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Guidance: 2012-13 Title I Reservations (Allowed)

Consolidated Application, Winter Release program guidance for the 2012-13 Title I Part A Reservations (Allowed).

Reservations are not calculated on carryover funds. As such, percentages should be calculated based on the "Title I Part A entitlement after transfer" rather than on the "Total allocation" as displayed on the Title I Part A LEA Allocation page.

Proportional Amounts of Reservations for Nonprofit Private School Equitable Services

LEAs must annually calculate the correct amount of funds to provide equitable services for participating private school students, their teachers and families. If an LEA reserves funds off the top of its Title I allocation for district-wide activities, the Title I regulations require that the LEA must also provide equitable services from these set-aside funds (34 CFR, Section 200.65). Some of the examples for the district-wide set aside are: instructional activities (such as assistance to schools, funds set aside for reading coaches, summer school, etc.), professional development, and parent involvement. 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—Equitable Calculations 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. Hence, 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.

Professional Development: The consultation with private school officials is critical to providing appropriate professional development activities for teachers of Title I participants in the private schools. If an LEA reserves funds under ESEA Section 1119 off the top of its Title I allocation for carrying out professional development activities, the LEA must provide equitable services to teachers of private school participants from this set-aside. As required under 34 CFR, Section 200.65, 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. It is not sufficient to merely extend an invitation to eligible private school teachers to attend the same professional development activities planned for the LEA’s Title I teachers. The professional development activities for the teachers of Title I participants must be planned and implemented to address how those teachers can better serve Title I students, such as by providing information on research-based reading and mathematics instruction. Consultation with private school officials will determine whether the LEA provides for these activities independently or in conjunction with the LEA’s professional development activities.

If a private school chooses not to participate in the professional development activities (the private school officials feel that their teachers’ participation in Title II provides adequate levels of professional development to address the needs of Title I students), the district can not combine professional development funds with the instructional funds for services at the private schools. The professional development funds must be spent on professional development or returned to the district’s Title I funds.

Frequently Asked Questions on Equitable Services
  1. Does the equitable services requirement in 34 CFR, Section 200.65 apply to LEA set-aside for LEA and school PI activities?

    The equitable services requirement does not apply to Title I Part A funds reserved for LEA and school PI activities. Therefore, the reservation screens do not facilitate the proportional amount calculation from the amounts reserved for PI activities.
  2. How does an LEA meet the equitability requirement for professional development?

    If an LEA reserves funds under ESEA 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. As required under ESEA Section 200.65, an LEA calculates these equitable services from the reserved funds in the 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 with meaningful consultation with private school officials and teachers.

    Example
    —Allocating Funds for Equitable Services for Private School Teachers: An LEA reserves six percent ($360,000) of its Title I allocation of $6 million for professional development as required under ESEA 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 reservation ($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. Professional development funds set aside by PI LEAs (required minimum of 10 percent) are not subject to the equitability requirement.
  3. 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, ESEA Section 200.64(a)(2)(i)(A) would apply and requires the LEA to provide equitable services to eligible private school children. The LEA must base equitable services supported with the reserved funds on the proportion of private school children from low-income families residing in participating public school attendance areas.
  4. Does the equitable services requirement in ESEA Section 1120(a) of the Title I statute apply to LEA set-asides for preschool programs?

    The equitable services requirement does not apply to children attending private preschool programs because the state of California does not consider preschool to be part of elementary education.
Salary Differentials

Any salary differential costs that pertain to administrative rather than direct service staff should be recorded on the Title I Part A LEA Allocation page in “Administrative reservation."

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