1. Title III Monitoring and Supplemen, Not - ELD

Report
Title III Application, Monitoring,
and Budget:
Supplement, Not Supplant
Title III Application Process
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Receive
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Revise
Rejoice!
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Title III Application
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http://www2.ed.gov/policy/fund/reg/edgarReg/edgar.html
EDGAR 76.708
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§ 76.708 When certain subgrantees may begin to obligate funds.
(a) If the authorizing statute for a program requires a State to make subgrants on the basis of a
formula (see § 76.5), the State may not authorize an applicant for a subgrant to obligate funds until
the later of the following two dates:
(1) The date that the State may begin to obligate funds under § 76.703; (July 1 for Title III) or
(2) The date that the applicant submits its application to the State in substantially approvable form.
(Reasonable to assume that it is in substantially approvable form and can begin to obligate funds –
make expenditures from the program/charge to program for activities)
(b) Reimbursement for obligations under paragraph (a) of this section is subject to final approval of
the application.
(c) If the authorizing statute for a program gives the State discretion to select subgrantees, the State
may not authorize an applicant for a subgrant to obligate funds until the subgrant is made.
However, the State may approve pre-agreement costs in accordance with the cost principles that
are appended to 34 CFR part 74 (Appendices C-F).
(Authority: 20 U.S.C. 1221e-3, 3474, and 6511(a))
[45 FR 22517, Apr. 3, 1980. Redesignated at 45 FR 77368, Nov. 21, 1980. Further redesignated at 60
FR 41295, Aug. 11, 1995]
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Title III, Part A
• 3113 – English Language Proficiency Standards
• 3115 Required Activities – Professional
Development
• 3116 – Annual Test
• 3122 – Annual Measurable Achievement
Objectives (AMAOs)
• 3302 – Parent Notification of LEP Program
Participation
• 3302 – Parent Notification of AMAO Failure Letter
Title III Monitoring
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Title III Monitoring: Accountability
SBE Policy GCS-A-012
Subgrantees receiving Title III funds (LEAs, public charter schools, & consortia)
must meet a series of Annual Measurable Achievement Objectives (AMAOs)
AMAO 1 – Progress
AMAO 2 – Proficiency
AMAO 3 – AMOs for the LEP Subgroup
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Title III, Sec. 3122(b)(2) and State Board Policy reference
(4) ACCOUNTABILITY- If a State educational agency determines
that an eligible entity has failed to meet the annual measurable
achievement objectives described in subsection (a) for 4 consecutive
years, the agency shall —
(A) require such entity to modify the entity's
curriculum, program, and method of instruction;
Policy Identification
Priority: Globally Competitive Students
Category: Testing
Policy ID Number: GCS-A-012
Sanctions for AMAOs Not Met
If the Title III subgrantee has failed to meet the AMAOs for four (4)
consecutive years, the State Board of Education shall require the Title
III subgrantee to modify its curriculum, program, or method of
instruction.
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Risk Factors
Risk factors include but are not limited to:
• size of subgrantee grant award,
• percentage of LEP students,
• program performance based on meeting AMAOs
1 and 2,
• student subgroup academic performance based
on AMOs for LEP students,
• change in program or leadership, and
• the length of time since previous onsite
monitoring.
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Timeline
•AMAO 3 Calculations
•Risk Factor Analysis
•Monitoring Schedule
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Title III Monitoring Instrument
http://eldnces.ncdpi.wikispaces.net/LEP+Coordinators
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Tying It All Together
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Application
Improvement Plan
Monitoring
Implementation
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Budgets
Basic Supplement, Not
Supplant
USDE, Student Achievement and School Accountability (SASA)
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Title III Grants
• PRC 104
– Funding for LEP students
– A sufficient number of LEP students to generate a
planning allotment of more than $10,000
• PRC 111
– Funding for a significant in crease in immigrant
children
– Having a significant increase in the percentage of
immigrant students enrolled as compared to the
average of the two preceding fiscal years
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Title I, Part A & Title III, Part A
Title I
Title III
Funds must
supplement, and not
supplant State and
local funds
(Section 1120A of
ESEA)
Funds must
supplement, and not
supplant other
Federal, State, and
local funds.
(Section 3115 of
ESEA)
USDE, Student Achievement and School Accountability (SASA)
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Title III “A Supplemental Program to
Serve English Learners”
• Cake – state and local funds used to provide
the Core EL program
• Icing/Frosting – Other federal funds
• Sprinkles – Title III funds
– High Quality Language Instruction Educational
Program (LIEP)
– High Quality Professional Development
USDE, Student Achievement and School Accountability (SASA)
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Developing My LEA’s Supplemental
Title III Program
Do all of the items on my local plan and budget
narrative meet the following criteria?
Are they allowable?
Are they allocable?
Are they reasonable and necessary to carry out
grant function?
Determine whether they should be included in the
2% limit as administrative costs?
USDE, Student Achievement and School Accountability (SASA)
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Supplement, Not Supplant
Requirement – General
The First Test of Supplanting:
Required by Law
The Department assumes supplanting exists if –
An LEA uses Title III funds to provide services
that the LEA is required to make available under
State or local laws, or other Federal laws.
USDE, Student Achievement and School Accountability (SASA)
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Supplement, Not Supplant
Requirement – General
The Second Test of Supplanting:
Prior Year
The Department assumes supplanting exists if – An
LEA uses Title III funds to provide services that the
LEA provided in the prior year with State, local or
other federal funds.
This assumption can be rebutted.
USDE, Student Achievement and School Accountability (SASA)
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To refute the “prior year” test of supplanting, the LEA
would need to have contemporaneous records to
confirm….
 Budget cuts were made in a number of areas,
not just for LEP students; and
 There was in fact a reduced amount of State or
local funds to pay for this activity/position; and
 The LEA made the decisions to eliminate the
position/activity without taking into
consideration of Federal funds.
USDE, Student Achievement and School Accountability (SASA)
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Questions to Ask When Considering Whether Title III
Funds Can be Used Without Violating the Supplement,
not Supplant Requirement
1. What is the instructional program/service
provided to all students?
2. What does the LEA do to meet Lau
requirements?
3. What service is the LEA required by other
Federal, State, and local laws or regulations
to provide?
4. Was the program/service previously provided
with State, local, and Federal funds?
USDE, Student Achievement and School Accountability (SASA)
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Title III Services to Supplement LIEP
• ELL PreK Services
[For LEP PreK students included in the Oct 1
Headcount]
• Additional Curriculum Support/ Activities
[SIOP lessons, integrated lessons with other
content areas, etc.]
• Additional Collaboration with content teachers
[SIOP coaches, Lead teachers, etc.]
Title III Services to Supplement LIEP
• Additional Interventions
[extra tutoring, content support in L1 or L2, newcomer
services, etc.]
• Extended School Year or School Day
[summer programs, before/after school opportunities,
etc.]
• Supplementing schools’ role
in the enrollment process and data collection for
Title III Reporting [e.g., intake office.]
Title III Services to Supplement LIEP
• Additional Parent Training
[Not provided to all parents; perhaps provided by a Title
III Parent Liaison]
• Additional Materials
[content materials in addition to content textbook,
materials for additional interventions or extended
schooling, etc.]
• Additional Training for Staff
[Extra training and support for new ESL teachers,
SIOP coaches, Lead teachers, etc.]
Significant Increase Immigrant Funds
PRC 111
• In order to receive funds, an approved Title III
Application for 2013-2014 explaining how
these funds would be used to provide
enhanced instructional opportunities for
immigrant children [ESEA Title III Sec. 3114
(e)] is required.
Immigrant Plan
An approved Immigrant Plan will require
• assessment of immigrant student needs,
• identification/development of appropriate
services,
• determination of priority for receiving the
services, and
• identification of immigrant students who meet
the priority.
Supplement, Not Supplant
FAQ Document
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Resources
• Office of Planning, Evaluation and Policy Development, Policy
and Program Studies Service
• Office of Management & Budget (OMB) Circular a-87:
http://www.whitehouse.gov/omb/circulars_a087_2004/
• EDGAR – (See parts 76 and 80 in particular)
http://www2.ed.gov/policy/fund/reg/edgarReg/edgar.pdf
• Office for Civil Rights, ELL Resources
http://www.ed.gov/about/offices/list/ocr/ellresources.html
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