the same way an LEA calculates the share for PD, PI, and HQT. (Take the number of FRPL students attending public schools, add the number of FRPL students attending private schools, and then divide the number of private school students into the total number of all students.) 

This equitable share for the private school may be used for instructional purposes only. In addition, if an LEA uses Title I funds for SES software programs, onsite support facilitators, or other supporting activities, these activities would also be subject to equitable services. Such activities should be included in the LEA’s “LEA-WIDE INSTRUCTIONAL” set-aside and coded as “E” in the budget.
	
	This concludes our conference call for this quarter. If you have any questions regarding this information, you may contact Sally Hugo at sally.hugo@fldoe.org or Anna Moore at anna.moore@fldoe.org 	
Roll Call 	Email BFEP@fldoe.org with the password “Back to School” in the subject line.