FLORIDA DEPARTMENT OF EDUCATION
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Jeanine Blomberg
COMMISSIONER OF
K12: 2007-105
EDUCATION
Date: June 5, 2007
Technical Assistance Paper
Providing Services to Eligible Private School Children
Summary
: Local Educational Agencies (LEAs) that receive Title I, Part A, funds must ensure that private
school students receive equitable services. This document describes the funding process, services that LEAs
must provide, the process LEAs must follow, and the documentation LEAs must keep.
Contact
:
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Lisa
Bacen
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Lisa.Bacen@fldoe.org
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850-245-0414
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Status
:
X New Technical Assistance Paper
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Revises and replaces existing Technical Assistance:
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Florida Department of Education
Division of K-12 Public Schools
Bureau of Student Assistance
http://www.fldoe.org/bsa/
PROVIDING SERVICES TO ELIGIBLE PRIVATE SCHOOL CHILDREN
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Under Title I of the No Child Left Behind Act of 2001
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Table of Contents
INTRODUCTION
………………………………………………………………………………... 7
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CONSULTATION
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A-1.
Are all private school students eligible to participate in Title I?........................................... 7
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A-2.
Which private schools must LEAs consult with?.................................................................. 8
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A-3.
What is consultation?............................................................................................................. 8
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A-4.
Is there a minimum definition of consultation?..................................................................... 8
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A-5.
When must consultation take place in order to be “timely”?................................................. 8
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A-6.
What must consultation include in order to be “meaningful”?..............................................8
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A-7.
How do LEAs begin the consultation process?..................................................................... 9
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A-8.
Who participates in the consultation process?.......................................................................9
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A-9.
How long does consultation continue?.................................................................................. 9
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A-10.
What records on consultation must an LEA maintain?..........................................................9
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A-11.
Because consultation is an on-going process, when should private school officials or
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their representative(s) sign the required written affirmation that appropriate consultation
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has taken place?.....................................................................................................................10
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A-12.
Must an LEA provide a copy of its Title I application if a private school official requests
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it?...........................................................................................................................................10
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B. ALLOCATING FUNDS FOR EQUITABLE SERVICES FOR PRIVATE SCHOOL
STUDENTS
B-1.
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How does an LEA allocate funds for Title I services under Section 1113(c) of the Title I
?
statute?.................................................................................................................................. 10
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B-2.
How may an LEA collect poverty data on private school children?..................................... 12
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B-3.
How does an LEA determine if it should collect the poverty data annually versus
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biennially (every two years) and must the collection of poverty data be uniform across
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the district?............................................................................................................................. 14
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B-4.
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If an LEA does not collect the names of low-income families, how do LEA officials or
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auditors determine that the poverty numbers provided by the private school officials are
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accurate?................................................................................................................................ 15
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B-5.
Is there a preferred method for collecting poverty data?....................................................... 15
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B-6.
May an LEA use more than one method of collecting poverty data?....................................15
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B-7.
May an LEA reserve funds off the top of its Title I allocation before it allocates funds to
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participating public school attendance areas?........................................................................15
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B-8.
What are the requirements if an LEA reserves Title I funds off the top for district-wide
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instructional programs for public elementary and secondary schools?................................. 15
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B-9.
Are private school children who receive Title I services eligible to receive supplemental
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educational services?............................................................................................................. 16
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B-10.
Does the equitable services requirement in Section 1120(a) of the Title I statute apply to
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LEA set-asides for preschool programs?............................................................................... 16
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2
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B-11.
Does the equitable services requirement in Section 1120(a) apply if the LEA takes funds
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off the top of its Title I allocation for summer school programs?......................................... 16
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B-12.
If funds are transferred into the Title I program from other NCLB programs under the
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transferability authority, do the requirements relating to the equitable participation of
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private school students apply to these funds?.......................................................................16
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B-13.
May an LEA transfer funds into the Title I program solely to provide services for private
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school students?..................................................................................................................... 17
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B-14.
Does the LEA have options on how to allocate funds to provide services for eligible
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private school students?......................................................................................................... 17
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B-15.
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If an LEA, in consultation with private school officials, decides to pool funds allocated
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for private school children and, later, eligible low-achieving children in some schools
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choose not to participate in the Title I programs, do the funds allocated for children in
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these private schools remain in the pool?.............................................................................. 17
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B-16.
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If there are no children from low-income families attending a private school, and so no
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funds are allocated for Title I services, may the private school children who meet the
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educational criteria obtain Title I services?........................................................................... 17
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B-17.
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When an LEA elects not to serve an eligible public school attendance area, as permitted
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under Section 1113(b)(1)(D) of the Title I statute, what are the procedures for serving the
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private school children who reside in that attendance area?..................................................18
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B-18.
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How are private school children to be identified as residing in a participating public
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school attendance area if an LEA is operating under an open enrollment, desegregation,
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or magnet plan?...................................................................................................................... 18
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C. ELIGIBLE CHILDREN
C-1.
Which private school students are eligible for Title I services?............................................ 18
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C-2.
What are the criteria for selecting private school children from preschool through
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grade 2?.................................................................................................................................. 19
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C-3.
Are private school children from low-income families automatically eligible for Title I
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services?................................................................................................................................. 19
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C-4.
How are the criteria determined?...........................................................................................19
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C-5.
May Title I funds be used to identify eligible private school students?................................ 19
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C-6.
May an LEA require private school officials to verify that students attending their school
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reside in a Title I public school attendance area?.................................................................. 19
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C-7.
Once participants are selected, how does an LEA determine what Title I services are to be
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provided?............................................................................................................................... 20
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C-8.
Must the number of private school children served be equal to the number of private
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school students from low-income families?.......................................................................... 20
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C-9.
If a school in the attendance area in which private school students reside is operating a
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schoolwide program, may private school students also be offered a schoolwide program?..20
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C-10.
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If after receiving an offer of equitable services, the private school officials or parents
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choose to have the children participate in only some of the services, may the LEA provide
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only those services?............................................................................................................... 20
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C-11.
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When a child who is most at risk of failing resides in a Title I attendance area in one LEA
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and attends a private school in another LEA, which LEA is responsible for serving the
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child?...................................................................................................................................... 20
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C-12.
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May an LEA establish a minimum number of private school children selected for the
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program in order to establish a Title I program in the private school? If so, what is the
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LEA's responsibility to serve children attending private schools with fewer than that
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minimum number?................................................................................................................. 21
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C-13.
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If the funds allocated for private school children are not sufficient to provide instructional
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services, may the funds be used to provide other services, such as professional
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development or counseling?.................................................................................................. 21
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D. DELIVERY OF INSTRUCTIONAL SERVICES
D-1.
Who is responsible for planning and designing the Title I program?....................................21
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D-2.
How does an LEA design a Title I program?........................................................................ 21
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D-3.
What types of services are available for private school participants?................................... 22
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D-4.
May an LEA just provide a private school with instructional materials and supplies paid
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with Title I funds?.................................................................................................................. 22
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D-5.
When should Title I services for private school participants start?...................................... 22
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D-6.
What are the obligations of an LEA that does not start the Title I program for private
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school participants at the same time it starts the Title I program for public school
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students?................................................................................................................................. 22
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D-7.
May private school officials order or purchase materials and supplies needed for the
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Title I program and be reimbursed by an LEA?.................................................................... 23
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D-8.
Where may Title I services take place?................................................................................. 23
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D-9.
Are private schools required to make space available in their schools for Title I services?. 23
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D-10.
May Title I, Part A teachers use private nonprofit school facilities such as a teachers’
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lounge?................................................................................................................................... 23
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D-11.
May Title I services be provided in religiously affiliated private schools?........................... 24
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D-12.
Must an LEA require the removal of religious symbols in private school classrooms in
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which Title I services are provided?...................................................................................... 24
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D-13.
May Title I, Part A, services be provided in the regular private school classroom through
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aides or joint (or team) teaching?...........................................................................................24
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D-14.
May space used for Title I instruction in a private school be used for non-Title I purposes
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at other times?....................................................................................................................... 24
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D-15.
May equipment used for Title I instruction in a private school be used for non-Title I
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purposes at other times?......................................................................................................... 24
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D-16.
May Title I, Part A teachers and other public school personnel meet or have discussions
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with private school teachers and administrators?................................................................. 24
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D-17.
May the Title I teacher use the same textbooks as those used by the private school
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students in their regular classroom?...................................................................................... 25
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D-18.
Who provides the Title I services to private school participants?......................................... 25
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D-19.
Must teachers and paraprofessionals hired by an LEA to provide Title I services to private
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school participants meet the highly qualified teacher and paraprofessional requirements in
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Section 1119?......................................................................................................................... 25
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D-20.
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After consultation with the appropriate private school officials, may an LEA employ a
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third-party contractor to provide Title I services to private school participants?.................. 25
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D-21.
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If an LEA contracts with a third-party provider, must the third-party provider employ
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Title I teachers and paraprofessionals that meet the highly qualified requirements in
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Section
1119 of Title
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I?................................................................................................................................ ……... 26
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D-22.
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May an LEA hire a private school teacher to provide Title I services to private school
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participants?........................................................................................................................... 26
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D-23.
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How does the requirement in Section 1119 of the Title I statute that paraprofessionals
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employed
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by an LEA work under the direct supervision of a public school teacher apply to the
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Title I program for private school participants?.................................................................... 26
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E. ADMINISTRATIVE COSTS
E-1.
May an LEA reserve funds for administering programs for private school children?.......... 26
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E-2.
May third-party contractors incur administrative costs?....................................................... 26
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E-3.
May Title I funds be used to purchase furniture for a Title I classroom?..............................27
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E-4.
What are special capital expenses?........................................................................................ 27
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E-5.
Are the costs of computer equipment and software considered to be special capital
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expenses?............................................................................................................................... 27
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E-6.
May Title I funds be used to renovate the private school site?..............................................28
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E-7.
Must an LEA provide transportation for private school children from the private school to
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another site in order to receive Title I services?.................................................................... 28
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F.
EQUITABLE SERVICES FOR PRIVATE SCHOOLS FAMILIES AND TEACHERS
F-1.
How does an LEA determine the amount of funds to be used for parental involvement
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activities for parents of participating private school students?..............................................28
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F-2.
How does an LEA provide equitable services for parents of private school students
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participating in the Title I program?...................................................................................... 28
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F-3.
How does an LEA meet the equitability requirement for professional development?.......... 29
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F-4.
Which private school teachers are eligible for professional development under “equitable
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services”?............................................................................................................................... 30
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F-5.
Must the LEA provide professional development activities to the Title I teachers who are
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employees of the LEA?..........................................................................................................30
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F-6
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How may the funds reserved for professional development for teachers of private school
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participants be used?.............................................................................................................. 30
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F-7.
May the private school officials arrange for professional development services for
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teachers of Title I participants and submit the invoice to the LEA for payment?................. 30
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F-8.
May Title I funds be used to pay stipends to private school teachers of Title I participants
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who participate in a Title I professional development program?.......................................... 31
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F-9.
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May Title I funds be used to pay for substitute teachers who replace private school
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teachers in their regular classroom while they attend Title I professional development
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activities?............................................................................................................................... 31
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G. STANDARDS, ASSESSMENT, AND PROGRAM MODIFICATION
G-1.
What standards apply to private school students who participate in Title I programs?........ 31
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G-2
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Must an LEA evaluate the progress of private school students?........................................... 31
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G-3.
Must an LEA evaluate students’ progress on a school-by-school basis?.............................. 32
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G-4.
What actions must an LEA take if the Title I program for the private school participants
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does not make the expected annual progress?....................................................................... 32
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G-5.
In what subjects does an LEA assess private school children?............................................. 32
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G-6.
May Title I funds be used to assess private school children?................................................32
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G-7.
May an LEA use the private school’s assessment data to determine progress of the LEA’s
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Title I program?..................................................................................................................... 32
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G-8.
May an LEA pay a private school for the assessment data of Title I participants?............... 32
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H. COMPLAINTS AND FEDERAL BYPASS
H-1.
Do private school officials have the right to complain?........................................................ 32
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H-2
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What happens if the United States Secretary of Education determines that an LEA has
substantially failed or is unwilling to provide for such participation as required by
Section 1120 of the Title I statute?....................................................................................... 33
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APPENDICES
Appendix A – Example of Timeline for LEA Consultation with Private School Officials……….. 34
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Appendix B – Sample Written Affirmation of Consultation………………………………………. 38
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Appendix C – Sample Contact Log…………………………………………………………………40
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Appendix D – LEA Worksheet to Determine the Amount of Title I Funds for Equitable Services. 41
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PROVIDING SERVICES TO ELIGIBLE PRIVATE SCHOOL CHILDREN
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Under Title I of the No Child Left Behind Act of 2001
INTRODUCTION
Serving private school students under the No Child Left Behind Act of 2001 (NCLB) is the most
common monitoring finding across the United States. The United States Department of Education
(USDE) has cited Florida and its districts in this area. The purpose of this Technical Assistance
Paper is to collect, in one document, the guidelines that districts should follow in serving eligible
private school students. This document draws heavily on two federal guidance documents:
Providing Services to Eligible Private School Children (2003); and Ensuring Equitable Services to
Private School Children: A Title I Resource Kit (2006). The intent of this document is to make sure
that Florida’s local educational agencies (LEAs) have all the information they need to serve these
children.
Under Title I of the No Child Left Behind Act of 2001 (NCLB), LEAs are required to provide
services for eligible private school students, as well as eligible public school students. In particular,
Section 1120 requires a participating LEA to provide eligible children attending private elementary
and secondary schools, their teachers, and their families with
Title I services or other benefits that are equitable to those provided to eligible public school
children, their teachers, and their families.
The Title I services for private school students must be developed in consultation with officials of
the private schools. The NCLB strengthened these requirements by, among other things, requiring
meetings with private school officials and a written affirmation signed by private school officials
that the required consultation has occurred.
The amount of Title I funds allocated to each participating public school attendance area is
determined primarily on the basis of the total number of low-income students—both public and
private-residing in each area. Expenditures for private school students in each area generally are
determined based on the proportion of students from low-income families residing in that area who
attend private school.
The Title I services provided by the LEA for private school participants are designed to meet their
educational needs and supplement the educational services provided by the private school. These
services may be provided by the LEA, or by a contractor who is independent of the private school
and any religious organization. Title I services or benefits must be secular, neutral, and
non-ideological.
A. CONSULTATION
A-1. Are all private school students eligible to participate in Title I?
No. Only students at private schools with official nonprofit status are eligible to be considered for
Title I, Part A, services. Schools must have a tax-exempt identification number, and an LEA can
verify a school’s nonprofit status by calling the Internal Revenue Service at 1-800-829-1040. Home
schools must meet this same requirement. (For information on student-level eligibility, see Section
C.)
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A-2. Which private schools must LEAs consult with?
The LEA must consult with all private schools with nonprofit status that serve students that live in
the LEA.
A-3. What is consultation?
Consultation is the statutorily required basis for all services to eligible private school students. LEAs
are required to annually discuss key issues that affect the ability of private school students, their
parents, and teachers to participate equitably in Title I programs with private school officials.
A-4. Is there a minimum definition of consultation?
No. However, federal guidance does define what is NOT considered adequate consultation. A
unilateral offer of services by an LEA with no opportunity for discussion is not adequate
consultation. Similarly, it is not adequate consultation to send a letter to officials of the private
schools explaining the intent of Title I. In general, consultation must meet two conditions: it must be
(1) timely; and (2) meaningful.
A-5. When must consultation take place in order to be “timely”?
Timely consultation takes place before decisions are made about Title I funding and services that
could affect the opportunity for eligible private school children, their teachers, and their families to
participate in Title I programs. Examples of such decisions are:
•
*Providing district-wide activities, such as a reading program, with Title I funds;
•
*Using Title I funds to finance a parent resource center;
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*Determining public school allocations;
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*Signing teacher contracts;
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*Ordering supplies and equipment for the Title I program.
A-6. What must consultation include in order to be “meaningful”?
Consultation is meaningful if it includes all of the statutorily required topics. Under Section 200.63
of the Title I regulations consultation must, at a minimum, address the following issues:
•
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How the LEA will identify the needs of eligible private school children.
•
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What services the LEA will offer to eligible private school children.
•
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How and when the LEA will make decisions about the delivery of services.
•
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How, where, and by whom the LEA will provide services to eligible private school children.
•
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How the LEA will assess academically the services to private school children in accordance
with Section 200.10 of the Title I regulations, and how the LEA will use the results of that
assessment to improve Title I services.
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•
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The size and scope of the equitable services that the LEA will provide to eligible private
school children and, consistent with Section 200.64 of the Title I regulations, the proportion
of its Title I funds that the LEA will allocate for these services and the amount of funds that
the LEA reserves from its Title I allocation for the purposes listed in Section 200.77 of the
Title I regulations.
•
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The method, or the sources of data, that the LEA will use (under Section 200.78 of the
Title I regulations) to determine the number of private school children from low-income
families residing in participating public school attendance areas, including whether the LEA
will extrapolate data if a survey is used.
•
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The services the LEA will provide to teachers and families of participating private school
children.
Consultation must also include:
•
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Discussion of service delivery mechanisms the LEA will use to provide services, and
•
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Thorough consideration and analysis of the views of the private school officials on whether
the LEA should contract with a third-party provider. If the LEA disagrees with the views of
the private school officials on that issue, the LEA must provide in writing to those officials
the reasons why the LEA has chosen not to use a third-party contractor.
A-7. How do LEAs begin the consultation process?
Every year, an LEA must contact officials of private schools with children who reside in the LEA
regardless of whether the private school they attend is located in the LEA.
A-8. Who participates in the consultation process?
Consultation includes appropriate public school officials and representatives of private schools and
their central administrative offices, if appropriate.
A-9. How long does consultation continue?
An LEA must meet with appropriate private school officials throughout the implementation and
assessment of Title I services. This consultation must include early discussions to prepare for the
next school year so that there is a timely start of the Title I program at the beginning of each school
year. Please see the sample timeline for LEA consultation in Appendix A.
A-10. What records on consultation must an LEA maintain?
Each LEA must maintain and provide to the Florida Department of Education a written affirmation,
signed by officials of each private school with participating children or appropriate representatives
of the private school officials that the required consultation has occurred. Appendix B provides
sample affirmations of consultation.
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However, LEAs may use their own forms as long as the forms contain the minimum information on
the sample form. Copies of these forms must be sent in to the Florida Department of Education as
part of the annual self-monitoring process.
FDOE will verify that signed consultation forms are submitted for each private school registered as
operating in each district. If the LEA cannot obtain a signature (for example, because the school
does not respond to repeated contacts), the LEA must provide this information in lieu of a signed
consultation form. If the private school simply indicates it does not wish to participate in Title I
services, LEAs should make every effort to obtain a signature indicating refusal of services.
A-11. Because consultation is an on-going process, when should private school officials or
their representative(s) sign the required written affirmation that appropriate consultation has
taken place?
An LEA is required to submit an affirmation that the consultation for the upcoming school year,
including funding decisions, has taken place at the time that it submits its annual self-monitoring
work papers. After the affirmation is obtained, consultation continues through the implementation
and assessment of services. Appendix D provides a sample contact log that may be used to track
ongoing contacts with private school officials.
A-12. Must an LEA provide a copy of its Title I application if a private school official requests
it?
Yes. An LEA must provide a copy of its Title I application when a private school official requests
it. All Title I applications, once approved, are maintained on the Bureau of Student Assistance web
site at the following address:
http://www.firn.edu/doe/bsa/index.html
. These documents are
public information.
B. ALLOCATING FUNDS FOR EQUITABLE SERVICES FOR PRIVATE
SCHOOL STUDENTS
Under Section 1113(a) of the Title I statute and Section 200.78 of the regulations, an LEA must
allocate
Title I funds to public school attendance areas, identified as eligible and selected to participate, in
rank order on the basis of the total number of children from low-income families residing in each
area.
B-1. How does an LEA allocate funds for Title I services under Section 1113(c) of the Title I
statute?
Under Section 1113(c) of Title I, an LEA calculates the per-pupil allocation (PPA) for each
participating public school attendance area (see Identifying and Serving Eligible Title I Schools
Technical Assistance Paper
http://info.fldoe.org/docushare/dsweb/Get/Document-4412/k12-
07-82memo.pdf
). Then, based on the total number of children from low-income families residing
in each attendance area attending either public or private schools, the LEA calculates the total
amount of funds for each area.
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From this amount, the LEA reserves an amount of funds for the private school children (equal to the
PPA multiplied by the number of low-income private school students in the area) to provide
equitable services to eligible private school participants.
Public school
attendance area
Column A
Per pupil allocation
(PPA) by attendance
area
Column B
Number of
public school
low-income
children by
attendance
area
Column C
Number of
private school
low-income
children by
attendance area
Column D
Total allocation for
each public school
[Col. A X Col. B]
Column E
Amount
available for
Title I services
to private
school children
(Col. A X Col.
C)
A
$800
500
130
$400,000
$104,000
B
$700
300
8
$210,000
$ 5,600
C
$600
200
3
$120,000
$ 1,800
D
$500
400
17
$200,000
$ 8,500
In this example, excerpted from the federal guidance, eligible public school attendance areas are identified and ranked
on the basis of the number of children from low-income families attending public schools.
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B-2.
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How may an LEA collect poverty data on private school children?
Section 1120(c)(1) of the Title I statute and Section 200.78(2) of the regulations allow an LEA to
calculate the number of children who are from low-income families and attend private schools in
several ways:
1.
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Using the same measure of poverty.
If available, an LEA should use the same measure of
poverty used to count public school children,
e.g., free and reduced price lunch data.
2.
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Using comparable poverty data from a survey and allowing such survey results to be
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extrapolated if complete actual data are unavailable.
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a.
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In order to obtain the number of private school children from low-income families, an
LEA may use a survey to obtain poverty data comparable to those used for public school
students. To the extent possible, the survey must protect the identity of families of private
school students.
The only information necessary for an LEA to collect in such a survey
of private school children is:
(1)
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geographic information verifying residence in a participating public school
attendance area;
(2)
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grade level of each child; and
(3)
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income level of parents.
Under Section 1002.42, Florida Statutes LEAs may not require that the private school
officials give the names of low-income families.
b.
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After obtaining income data from a representative sample of families with children in
private schools, an LEA may extrapolate those data to the entire private school student
population if complete actual data are unavailable. The LEA should take care to ensure
that the data are truly representative of the private school students in the district.
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EXAMPLES OF REPRESENTATIVE SAMPLE AND EXTRAPOLATION:
Column 1
Column 2
Column 3
Column 4
Column 5
Public
school
attendance
area
# of
resident
private
school
children
# of private
school
children
submitting
surveys
# of low-
income
private
school
children
from
survey
extrapolated #
of low-income
private school
children
A
150
115
100
130
B
20
10
4
8
Key:
Column 1. public school attendance area
Column 2. number (#) of resident private school children
Column 3. number of private school children submitting surveys
Column 4. number of low-income private school children on returned surveys
Column 5. extrapolated number of low-income private school children.
CALCULATIONS:
Col. 5 (extrapolated number of low-income children) =
Col. 4 (# of low-income on survey) multiplied by Col. 2 (# resident private school children)
Col. 3 (total submitted surveys)
Or
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100
times 150 = 130
4 times 20 = 8
115
10
3.
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Using comparable poverty data from a different source.
If data from the same source used
for public school children are not available, an LEA may use poverty data for private school
children that are from a different source than the data it uses for public school children so
long as the income threshold in both sources is generally the same.
For example, an LEA uses free and reduced price lunch data but private school children do
not participate in the free lunch program; however, private school officials are able to
provide an LEA with a count of children who are from low-income families using other
sources of poverty data such as Temporary Assistance to Needy Families (TANF) or tuition
scholarship programs. If the different sources use different definitions of low-income, an
LEA would need to adjust the results accordingly.
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4.
?
Using proportionality. An LEA may apply the low-income percentage of each participating
public school attendance area to the number of private school children who reside in that
school attendance area. To do this, an LEA will need the addresses and grade levels of
those students attending private schools. Under Florida Statute 1002.42, an LEA cannot
require that a private school provide this information. However, private schools may provide
the information on a voluntary basis.
EXAMPLE OF PROPORTIONALITY CALCULATIONS:
An LEA calculates the percent of poverty of a public school attendance area to be 60 percent.
The LEA then applies the poverty percentage of the public school attendance area to the number
of private school children residing in that public school attendance area. For example, if the
number of private school children residing in the public school attendance area is 50, then 60
percent of 50 children or 30 children are considered to be from low-income families. The LEA
calculates the per-pupil amount on this number (30 children).
5.
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Using an equated measure.
An LEA may use an equated measure of low-income status by
correlating sources of data—that is, determining the proportional relationship between two
sources of data on public school children and applying that ratio to a known source of data
on private school children.
An LEA uses free and reduced-price lunch data, but those data
are not available for private school students. However, if TANF data are available, the LEA
could determine an equated measure of poor students in private schools based on free and
reduced-price lunch data by correlating the two sets of data as follows: TANF in the public
school is to free and reduced price-lunch as TANF in private schools is to “X.”
TANF (public)
?
= TANF (private)
Free & reduced price lunch (public)
X
(private)
In this example, the LEA may then use the equated number of private school students based
on free and reduced-price lunch data (“X”) as the number of poor private school students.
B-3. How does an LEA determine if it should collect the poverty data annually versus
biennially (every two years) and must the collection of poverty data be uniform across the
district?
Section 1120(a)(4) of the Title I statute permits an LEA to determine the number of children from
low-income families who attend private schools "each year or every 2 years." This provision was
included to reduce the burden of annually collecting poverty data from private schools, particularly
if those private schools do not otherwise maintain poverty data and have to obtain those data
through a survey. An LEA should consult with appropriate private school officials about the
availability of poverty data on private school students and by this process determine whether it
would be more feasible to collect annually or biennially. It is not necessary that an LEA adopt a
uniform procedure with regard to all private schools. For example, if some private schools have free
and reduced price lunch data available, the LEA could collect those data annually. For other private
schools that rely on a survey, the LEA could collect data biennially. If data are collected from
different years, the LEA should ensure that the data for the district, taken as a whole, appropriately
and consistently represent concentrations of low-income students.
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B-4. If an LEA does not collect the names of low-income families, how do LEA officials or
auditors determine that the poverty numbers provided by the private school officials are
accurate?
Private school officials should maintain the poverty data in their files. If LEA officials or auditors
wish to review the poverty data, they may review the data at the private schools.
B-5. Is there a preferred method for collecting poverty data?
Yes. If the same data source is available for public and private schools, then that is the preferred
method for determining the number of public and private school children from low-income families
because of comparable data. However, if the data used for public school children are not available
for the private school children, then, after consultation with the appropriate private school officials,
the other methods described in this guidance may be used to collect poverty data for private school
students.
B-6. May an LEA use more than one method of collecting poverty data?
Yes. Since some private schools within an LEA do not participate in the free and reduced price
lunch program, it may be necessary for an LEA, after consultation with appropriate private school
officials, to use more than one method of collecting data on children living in poverty. However,
the LEA must ensure that there are no duplicate counts and that the methods used have comparable
income levels.
B-7. May an LEA reserve funds off the top of its Title I allocation before it allocates funds to
participating public school attendance areas?
Yes. The provisions for allocating Title I funds are in Section 200.77 of the Title I regulations.
Before allocating Title I funds to participating public school attendance areas, an LEA must reserve
a portion of its Title I allocation “off the top,” as needed, for specific purposes. These purposes may
be to provide services for neglected children in local institutions or for homeless children, carry out
parental involvement and professional development activities, pay for choice-related transportation
and supplemental educational services, or administer Title I programs for public and private school
children, including paying any special capital expenses. The LEA may also reserve funds off the top
for other authorized activities, such as school improvement activities or district-wide instructional
programs.
B-8. What are the requirements if an LEA reserves Title I funds off the top for district-wide
instructional programs for public elementary and secondary schools?
If an LEA reserves funds off the top of its Title I allocation for district-wide instructional programs
for public elementary and secondary school students, the equitable services requirement applies.
Section 200.64(a)(2)(i)(A) of the Title I regulations requires that, if an LEA reserves funds for
instructional and related activities for public elementary or secondary school students at the district
level, the LEA must also provide from these funds, as applicable, equitable services to eligible
private school children.
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The amount of funds available to provide equitable services from the applicable reserved funds must
be proportional to the number of private school children from low-income families residing in
participating public school attendance areas.
EXAMPLE OF EQUITABLE CACULATIONS FOR DISTRICT – WIDE ACTIVITIES:
An LEA reserves $500,000 for a district-wide reading initiative. The number of public and private
school children from low-income families residing in participating Title I attendance areas is
25,000. Five percent of the 25,000 children from low-income families attend private schools; thus
five percent of the $500,000 reservation, or $25,000, is available for equitable services for private
school participants. Thus, the LEA has $475,000 for its public school district-wide reading
initiative and $25,000 for Title I services to private school participants. The Title I program funded
with this $25,000 must meet the needs of the private school participants but does not have to be
identical to the district-wide reading initiative. The LEA must consult with appropriate private
school officials to determine how these funds will be used to benefit private school participants.
B-9. Are private school children who receive Title I services eligible to receive supplemental
educational services?
No. Only children from low-income families attending public schools identified for improvement,
corrective action, and restructuring–not all children participating in Title I–are eligible to receive
supplemental educational services.
B-10. Does the equitable services requirement in Section 1120(a) of the Title I statute apply to
LEA set-asides for preschool programs?
No. The equitable services requirement does not apply to children attending private preschool
programs, since Florida does not consider preschool to be part of elementary education.
B-11. Does the equitable services requirement in Section 1120(a) apply if the LEA takes funds
off the top of its Title I allocation for summer school programs?
Yes. Since a Title I summer school program provides instructional services, Section
200.64(a)(2)(i)(A) of the Title I regulations would apply and would require the LEA to provide
equitable services to eligible private school children. The LEA must determine equitable services
based on the reserved funds and the proportion of private school children from low-income families
residing in participating public school attendance areas.
B-12. If funds are transferred into the Title I program from other NCLB programs under the
transferability authority, do the requirements relating to the equitable participation of private
school students apply to these funds?
Yes. With respect to any funds transferred into the Title I program, the LEA must provide equitable
services for private school students.
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B-13. May an LEA transfer funds into the Title I program solely to provide services for
private school students?
No. The LEA may not transfer to the Title I program only the portion of funds available for services
for private school students from one or more of the programs whose funds may be transferred.
Funds that are transferred into Title I must be used for all the required set-asides, including
parent involvement and professional development.
B-14. Does the LEA have options on how to allocate funds to provide services for eligible
private school students?
Yes, although it must make this decision in consultation with the private schools. The LEA and
private school officials may choose one or both of the following options for using the funds reserved
for instructional services for eligible private school children.
(1)
On a School-by-School Basis: Provide equitable services to eligible children in each
private school with the funds allocated for the children who reside in participating public
school attendance areas and attend that private school.
(2)
Pooling Option: Combine funds allocated for private school children in all
participating areas to create a pool of funds from which the LEA provides equitable services
to eligible private school children who are in the greatest educational need of those services
and reside in participating public school attendance areas. If it pursues this option, the LEA,
in consultation with officials from the private schools, must establish criteria to determine the
eligible private school students in greatest educational need who should receive services.
Under this option, the services provided to eligible children attending a particular private
school do not depend on the amount of funds allocated for children in that school.
When it applies for NCLB funding in its annual application, the LEA must indicate whether it will
use school-by-school or pooling to provide equitable services.
B-15. If an LEA, in consultation with private school officials, decides to pool funds allocated
for private school children and, later, eligible low-achieving children in some schools choose
not to participate in the Title I programs, do the funds allocated for children in these private
schools remain in the pool?
Yes. An LEA allocates Title I funds to participating public school attendance areas using data on
the number of low-income children, both public and private, who reside in that public school
attendance area. Once funds are allocated, if a particular private school with eligible low-achieving
children does not wish to have its students participate in the Title I program, any funds allocated for
children in that private school remain in the pool.
B-16. If there are no children from low-income families attending a private school, and so no
funds are allocated for Title I services, may the private school children who meet the
educational criteria obtain Title I services?
If there are no children from low-income families to generate funds, and the LEA is not pooling the
funds, then children in that private school who meet the educational criteria will not receive Title I
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services because there are no funds available to provide services. If the LEA is pooling funds, then
eligible low-achieving children who meet the educational criteria and attend private schools with no
children from low-income families may receive Title I services.
B-17. When an LEA elects not to serve an eligible public school attendance area, as permitted
under Section 1113(b)(1)(D) of the Title I statute, what are the procedures for serving the
private school children who reside in that attendance area?
An LEA may elect not to serve ("skip") an eligible public school attendance area or school that has a
higher percentage of children from low-income families than other schools it elects to serve if (1)
the school meets the comparability requirements, (2) the school is receiving supplemental funds
from other State or local sources that are spent according to the requirements of either Section 1114
or 1115, and (3) the funds expended from such other sources equal or exceed the amount that would
be provided under Part A. Eligible private school children who reside in a “skipped” attendance
area, however, must be provided Title I services even though the public school attendance area is
skipped.
On its Public School Eligibility Survey, each LEA must determine which school attendance areas
would have received Title I funds absent any skipping and what the per-pupil allocations for those
areas would have been. The LEA must then determine the amount of funds that would have been
allocated for private school children residing in those school attendance areas. This amount is
included in the funds available for serving eligible private school children residing in the LEA. If
the LEA skips one or more of its higher-ranked school attendance areas, enabling the LEA to use
Title I funds to serve additional lower-ranked areas, low-income private school children residing in
those additional areas would not warrant the allocation of funds. LEAs should indicate this using
the “Other” selection code on the Public Schools Eligibility Survey.
B-18. How are private school children to be identified as residing in a participating public
school attendance area if an LEA is operating under an open enrollment, desegregation, or
magnet plan?
If an LEA identifies a public school as eligible on the basis of enrollment, rather than serving an
eligible school attendance area, the LEA must, in consultation with private school officials,
determine an equitable way to identify eligible private school children. For example, the LEA may
assign a private school child to the public school attendance area in which the child resides or to the
public school that the child would have attended if not enrolled in a private school.
C. ELIGIBLE CHILDREN
C-1. Which private school students are eligible for Title I services?
To be eligible for Title I services, a private school child must reside in a participating public school
attendance area and must meet the requirements in Section 1115(b) of Title I, which requires the
LEA to use multiple, educationally related, objective criteria in selecting the most educationally
needy children to participate in the Title I program. Under that section of the statute, certain
children may be identified as eligible solely by virtue of their status: for example, homeless children
and children who in the preceding two years had participated in Head Start, Even Start, Early
Reading First, a Title I preschool program, or a Title I, Part C (Migrant Education) program.
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C-2. What are the criteria for selecting private school children from preschool through
grade 2?
Children from preschool through grade 2 are selected solely on the basis of such criteria as teacher
judgment, interviews with parents, and developmentally appropriate measures.
C-3. Are private school children from low-income families automatically eligible for Title I
services?
No. Student eligibility for Title I services for private school children is determined by (1) residence
in a participating public school attendance area, and (2) educational need. Poverty is not a criterion.
C-4. How are the criteria determined?
In consultation with private school officials, an LEA must establish multiple, educationally related,
objective criteria to determine which private school children are eligible for Title I services, and,
within the eligible group, which children will be served. To the extent appropriate, the LEA must
select private school children who are failing, or most at risk of failing, to meet the state student
academic achievement standards. Criteria may include the results of achievement tests (including,
but not limited to, the SAT 9, SAT 10, or another norm-referenced test); teacher referrals and
recommendations, and grades.
LEA and private school officials decide that the criteria for private school students are (1) test
scores on a national norm-referenced test given annually by the private school and (2) teacher
referral.
The criteria should provide accurate and unduplicated information. The private school
principal provides the names, addresses, and grades of the private school children meeting the
agreed upon criteria. The LEA checks the addresses of the children on the list to determine those
who live in participating public school attendance areas. Based on established educational
criteria, the LEA then selects, from among those who are eligible and live in participating public
school attendance areas, those private school children who are failing, or those who are most at
risk of failing, to meet high achievement standards.
EXAMPLE OF THE STEPS AN LEA USES TO SELECT PARTICIPANTS:
C-5. May Title I funds be used to identify eligible private school students?
No. Title I funds may not be used to identify private school children who are eligible to participate.
Title I funds, however, may be used to select participants from among those who are eligible and to
determine the specific educational needs of those children.
C-6. May an LEA require private school officials to verify that students attending their school
reside in a Title I public school attendance area?
No. It is an LEA’s responsibility to verify that the eligible private school children reside in
participating public school attendance areas.
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The officials of the private school may help with this determination if they wish. However, under
both U.S. and Florida statute, the LEA cannot require private school officials to do this verification.
Section 1002.42, F.S.
C-7. Once participants are selected, how does an LEA determine what Title I services are to
be provided?
An LEA, in consultation with appropriate private school officials, determines the appropriate Title I
services based on the needs of the private school students. Title I services may be provided in
subject areas or at grade levels that are different from those provided public school students, as long
as these services are provided in the same grade-span as the services provided to public school
children. These services must hold reasonable promise that the academic performance of private
school participants will improve.
C-8. Must the number of private school children served be equal to the number of private
school students from low-income families?
No. The needs of eligible private school children and the amount of funds available determine
which students receive the services determined during consultation.
C-9. If a school in the attendance area in which private school students reside is operating a
schoolwide program, may private school students be offered a schoolwide program also?
No. Since private schools are not eligible for Title I services, schoolwide programs may not be
operated in private schools. However, eligible private school children residing in an area served by
a schoolwide public school program must be offered equitable services.
C-10. If after receiving an offer of equitable services, the private school officials or parents
choose to have the children participate in only some of the services, may the LEA provide only
those services?
Yes. Federal statute requires that an LEA offer equitable services to private school children, but not
that private school children accept or participate in all those services. An LEA meets its
responsibility to provide services even if the services are wholly or partially refused by private
school officials or parents. The LEA must continue to offer equitable services each year and cannot
presume to reduce the services offered based on what was offered or accepted in the past.
C-11. When a child who is most at risk of failing resides in a Title I attendance area in one
LEA and attends a private school in another LEA, which LEA is responsible for serving the
child?
Section 200.62(b)(1)(i) of the Title I regulations defines Title I eligible private school children as
those who reside in participating public school attendance areas of the LEA, regardless of whether
the private school they attend is located in the LEA. Thus, the LEA in which the child resides is
responsible for providing services to the child, but it may arrange to have services provided by
another LEA and reimburse that LEA for costs.
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C-12. May an LEA establish a minimum number of private school children selected for the
program in order to establish a Title I program in the private school? If so, what is the LEA's
responsibility to serve children attending private schools with fewer than that minimum
number?
No. Section 1120(a) of Title I requires that LEAs provide for the participation, on an equitable basis,
of eligible children enrolled in private schools. The requirement applies regardless of the number of
children attending a private school; there is no minimum number. However, when the number of
eligible children at one location is very small, the cost of establishing certain types of programs to
serve them may be prohibitive, especially when these children may be from different grades or have
different educational needs. In this case, the LEAs should consider other options. If feasible and
equitable, they might adopt methods that are cost-effective for serving small numbers, such as take-
home computer programs, individual tutoring programs, professional development activities with
the classroom teachers of Title I participants, or other strategies.
C-13. If the funds allocated for private school children are not sufficient to provide
instructional services, may the funds be used to provide other services, such as professional
development or counseling?
Yes. After consultation with private school officials, an LEA may provide Title I services other
than direct instruction if the provision of services, such as counseling, staff development, and
parental involvement is appropriate to assist those children identified as failing or most at risk of
failing to meet high student academic achievement standards. The LEA must measure the effect of
the services on the academic achievement of participating children.
D. DELIVERY OF INSTRUCTIONAL SERVICES
D-1. Who is responsible for planning and designing the Title I 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.
D-2. How does an LEA design a Title I program?
Consistent with Section 1115(c) of the Title I statute, the LEA provides a Title I program to private
school children, employing 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. This program should complement classroom
instruction and should not be a separate instructional program.
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D-3. What types of services are available for private school participants?
Services, determined in consultation, may include a wide range of allowable activities such as the
following:
•
?
Books, materials, and equipment necessary to implement the Title I program (The
LEA retains title to the books, other materials, and equipment purchased with Title I
funds.
Materials, etc. purchased with Title I funds may be used only by Title I
participants. Each item purchased with Title I funds must be labeled “Property of
_________School District.” The labels should not be either easily erased or
removable.);
•
?
Extended-day services;
•
?
Summer programs;
•
?
Saturday programs;
•
?
Counseling programs;
•
?
Computer-assisted instruction (CAI) with non-instructional computer technicians
who supervise computer labs, maintain discipline, and escort students to and from
class (Their salaries are an administrative cost under Sec 200.77(f) of the Title I
regulations and may not be charged to funds generated by private school children
from low-income families, which are only to be used for instruction.);
•
?
Home tutoring;
•
?
Computers and software products; and
•
?
Take-home computers (The LEA retains title to the books, other materials, and
equipment purchased with Title I funds. Materials, etc. purchased with Title I funds
may be used only by Title I participants. Each item purchased with Title I funds
must be labeled “Property of _________School District.” The labels should not be
either easily erased or removable).
D-4. May an LEA just provide a private school with instructional materials and supplies paid
with Title I funds?
No. Simply providing the private school with instructional materials and supplies is NOT an option
available to the LEA because, according to federal guidance, it is neither a proper Title I program
implemented by the LEA nor does it meet the equitability requirement.
D-5. When should Title I services for private school participants start?
Under the equitable services provision of the Title I statute, the Title I program for private school
participants must begin at the same time as the Title I program for public school participants.
Therefore, the required consultation should begin early enough so that Title I teachers can be hired
and materials ordered in order for the Title I program to start at the beginning of each school year.
D-6. What are the obligations of an LEA that does not start the Title I program for private
school participants at the same time it starts the Title I program for public school students?
An LEA is obligated to provide Title I services on an equitable basis, and the expectation is that
Title I services start at the beginning of each school year.
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If the LEA begins the Title I program late in the school year, in order to comply with applicable
requirements, the LEA should provide additional services during the remainder of the year and carry
over any unspent funds that should have been used to provide equitable services for private school
students and add them to the instructional funds for the private school participants for the next
school year.
D-7. May private school officials order or purchase materials and supplies needed for the
Title I program and be reimbursed by an LEA?
No. Private school officials have no authority to obligate or receive Title I funds. The statute
clearly states that the LEA must maintain control of Title I funds, materials, equipment, and
property. No Title I funds may be paid to a private school, under any circumstances.
D-8. Where may Title I services take place?
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.
The following conditions must be met:
•
?
Title I services must be provided in a separate space that is under the LEA’s control
when Title I services are being provided;
•
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If the services are provided in a library or private school classroom, the space must be
separate and partitioned off; and
•
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Computer equipment and other supplies purchased with Title I funds may be used only
by Title I students in the Title I program.
D-9.
Are private schools required to make space available in their schools for Title I
services?
No. If space is not available in a private school, or if the private school chooses not to make its
facilities available to the LEA for this purpose, Title I services must be provided in another location.
The LEA still has the responsibility of providing equitable Title I services for private school
children under these circumstances, although the services would be at a location outside the private
school. The extra costs of providing services at a location outside the private school would be taken
off-the-top of the LEA’s Title I allocation before funds are allocated for instructional services for
public and private school children.
D-10. May Title I, Part A teachers use private nonprofit school facilities such as a teachers’
lounge?
Yes. There is no prohibition against reasonable use of private nonprofit school facilities by a Title I,
Part A teacher or other Title I, Part A personnel.
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D-11. May Title I services be provided in religiously affiliated private schools?
Yes. The Supreme Court decided in 1997 (
Agostini v. Felton
) that Title I instructional services may
be provided by public school employees in religiously affiliated private schools without violating
the Establishment Clause of the United States Constitution.
D-12. Must an LEA require the removal of religious symbols in private school classrooms in
which Title I services are provided?
No. The constitutionality of Title I instructional services provided in a private school will depend on
consideration of the program's safeguards viewed as a whole, not of any one factor, such as whether
or not there are religious symbols in the space used for that instruction. However, a valid program
must contain safeguards to ensure that public employees do not promote religion in the course of
carrying out their Title I duties.
D-13. May Title I, Part A, services be provided in the regular private school classroom
through aides or joint (or team) teaching?
No. Although the Supreme Court did not specifically rule this out, the USDE strongly recommends
that LEAs not provide these kinds of services. The Supreme Court in
Agostini
emphasized that the
Title I, Part A program was totally separate from the private, nonprofit school’s educational program
and under the sole control of the LEA. Providing Title I, Part A instruction as part of private school
classes raises significantly different issues and increases the risk that such services would be
unconstitutional.
D-14. May space used for Title I instruction in a private school be used for non-Title I
purposes at other times?
Yes. The LEA should have the exclusive use and control of the Title I space during the time when
Title I services are being conducted, but the space may be used for other purposes at other times.
D-15. May equipment used for Title I instruction in a private school be used for non-Title I
purposes at other times?
No. The USDE has stated that, although space may be used for both Title I and non-Title I purposes,
equipment purchased with public funds for Title I use may not be used for any other purpose, even
during other times.
D-16. May Title I, Part A teachers and other public school personnel meet or have discussions
with private school teachers and administrators?
Yes. To facilitate the delivery of well-coordinated and high-quality services, Title I teachers,
teachers of private school participants, private school officials and LEA staff members should meet
and discuss the design and implementation of the Title I program. These meetings should be one-
on-one between the Title I teachers and the private school teachers of Title I participants to ensure
that the Title I program supplements and coordinates with the regular classroom instruction received
by the private school participants.
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EXAMPLES OF COMMUNICATION WITH THE REGULAR CLASSROOM TEACHER:
In one program, each Friday afternoon, the private school classroom teacher provides the Title I
teacher with a copy of the regular classroom teacher’s weekly lesson plan for the next week in
those subjects that the Title I teacher instructs, so that the Title I teacher can adapt the Title I
instruction to support the instruction occurring in the regular private school classroom.
In another program, a regular classroom teacher provides the Title I teacher, on a weekly basis,
with a simple form that is used to inform the Title I teacher of a child's individual needs as well as
the content and skills being taught in the regular classroom. The Title I teacher then adjusts the
Title I services to meet the child’s needs and to supplement the instruction provided.
D-17. May the Title I teacher use the same textbooks as those used by the private school
students in their regular classroom?
Yes. The Title I teacher may use the same textbooks and materials as those used in the regular
private school classroom so long as the textbooks and materials are secular, neutral, and
non-ideological, and the instructional services supplement and do not replace the instructional
program in the participants’ regular classrooms.
D-18. Who provides the Title I services to private school participants?
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).
D-19. Must teachers and paraprofessionals hired by an LEA to provide Title I services to
private school participants meet the highly qualified teacher and paraprofessional
requirements in Section 1119?
Yes. 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 Section 1119 of the statute.
D-20. After consultation with the appropriate private school officials, may an LEA employ a
third-party contractor to provide Title I services to private school participants?
Yes. An LEA may provide Title I services directly or indirectly through contracts with public and
private agencies, organizations, and institutions as 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.
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D-21. If an LEA contracts with a third-party provider, must the third-party provider employ
Title I teachers and paraprofessionals that meet the highly qualified requirements in Section
1119 of Title I?
No. The highly qualified personnel requirements only apply to those teachers and paraprofessionals
who are directly employed by the LEA.
D-22. May an LEA hire a private school teacher to provide Title I services to private school
participants?
Yes, as long as the private school teacher meets the highly qualified teacher standards required in
Section 1119 of the Title I statute and is independent of the private school in the provision of Title I
services.
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.
D-23. How does the requirement in Section 1119 of the Title I statute that paraprofessionals
employed by an LEA work under the direct supervision of a public school teacher apply to the
Title I program for private school participants?
Paraprofessionals providing instructional support must work under the direct supervision of a public
school teacher (see Section 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. As a result, a Title I program for private school participants
staffed entirely by paraprofessionals is not permitted.
Paraprofessionals paid with Title I funds must work under the supervision of public school teachers,
e.g., those hired by the LEA to provide Title I services to private school students.
E. ADMINISTRATIVE COSTS
E-1. May an LEA reserve funds for administering programs for private school children?
Yes. An LEA may reserve an amount that is reasonable and necessary to administer Title I
programs for both public and private school children, including special capital expense costs. This
reservation for administration, including funds needed to administer Title I programs for private
school students, is taken "off-the-top" of the LEA's allocation and not from the funds allocated for
Title I services for private school children. Funds for instructional services are allocated after
administrative and other “off-the-top” costs are determined.
E-2. May third-party contractors incur administrative costs?
Yes, a third-party contractor hired by an LEA to provide services to private school participants may
incur administrative costs. These costs must come off the top of the LEA’s Title I allocation as
administrative costs. The LEA may not charge a third-party contractor’s administrative costs to the
funds allocated for private school children for instructional services.
26
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The parties should identify in the contract the portion of the costs that are administrative, and the
LEA should use funds taken “off-the-top” of its allocation to pay this portion of the contract.
E-3. May Title I funds be used to purchase furniture for a Title I classroom?
Yes. Title I funds may be used to purchase furniture for a Title I classroom if that cost is reasonable
and necessary for the operation of the Title I program; however, the cost of the furniture must be
charged to administrative costs. If an LEA purchases furniture with Title I funds, only Title I
participants may use it.
E-4. What are special capital expenses?
Special capital expenses refer to expenditures for non-instructional goods and services that were or
are still being incurred as a result of implementing alternative delivery systems such as the
following:
•
?
Purchase or lease of real and personal property (including mobile educational units and
neutral sites).
•
?
Insurance and maintenance costs.
•
?
Transportation between a private school and another site.
•
?
Buy-out leases for mobile vans or neutral space or other costs relating to terminating
arrangements for providing Title I services to private school children outside of their private
school.
•
?
Other comparable goods and services, which include costs to escort children to and from
instructional areas and, in the case of computer-assisted instruction (CAI), costs to install
equipment and pay for non-instructional computer technicians.
(Note: Technicians perform non-instructional duties, such as operating and maintaining
computer equipment and keeping order in a Title I CAI classroom. Whether employees should
be considered Title I instructional personnel or non-instructional technicians depends on the
functions performed by the employees in addition to their job titles or classifications.)
Under Section 200.77(f) of the Title I regulations, these special capital expenses must be considered
administrative costs and taken off the top of the LEA’s total Title I allocation.
E-5. Are the costs of computer equipment and software considered to be special capital
expenses?
No. Costs for computers and software are considered to be instructional costs and are paid from the
funds allocated for instructional services for private school children. All such equipment must be
clearly labeled as LEA, not private school, property, and counted in the LEA’s inventory.
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E-6. May Title I funds be used to renovate the private school site?
No. Federal funds cannot be used for any construction or renovations.
E-7. Must an LEA provide transportation for private school children from the private school
to another site in order to receive Title I Services ?
Yes. If eligible private school children need to be transported from their private school to another
site, the LEA, as the provider of equitable services, has the responsibility of providing that
transportation. The cost of such transportation is an administrative cost and should not be charged
to the instructional funds allocated for private school children.
F.
EQUITABLE SERVICES FOR PRIVATE SCHOOL FAMILIES AND
TEACHERS
F-1. How does an LEA determine the amount of funds to be used for parental involvement
activities for parents of participating private school students?
Section 1118 of Title I requires an LEA to reserve funds off the top of its Title I allocation to carry
out required Title I parental involvement activities. Section 200.65 of the regulations requires the
LEA to calculate the amount of funds available for parental involvement activities from the reserved
funds based on the proportion of private school children from low-income families residing in
participating public school attendance areas.
Appendix D provides a useful worksheet for these calculations.
An LEA reserves one percent ($60,000) of its Title I allocation of $6,000,000 for parental
involvement activities. The number of public and private school children from low-income
families residing in participating Title I attendance areas is 25,000. Five percent of the 25,000
children attend private schools; thus five percent of the $60,000 reservation, or $3,000, is available
for equitable services for parents of private school participants. The parent involvement program
funded by Title I must meet the needs of the parents of private school participants. After
consultation with the appropriate private school officials, the LEA may conduct these activities
independently or in conjunction with the LEA’s regular parent involvement activities.
EXAMPLE OF EQUITABLE SERVICES FOR FAMILIES:
F-2. How does an LEA provide equitable services for parents of private school students
participating in the Title I program?
An LEA must provide equitable services to parents of private school participants from the funds set
aside for this purpose. Activities for the parents of private school participants must be planned and
implemented after meaningful consultation with private school officials and parents. Activities that
LEAs can provide parents that will assist private school students in achieving high academic
standards should be discussed. A written agreement between the LEA and parents of private school
participants regarding the responsibilities of the LEA and parents in the Title I program, parent
28
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meetings, communication between the Title I teachers and parents on students’ academic progress,
parent-teacher conferences, and parent education should be developed.
During the consultation process, the LEA, private school officials and parents discuss a number of
options for parental involvement in the Title I program, including parent meetings, parent compacts,
parent-teacher conferences, parent training activities, and reasonable access to Title I staff. After
considering the needs of the private school parents and the views of the private school officials and
parents, the LEA conducts an annual meeting with parents, initiates written compacts between the
LEA and parents outlining their shared responsibilities in the Title I program and provides
workshops for parents on how to work at home with their children in reading and math. The LEA
also provides parents of each private school participant an individual student report on the
performance of that participant on the FCAT or on an appropriate alternative assessment and
informs parents about how their children are achieving in the Title I program through monthly
reports to parents.
EXAMPLES OF PARENT INVOLVEMENT ACTIVITIES:
One LEA encourages and enhances parental involvement through hands-on workshops and
individual meetings to provide parents with strategies and techniques for improving their children’s
learning. For example, a joint compact between the Title I teachers and the parents of participating
students outlines their shared responsibilities for improved student achievement under Title I using
books and tapes in a read-aloud program. In addition, parents use a variety of teacher-made and
commercially prepared activity kits, resource books, and guides to enhance their involvement in
their children’s education. Progress reports are distributed to parents twice a year, and a parent
representative from each private school community is invited to the District-wide Private School
Steering Committee to share ideas and recommendations regarding services to be implemented for
private school participants, their teachers, and their families.
F-3. How does an LEA meet the equitability requirement for professional development?
If an LEA reserves funds under Section 1119 off the top of its Title I allocation for carrying out
Title I professional development activities, the LEA must provide equitable services to teachers of
private school participants from this set-aside. This applies to funds reserved for professional
development over and above the requirements of Section 1116 to set aside 10 percent for districts in
need of improvement, 10 percent for schools in need of improvement, and Section 1119 to set aside
a maximum of 5 percent for highly qualified teachers.
As required under Section 200.65 of the regulations, an LEA calculates these equitable services
from the reserved funds in proportion to the number of private school children from low-income
families residing in participating public school attendance areas. Activities for the teachers of
private school participants must be planned and implemented in meaningful consultation with
private school officials and teachers.
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An LEA reserves six percent ($360,000) of its Title I allocation of $6 million for professional
development as required under Section 1119. The number of public and private school children
from low-income families residing in participating Title I attendance areas is 25,000. Five percent
of the 25,000 children attend private schools; thus five percent of the $360,000 reserved ($18,000)
is available for equitable services for the teachers of private school participants. The professional
development activities funded by Title I must meet the needs of the teachers of private school
participants. After consultation with the appropriate private school officials, the LEA may
conduct these activities independently or in conjunction with the LEA’s professional development
activities
.
EXAMPLE OF ALLOCATING FUNDS FOR EQUITABLE SERVICES FOR PRIVATE
SCHOOL TEACHERS:
F-4. Which private school teachers are eligible for professional development under “equitable
services”?
Eligible private school teachers include teachers that instruct private school students who are
receiving Title I services. These are the regular classroom teachers of the private school students
who receive Title I services, not the teachers who provide the Title I services under contract with the
LEA.
F-5. Must the LEA provide professional development activities to the Title I teachers who are
employees of the LEA?
No. The LEA is not required to provide professional development activities for Title I teachers who
are employees of the LEA. The costs of this training should be paid from the funds reserved for the
professional development of the LEA’s teachers and not from the funds required to provide
equitable services to teachers of private school participants.
F-6. How may the funds reserved for professional development for teachers of private school
participants be used?
The professional development activities for private school teachers should address how those
teachers can serve Title I students better, such as by providing information on research-based
reading and mathematics instruction. Funds reserved for this purpose may not be used to upgrade
the instructional program in the regular classroom of the private school.
F-7. May the private school officials arrange for professional development services for
teachers of Title I participants and submit an invoice to the LEA for payment?
No. Private school officials are not authorized to obligate or receive Title I funds. Section 1120 (d)
clearly states that the LEA must maintain control of Title I funds. No Title I funds may be paid to
the private school.
30
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F-8. May Title I funds be used to pay stipends to private school teachers of Title I participants
who participate in a Title I professional development program?
Yes. Title I funds may be used to pay for stipends for private school teachers, if reasonable and
necessary. For example, if the professional development activity is conducted during after-school
hours or in the summer, stipends may be needed to compensate teachers for their participation
outside their regular employment hours.
Stipends for private school teachers must be available on the same basis as those for public school
teachers
and
the stipends must be paid directly to the private school teachers for their own use and
not to the private school.
F-9. May Title I funds be used to pay for substitute teachers who replace private school
teachers in their regular classroom while they attend Title I professional development
activities?
No. Title I funds may not be used to hire substitute private school teachers. After consultation, the
LEA should offer professional development activities at a time and place that is convenient for the
teachers of private school participants.
G. STANDARDS, ASSESSMENT, AND PROGRAM MODIFICATION
G-1. What standards apply to private school students who participate in Title I programs?
Private school students who participate in Title I programs must be held to high standards. However,
it may not be appropriate to expect private school children to meet Florida’s standards if, for
example, those standards are not aligned with the curriculum of the private school.
If the LEA, in consultation with private school officials, determines that it would be inappropriate to
measure the achievement of participating private school children in relation to Florida’s standards,
the LEA must use alternative standards that reasonably promise that the services provided will
enable the private school participants to achieve the high level called for by achievement standards
of Florida’s students.
G-2. Must an LEA evaluate the progress of private school students?
Yes. An LEA must annually assess the progress of the Title I program toward enabling private
school Title I participants to meet the agreed-upon standards. The LEA may use Florida’s
assessment system (under Section 1111(b)(3) of Title I) or other assessment measures that more
accurately reflect the progress of the participating private school students toward meeting the
standards that the LEA, in consultation with private school officials, has determined are appropriate.
Every year the LEA and private school officials must consult on what constitutes annual progress
for the Title I program.
While LEAs are required to assess the progress of Title I students annually, they should also consult
with private school officials and teachers regularly about the progress Title I private school
participants are making in their regular classrooms.
31
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G-3. Must an LEA evaluate students’ progress on a school-by-school basis?
No. In measuring annual progress, the LEA has the flexibility to group children in a manner that
will provide the most accurate information about their progress. For example, the LEA may decide
to group children by instructional method, grade level, school, or other appropriate basis.
G-4. What actions must an LEA take if the Title I program for the private school participants
does not make the expected annual progress?
If the Title I program for the private school participants does not make the expected annual progress,
the LEA must annually make modifications to the Title I program, in consultation with private
school officials.
G-5. In what subjects does an LEA assess private school children?
An LEA normally would assess private school children in the subjects in which the LEA provides
Title I services to those children.
G-6. May Title I funds be used to assess private school children?
Yes. Title I funds may be used to assess private school children if the assessment is used only for
Title I purposes. To the extent, however, that an assessment is conducted for other purposes, it may
not be paid for from Title I funds.
G-7. May an LEA use the private school’s assessment data to determine progress of the
LEA’s Title I program?
Yes. Officials of the private schools may provide the LEA with the assessment data on Title I
participants that the private school has collected as part of its testing program. However, private
school officials are not obligated to do this, and refusal by private school officials to provide these
data does not release the LEA from its obligation to provide services and assess the progress of the
private school participants in the Title I program.
G-8. May an LEA pay a private school for the assessment data of Title I participants?
No.
H. COMPLAINTS AND FEDERAL BYPASS
H-1. Do private school officials have the right to complain?
Yes. Private school officials have the right to complain to the FDOE if they believe that an LEA did
not engage in timely and meaningful consultation or did not consider their views. Private school
officials have access to the Department’s NCLB complaint process. If FDOE receives a complaint
from a private school regarding Title I services, it will investigate the complaint and seek further
information.
32
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H-2. What happens if the United States Secretary of Education determines that an LEA has
substantially failed or is unwilling to provide for such participation as required by Section
1120 of the Title I statute?
If the United States Secretary of Education determines that an LEA has substantially failed or is
unwilling to provide for such participation as required by Section 1120 of the Title I statute, the
Secretary waives the requirements that the LEA serve private school children and arranges for the
provision of such services by another entity; this process is called bypass. In making the
determination to bypass an LEA, the Secretary considers one or more factors, including the quality,
size, scope, and location of the program and the opportunity of private school children to participate
in the program.
To implement a bypass, the Department generally enters into a contract with a third party, awarded
in accordance with the Federal Acquisition Regulations (FAR) and deducts funds from the State’s
Title I allocation. Accordingly, Florida would then reduce the allocations of the bypassed LEAs.
The Department administers any bypass contract in accordance with the FAR.
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Appendix A: Example of Timeline for LEA Consultation with Private
?
School Officials
?
Example of a Timeline for LEA Consultation
?
With Private School Officials*
?
Month
November/December
in preparation for
the next school year
LEA Activity
Obtain complete list of all private schools with
students who are residents of the LEA.
Meet with private school officials to review
timeline and consultation process. Establish a
consultation calendar and procedures for collecting
poverty data (i.e. data on low-income families).
Legal Basis**
LEA uses list to ask all private
school officials if they want
their eligible students to
participate in Title I the next
school year.
See Section 1120(a) of the
Elementary and Secondary
School Act.
December through
February in
preparation for the
next school year
Obtain from principals or a central office serving a
group of private schools the following poverty
data (as appropriate) on private school students:
•
Same poverty measure used to count
public school students, which is usually
free and reduced-priced lunch;
•
Survey of private school parents asking
for income data, address, and grade
level of children from which the LEA
must extrapolate these data (see
Section 2);
•
Alternative poverty data such as
scholarships, Temporary Aid to Needy
Families, Medicaid, etc.
~or~
•
Decide through consultation to use
proportionality (see Section 2).
Private school students from
low-income families who live
in Title I participating public
school attendance areas
generate funds for
instructional services.
See Section 1120(c)(1) &
Section 200.78(a)(2) of the
Title I regulations.
February/March
in preparation for
the next school year
Match addresses of private school students
from low-income families to participating public
school attendance areas.
Estimate the amount of funds generated for
instruction using the same estimated per-pupil
amount as that used for public school students
in participating public school attendance areas.
Meet with private school officials to discuss
poverty data collected, amount of estimated
instructional funds generated, and determine if
funds will be pooled, not pooled, or a
combination of both options.
See Section 1120(b)(1)(f) &
(2) and Section 200.64(a).
* In this example, multiple meetings will be required to cover each LEA activity.
** This column references Title I, Sec. 1120 and 34
CFR
200.
34
Month
LEA Activity
Legal Basis
Determine the multiple, educationally related,
objective criteria to be used to select eligible
students (educationally needy students who
reside in Title I attendance areas) in
consultation with private school officials.
Obtain from private school officials lists of
names, addresses, and grades of private
school students who meet the criteria.
From these lists, select for Title I services those
students most at-risk of failing, as decided in
consultation.
Discuss with private school officials the needs
of selected students, appropriate Title I services
to serve those needs, and location of services.
Design services that meet participants’ needs
based on consultation, using the estimated
amount of funds generated by private school
students from low-income families, and the
equitable share of funds reserved for district-
wide instructional activities.
Determine with private school officials the
standards and annual assessments for
measuring progress of the Title I program.
Define annual progress. Determine criteria for
making program modifications when annual
progress is not achieved.
Assess the achievement of
current year’s
program using the standards previously agreed
upon last year.
After appropriate consultation, make
modifications to next year’s Title I program, if
annual progress has not been met.
March/April
in preparation for
the next school year
Multiple, educationally related,
objective criteria required
under Section 1115(b). See
Section 200.62(b).
See Section 1120(b).
See Section 200.62(b)(2).
See Section 1120(b)(1) and
Section 200.63(a) and (b).
See Section 200.64.
LEA must assess quality and
effectiveness of Title I
program each year. LEA
modifies the design of
services if annual progress is
not met.
See Section 1120(b)(1)(D)
and Section 200.63(b)(5).
35
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Month
LEA Activity
Legal Basis
April/June
in preparation for
the next school year
Determine in consultation with private school
officials the professional development and
parent involvement needs of private school
teachers and families of private school
participants.
Design activities that LEA will implement the
next school year (independently or in
conjunction with LEA activities) for teachers
and families of participants.
Inform private school officials of tentative
program designs, service delivery models,
number of Title I participants, allocations,
location of services, and estimated costs.
Provide opportunities for private school officials
to comment.
Update private school officials if there are any
changes. Generate a list of students who will
receive Title I services beginning in September
of the next school year.
Obtain written affirmation from private school
officials or their representatives that timely and
meaningful consultation has occurred.
Consultation must be ongoing, however, and
should continue throughout the school year.
Complete all necessary reports, contract
negotiations, ordering of materials, hiring of
teachers, etc. Consultation should be
completed for the next school year prior to LEA
submitting its Title I application to the SEA.
Equitable services for
teachers and families of
participants apply to funds
reserved under Section 1118
and Section 1119.
See Section 1120(a) and
Section 200.65.
LEAs must provide
opportunities for consultation
with private school officials if
program is modified or private
school officials request more
discussion.
See Section 1120(b) and
Section 200.63.
See Section 1120(b)(4) and
Section 200.63(e).
These actions ensure that
programs will begin at the
start of the school year.
See Section 1120(a)(3) and
Section 200.62(a)(1).
August
in preparation for
the beginning of
school year
Report on readiness of Title I program for
private school participants to private school
officials.
Private school officials should
be aware of how the LEA will
implement the program in
September, including staffing,
number of students to be
served, location, etc.
See Section 1120(b)(2) and
Section 200.63(c).
36
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Month
LEA Activity
Legal Basis
September of school
year
LEA begins Title I services for students
identified the previous spring as participants
and provides private school officials with their
names, services to be provided, and names of
Title I teachers.
See Section 1120(a)(1) and
Section 200.62(a)(1).
Obtain a list of newly enrolled students who
meet eligibility criteria. Consult with private
school officials on how new students might be
accommodated in the program.
Initiate professional development and parent
involvement activities based on previous
spring’s consultation.
See Section 200.65.
October of school
year
LEA provides information about possible
adjustments and program changes to private
school officials.
Start planning for the next school year’s
consultation cycle.
See Section 1120(b)(2) and
Section 200.63(c).
Key issues relating to provision of Title I services are discussed during consultation, which provides an
opportunity for both public and private school officials to express their views and to have those views
considered. Ultimately, 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.
As a result, private school officials who want services for their eligible students should be aware of their roles
in the consultation process to ensure that Title I programs designed by the LEA effectively meet the needs of
their participating children, their teachers, and their families. Roles for the private school officials are:
•
?
Participating in consultation;
•
?
Providing lists of addresses and grades of low-income families;
•
?
Providing lists of names, addresses, and grade levels of children who meet the multiple, educationally
related, objective criteria for participation eligibility:
•
?
Suggesting ideas, program designs, and modifications that meet the needs of their eligible children, their
teachers, and their families; and
•
?
Providing a dedicated space, if appropriate.
Source: Ensuring Equitable Services to Private School Children: A Title I Resource Kit, U.S.
Department of Education, September 2006.
37
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Appendix B: Sample Written Affirmation of Consultation
LEA Affirmation of Consultation
?
With Private School Officials
?
Sec. 1120(b) of the
Elementary and Secondary Education Act
and Sec. 200.63 of the Title I regulations
require that timely and meaningful consultation occur between the local education agency (LEA) and private
school officials prior to any decision that affects the opportunities of eligible private school children,
teachers, and other educational personnel to participate in programs under this act. Consultation shall
continue throughout the implementation and assessment of activities under this section.
The following topics
must
be discussed during the ongoing consultation process:
•
?
How the LEA will identify the needs of eligible private school children;
•
?
What services the LEA will offer to eligible private school children;
•
?
How and when the LEA will make decisions about the delivery of services;
•
?
How, where and by whom the LEA will provide services to eligible private school children,
including a thorough consideration and analysis of the views of the private school officials on the
provision of services through a contract with a third-party provider;
•
?
How the LEA will assess academically the services to eligible private school children in accordance
with Sec. 200.10 of the Title I regulations and how the LEA will use the results of that assessment to
improve Title I instructional services;
•
?
The size and scope of the equitable services that the LEA will provide to eligible private school
children and, consistent with Section 200.64, the proportion of funds that will be allocated to provide
these services;
•
?
The method or sources of data that the LEA will use under Section 200.78 to determine the number
of private school children from low-income families residing in participating public school
attendance areas, including whether the LEA will extrapolate data, if a survey is used;
•
?
The equitable services the LEA will provide to teachers and families of participating private school
children; and
•
?
If the LEA disagrees with the views of the private school officials on the provisions of services
through a contract, the LEA must provide the private schools the reasons in writing why the LEA
chooses not to use a contractor.
We agree that timely and meaningful consultation occurred before the LEA made any decision that affected
the participation of eligible private school children in the Title I, Part A, program.
______________________________________
______________________________________
Public School Official
Date
Private School Representative
Date
______________________________________
_______________________________________
School
District
Name
of
Private
School
Agency
or
School
The LEA must maintain a copy of this form in its records and provide copies to the FDOE.
38
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LEA Affirmation of Consultation With Private School
?
Officials That Includes Student Selection Criteria
?
Name of LEA____________________________________________________________
Name of Private School_____________________________________________________
To ensure timely and meaningful consultation during the design and development of the LEA’s programs under
Title I, Part A, the LEA has consulted with private school officials on the following issues:
•
?
Data sources to be used to identify children’s needs;
•
?
Services to be offered;
•
?
How, where, and by whom the services will be provided;
•
?
How the services will be academically assessed and how the results of that assessment will be used to
improve services;
•
?
The size and scope of the equitable services to be provided to the eligible private school children, and
the proportion of funds that is allocated for such services;
•
?
The method or sources of data used to determine the number of children from low-income families in
participating school attendance areas who attend private schools;
•
?
The delivery of services to private school children;
•
?
The needs of private school teachers who teach Title I students and the professional development
program that will be designed to meet their needs;
•
?
The needs of families of Title I children and the family involvement program that will be designed to
meet their needs; and
•
?
Disagreements regarding contract.
Consultation included meetings with private school officials before the LEA made any decision that affected the
opportunities of eligible school children to participate in Title I, Part A, programs. Such meetings will continue
throughout the implementation of the program and will include assessment of services provided.
The following multiple, educationally related, objective criteria are used to determine private school student
eligibility for the Title I, Part A, program:
Grade
level
Criteria
Method to determine greatest need
I affirm that the required consultation has occurred.
Signature of private school official
Name of private school official
Date
Signature of public school official
Name of public school official
Date
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Appendix C: Sample Contact Log
Title I
Log of LEA Contacts With Private School Officials
LEA ___________________________________________________________
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Title I Coordinator___________________ Telephone Number___________________
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Title I Coordinator: Complete an entry for each conversation you had with private school
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officials to create an accurate log of contacts.
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Private school
Telephone
Telephone contact:
date/time/name
Purpose of contact
Source: Ensuring Equitable Services to Private School Children: A Title I Resource Kit, U.S.
Department of Education, September 2006.
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Appendix D: LEA Worksheet to Determine the Amount of Title I Funds
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for Equitable Services
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District_______________________________
LEA Worksheet to Determine the Amount of
Title I Funds for Equitable Services
1.
District-wide Instructional Program(s) Reservation (does not apply to preschool programs)
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In participating public school attendance areas:
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Number of private school children
Total number of children
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from low-income families
from low-income families
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_____________________
÷
___________________
=
_______ Proportion of Reservation
_____ (Proportion of Reservation) x $______________Reservation =
$___________for Equitable Services
2.
Parental Involvement Reservation under Sec. 1118 of
ESEA
In participating public school attendance areas:
Number of private school children
Total number of children
from low-income families
from low-income families
______________________
÷
___________________
=
_______ Proportion of Reservation
_____(Proportion of Reservation) x $_____________Reservation =
$_______ for Equitable Services
3.
Professional Development Reservation under Sec. 1119 of
ESEA
In participating public school attendance areas:
Number of private school children
Total number of children
from low-income families
from low-income families
______________________
÷
___________________
=
_______ Proportion of Reservation
____ (Proportion of Reservation) x $______________Reservation
=
$___________ for Equitable Services
Source: Ensuring Equitable Services to Private School Children: A Title I Resource Kit, U.S.
Department of Education, September 2006.
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ADDITIONAL RESOURCES
LEAs are strongly encouraged to use the tools provided by the United States Department of
Education in Source: Ensuring Equitable Services to Private School Children: A Title I Resource
Kit, U.S. Department of Education, September 2006.
This publication is available for download on the Florida Department of Education’s Title I Web
site, at the following address:
http://www.firn.edu/doe/title1/titleItoolkit.html
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