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Frequently Asked Questions

Answers frequently asked questions about federal Title I Schoolwide Program (SWP), the formal process for becoming a Schoolwide Program school site and proper implementation of funding resources.
  1. Who needs to be involved in creating a school plan and implementing it?
  2. Why is the comprehensive needs assessment so important?
  3. After the school plan is submitted to the local school board, when may a school begin to operate as a schoolwide program?
  4. If a school is eligible to become a SWP, must it become one or is becoming a SWP optional?
  5. When should the school develop its SWP budget?
  6. If only a few migrant students are at a school, does the school still need representation of migrant students in planning a SWP?
  7. May a local educational agency use one low-income measure to identify/rank participating schools and a different low-income measure to make schools eligible for SWP?
  8. May Title I funds be used to meet the needs of English learners in a SWP?
  9. May a school use the Single Plan for Student Achievement in the development of a SWP plan?
  10. What is the process for updating SWP plans?
  11. How long is my school's SWP status effective?
  12. How is fund expenditure treated in the SWP school?
  13. Must the SWP school meet the statutory or regulatory requirements of different Federal programs?
  14. What advantages do SWPs offer?
  15. What happens if a school that becomes a SWP drops below the initial eligibility threshold in a subsequent year?
  16. How are migrant funds treated in a SWP?
  17. How is Indian education addressed in the SWP?
  18. What does the issue of "Supplement Versus Supplant" mean to a school and LEA?
  19. What is the accounting reporting requirement for multi-funded employees at SWP schools?
  20. What fiscal record-keeping requirements apply to an LEA or a school with respect to Federal funds that are consolidated in a SWP?

 

  1. Who needs to be involved in creating a school plan and implementing it?

The plan should be developed by representatives of the school community (stakeholders), including parents, and other people who will carry out the plan, including teachers, principals, and administrators. If appropriate, technical assistance providers, school staff, and, at secondary schools, students may also be included.

Except as noted below, a SWP is allowed to consolidate funds from any federal education program, whose funds can be used to carry out activities in a public elementary or secondary school. This authority also extends to services, materials, and equipment purchased with those funds provided to a SWP school.

A school that operates SWP may NOT consolidate funds under Subpart 1 of Part B of Title I of the Elementary and Secondary Education Act (ESEA) (Reading First), which establishes reading programs for students in kindergarten through grade 3.

Within the general SWP consolidation authority, a SWP school may consolidate funds received under the following programs only as outlined below:

Migrant Education: Before a school operating as a SWP consolidates funds received under Part C of Title I, ESEA for the education of migratory children, the school in consultation with parents of migratory children or organizations representing those parents, or both, must first meet the unique educational needs of migratory students that result from the effects of their migratory lifestyle and those other needs that are necessary to permit those students to participate effectively in school, and must document that these needs have been met.

Indian Education: A school operating as a SWP may consolidate Indian education funds received under Subpart 1 of Part A of Title VII of the ESEA only if the parent committee established by the LEA to help develop the Indian education program under Section 7114(c)(4) of the ESEA approves the inclusion of those funds.

Individuals with Disabilities Education Act (IDEA): A school that operates as a SWP may also consolidate funds received under Part B of IDEA. However, the amount of funds consolidated may not exceed the amount received by the LEA under Part B of IDEA for that fiscal year, divided by the number of children with disabilities in the jurisdiction of the LEA, and multiplied by the number of children with disabilities participating in the SWP. A school may also consolidate funds it receives for students with disabilities under Section 8003(d) of the ESEA. A school that consolidates funds under Part B of IDEA or Section 8003(d) of the ESEA may use those funds in its SWP for any activities under its SWP plan but must comply with all of the other requirements of Part B of IDEA to the same extent as it would if it did not consolidate funds under Part B of IDEA or Section 8003(d) of the ESEA in the SWP.

  1. Why is the comprehensive needs assessment so important?

The needs assessment should identify gaps between the current status of the school and its vision of where it wants to be, relative to key indicators or focus areas. Data obtained from the needs assessment provide the foundation for the goals of the comprehensive SWP plan.The program's evaluation measures how successful the school has been in addressing identified needs, and meeting the goals of the plan.

  1. After the school plan is submitted to the local school board, when may a school begin to operate as a SWP?

A school may begin to operate the SWP effective the date that the plan is approved by the local board. After local board approval of the SWP plan, the local educational agency (LEA) representing the approved school reports the change in Schoolwide Program status within the Consolidated Application and Reporting System utilizing the data collection report named Title I, Part A Notice of Authorization of School Wide Program for the fiscal year in which implementation of SWP is begun. The status information provided by the LEA in this report feeds into other reports, and therefore, it is very important that the change is reported in the data collection report that pertains to the correct fiscal year of the initial implementation. The CARS will provide a printout receipt in the Reports tab. The LEA and the approved school(s) should retain this printout in their files in a location that is readily accessible as this is an auditable document.

  1. If a school is eligible to become a SWP, must it become one or is becoming a SWP optional?

The LEA is required to inform any school meeting the poverty criteria of the option to become a SWP. However, the school makes the decision about whether to implement a SWP based on the criteria of enhancing student academic success.

  1. When should the school develop its SWP budget?

The school develops its SWP budget when it prepares the school plan. Schools that choose to become a SWP instead of a targeted assistance status (TAS) school have fiscal advantage. SWP schools are allowed under federal law to consolidate funds from Federal, state, and local funding sources to upgrade the entire educational program. This consolidation of funding is not allowed under the default, TAS status.

  1. If only a few migrant students are at a school, does the school still need representation of migrant students in planning a SWP?

Yes. Before a school operating as a SWP consolidates funds received under Part C of Title I, ESEA for the education of migratory children, the school in consultation with parents of migratory children or organizations representing those parents, or both, must first meet the unique educational needs of migratory students that are necessary to permit those students to participate effectively in school. The school must document these needs have been met.

  1. May an LEA use one low-income measure to identify/rank participating schools and a different low-income measure to make schools eligible for SWP?

Yes. The LEA must use one consistent low-income measure to rank participant schools in the Title I program. However, once a school is slated to participate, a different low-income measure may be used to qualify the school for SWP status (e.g., If school X is ranked high enough to receive Title I funds based on the LEA's low-income measure but does not meet the 40 percent requirement for SWP, another measure may be used for the sole purpose of changing that school's status to SWP). This change in status will not alter the low-income count for funding purposes.

  1. May Title I funds be used to meet the needs of English learners in a SWP?

A SWP is designed to upgrade the entire instructional program for all children, including English learners.

  1. May a school use the Single Plan for Student Achievement in the development of a SWP plan?

The single plan for student achievement (DOC; 1MB; 01-Sep-2010) template was designed to meet state and Federal content requirements for school plans funded through the Consolidation Application. When using this template for the SWP, schools should take care to ensure that the ten Federally required components for Title I SWP schools are included in their completed plan. The components of a Title I Schoolwide Program Plan are available on the CDE Web page Schoolwide Programs.

  1. What is the process for updating SWP plans?

The SWP plan must be evaluated annually and revised based on results of the annual evaluation.

  1. How long is my school's SWP status effective?

Once a Title I school becomes a SWP, it retains its status as SWP even if the eligible population drops below the initial 40 percent poverty rate required to qualify for SWP status.

If, over a period of time, a school operating a SWP has not been effective in increasing the achievement of students, the LEA may require the school to discontinue the schoolwide program and operate a targeted assistance program.

  1. How is fund expenditure treated in the SWP school?

A school that consolidates funds from different federal programs in a SWP is not required to maintain separate accounting records of the specific activities supported by those particular funds. The school is required only to maintain records that show that the SWP as a whole addresses the intent and purposes of each of the federal programs whose funds were consolidated to support the SWP. The school must ensure that the needs of the program participants are addressed. The school must meet the requirements of all consolidated programs in regard to health, safety, civil rights, student and parental participation, services to students of private schools, comparability of services, and maintenance of effort and use of federal funds to supplement, not supplant, non-federal funds.

  1. Must the SWP school meet the statutory or regulatory requirements of different federal Programs?

The school is not required to meet specific statutory or regulatory requirements of each separate federal program as long as the intent and purposes of all funded programs are fulfilled, and certain requirements regarding civil rights, health and safety, are met.

  1. What advantages do SWPs offer?

The SWP provisions provide many advantages to schools developing SWPs. By allowing schools to integrate their programs, strategies, and resources, the SWP authority can become the catalyst for comprehensive reform of the entire instructional program. Please review the following example:

A SWP funded under Title I, Part A, also receiving professional development funds under Title II, educational funds under Title III, and vocational education funds under the Perkins Act. This SWP school would not have to document it spent professional development funds on professional development activities or Perkins money on vocational education programs. Nor does the school have to demonstrate it is complying with all the requirements of each program or show its SWP plan contains sufficient activities to reasonably address the needs identified through the comprehensive needs assessment. It could combine those funds with other funds to support overall SWP initiatives for all students. Ultimately, evaluation of the SWP's effectiveness will show whether the intended beneficiaries' needs are being met by the many resources of the various programs.

  1. What happens if a school that becomes a SWP drops below the initial eligibility threshold in a subsequent year?

To promote effective long-term planning, a school maintains its SWP eligibility even if it drops below the initial 40 percent poverty threshold required for eligibility into the program. If, however, the school becomes ineligible for Title I funds based on percentage of poverty, the LEA may qualify the school under the "grandfathering" provision for only one additional year.

  1. How are migrant funds treated in SWP?

Before a school operating as a schoolwide program consolidates funds received under Part C of Title I, ESEA for the education of migratory children, the school, in consultation with parents of migratory children or organizations representing those parents, or both, must first meet the unique educational needs of migratory students that result from the effects of their migratory lifestyle and those other needs that are necessary to permit those students to participate effectively in school, and must document that these needs have been met.

  1. How is Indian education addressed in the SWP?

A school operating as a schoolwide program may consolidate Indian education funds received under Subpart 1 of Part A of Title VII of the ESEA only if the parent committee established by the LEA to help develop the Indian education under section 7114(c)(4) of the ESEA approves the inclusion of those funds.

  1. What does the issue of "Supplement Versus Supplant" mean to a school and LEA?

Both the TAS and SWP requirements prohibit the use of federal funds to supplant state or local funds. This provision is conceptually confusing because it is sometimes difficult to determine whether a particular use of funds is, in fact, a case of supplanting.

An LEA may use Title I funds only to supplement and, to the extent practical, increase the level of funds that would, in the absence of Title I funds, be made available from non-Federal sources for the education of students participating in Title I programs. In no case may Title I funds be used to supplant--i.e., take the place of--funds from non-Federal sources. To meet this requirement, an LEA is not required to provide Title I services using a particular instructional method or in a particular instructional setting.

In operating a TAS, Title I, Part A of the ESEA gives LEA and school personnel flexibility in selecting the instructional strategies they believe will best meet the needs of students who are at risk of not meeting challenging State academic achievement standards. The expectation is LEAs and schools will use sound instructional strategies of high quality to ensure the students served will reach proficiency on challenging State academic standards and assessments. At the same time, the type of services supported by Title I must supplement or be in addition to the educational services that an LEA would, in the absence of Title I, provide to its students using state or local funds. Programs which do not remove children from the regular classroom during regular hours for Title I services and, instead, provide extended learning time (e.g. extended school year, before- and after-school, and summer programs etc.) are supplemental.

Unlike a TAS, a SWP school is not required to select and provide supplemental services to specific children identified as in need of services. A school operating a SWP does not have to: (1) show that federal funds used with the school are paying for additional services that would not otherwise be provided; (2) demonstrate that federal funds are used only for specific target populations; or (3) separately track federal program funds once they reach the school.

A SWP school, however, must use Title I funds only to supplement the amount of funds that would, in the absence of the Title I funds, be made available from non-federal sources for that school, including funds needed to provided services that are required by law for students with disabilities and English Learners.

Presumption of Supplanting

It is presumed supplanting has occurred if:

  1. What is the time accounting reporting requirement for employees at SWP schools?

Generally, Attachment B.8.h(3) of Office of Management and Budget (OMB) Circular A-87 External link opens in new window or tab. provides that charges for the wages or salary of an employee who works solely on a single federal program or cost objective must be supported by periodic certifications that the employee worked solely on that program or cost objective. These certifications must be prepared at least semi-annually and must be signed by the employee or supervisory official having first-hand knowledge of the work performed by the employee. If an employee works on multiple activities or cost objectives, the employee is required to prepare monthly personnel activity reports or equivalent documentation to support a distribution of his or her salary or wages among the Federal programs or cost objectives.

Application of the OMB Circular A-87 requirements to employees in a school operating SWP varies under different circumstances. For example:

  1. If a school operating a SWP consolidates federal, state, and local funds under section 1114(a)(3)(C) in a single account, an employee who is paid with funds from the single account is not required to file semi-annual certification. Because federal funds are consolidated with state and local funds in a single account, there is no distinction between staff paid with federal funds and staff paid with state or local funds from the single account. In effect, payment from the single account certifies that the employee works only activities of a single program or cost objective—i.e., the SWP.

  2. If a school operating a SWP does not consolidate federal funds it receives in a single account, an employee who works, in whole or in part, on a federal program or cost objective must meet OMB Circular A-87 requirements as follows:

    1. An employee who works solely on a single cost objective (i.e., a single federal program whose funds have not been consolidated in a single account) must furnish a semi-annual certification that he/she has been engaged solely in activities supported by the applicable source in accordance with OMB Circular A-87.
    2. An employee who works on multiple activities or cost objectives (i.e., in part on a federal program whose funds have not been consolidated in a single account and in part on federal programs supported with funds consolidated in a single account or on activities funded from other revenue source) must maintain monthlytime and effort distribution records in accordance with OMB Circular A-87. The employee must document the portion of time and effort dedicated to:

      1. The federal program and
      2. Each program or other cost objective supported by either consolidated federal administrative funds or other revenue sources.
  1. What fiscal record-keeping requirements apply to an LEA or a school with respect to federal funds that are consolidated in a SWP?

An LEA must be able to show the amount of funds from each Federal education program for each grant year that was consolidated in the single SWP account the LEA allocated to a SWP school. The LEA may use any reasonable method to demonstrate how federal funds that were consolidated in a SWP have been expended. For example, the LEA could allocate expenditures of federal funds consolidated in a SWP school in proportion to the amount of funds allocated to the school under each Federal program.

A school operating a SWP that consolidates in a single account and uses, in a SWP, funds from other federal education programs administered by the Secretary (except Reading First) is not required to maintain separate fiscal accounting records, by program, that identify the specific activities supported by those program funds. The school must, however, maintain records that demonstrate that the SWP, considered as a whole, addresses the intent and purposes of each of the federal education programs whose funds were consolidated to support it.

 

Questions: Title I Monitoring and Support Office | TIMSO@cde.ca.gov | 916-319-0854 
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