Using Title I Funding to Support ELs and Avoiding supplanting of Core EL programs National Title I Conference February 4th, 2014 David Holbrook - presenter National Council of State Title III Directors Patricia Adkisson (AK) - President Nadja Trez (NC) – President Elect David Nieto (IL) - Vice President Terry Richard (DE) – Secretary Cori Alston (GA) - Treasurer Morgan Cox (CO) – Membership Coordinator David Holbrook (WY) – Past-President Jesse Markow (WIDA) – Advisory member Kenji Hakuta (Stanford University) - Advisory member Gabriela Uro (Council of Great City Schools) – Advisory member Rick Passovoy (TransACT Communications, Inc) – Advisory member
AGENDA • ELs and Civil Rights guidance/legislation • How to include identification of Core EL Programs in your consolidated grant application • Intersection of Title I and Title III • Inappropriate use of Title I and Title III funds • Appropriate use of Title I funds to serve ELs • Closing: Question - Comments
ELs and Civil Rights • An Office of Civil Rights (OCR) document sets the foundation for the provision of services to English Learner (EL) students. • The OCR document titled ‘The Provision of an Equal Education Opportunity to Limited- English Proficient Students’ includes five points related to procedures that should be used by LEAs to ensure that their programs are serving EL students effectively. (http://www.ed.gov/about/offices/list/ocr/ee olep/index.html).
ELs and Civil Rights Five Points from OCR 1. identify students who need assistance 2. develop a program which, in the view of experts in the field, has a reasonable chance for success 3. ensure that necessary staff, curricular materials, and facilities are in place and used properly 4. develop appropriate evaluation standards, including program exit criteria, for measuring the progress of students; and 5. assess the success of the program and modify it where needed
How to document your Core EL program • In your state’s consolidated grant application there should be a place to include GEPA information related to your district’s EL plan. • Use this place to report your district / school Core EL plan. • This could be lengthy if each school has a different type of program used for serving ELs. • You may not use Title I or Title III funds for programs reported in your GEPA Core EL plan.
Wyoming example – Core EL program identified through GEPA narrative Wyoming incorporates 7 questions into its request for a GEPA EL plan in order to allow a district to clearly identify its Core EL plan Students who are English Learners (ELs). The plan in this question must include the method for identification and placement of EL students (i.e. home language survey and EL screener), the staff, materials, and facilities identified to be used in the 'core' English language instruction program, and methods and procedures the school district will use to measure the effectiveness of the program. (1,500 Character Maximum) a) What questions are asked on your district's home language survey? (1,500 Character Maximum) b) What English Language Proficiency Screening Assessment do you use to determine if a student is an English Learner? (examples: W-APT, SELP B, IPT, Woodcock Munoz, Las Links) (1,500 Character Maximum)
Wyoming example – Cont.’ c) What type of EL services are provided by your district? (for Example: Dual Language, Two-Way Immersion, Heritage Language, ESL pull-out, Sheltered Instruction, etc. (1,500 Character Maximum) d) What staff (how many instructors including teachers and paraprofessionals) are used in your Core EL program? (Do not include staff that provide EL services that are supplemental to your Core EL program.) (1,500 Character Maximum) e) What materials are used in your Core EL program? (Do not include materials that are purchased to supplement your Core EL program, only include EL curriculum, etc. that is used for English Language Acquisition and/or access to mainstream content that is part of your Core EL program) (1,500 Character Maximum) f) What facilities are used in your Core EL program? (For most this will be your regular classroom, but if you have a designated/dedicated EL classroom that is used by all ELs, you should include this information.) (1,500 Character Maximum) g) How do you measure the effectiveness of your EL program? (Use of your ACCESS for ELLs data analysis and AMAO results is the most common method.)
Intersection of Title I and Title III Title I and Title III are linked in the following significant ways: • Title III requires that States establish English language proficiency standards that align with the content standards required under Title I. • Title I and Title III both require annual assessments of English language proficiency (Title I for all EL students). • Student achievement data must be disaggregated for the EL subgroup for adequate yearly progress (AYP) determinations (ESEA subgroup reporting against AMOs under Flexibiltiy). • AYP for the EL subgroup = AMAO #3 one of the annual measurable achievement objectives (AMAOs) under Title III. • Strategies used to improve achievement under both Title I and Title III need to be comprehensive and coordinated in order to ensure that they address the needs of EL students.
Intersection of Title I and Title III Title I and Title III programs share the following administrative processes: • Title I and Title III State formula grant awards are both processed and distributed by the US Department of Education’s Office of Elementary and Secondary Education (OESE). • States submit a Consolidated Application for both Title I and Title III State formula grant programs. • States report their Title I and Title III data to OESE as part of their Consolidated State Performance Reports (CSPRs) each year. From USDE Q&A, June 9, 2008
Intersection of Title I and Title III Other similarities: • Anything funded with either Title I or Title III money must be supplemental to the school’s Core EL program • Title I and Title III both require that supplemental programs need be ‘research based’ or come from ‘scientifically based research’. So EL programs funded by Title I would need to meet this criteria. • Former ELs, students who were ELs but who have attained English proficiency and have been placed in monitor status for the two years after attaining English proficiency, may be included in AYP calculations for the EL subgroup.
Improper use of Title I and Title III Funds Supplement not Supplant 11
Improper use of Title I and Title III Funds OCR and the Supplement not Supplant guidance both need to be taken into consideration: • OCR requires a “core” EL program. No Title I funds or Title III funds can be used to pay for elements of a LEAs “core” EL program as required by OCR. • The Supplement not Supplant guidance basic supplanting tests are: a) You cannot use Title III funds for programs/services required by other Federal, State or Local laws. For Title I it is only other State or Local laws b) And you cannot use Title I or Title III funds to pay for something that was paid for in the previous year with other Federal, State or Local funds.
Improper use of Title I and Title III Funds • OCR requires that districts identify ELs students that need assistance. • The Home Language Survey and English Language Proficiency (ELP) screening assessment are generally used as the means to identify EL students. • Because the EL screener is part of a process required by OCR, no Title I or Title III funds can be used to purchase, train personnel to administer, or actually administer the EL screening assessment. • OCR requires a “core” EL program. So the staff, curricular materials, and facilities used for your “core” EL program cannot be paid for with Title I or Title III funds.
Improper use of Title I and Title III Funds ELP assessment • Title I requires that ALL ELs be assessed using the State’s ELP assessment. • Because of this, in most cases Title III funds cannot be used to pay for the State’s ELP assessment, training to administer the assessment, and the administration of the assessment (except in private schools where requested). • Title I funds cannot be used to pay for this either because not all ELs are Title I students. And Title I funds cannot be used for non-Title I students.
Appropriate use of Title I Funds for ELs Supplemental = in addition to 15
Appropriate use of Title I Funds for ELs Title I funds can be used to pay for any ‘research based’ EL programs, but: a) These programs must not be part of the district’s “core” EL program; b) These programs can only be implemented using Title I funds in Title I funded schools; and c) These programs can be the same as Title III programs, but they have to follow all the Title I regulations, be supplemental, and if implemented district wide, the amount of Title I funding cannot exceed the proportion of funding based on the # of ELs in Title I schools vs. non-Title I schools .
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