Archived: ELEMENTARY AND SECONDARY EDUCATION ACT (ESEA): IMPROVING AMERICA'S SCHOOLS ACT OF 1994 (IASA) GUIDANCE

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

Local Applications

In order to receive Title VI funds, an LEA must submit an application to the SEA. The SEA sets the due date for local applications. An LEA may submit a separate application for Title VI funds or, under circumstances described below, a consolidated application.

Consolidated Application

Section 14305 of the ESEA (20 USC 8855) provides the authority for LEAs to submit consolidated applications. There are two circumstances under which an LEA may submit a consolidated application. First, under section 14305(a), an LEA that is receiving funds under more than one of the ESEA programs for which consolidation is permitted may submit a consolidated application to the SEA. Second, under section 14305(b), if an SEA has obtained approval from the Department of a consolidated State application, it may, if it desires, require LEAs receiving funds under more than one program included in the consolidated State application to submit a consolidated local application.

SEAs are free to determine the content of consolidated local applications; however, under section 14305(d), SEAs may require as part of a consolidated local application only those descriptions, information, assurances and other material that are absolutely necessary. The flexibility that SEAs have to design the content of consolidated local applications means that they are not required to include specific application requirements set forth in individual program statutes. Therefore, an SEA that designs a consolidated local application that covers Title VI is not required to include any of the local application requirements found in section 6303. Under the Department's interpretation, however, exclusion of any of these specific Title VI local application requirements from the consolidated local application would not change an LEA's responsibility to comply with any program requirements that are expressed through the local application requirements.

Example. Title VI requires that local applications provide for systematic consultation with parents, teachers and administrative personnel, and other groups involved in implementation of Title VI. If an SEA designs a consolidated local application that covers Title VI and excludes this specific application requirement from the consolidated application, an LEA would not be required to address systematic consultation in the consolidated application, but would still be required to carry out the systematic consultation requirement in its program.

Finally, in developing consolidated local applications, SEAs must collaborate with LEAs under section 14305(c). In designing consolidated local applications that cover Title VI, SEAs and LEAs are encouraged to work together to emphasize the relationship of the planned Title VI program to the State's Goals 2000 or other systemic reform plan, as well as to the other programs covered in the consolidated application.

Single Application

If an LEA chooses to submit a separate Title VI application, it must include the following information:

the amount of funds it intends to allocate to the various Title VI innovative programs, along with a description of the programs, projects and activities it will carry out and its reasons for selecting these programs, projects and activities
the allocation of funds required to provide equitable services to participating private school children in accordance with section 6402 of Title VI (Note: The LEA must also include the information required in section 76.656 of EDGAR.)
a description of how assistance under Title VI will contribute to meeting the National Education Goals and improving student achievement or improving the quality of education for students
assurances of compliance with the provisions of Title VI
an agreement that the LEA will keep such records and provide such information to the SEA as reasonably may be required for fiscal audit and program evaluation, consistent with the SEA's responsibilities
provision, in the allocation of funds, for systematic consultation with parents of children attending schools within the LEA, with teachers and administrative personnel, and with other groups involved in implementation of Title VI as the LEA considers appropriate.

In keeping with the opportunity that exists to use Title VI funds in ways that support reform efforts, the Department encourages LEAs to include in their applications a discussion of how the planned Title VI activities relate to its statewide school reform plan, including the State's or LEA's Goals 2000 plan.

Supplemental Guidance

Consolidated Planning/Cash Management Improvement Act - A number of State coordinators have noted that, with respect to FY 95 funding, it is unlikely that LEAs will be engaging in any consolidated planning before July 1 because the approval process for consolidated State plans probably will not be completed until June. A question was raised regarding whether the Cash Management Improvement Act (CMIA) would therefore have any effect on the consolidated planning process. The CMIA applies only to SEAs, not LEAs. Therefore, it is the Department's interpretation that as long as SEAs have submitted their consolidated State plans and obtained Department approval by July 1, the CMIA will have no implications for the consolidated planning process, even if LEAs do not begin developing consolidated local plans until after July 1.

Systematic Consultation - The Department believes it is imperative in our mission of educational reform that broad-based alliances of involvement be formed to meet the challenge of helping all students achieve to high standards. Title VI charges the LEA with bringing together all key groups, particularly parents with teachers and local school administrators, and other groups involved in the implementation of Title VI (such as librarians, school counselors, and other pupil services personnel) as considered appropriate by the

LEA, for systematic consultation. Such consultation must cover the allocation of funds for programs authorized by Title VI and the design, planning and implementation of those programs. Each LEA may determine, based on local needs and circumstances, what constitutes systematic consultation. In general, the Department envisions that such consultation would be an ongoing process that is open to all interested persons and is calculated to provide advice within a timeframe that can affect ultimate decisions regarding Title VI programs.

LEAs have used a number of strategies to ensure that they maintain meaningful systematic consultation with parents. Among these strategies are:
Soliciting parents' and appropriate school personnel suggestions in the allocation of funds and in the design, planning, and implementation of the program.
Providing timely responses to parents' recommendations.
Providing reasonable access to meeting space and materials.
Providing opportunities for parents to view the program's operations.
Issuing monthly newsletters.
Conducting parent workshops.
Inviting one or more parent representatives to participate on budget committees advising school administrators on the use of local, State and Federal funds.
Hiring community aides to work with parents in the home and to serve as a link between school and home.
Providing training designed to help parents work with their children at home.
Facilitating volunteer or paid participation by parents in school activities.
Designating LEA parent coordinators.
Establishing parent advisory councils.
Having materials in appropriate languages and formats to bring about consultation with all appropriate persons.
Informing parents of their children's participation in special Title VI projects; e.g., gifted and talented, magnet schools, drop-out prevention.
Providing parents, or making available to parents, in an ongoing, timely and adequate manner information such as proposed and final project applications; project plans; budgetary information; and evaluation data.
Using language(s) of predominant linguistic groups in meetings, communications and other informational materials.

Combinations of these activities can often ensure effective two-way communication. Meaningful parent involvement requires adequate information upon which to base that involvement. Schools are encouraged to capitalize upon this relationship and afford parents the opportunity to become involved in critical choices regarding their children's education.

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[Uses Of Funds By LEAS]

[Participation OF Children Enrolled In Private Non-profit Schools]