ESSA: A Starter Kit for Private School Educators
Title I, Part A: Improving Basic Programs
What is Title I, Part A?
Title I, Part A is ESSA’s flagship program. Its purpose is to close the academic achievement gap by providing various forms of assistance to students considered most academically at-risk. Congress authorized spending of up to $15 billion for Title I in fiscal year 2017 – an amount that is greater than the sum of spending limits for all the other ESSA titles, combined.
How does Title I-A funding work?
Funding flows from the U.S. Department of Education to state departments of education (SEAs), and from there to local public school districts (LEAs). The amount of funding received by a state, as well as by its respective LEAs is determined by a formula that is weighted by the incidence of poverty. In order to plug values into the formula, each district conducts a count of children whose families meet a designated poverty criterion. The count includes children who attend private schools. Each district can choose one of four ways to determine the number of private school students who meet the criterion. A district may:
- use the same measure of low income used to count public school children. For example, a district can use eligibility to participate in the National School Lunch Program as the criterion it employs to count qualifying children enrolled in its (public) schools, and may then ask private schools to provide counts of students who meet the same criterion. (Note that students need only be eligible to participate in the National School Lunch Program to be included in the count.)
- use comparable poverty data from a survey and allowing such survey results to be extrapolated if complete actual data are unavailable. For example, a district may create a survey which, through private schools located within its boundaries, it disseminates to private school families who will be identified by numbers, rather than names. The survey would ask parents to indicate the public school district in which they reside, the number of school-aged children at the family residence, and an indication of whether the family’s combined income fell below an established poverty threshold. The district would then use the results of the data compiled from the returned questionnaires to estimate the total number of private school children from low-income families residing within its boundaries.
- use comparable poverty data from a different source. For example, a public school district could use National School Lunch Program eligibility data to count its students, and use a comparable source of poverty data, such as eligibility for Temporary Assistance to Needy Families, making adjustments, as necessary.
- use proportionality. For example, if a district has determined that 40 percent of the public school students who reside within Title I attendance areas (areas with high concentrations of poverty) meet the poverty criterion, it may estimate that 40 percent of the private school students residing within its Title I attendance areas do so.
Example: Assume that 20 students enrolled in your private school come from families that meet the Title I poverty criterion used by the public school district in which they reside. Further assume that the total number of public and private school students whose families meet the poverty criterion is 4,000, and that the district’s total Title I, Part A allocation is $5 million. Because your school’s 20 students accounted for one-half-of-one-percent of the total amount of funds generated, the district would reserve $25,000 to provide services to students in your school who reside within the public school district boundaries, and who have been determined to be at-risk of academic failure.
Keep in mind: The services provided by the $25,000 need not be received by the same children responsible for generating the Title I, Part A funding. It may be the case that only 10 students in your school are considered to be at risk of failing, and that some, but not others come from families that meet the Title I poverty criterion. Be that as it may, all ten students would be eligible to receive Title I services funded by the $25,000. Also, it must be borne in mind that children enrolled in a private school often reside in more than one public school district. Because participation in Title I, Part A is determined by the district in which a child resides (and not the district in which his/her private school is located), private school officials often need to participate in consultation with representatives of multiple public school districts.
It all starts with consultation!
Consultation with public school district representatives should begin well in advance of a school year. Private school officials will need to know how much funding is available to provide Title I, Part A services to eligible students in their school. Agreement must be reached on the means employed to identify the private school students in need of services. Most importantly, the specific nature of the services must be planned. Finally, the parties to the consultation must agree on how the academic progress of participating students is to be assessed.
Potential Pitfalls: Staff turnover and reassignments can be endemic in public school districts. You may well find yourself dealing with a counterpart who’s as new to doing this as you. Add to that the fact that you’ll both be dealing with a new law, one for which a full set of regulations and guidance has yet to be issued – and you may end up hearing a lot of “don’t know,” and “can’t tell you.”
Do not despair! First, be prepared for such encounters. It’s better to hear an honest “I don’t know,” than to be provided with misinformation. In fact, anyone who holds themselves out as an expert on ESSA at this stage of its evolution should be regarded with some degree of suspicion.
Second, uncertainty must not stop you from proceeding. Ask your district colleague whether the district is planning to provide Title I, Part A services to its public school students in the coming academic year, and you can almost certainly expect an affirmative response. At that point, you can politely point out that the law requires the district to provide comparable services to eligible private school children…and that the services won’t be equitable if they’re not appropriately planned.
Finally, keep in mind that consultation must be both timely and meaningful. District employees have an obligation to obtain whatever information in necessary to facilitate timely and purposeful planning. If district staff have questions, they should contact the California Department of Education. If you have questions, CAPSO is here to help!
Remain positive. Chances are good that the bumps in the road will be surmounted, things will work out, and your students will receive the extra, individualized help they need to get them over the hump and onto the path to academic success.
Title I, Part C: Education of Migratory Children
This portion of Title I contains provisions designed to ensure that children whose families migrate from state to state during the course of a school year:
- are not penalized in any manner by disparities among the states in curriculum, graduation requirements, and challenging state academic standards;
- receive full and appropriate opportunities to meet the same challenging state academic standards that all children are expected to meet; and,
- receive assistance to help overcome educational disruption, cultural and language
barriers, social isolation, various health-related problems, and other factors that
inhibit the ability of such children to succeed in school. (ESSA §1301(a))
ESSA §8501(b)(1)(A) provides that if such children are enrolled in private schools, they, their parents and teachers, are entitled to receive services that are comparable to those received by similar children enrolled in public schools. Funding is provided on a proportionate basis, with a total of $375 million having been authorized for each of fiscal years 2017 through 2020.
If you have reason to believe such children are enrolled in your private school, you should bring the matter to the attention of your local public school district colleagues, so as to consider their eligibility for assistance.