The Mechanics and Benefits of Consolidating Funds Under a Schoolwide - - PowerPoint PPT Presentation

The Mechanics and Benefits of Consolidating Funds Under a Schoolwide Program

Leigh Manasevit, Esq. and Mike Bender, Esq. Brustein & Manasevit, PLLC www.bruman.com May 13, 2015

Agenda

• LEA‐Level Consolidated Admin
• Basics of a Schoolwide Program

– Requirements to Operate Schoolwide Program – Schoolwide Plans

• Consolidation of Funds

– Types of Consolidation – Accounting Methods

• Benefits of Consolidation

– Allowability – Time and Effort

• General Fiscal Requirements

– Supplement, Not Supplant – Maintenance of Effort

Brustein & Manasevit, PLLC 2

Brustein & Manasevit, PLLC 3

Consolidated Administration

• Similar Concept BUT NOT Part of Consolidated Schoolwide

Program

• What is Consolidated Administration?

– An LEA may consolidate administrative funds under the ESEA, but only with approval from SEA. – Up to statutory cap, SEA‐established limitation, or “necessary and reasonable” standard – No additional admin

• Similar flexibilities to schoolwide program

– Not required to keep separate records, by individual program, to account for administrative costs for programs in consolidation. – Do not need to track time and effort spent on individual covered programs

Consolidated Administration

• Use the funds for the administration of participating programs
• Additional use of funds in consolidated administration:

– Any acceptable use for administration under – Coordination of the consolidated programs with other federal and non‐ federal programs; – Establishment and operation of peer‐review mechanisms under ESEA; – Administration of Title IX (Consolidated planning, administration, waivers); – Dissemination of information regarding model programs and practices; – Technical assistance under any ESEA program; – District‐level activities designed to implement Title IX; – Training personnel engaged in audit and other monitoring activities; and – Implementation of CAROI.

Brustein & Manasevit, PLLC 4

BASICS OF A SCHOOLWIDE PROGRAM

Brustein & Manasevit, PLLC 5

Laws, regulations, & guidance

• Laws and Regulations

– ESEA § 1114, 34 C.F.R. 200.25‐200.29

• Describes the legal foundation of the schoolwide program

– 67 Fed. Reg. 40360‐64 (July 2, 2004)

• Lists programs that can be consolidated
• Guidance

– Designing Schoolwide Programs, Non‐Regulatory Guidance, ED (March 2006) – Title I Fiscal Issues, Non‐Regulatory Guidance, ED (February 2008)

Brustein & Manasevit, PLLC 6

Targeted Assistance Programs v. Schoolwide Programs

• ESEA authorizes two program

designs for Title I Schools –Targeted Assistance Programs –Schoolwide Programs

Brustein & Manasevit, PLLC 7

Targeted Assistance Programs v. Schoolwide Programs (cont.)

• Targeted Assistance Programs

– School Eligibility

• Any school that receives a Title I allocation is eligible
• May serve all grades or only some grades; all subjects or only

certain subjects.

– Student Eligibility

• Provide supplemental educational services only to those

“failing, or most at risk of failing, to meet the state’s challenging student academic achievement standards.”

• Must use multiple educationally related objective criteria to

select students.

Brustein & Manasevit, PLLC 8

Targeted Assistance Programs v. Schoolwide Programs (cont.)

• Schoolwide Program

– School Eligibility

• Must meet required poverty threshold of 40%

– Waiver available

– Student Eligibility

• Comprehensive reform strategy to upgrade entire educational

program of a Title I school

• All students eligible for services.

– Consolidation of funds

Brustein & Manasevit, PLLC 9

So how do you become a schoolwide school?

Brustein & Manasevit, PLLC 10

Step 1 – Receive a Title I Allocation

• First, the school must receive a Title I

allocation

– Must meet the required poverty threshold – High enough on the district’s ranked list of eligible schools.

Brustein & Manasevit, PLLC 11

Step 2 – Meet the required poverty threshold

• In addition to receiving a Title I allocation,

school must also meet required poverty threshold of at least 40%

– School must serve an eligible school attendance area where at least 40% of the children are from low‐ income families – Alternative method is to count children enrolled in school

• Exceptions!

Brustein & Manasevit, PLLC 12

Exceptions to Poverty Threshold

• U.S. Secretary of Education can waive

40% threshold

–ED‐Flex Waiver –SIG schools –ESEA Flexibility

Brustein & Manasevit, PLLC 13

Step 3 – Planning – Planning ‐ Planning

• Any eligible school that desires to operate a

schoolwide program must then undertake a one year planning process, unless the LEA determines that less time is needed.

– Comprehensive Needs Assessment – Schoolwide Plan

Brustein & Manasevit, PLLC 14

Year‐Long Planning Process

• Comprehensive Needs Assessment

– Based on the academic achievement information of all school’s students – Must determine the needs of the school in relation to each of the required key schoolwide program components – Conducted with input from broad array of sources – Must document how the assessment was carried

• ut, the results, and the conclusions.

Brustein & Manasevit, PLLC 15

Year‐Long Planning Process

• Schoolwide Plan

– Importance of a compliant plan cannot be

• veremphasized.

– Use the needs assessment and develop in consultation with LEA, school support team, parents, teachers, principals, and administrators. – Must be available to LEA, parents and public – TEA Characteristic (Campus Improvement Plan)

Brustein & Manasevit, PLLC 16

Year‐Long Planning Process

• Schoolwide Plan

– Must include:

• How will school implement mandatory schoolwide

program components;

• How will the school use resources; and
• List of federal, state, and local programs that will be
• consolidated. (Critical!)

– Statute does not say how often plan must be revised. – But must review annually and revise as necessary.

Brustein & Manasevit, PLLC 17

The importance of the schoolwide plan

• Provides information to auditors and monitors about which

programs are included if there is a consolidation.

• Auditors will hold the school accountable in accordance with

whether:

– The plan’s activities meet the intent and purposes of the consolidated federal programs; – The school is implementing the activities detailed in the plan

• LEA may attribute expenditures to particular fund sources without

regard to whether they actually support particular fund source as long as the expenditures support the schoolwide plan.

– Use of funds also affected by level of consolidation

Brustein & Manasevit, PLLC 18

Annual Evaluation

• Must annually evaluate the implementation of, and the

results achieved by, the program.

• TEA’s Guidance asks LEAs to consider two basic questions

– Is your campus implementing the schoolwide program as it was intended? – Did you campus improve student achievement in meeting the state’s academic standards to the desired level, particularly for those students who had been furthest from achieving the standards?

Brustein & Manasevit, PLLC 19

Annual Evaluation

• Use data from state’s annual assessments and other

indicators of academic achievement.

– Empirical data (test scores); and – Qualitative data (personal interviews, observations).

• Monitoring findings for not using annual evaluation

to update plan.

Brustein & Manasevit, PLLC 20

Required Components of Schoolwide Programs

• Comprehensive needs assessment
• Schoolwide reform strategies
• Instruction by highly qualified teachers
• High‐quality and ongoing professional development
• Strategies to attract HQTs to high‐need schools
• Strategies to increase parental involvement
• Plans for assisting preschool students in the successful transition
• Measures to include teachers in decisions regarding the use of academic

assessments

• Activities to ensure that students who experience difficultly attaining

proficiency receive effective and timely additional assistance

• Coordination and integration of federal, state, and local services and

programs

Brustein & Manasevit, PLLC 21

Types of schoolwide programs

• Only Title I funds support the schoolwide plan; no funds are

consolidated

– Least amount of flexibility – EDGAR applies

• Consolidates only federal funds

– Moderate amount of flexibility – EDGAR applies

• Consolidates state, local and federal funds

– Most amount of flexibility – Loss of federal identity but state/local rules still apply

Brustein & Manasevit, PLLC 22

Mechanics of Funding Consolidation

Brustein & Manasevit, PLLC 23

How should the process of consolidation begin?

• Who makes the decision to consolidate?
• Starting points?
• School responsibilities?
• District responsibilities?
• Training and policies and procedures

Brustein & Manasevit, PLLC 24

What does it mean to consolidate funds in a schoolwide program?

• Lose their individual identity and treated like a single “pool”
• f funds.
• What does “pool” mean?

– Not required to combine funds in a single account or “pool” with its

• wn accounting code

– Used figuratively to convey the idea that a schoolwide program has the use of all consolidated funds to support schoolwide program

• TEA accounting codes

– LEAs are allowed to use fund code 282 to identify schoolwide program expenditures

Brustein & Manasevit, PLLC 25

What programs can be consolidated?

• U.S. Department of Education Programs

– Formula Grants: Can consolidate funds from nearly every noncompetitive, formula grant.

• Title I, Part A; Migrant Education Program (Title I, Part C); Preparing,

Training and Recruiting HQTs and Principals (Title II, Part A); English Language Acquisition (Title III, Part A); Safe and Drug‐Free Schools (Title IV, Part A); Perkins; and the IDEA

– Discretionary Grants: Can consolidate funds it receives from discretionary grants

• 21st CCLC & Adult Education
• Must still carry out activities described in the application under which the

funds were awarded

– Must be named in schoolwide plan!

Brustein & Manasevit, PLLC 26

What programs can be consolidated?

• Other federal awarding agencies

– Cannot consolidate. – Authority to consolidate extends only to funds administered by ED.

• National School Lunch & Head Start
• State and local programs

– Can consolidate state and local funds except for special allotments – CAUTION – STATE RULES MAY RESTRICT

Brustein & Manasevit, PLLC 27

Special Restrictions

• Migrant Education Program

– School must consult with parents of migratory children or

• rganizations representing those parents

– Meet the identified needs of migratory children to participate effectively in school. – Must document that services to address those needs has been provided.

• Indian Education Program

– Can only use these funds to support schoolwide program if parent committee established under program approves

Brustein & Manasevit, PLLC 28

Special Restrictions

• IDEA

– Programmatic Responsibilities

• IDEA funds can be consolidated but all programmatic protections must

apply, including the provision of FAPE.

• In other words, IDEA services must be provided, but not necessary to

track IDEA dollar to IDEA service.

– Restrictions on Consolidation

• Amount of funds cannot exceed the number of students with disabilities

multiplied by per‐disabled‐child amount of Part B funds received by LEA

• What about the non‐consolidated funds?

– Any non‐consolidated funds can be spent to ensure that programmatic requirements are met and all children with disabilities are served. – But must track those separately.

Brustein & Manasevit, PLLC 29

Accounting for Funds in a Schoolwide Consolidation

• Generally, the LEA accounts for all expenditures under

the schoolwide plan as expenditures from the consolidated pool.

– TEA Accounting Code 282

• LEA may attribute expenditures to particular fund sources

without regard to whether they actually support the particular fund source.

– As long as expenditures support the schoolwide plan. – Depends on level of consolidation.

• But LEAs must still demonstrate that consolidated funds have

been expended.

• May use any reasonable method, but there are at least three
• ptions approved by ED.

30

Brustein & Manasevit, PLLC

Accounting for Funds in a Schoolwide Consolidation

Option 1: Across all SW schools in LEA

• Consolidated schoolwide pool with its own

accounting code

• The expenditures attributed to that code are

charged on a proportional basis

– If Title I contributed 16%, then 16% of SWP expenses charged to Title I

31

Brustein & Manasevit, PLLC

Accounting Method #1

32

Brustein & Manasevit, PLLC

Programs Contributing Funds to the Consolidated Schoolwide Pool

School Title I ‐ A Title II‐A 21st CCLC IDEA‐ B State and Local Funds Total for Each Building Lincoln $200,000 $50,000 $20,000 $100,000 $1,000,000 $1,370,000 Washington 300,000 25,000 35,000 75,000 1,250,000 1,685,000 Jefferson 325,000 70,000 22,500 90,000 1,400,000 1,907,500 Total Funds LEA Distributes to Individual Schools 825,000 145,000 77,500 265,000 3,650,000 4,962,500 Percent of Total 16.6% 2.9% 1.6% 5.3% 73.6% 100%

Accounting Method #1 ‐ Example

• For example:

– Lincoln spends $2,000 to send teachers to a PD conference. – LEA charges each grant’s share of the expenditure using proportionality.

• $332 to the Title I, Part A program ($2,000 x 16.6%);
• $58 to the Title II, Part A program ($2,000 x 2.9%);
• $32 to the 21st CCLC program ($2,000 x 1.6%);
• $106 to the IDEA, Part B program ($2,000 x 5.3%); and
• $1,472 to the state and local funds ($2,000 x 73.6%).

33

Brustein & Manasevit, PLLC

Accounting for Funds in a Schoolwide Consolidation

EXAMPLE 2: Single school model

• No single accounting code for SWP
• For accounting purposes, LEA attributes expenditures back to

specific program REGARDLESS of what services those funds support

• Two options for distributing expenditures:

– 1) proportion of revenues or 2) sequence charging

Brustein & Manasevit, PLLC 34

Accounting Method #2 – Proportion by Single‐School

Brustein & Manasevit, PLLC 35 Adams Middle School Source of Funds Revenues Percent of Total Expenditures Total $1,000,000 100.0% $950,000 State and Local Funds (included in schoolwide program) 700,000 70.0% 665,000 Federal Programs (included in schoolwide program) Title I, Part A 200,000 20.0% 190,000 Title II, Part A ‐‐ Improving Teacher Quality 50,000 5.0% 47,500 IDEA Part B (Special Education) * 50,000 5.0% 47,500

Example ‐ Adams Middle School spends $1,000 on 5 replacement computers for a computer lab. LEA charges each grant’s share of the expenditure using proportionality.

• $200 to the Title I, Part A program ($1,000 x 20.0%);
• $50 to the Title II, Part A program ($1,000 x 5.0%);
• $50 to the IDEA, Part B program ($1,000 x 5.0%); and
• $700 to state and local funds ($1,000 x 70.0%).

Accounting Method ‐ #3 Sequence Charging by Single School

• The third approved option allows an LEA to charge 100% of a

school’s schoolwide expenditures to state and local sources first, then Title I, Part A, then other federal programs until each is expended fully or until the maximum carryover amount is all that remains.

Brustein & Manasevit, PLLC 36

Accounting Method #3 – Sequence Charging by Single‐School

Brustein & Manasevit, PLLC 37 Adams Middle School Source of Funds Revenues Total Expenditures ($950,000) Charged to Federal, State, and Local Programs Amount Remaining Total Included in Schoolwide Consolidated Pool $1,000,000 State and Local Sources 700,000 $700,000 Title I, Part A 200,000 200,000 Title II, Part A ‐‐ Improving Teacher Quality 50,000 50,000 IDEA Part B (Special Education) * 50,000 $50,000

Reporting with SW Consolidation

Proportional Basis (or “any other reasonable method”)

• Use for identifying:

– Carryover – Amount unused non‐federal funding – MOE – Comparability – Reporting expenditures back to State or USDE – State Per Pupil Expenditure (SPPE)

38

Brustein & Manasevit, PLLC

Benefits of Consolidation

Brustein & Manasevit, PLLC 39

Formula Grants

All Types of Consolidation

• Not required to meet school‐level statutory or regulatory

requirements

• Need to address intents and purposes of combined

programs AND ensure that the needs of the intended beneficiaries of these programs are addressed

• Example: Title II, Part A is consolidated

– One purpose of Title II, Part A is to increase the number of HQTs, principals and assistant principals – Can spend consolidated funds on recruitment initiatives to increase the number of HQTs if plan allows for it.

40

Brustein & Manasevit, PLLC

Formula Grants (cont.)

All Types of Consolidation

• Must still meet accountability provisions of ESEA § 1116,

including:

– Annual review by district; – Potential identification for school improvement and appropriate corrective action; and – Accountability provisions required by ESEA waiver.

• Must also meet program‐linked requirements relating to

health, safety, civil rights, student and parental participation and involvement, services to private school children, and various programmatic fiscal requirements

– But consolidation may change some of those fiscal requirements!

41

Brustein & Manasevit, PLLC

Discretionary Programs

All Types of Consolidation

• Less flexibility than formula grants.
• Not enough to simply meet the intents and purposes of

the discretionary grant.

• Must still carry out all activities described in the

application

• BUT may use any of the combined funding sources to do

so.

42

Brustein & Manasevit, PLLC

Discretionary Programs ‐ Example

• Example: A consolidated program wins a TIF grant.

– Can combine TIF funding into its schoolwide program and plan – If a school states in its application that it will use TIF funds to provide performance‐based compensation, it has to do that. – However, can use any consolidated funds to do so.

• Not required to track TIF funds to specific TIF expenditures.

43

Brustein & Manasevit, PLLC

Flexibility in Use of Funds

• Full Consolidation

– Federal funds lose their identity – Not required to be spent in accordance with specific program requirements or cross‐cutting federal requirements (EDGAR)

• Federal Consolidation Only

– Funds lose program‐specific identity but not federal identity. – Consolidated federal funds must be used to address the specific “educational needs” of the school identified in needs assessment and comprehensive plan – EDGAR still applies

44

Brustein & Manasevit, PLLC

Use of Funds Example

• School consolidates 21st CCLC funds

– Runs an after‐school program which meets the intents and purpose of the 21st CCLC program. – To promote program, school uses consolidated funds to order jackets with the school’s name to provide as promotional item. – EDGAR’s cost principles state that promotional items are unallowable – Allowable or Unallowable?

• Full Consolidation: Allowable – 21st CCLC funds have lost their federal

identity so cost principles do not apply.

• Only Federal Consolidation: Unallowable – 21st CCLC funds have lost their

program identity but not their federal identity.

Brustein & Manasevit, PLLC 45

Use of Funds – Basic Operational Expenses

• Basic operational expenses includes maintenance and repairs,

landscaping, and custodial services.

• Again, depends on level of consolidation

– Full Consolidation – Allowable, because it is impossible to attribute specific activities to consolidated federal funds – Federal Only – Unallowable, because consolidated funds must be used to address educational needs identified in needs assessment and articulated in plan.

• Be careful of supplement, not supplant.

– School must receive all the state and local funds it would otherwise need to operate in the absence of Federal funds

Brustein & Manasevit, PLLC 46

Record‐Keeping Flexibility

• Full Consolidation

– Flexibility: Not required to maintain separate fiscal accounting records by program that identify the specific activities supported by the program funds. – But: Must maintain records that demonstrate the schoolwide program, as a whole, addresses the intent and purposes of each consolidated federal education program

Brustein & Manasevit, PLLC 47

Record‐Keeping Flexibility

• Full Consolidation Example

– An LEA allocates $25,000 in Title II, Part A funds to a school operating a schoolwide program with full consolidation.

• School spends $5,000 on bonuses for HQTs.
• Normally, documentation must be kept to show that this $5,000 came

from Title II, Part A program

• Only need to document (1) $5,000 in bonuses were paid to HQTs; and (2)

the cost was included in the plan.

Brustein & Manasevit, PLLC 48

Record‐Keeping Flexibility

• Federal only

– Flexibility: Records do not need to identify that funds came from a specific program – But: Must show

• That the funds supported activities that addressed specific educational

needs of the school as articulated in plan.

• That the expenditures met all federal cost principles

Brustein & Manasevit, PLLC 49

Record‐Keeping Flexibility

• Regardless of level of consolidation:

– Must show the amount of funds from each federal education program for each grant that the LEA allocated to a schoolwide program

• Allows LEAs to apportion and return to ED any unspent funds

Brustein & Manasevit, PLLC 50

Time and Effort

• Full Consolidation:

– FLEXIBILITY: No Time and Effort!!!!!

Brustein & Manasevit, PLLC 51

Time and Effort

• Federal only

– Time and Effort still required – If employee is solely working on schoolwide program, then can complete semi‐annual certification – If the employee is also working on a state program or a unconsolidated federal program, then PAR.

Brustein & Manasevit, PLLC 52

Procurement Flexibility

• Full consolidation:

– Again, because federal funds lose their federal identity in a consolidated pool, federal procurement requirements do not apply if using consolidated funds. – Must follow state and local rules. – Example:

• EDGAR prohibits specifying a brand name on a request for quotations

without including “or equal.”

• Look to state or local rules.
• If no prohibition, school can request a brand name for procurement.
• Federal only:

– EDGAR rules still apply because no loss of federal identity.

Brustein & Manasevit, PLLC 53

Inventory Management Flexibility

• Full Consolidation:

– School is generally expected to follow state and local rules rather than federal rules for property purchased with consolidated funds. – Example: A school purchases $6,000 piece of equipment with consolidated funds, it is not required to keep property records required by EDGAR. – Must still keep records identifying property as schoolwide property and documentation that the equipment was purchased with consolidated funds.

• Allows LEA and school to justify lack of more restrictive requirements.
• Federal only: Inventory management rules would still apply.

Brustein & Manasevit, PLLC 54

General Fiscal Requirements

Brustein & Manasevit, PLLC 55

Fiscal requirements and issues

• Supplement, not supplant
• Comparability
• Maintenance of Effort
• Set‐Asides
• Carryover
• Statutory Caps

Brustein & Manasevit, PLLC 56

Supplement‐not‐supplant, generally

• Fundamental Title I fiscal principle.
• Prohibits the use of federal funds to perform a service that

would normally be paid for with state or local money.

• For example, principal’s salary or buying basic textbooks.
• Still applicable in schoolwide programs, but tweaked

Brustein & Manasevit, PLLC 57

SNS – Schoolwide programs

• Do not focus on particular services.

– Not required to demonstrate that any particular service is supplementary to the services. – Auditors will not look to whether Title I funding or consolidated funds were used to buy an additional service or benefit.

Brustein & Manasevit, PLLC 58

SNS – Schoolwide programs

• Focus instead on allocation.

– Federal funds must be used to supplement the total amount of funds that would, in the absence of federal funds, be made available from non‐federal funds. – LEA must demonstrate, through its regular procedures for distributing funds, that it distributes state and local funds fairly and equitably to all its schools

• Regardless of whether those schools are receiving federal funds.

– School must receive all the state and local funds it would otherwise need to operate in the absence of Federal funds

Brustein & Manasevit, PLLC 59

Comparability

• Requires LEAs be able to document that services provided

with state and local funds in Title I schools are comparable to those provided in non‐Title I schools.

• Remember: No requirement to track funds separately in a

fully consolidated schoolwide program

• So how do you demonstrate compliance?

Brustein & Manasevit, PLLC 60

Comparability – Demonstrating Compliance

• Determine the percentage that federal funds constitute of the

total funds available in a schoolwide program school.

The LEA would assume that the same percentage of instructional staff was paid with federal funds and delete those staff from its comparability determination.

Brustein & Manasevit, PLLC 61 Schools Student Enrollment FTE Instructional Staff % of Federal Funds in Consolidation New FTE Student/FTE Ratio

Title I Roosevelt High 808 100 40% 60 13.4 Non‐Title I Lincoln High 647 49 0% 49 13.2

Maintenance of Effort

• Requires LEAs to demonstrate that the level of state and local

funding remains relatively constant from year to year.

• To demonstrate compliance, an LEA could allocate

expenditures of federal funds in a schoolwide program in proportion to the amount of federal funds provided to the schoolwide program

• Example – A school runs a consolidated schoolwide program

where federal programs contribute 25% of the funds in a schoolwide program.

– LEA would consider 25% of the funds expended in the schoolwide program to be federal funds that must be excluded from MOE calculation.

Brustein & Manasevit, PLLC 62

Calculating Carryover Caps

• Consolidation of funds does not change ability of the LEA to

carryover unspent funds, up to any limitation.

• Other consolidated federal programs are not included in base

when calculating carryover cap.

• Any cap is calculated only on the allocation an LEA receives for

that program in a given year.

– For example, an LEA allocates $500,000 in Title I, Part A funds to a school that operates a schoolwide program. – These Title I, Part A funds are consolidated with $50,000 in Title II, Part A funds. – The $50,000 in Title II, Part A funds are not used in calculating the 15% carryover on Title I, Part A funds.

Brustein & Manasevit, PLLC 63

Calculating Carryover Caps

• All funds from a federal program with a carryover cap,

regardless of whether used in schoolwide or targeted assistance schools, would be included in cap.

• Example, an LEA receives $1,000,000 in Title I, Part A funds.

– Allocates $500,000 to a targeted assistance school – And $500,000 to a consolidated schoolwide program. – The entire $1,000,000 is used in calculating the cap.

Brustein & Manasevit, PLLC 64

Calculating Carryover Amounts

• The amount of funds available for carryover is calculated

based on the accounting method used by the LEA.

– First two approved options rely on an allocation method to attribute a portion of each school‐level expenditure back to each contributing program.

• Makes it relatively easy to determine the amount of unspent funds at the

end of the 15 months.

– Under the third option, LEA uses a method that charges one funding source until its funds are fully expended, or until only the max carryover amount is left, then moves onto the next.

• For Title I, Part A, a LEA could simply stop attributing expenditures to Title

I, Part A when only the max carryover amount remains.

Brustein & Manasevit, PLLC 65

School‐Level Set Asides

• A consolidated schoolwide program cannot, theoretically,

distinguish Title I dollars from other combined funding sources.

• How does the LEA know if a schoolwide program identified for

school improvement is using 10% of its Title I funds for professional development? Or parental involvement?

Brustein & Manasevit, PLLC 66

School‐Level Set Asides

• If school is identified for improvement, the school must simply

show that it spent 10% of Title I allocation on professional development.

• Parental involvement – Same concept.
• Activities do not need to be provided with Title I funds.
• However, the parental involvement activities conducted must

meet all the programmatic requirements specified in law, not simply the “intents and purposes” of parental involvement activities.

Brustein & Manasevit, PLLC 67

QUESTIONS?

Brustein & Manasevit, PLLC 68

Brustein & Manasevit, PLLC 69

This presentation is intended solely to provide general information and does not constitute legal advice or a legal service. This presentation does not create a client‐ lawyer relationship with Brustein & Manasevit, PLLC and, therefore, carries none of the protections under the D.C. Rules of Professional Conduct. Attendance at this presentation, a later review of any printed or electronic materials, or any follow‐up questions or communications arising out of this presentation with any attorney at Brustein & Manasevit, PLLC does not create an attorney‐client relationship with Brustein & Manasevit, PLLC. You should not take any action based upon any information in this presentation without first consulting legal counsel familiar with your particular circumstances.