Policy Guidance for Title I, Part A: Improving Basic Programs Operated by Local Educational Agencies - April 1996

A r c h i v e d  I n f o r m a t i o n

Parental Involvement

The statute places considerable emphasis on parental involvement. Section 1118 contains many provisions pertaining to an LEA's responsibilities for carrying out parental involvement activities. If an LEA reserves funds "off the top" of its Title I allocation for carrying out Title I parental involvement activities, the LEA must involve parents of private school participants in those activities. If, instead, the LEA requires its Title I schools to provide parental involvement activities for public school parents from the Title I funds the schools receive, the LEA must provide activities for private school parents from the funds generated for providing services to private school children. Activities for the parents of private school participants must be designed in consultation with private school officials and parents. Furthermore, an LEA has the responsibility for consulting with private school officials and parents of participating private school children to jointly develop a compact between the LEA and parents of private school participants that outlines their shared responsibility for improved student achievement under Title I. A compact between the private school and participating private school children is not required, however. (See "Parental Involvement" guidance.)

Professional Development

Professional development is another major emphasis in Title I. Section 1119 contains provisions for required professional development activities. Many other sections of Title I also include references to professional development.

Private school officials and staff who work directly with private school children who participate in Title I may be included in professional development activities. In addition, parents of private school participants may participate in professional development activities if appropriate. Public school teachers who provide Title I services to private school children must be provided professional development, if needed. (See "Professional Development" guidance.)

Standards, Assessment, and Program Improvment

In consultation with private school officials, an LEA must provide participating private school children an equitable opportunity to meet the State's content and student performance standards. In some instances, however, it may not be appropriate to expect private school children to meet the State's standards--for example, if those standards are not aligned with the curriculum of the private school. If the LEA, in consultation with private school officials, determines that it would be inappropriate to measure the achievement of participating private school children in relation to the State's content and performance standards, the LEA must develop alternative standards that provide reasonable promise of those children achieving the high levels called for by the State's student performance standards.

An LEA must assess annually the progress of the Title I program toward enabling private school Title I participants to meet the State's challenging student performance standards (or the LEA's alternative standards). Generally, an LEA must assess the progress of the Title I program using the State's definition of adequate yearly progress. However, the LEA may need to modify that definition, in consultation with private school officials, to better measure the progress for participating private school children. In measuring adequate yearly progress, the LEA has the flexibility to group children in a manner that will provide the most accurate information of this progress. For example, the LEA may decide to group children by the type of instructional method, grade level, school, or other appropriate basis.

In general, an LEA must use the State assessment system (i.e., the final assessment required under section 1111(b)(3) of Title I or the transitional assessment under section 1111(b)(7)) as well as any additional measures or indicators the LEA deems necessary to measure how well the Title I program is enabling the private school students to meet the State's challenging student performance standards. In some instances, however, it may not be appropriate for the LEA to use the State assessment system. If the LEA, in consultation with private school officials, determines that the State assessment would not provide accurate information about the progress of participating private school children, the LEA may use other assessment measures that more accurately reflect the progress of those children toward meeting the State's standards.

If an LEA determines that the Title I program serving private school children has not made adequate progress (or met the criteria established by the State for transitional assessments) for two consecutive school years, the LEA must develop a program improvement plan that has the greatest likelihood of improving the performance of participating children in meeting the State's student performance standards.

Q39. In what subjects does an LEA assess private school children?

A. An LEA normally would assess private school children in the subjects in which the LEA provides Title I services to those children.

Q40. May Title I funds be used to assess private school children?

A. Title I funds may be used to assess private school children if the assessment is being used only for Title I purposes. To the extent, however, that an assessment is conducted for other purposes, it may not be paid for from Title I funds. For example, if private school children, in general, are included in the State assessment, Title I funds may not be used to pay for the assessment of those private school children participating in Title I.

Bypass

If an LEA is prohibited by law from providing for the participation on an equitable basis of eligible children enrolled in private elementary and secondary schools or if the Secretary determines that an LEA has substantially failed or is unwilling to provide for such participation, the Secretary waives the requirements for the LEA to serve private school children and arranges for the provision of such services. The Secretary informs the LEA and SEA that a bypass will be invoked. [The specific steps are found in section 14506 of the ESEA]

To implement a bypass, funds are deducted from the LEA's Title I allocation. In computing the amount to be deducted, administrative costs for serving private school children and capital expenses are included in the amount deducted from the allocation. Funds for educational services are generated on the basis of the number of low-income private school children residing in participating public school attendance areas. The Department ensures that services are provided in a cost-effective manner.
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