Child Development Division
| Subject: William F. Goodling Even Start Program Requirements | Number: 05-04 (a) |
| Authority: Guidance for the William F. Goodling Even Start Family Literacy Programs |
Date: April 2005 Expires: Until Rescinded |
Attention: Directors and Program Coordinators of All Even Start Projects
Purpose
The purpose of this Management Bulletin is to provide information to Even Start project administrators and staff on program requirements and eligibility criteria for families participating in the Even Start local projects in the state.
Background
There has been a need in the field for a document that provides guidance on the issues most frequently addressed by project coordinators and/or LEA administration as they establish and improve new and continuing Even Start projects. This bulletin addresses these issues and cites the relevant passages from the William F. Goodling Even Start Family Literacy Program statute, Part B, Subpart 3 of Title I of the Elementary and Secondary Education Act, the document that provides guidance on ensuring comprehensive and timely implementation of the California Even Start projects, and the California William F. Goodling Even Start Family Literacy Program Request for Applications (RFA) 2004-2005 (see Attachment A).
Specifically, this bulletin addresses the criteria and requirements for eligibility, private school consultation and participation, highly qualified staff, partnerships and matching resources, and maintenance of effort. Also included is a matrix on staffing requirements for the California Even Start projects (see Attachment B).
Introduction
Even Start is an education program for the nation's low-income families that is designed to improve the academic achievement of parents and their young children, especially in the area of reading. The Even Start Family Literacy program was first enacted in 1988 as Part B of Chapter I of Title I of the Elementary and Secondary Education Act of 1965 (ESEA). Most recently, the program was reauthorized and amended by the No Child Left Behind Act of 2001 (NCLB). Funds for the Even Start program were initially appropriated in 1989. The majority of the funds go to states for state-administered subgrants. In California, these subgrants currently fund 153 projects throughout the state.
The goal of Even Start is to help break the intergenerational cycle of poverty and low literacy in the Nation. The program integrates early childhood education, adult literacy (adult basic and secondary-level education and/or instruction for English language learners), parenting education, and interactive parent and child literacy activities into a single, unified family literacy program. Even Start supports integrated family literacy services for parents and children, primarily from birth through age seven, and has three interrelated goals:
- To help parents improve their literacy or basic educational skills
- To help parents become full partners in educating their children
- To assist children in reaching their full potential as learners
I. Eligibility
Identification and Recruitment of Families Most in Need of Even Start Services (Section 1235(1))
Each program must identify and recruit families most in need of Even Start services, as indicated by a low level of income, a low level of adult literacy or English language proficiency of the eligible parent or parents, and other need-related indicators. It is important to note the distinction between families that are considered "eligible" for Even Start services and those actually served by a project. Even Start projects serve a small subset of the "eligible" population and must target families most in need of family literacy services.
A. Literacy
Adult Education Services and Literacy Level Documentation
The term adult education means services or instruction below the postsecondary level for individuals who have attained 16 years of age; are not enrolled or required to be enrolled in secondary school under state law and lack sufficient mastery of basic educational skills to enable the individuals to function effectively in society; do not have a secondary school diploma or its recognized equivalent and have not achieved an equivalent level of education; or are unable to speak, read, or write the English language. Literacy documentation could include, but is not limited to: CASA scores, English language proficiency scores, verification of attendance in Adult Education, birth certificate, school record or any verification of age if within school compulsory attendance age range, or school records verifying attendance in a secondary school.
Eligible Adult Criteria
The adults who meet the following criteria are eligible for the Even Start program: parents of students enrolled in an Immediate Intervention/Underperforming Schools Program, Program Improvement, and High Priority schools; parents who are eligible for participation in adult education and literacy activities under the Adult Education and Family Literacy Act; parents who are within the state's compulsory school attendance age range, so long as the local educational agency (LEA) provides or ensures the availability of the basic education component required under Subpart 3, Section 1236(a)(1)(a), No Child Left Behind Act of 2001; parents who are attending secondary school; a parent or guardian who meets the low-income requirements.
A person acting in place of a parent or legal guardian including, but not limited to, persons such as a grandparent, stepparent, aunt, uncle, older sibling, or other person with whom the child either lives or who has been designated by a parent, legal guardian, or court to act in place of the parent, legal guardian, or court regarding all aspects of the child's education (In Loco Parentis) is also eligible for the Even Start program.
Local projects can serve teen parents, regardless of age, so long as the teen parent is attending secondary school. If the teen parent is not attending secondary school, the teen parent is eligible if (1) he or she is within the state's compulsory school attendance age range and an LEA provides the educational component or ensures its availability to the teen; or (2) the teen is older than the compulsory school attendance age range and is eligible for services under the Adult Education and Family Literacy Act.
B. Children Zero to Seven Years
Eligible Children Criteria and Documentation
Children from birth through age seven are eligible to participate in Even Start if their parent or parents are eligible for and participating in Even Start services (Section 1236 (a)(2)). Children over the age of seven are also eligible to participate in Even Start with an eligible parent if the local project collaborates with a program under Title I, Part A of ESEA, and Title I, Part A funds contribute to the cost of providing Even Start program services to those children.
Documentation to support children's eligibility may include, but is not limited to, birth certificates, school records, physician records, or baptismal records.
C. Income
Each project must identify and recruit families most in need of Even Start services, as indicated by a low level of income, a low level of adult literacy or English language proficiency of the eligible parent or parents, and other need-related indicators. This does not necessarily mean that the most destitute in a community will be served. As it happens, some of those families are not willing or available to participate.
To determine low-income levels, information, such as the following, may be used: the child has sibling currently attending a Title I school; the family is eligible for free and reduced price lunch; the family is participating in CalWORKs; the family meets the criteria for the service area county definition of low income or low poverty; the family is eligible to receive housing and other support services; personal statements of work and income; or a combination of any of the above.
Projects will need to document the criteria used to determine income eligibility and collect documentation to verify this status. Documents that meet compliance criteria include, but are not limited to: pay stubs, tax returns, TANF/public support county printouts, Social Security wages, self declaration, acceptance form for free or reduced price lunch, verification of address in Title I School District, and school records verifying attendance in Title I School District.
The project may use the local housing indexes and/or county guidelines as criteria for low-level income within the context of their community. The information should be written and on file. All families must show proof of income that demonstrates they meet the criteria. A family is eligible for the project if the person who receives the services is income eligible and meets the other eligibility requirements. In other words, a family could participate in the project even if one of the spouses receives a salary that would make him/her ineligible.D. Other Considerations
Families generally may participate in Even Start Family Literacy program services until all family members become ineligible for participation. In the case of families who enter the program with children ages birth through seven, when the parent has achieved his or her educational goals, the family continues to be eligible until all the children in the family reach age eight.
In contrast, if all children in a family have reached the age of eight and the participating parent has not achieved his or her educational goals, the family continues to be eligible for two more years until the youngest participating child is 10 years old or until the parent is no longer eligible for adult education services under the Adult Education and Family Literacy Act, whichever occurs earlier. In both situations, if a family chooses to continue participating in Even Start under the provisions for continuing family eligibility, the family must participate in all remaining appropriate Even Start services (parenting education, interactive parent and child literacy activities, home visits) until the family exits the program (Section 1236(b)(2)).
If the Even Start program collaborates with a Title I, Part A program and the Part A program contributes to paying the cost of the Even Start program, families are eligible and may participate in the Even Start program until the parent reaches his or her educational goals, regardless of the age of the child. However, the focus of the local program must continue to remain on serving families with young children. Family ineligibility in this situation occurs when the parent attains his or her educational goals (Section 1236(b)(3) and the Title I, Part A Collaboration section of the Guidance document).
Even Start is unique in that it is designed as a family literacy program, in which the eligibility of parents and children is interdependent (Section 1236). To be eligible, at least one parent and one or more eligible children must participate together in an Even Start project. However, should a child or parent be temporarily absent due to extenuating circumstances, the other eligible family members may continue to receive Even Start services.
II. Private School Consultation and Participation
The equitable participation provisions in Title IX of NCLB (Uniform Provisions) that apply to Even Start under NCLB are found in sections 9501-9504. These provisions require recipients of federal funds to provide eligible school-age children who are enrolled in private and religiously affiliated elementary and secondary schools, and their teachers or other educational personnel, educational services and benefits under their Even Start program on an equitable basis. They apply to local Even Start programs regardless of whether the fiscal agent is a local education agency, a nonprofit or community-based organization, or other partner in the eligible entity partnership.
Consultation and Participation
Consultation between public and private school officials must occur before any decision is made that could affect the participation of the private school families (that is, as the project is being planned and designed and before the application is written and submitted to the subgrant competition) and should continue throughout the implementation and assessment of activities. Failure to engage appropriate private school officials in timely and meaningful consultation may result in the denial or revocation of funding.
Consultation generally must include discussions on such issues as how the private school families' needs will be identified; what services will be offered; how and where the services will be offered and provided; who will provide services; how the services will be assessed and how the results of assessments will be used to improve those services; the amount of funds available for services; the size and scope of services to be provided; and how and when the LEA/agency will make decisions about the delivery of services.
Even Start projects must consult with private school officials to determine how to ensure that eligible, most-in-need families with children enrolled in private schools are given the same opportunity to participate in the Even Start project as their public school counterparts. Specifically, the eligible entity must consult with private school officials to determine how to provide equitable Even Start services to eligible families in Even Start who have children enrolled in private elementary schools or parents enrolled in private secondary schools.
Eligible entities must provide the equitable services after timely and meaningful consultation with the appropriate private school officials. The services must be provided by the eligible entity or through a contractor that is independent of any private school or religious organization. Services to private nonprofit schools are not required to be the same program offered by public schools.
Services must be comparable to the services for their public school counterparts in terms of quality, scope, and opportunity for participation. In addition, total program expenditures for services and benefits for participating elementary and secondary private school students must be equal on a per pupil basis (taking into account the relative numbers of those private and public school students participating in the Even Start program and their needs) to the expenditures for participating elementary and secondary public school students.
All participating Even Start projects are therefore directed to ensure that consultation has taken place with private nonprofit and religiously affiliated schools within their respective service areas. All public elementary and high schools that are partners in an eligible entity that receives an Even Start subgrant under Title I, Part B, Subpart 3 of the Elementary and Secondary Education Act, as amended by the No Child Left Behind Act, must comply with this requirement. Each project should check with its district administration to find out how consultation and participation with private nonprofit and religiously affiliated schools is arranged. If you have not included these schools in your activities, you need to do so as soon as possible.
III. Highly Qualified Staff
William F. Goodling Even Start Family Literacy programs reauthorized as Title I, Part B, Subpart 3 of ESEA, No Child Left Behind Act of 2001 must meet the following qualification requirements for staff whose salaries are paid in whole or in part with Even Start funds (Section 1235(5)).
All staff hired after January 2002 must be fully compliant
with Title I guidelines.
Staff hired prior to January 2002, must have been fully
compliant by December 21, 2004. Staff hired in a school
district prior to January 2002 and who transfer into Even Start
or Title I programs must meet requirements by January 2006.
Staff who are not paid with Even Start funds, such as staff supported by collaborators or partners, are not subject to these requirements. However, whatever the funding source, projects are encouraged to hire the most highly qualified staff available. If the collaborators or partners are funded by NCLB, they are required to follow requirements for "highly qualified teachers" for K-12 public school programs.
A. Teachers/Instructional Staff
Instructional staff are those staff members who provide instruction in the four core Even Start components. Instructional staff hired prior to January 2002 must have met the following requirements by December 21, 2004:
- Must have obtained an associate's, bachelor's, or graduate degree in a field related to early childhood education, elementary or secondary school education, or adult education.
- Must meet qualifications established by the state for early childhood education, elementary or secondary school education, or adult education provided as part of an Even Start program or other family literacy program (Section 1235(5)(A)(i)).
B. Paraprofessionals/Instructional Aides
All paraprofessionals hired after the date of the enactment of the No Child Left Behind Act of 2001 and working in a program supported with funds under this part must have completed at least two years of study at an institution of higher education; obtained an associate's (or higher) degree; or met a rigorous standard of quality and demonstrate, through a formal state or local academic assessment, knowledge of, and the ability to assist in instructing reading, writing, and mathematics or knowledge of, and the ability to assist in instructing reading readiness, writing readiness, and mathematics readiness, as appropriate.
Clarification: A secondary school diploma (or its recognized equivalent ) is also necessary to satisfy the requirements listed above.
Existing paraprofessionals hired before the date of enactment of No Child Left Behind Act of 2001 and working in a program supported with funds under this part shall satisfy the requirements listed above no later than January 8, 2006.
The requirements described above do not apply to a paraprofessional who is proficient in English and a language other than English and who provides services primarily to enhance the participation of children in programs under this part by acting as a translator or whose duties consist solely of conducting parental involvement activities consistent with Section 1118 of the No Child Left Behind Act.
Paraprofessionals who provide support for academic instruction must have received a high school diploma or its recognized equivalent by December 21, 2004 (Section 1235(5)(A)(iii)). Paraprofessionals can reinforce and practice instructional activities with students after instructors have initially taught the activity or lesson.
Staff qualifications are different for Even Start paraprofessionals when Even Start is part of a schoolwide program as defined in Section 1114. When Even Start is part of a schoolwide program, these paraprofessionals, regardless of the source of their salary, must meet the Title I, Part A paraprofessional requirements. Projects that have staff members who receive funding from multiple sources should check all requirements that apply to other funding, e.g., migrant, First 5, etc.
C. Other Personnel
Coordinator
The individual responsible for the administration of family literacy services must have training in the operation of a family literacy program. States have discretion over what qualifies as appropriate training. However, to ensure successful Even Start projects, training should be of sufficient quality, duration, and intensity to increase an administrator's knowledge of how to manage and operate a family literacy program successfully. This individual must be able to communicate and facilitate collaborative responsibilities in a complex educational program, understand categorical education programs, and actively participate in program improvement.
Evaluator
Project evaluators must have a master's degree or an administrative credential with an emphasis on evaluation and also have formal training and experience in data collection and analysis. They should also have five years of experience in program evaluation, recent experience in family literacy programs, experience developing and implementing the evaluation design and assessment instruments, and the ability to make program recommendations.
It is also critical that the person be able to take into account the needs of second-language learners and be able to communicate with diverse populations both orally and in writing.
Project Leadership and Management
Even Start staff members must possess adequate professional qualifications and experience in at least one of four areas: early childhood, adult education, parenting education, or parent and children interactive literacy activities. The project leadership and management must be sufficient to ensure proper coordination of the program, implementation of activities, and monitoring of the attainment of goals and objectives, including the following:
- How the project administration will establish the program elements such as recruitment strategies, system for eligibility, documentation, active and viable partnerships, coordination with the K-12 public and private schools, and maintenance of effort requirements
- How the project director will manage the budget and resources on behalf of the LEA/co-applicant partnership, including preparing an annual budget, approving expenditures, record keeping of both cash and matching resource expenditures, monitoring the budget status monthly, and filing necessary reports for continued federal funding
- How the local management plan is to be implemented to meet local and state requirements, including the ways the project will be reviewed and the data analyzed for ongoing program monitoring, improvement, and the annual evaluation report
- How the project administration will establish and maintain a system of communication that employs a variety of internal and external communication strategies between staff, parents, and the community
IV. Partnerships and Matching Resources
To qualify as an "eligible entity" for an Even Start subgrant, an applicant must be a partnership between one or more LEAs and one or more nonprofit community-based organizations, public agencies other than a LEA, institutions of higher education (including two- and four-year institutions), or public or private nonprofit organizations of demonstrated quality other than an LEA (Section 1232(e)(1)).
A partnership may take a number of different forms and can designate any partner as the fiscal agent for the subgrant or form a formal legal entity that is a partnership to serve as the fiscal agent. However, in each case, the partners should clearly delineate their respective roles and functions, identify the partner(s) that will serve as the fiscal agent, and agree in writing to any required assurances and authorizations. For example, an Even Start project in a midwestern state is administered by a partnership comprised of the local school district, Department of Family Services, and Head Start. The LEA is the fiscal agent for the grant, and there is a signed, written agreement between the partners outlining the responsibilities of each of the three entities.
The partnership provisions in the Even Start law strengthen the connections between schools and communities and improve a project's ability to reach families in greatest need of services through community outreach. The connection of a project to an LEA and a school's resources also allows for greater ease in the continuity of family literacy services, especially when children make the transition between an early childhood education provider to a school.
In order to reach out to the greatest number of possible applicants, the Secretary encourages states to inform all potentially eligible partners of the availability of funds for an Even Start project and the process they should follow in applying for a subgrant.
Even Start projects are cooperative programs that build on high-quality, existing community resources to create a new range of services to serve families' educational needs (Section 1231(2)(A)). In addition to the formal partners who comprise the eligible entity applying for funding and administering the grant, an Even Start project has a number of collaborators who provide direct instructional or support services to participating families and may contribute to the local program's matching or cost share. These collaborators may include such local agencies as the community library, the community college, the welfare agency, a day care program, a professional association, a faith-based organization, or a volunteer organization. The Department encourages projects to cultivate community investment in the program by building on high-quality community resources or bolstering the quality of these community resources, if necessary by supplementing those services.
Project Funding: Federal and Local Share
An Even Start project's funding is comprised of a portion of funds attributable to the federal grant (federal share) and a portion contributed by the program (local share). The amount of the local share in the first year of the local program's grant must be at least 10 percent of the total cost of the project. In the second year of federal funding, the project must provide at least 20 percent of the total cost of the second-year budget; in the third year, at least 30 percent of the third-year total budget cost; in the fourth year, at least 40 percent of the fourth-year total budget cost; in the fifth through eighth years, at least 50 percent of each year's total budget cost; and in each subsequent year, at least 65 percent of each year's total budget cost. (See Duration of a Project-Continuing Eligibility (Section 1234(b)(1)).
To clarify with an example: In the first year of federal funding, a project is responsible for providing at least 10 percent of the total cost of the project. Therefore, to determine the maximum federal share from the total cost of the proposed project, the total project cost is multiplied by 90 percent. For example, if $225,000 is the total cost of the project, that figure is multiplied by 90 percent to determine the maximum federal share ($225,000 x .90 = $202,500). Based on a total budget of $225,000, the federal share must be no more than $202,500 in the first year. The local share is then calculated by subtracting the federal share from the total project cost ($225,000 - $202,500 = $22,500).
A local project may provide its local share in cash or through in-kind contributions, fairly evaluated. The project may obtain its local share from any source, including any federal funds other than Even Start funds. (Section1234(b)(1)(B)). For an explanation of how to place a value on a specific third-party-in-kind contributions, see EDGAR, section 74.23 (for institutions of higher education and nonprofit organizations) and section 80.24 (for LEAs and Indian tribes).
An Even Start project may only use allowable costs to satisfy the project's local share. For example, indirect costs are not allowable for Even Start local projects and, therefore, may not be used to meet a project's local share (Section 1234(b)(3)). One local project used the following in-kind contributions to the project as its local share: computers donated by a local business for adult education classes, use of a portion of the local library for parenting classes, use of a portion of the reading supervisor's time, use of a local church basement for the early childhood education component, and time donated by a senior citizens' group for child care.
In addition, a project may only count costs or values of third-party-in-kind contributions toward satisfying its local share for one federal grant or contract at a time. For example, if Head Start is a collaborating agency with an Even Start project and counts a volunteer teacher's time for all of the children (including the children participating in Even Start) toward satisfying a Head Start matching requirement, the Even Start project may not count that same teacher's time toward meeting the Even Start local share. As an alternative, the Head Start program and the Even Start project may agree to split the value of the volunteer teacher's time proportionately based on the numbers of Head Start and Even Start children served by that teacher for the purpose meeting the respective matching requirement.
V. Eligible Expenditures
Allowable Costs
An Even Start project must use federal Even Start funds to support the cost of providing family literacy services that involve parents and children, primarily from birth through age seven, in a cooperative effort to help parents become full partners in the education of their children and to assist children in reaching their full potential as learners. (Section 1234(a)). The remaining cost of the project may be provided in cash or in kind from any source, including any federal funds other than Even Start.
Projects may use federal Even Start grant funds and matching resources only for the allowable costs of those programs (EDGAR, section 80.22). For each type of organization, there is a separate set of federal principles for determining allowable costs. State-administered grants that have LEAs as the fiscal agent and Indian tribes and tribal organizations must use the cost principles in OMB Circular A-87. Grantees that have institutions of higher education (IHEs) as the fiscal agent must use the cost principles of OMB Circular A-21, and nonprofit organizations that are fiscal agents must use OMB Circular A-122. http://www.whitehouse.gov/omb/circulars/index.html (Outside Source)
The cost principles provide general rules for allowability, and in addition, list alphabetically certain specific items of cost (such as "materials cost"), indicating whether those specific cost items are allowable, unallowable or allowable only with prior approval of the awarding agency. In general, unless prohibited by the statute, regulations, or cost principles, local projects may use Even Start funds and matching resources for costs that are necessary and reasonable to meet the objectives of their projects and provide each of the 15 required program elements, including the four core family literacy instructional components.
The following are some examples of allowable costs: materials and supplies, equipment, food and meals for project participants, minor remodeling, rental costs of buildings and equipment, and transportation. More detailed information can be found in Guidance for the William F. Goodling Even Start Family Literacy Programs, Part B, Subpart 3 of Title I of the Elementary and Secondary Education Act (ESEA).
Unallowable Costs
The following are some examples of unallowable costs. Other unallowable costs are found in EDGAR and the applicable cost principles.
- Indirect Costs
Local Even Start programs may not use project funds (including Even Start and matching funds) for any indirect costs of a program (Section 1234(b)(3)). The differences between direct and indirect costs are explained in the applicable cost principles described in previous section. In general, indirect costs are those costs that are incurred for common or joint purposes among multiple cost objectives (for example, the Even Start program and the school district's program) and cannot be readily and specifically identified with a particular final cost objective without effort disproportionate to the results achieved (for example, the cost of the heating and lights for a building in which multiple programs are located).
- Capital Outlay
An Even Start project may not use federal Even Start funds or matching resources to acquire real property, or for construction or renovation. (See EDGAR, section 75.533 for direct grantees of the Department, and section 76.533 for State-administered subgrants.) Construction includes structural alterations to buildings, but does not include minor remodeling.
VI. Maintenance of Effort
Beginning with fiscal year 2002, Even Start programs are subject to a maintenance of effort requirement (section 9521). Maintenance of effort (MOE) under Section 9521 means that either an LEA's combined fiscal effort per student, or the aggregate expenditures of the LEA and the state for the fiscal year preceding a particular funding year must not be less than the combined fiscal effort or aggregate expenditures for the second preceding year.
As applied to Even Start, a project may receive funds only if the California Department of Education (CDE) determines that the project's LEA partner met the MOE requirement for the funding year; if the LEA partner fails MOE, funding for the project will be reduced in the exact proportion by which the partner failed to meet the requirement.
An LEA that failed to maintain effort can request a waiver from the United States Department of Education (USDE). USDE may waive the requirement if such a waiver would be equitable due to: (1) exceptional or uncontrollable circumstances such as a natural disaster or (2) a precipitous decline in the financial resources of the local educational agency.
The CDE determines annually, as part of the funding process, if LEAs have met the MOE requirement. LEAs that fail are notified by mail. For additional information on the maintenance-of-effort requirement, you may contact the School Fiscal Services Division, Office of Financial Accountability and Information Services, at 916-322-1770 or sacsinfor@cde.ca.gov.
Statutory Requirements
Statutory requirements for Even Start Projects are contained in the William F. Goodling Even Start Family Literacy Program, Part B, Subpart 3 of Title I of the Elementary and Secondary Education Act, reauthorized and amended by the No Child Left Behind Act of 2001 (NCLB).
A state may provide technical assistance under Section 1233(a)(2) to improve or replicate Even Start projects.
Attachments
A. Reference Listing
B. William F. Goodling Family Literacy
Even Start Projects, Staff Matrix
This Management Bulletin is mandatory only to the extent that it cites a specific statutory and/or regulatory requirements. Any portion of this Management Bulletin that is not supported by a specific statutory and/or regulatory requirements is not prescriptive pursuant to Education Code 33308.5.
