State Tribal Education Partnership (STEP) (84.415A)

Program Overview

The purposes of this program are to: 

1. Promote increased collaboration between tribal education agencies (TEAs) and the State educational agencies (SEAs) and local educational agencies (LEAs) that serve students from the affected tribes; and 
2. Build the capacity of TEAs to conduct certain administrative functions under certain Elementary and Secondary Education Act of 1965 (ESEA) formula grant programs for eligible schools, as determined by the TEA, SEA, and LEA.

Types of Projects

The absolute funding priorities for the program in FY2020 limit projects to building capacity to administer and coordinate education programs that are designed to do one or more of the following:

1. Recruit or retain educators, including by supplementing efforts to recruit or retain educators employed by the TEA or by a partnering LEA.
2. Promote the availability of work-based learning experiences (such as internships, apprenticeships, and fellowships) or career exploration opportunities for elementary and secondary students served by the TEA that align with in-demand industry sectors or occupations (as defined in section 3(23) of the Workforce Innovation and Opportunity Act of 2014), without providing direct services.
3. For a TEA located in a State with a State statute specifically authorizing the establishment of charter schools, build TEA capacity necessary to open a new charter school, including a Tribally authorized charter school, such as by developing the charter school concept; writing a mission statement; defining an educational model; establishing a governance structure; developing a budget; establishing curriculum; choosing a location; developing partnerships with key stakeholders; or developing other materials related to applying for a charter from the appropriate authorizing entity.
4. Build TEA capacity necessary to convert a BIE-operated school to a BIE-funded Tribally-operated school, such as by developing structures necessary to ensure smooth transition of instruction; ensuring necessary and appropriate facilities; developing processes and procedures for oversight of funds and compliance with statute and regulations; and preparing to hire teachers and staff.

Projects may be carried out by either established TEAs (Absolute Priority 2) or TEAs with limited prior experience (Absolute Priority 3).

Applicant Information

FY 2026 84.415A STEP Application Notice and Instructions

Pre-Application Webinars

• Thursday, May 14, 2026, 2:00 PM Eastern Time: Register Online
• Monday, May 18, 2026, 2:00 PM Eastern Time: Register Online

Eligibility

Who May Apply: 

1. Indian Tribes
   1. An Indian Tribe that receives funds from BIE under section 1140 of the Education Amendments of 1978 (25 U.S.C. 2020) is not eligible to receive funds under this program. 
2. Tribal organization approved by an Indian Tribe
3. Tribal Educational Agency (TEA)
4. A consortium of eligible applicants listed above

Common Terms and Definitions

Agreement means a signed written agreement between the TEA and one SEA; the TEA and one or more LEAs; or the TEA and both an SEA and one or more LEAs, that documents the commitment of the TEA, SEA, and LEA, as applicable, to work together. For the purposes of this agreement, a BIE-funded school is considered an LEA. If a TEA operates a BIE-funded school, such agreement must include at least one other LEA not run by the Tribe or an SEA.

The agreement must include:

1. An explanation of how the parties will work collaboratively to directly administer education programs, including ESEA formula grant programs, consistent with State law and under written agreement between the parties;
2. A description of the primary SEA-type functions (as defined in this notice) or LEA-type functions (as defined in this notice) that the TEA will assume;
3. The training and other activities that the SEA or LEA, as appropriate, will provide for the TEA to gain the knowledge and skills needed to administer education programs in areas such as data collection and analysis, grants management and monitoring, fiscal accountability, and other areas as needed;
4. The assistance that the TEA will provide to the SEA or LEA, as appropriate, to facilitate the project, in areas related to Tribal history, language, and culture; and
5. A statement concerning student data that commits the parties to making their best efforts to reach consensus and finalize agreement, within 90 days after the start of the project, on a provision on data sharing that is consistent with FERPA, if data sharing is required by the project design;
6. The goals, objectives, and outcomes to be achieved by the proposed project that are clearly specified and measurable;
7. A timetable for accomplishing each of the objectives and activities that the applicant will undertake to achieve the program outcomes in the program requirements; and
8. An assurance that all relevant parties will participate in each Tribal consultation required under Federal education programs.

Directly administer education programs means conducting SEA-type functions or LEA-type functions for education programs, including ESEA formula grant programs, consistent with State law and under the agreement.

Education program means any Federal, State, local, or private education program that supports elementary or secondary students.

Established TEA means a TEA that:

1. Previously received a STEP grant in 2012 or 2015; or
2. Has an existing prior relationship with an SEA or LEA as evidenced by a prior written agreement between the TEA and SEA or LEA, and meets two or more of the following criteria:
   1. Has an existing Tribal education code.
   2. Has administered at least one education program within the past five years.
   3. Has administered at least one Federal, State, local, or private grant within the past five years.

Existing capacity means meeting two or more of the following criteria:

1. Has an existing Tribal education code.
2. Has established standard operating procedures related to elementary or secondary education operations.
3. Has administered at least one education program within the past five years.
4. Has administered at least one Federal, State, local, or private grant within the past five years, which may include a one-year STEP Development grant received in 2019.

Indian Tribe means a federally-recognized or a State-recognized Tribe.

LEA-type function means the type of activity that LEAs typically conduct, such as direct provision of educational services to students, grant implementation, school district curriculum development, staff professional development pursuant to State guidelines, and data submissions.

Project component means an activity, strategy, intervention, process, product, practice, or policy included in a project. Evidence may pertain to an individual project component or to a combination of project components (e.g., training teachers on instructional practices for English learners and follow-on coaching for these teachers).

Relevant outcome means the student outcome(s) or other outcome(s) the key project component (as defined in this notice) is designed to achieve, consistent with the specific goals of the program.

SEA-type function means the type of activity that SEAs typically conduct, such as overall education policy development, supervision and monitoring of school districts, provision of technical assistance to districts, statewide curriculum development, collecting and analyzing performance data, and evaluating programs.

Tribal educational agency (TEA) means the agency, department, or instrumentality of an eligible Indian tribe that is primarily responsible for supporting tribal students' elementary and secondary education, which may include early learning.

Tribal Consultations

Tribal Consultations and Engagement Sessions: View previous and upcoming consultations and engagement sessions, transcripts, recordings, and resources.

Legislation

FY 2023

Objective: The project’s objectives are to (1) engage in cross-agency coordination and consultation between a consortium of Tribal Education Agencies (TEA) from Idaho Tribes, Idaho State Education Agency (SEA), Idaho State Department of Education (SDE), and targeted Local Education Agencies (LEA); (2) identify and minimize barriers for access to Native American student data through cross-agency data sharing agreements and culturally responsive methods to support Native American student identification; and (3) administer one Indian education program as responsible fiscal agents, previously assumed by the SEA, 5 SDE, or partner LEAs, and expand their responsibilities in implementation of Elementary and Secondary Education Act (ESEA) programs that impact Native American student academic achievement, college readiness, and career pathways preparation

Primary Activities: This project will complete the final written agreement and the tribal consultation plan; conduct LEA professional development on tribal history, language, and culture and culturally responsive strategies; conduct monthly TEA-LEA leadership team meetings; and participate in student and community engagement.

Outcomes: Strengthen relationships and meaningful consultation between a consortium of TEAs from Idaho Tribes, the Idaho SEA, the Idaho SDE, and targeted LEAs. The project will serve more than 50 Native American K – 12 students with the critical need for improved academic achievement and accurate identification in student counts.

Objective: The OK STEP Project has four goals with associated objectives: (1) to promote Tribal self-determination among the Absentee Shawnee Tribe, Kiowa Tribe, and Sac and Fox Nation to empower participating TEA to shape their education systems and align education programs with cultural values and aspirations; (2) to improve the academic achievement of Native students among the three TEAs to identify evidence-based practices and culturally responsive approaches and document the specific needs of Native students enrolled in participating LEA; (3) to foster coordination/collaboration among the three TEAs, the OK State Department of Education, and nine LEAs will establish effective collaboration and communication channels and create an informed and collaborative educational environment; and (4) to strengthen community engagement among the participating TEAs to involve Tribal parents and stakeholders and foster a sense of ownership and shared responsibility for achieving desired outcomes.

Primary Activities: This project will enhance the identification of Native students eligible for the Title VI Indian Education Formula Grant Program; develop methods to identify and support under-identified Native students; increase the capacity of early-stage TEAs; and facilitate systemic change in key areas like college readiness, workforce development, and family engagement.

Outcomes: To increase the capacity of early tribal education agencies among three eligible Oklahoma tribes: Absentee Shawnee Tribe, Kiowa Tribe, and Sac and Fox Nation.

Objective: The goals of this project are to (1) promote learning across generations, acknowledging the value of modern education while honoring the wisdom of our Anishinaabe ancestors so that all Tribal members can walk in two worlds, and (2) increase Ojibwe Language Immersion education opportunities by completing teacher language capacity training programs.

Population Served: K through 5 Native American Students Primary Activities: This project will provide leadership in strengthening existing relationships with the LEA and SEA through formal agreements and implement cohort-based Ojibwe Language Teacher Training programs to ensure that Red Cliff has built the capacity to initiate an Ojibwe Language Immersion School with qualified and proficient language teachers.

Outcomes: To expand the project’s TEA capacity to support community aspirations for a healthy and prosperous community through education/workforce development, language preservation and revitalization.

Objective: The project’s objectives are to (1) support the staff capacity of Chugachmiut TEA; (2) conduct a community needs assessment survey to identify challenges in the region’s education delivery, gaps in services and opportunities for new programs and initiatives; and (3) establish and enhance partnerships with LEAs, educational nonprofits and Chugachmiut service departments. 

Population Served: K – 12 AI/AN Students Primary Activities: The project will: (a) perform a community needs and asset mapping survey; (b) assemble educators and stakeholders at a tribal education summit; (c) offer LEAs training and teaching tools for Suqpiaq language, history, and culture and (d) promote coordination and collaboration with local school districts and other community organizations. 

Outcomes: These action items will enable Chugachmiut to establish a robust education department grounded in relevant, timely data and informed by productive and mutually supportive relationships with LEAs throughout the region. With this expanded capacity, Chugachmiut’s Tribal Education Department will be well situated to strategize a slate of culturally informed programmatic offerings to advance the educational destinies of our region’s youth.

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FY 2022

Objective: 1) Engage our TEA and tribal leaders to develop a clear and comprehensive understanding of the process of launching a Native charter school; 2) Engage in a thorough and inclusive community planning process to determine key quality components of our school’s design and resources needed for a successful charter school model; and, 3) Build in sustainable practices to ensure funding beyond the STEP program.

Primary Activities: Our knowledge-building and community planning processes for school design will be supported through technical assistance provided by our SEA, as well as collaborative partners to build our capacity for this work. As we undertake the project as an established TEA (Absolute Priority 2), we have in place many of the relationships necessary to work with our partners to maximize the likelihood of the project’s success. These relationships, along with requested grant resources, will help our tribal community determine culturally responsive school components through sovereign decision making, culminating in a charter school application submitted to our Tribal Council for authorization.

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FY 2020

Objectives: (1) to recruit, retrain, and retain educators employed by the Blue Lake Rancheria Tribal Education Agency (TEA) or by the partnering local education agency; and (2) the promotion of experiential learning experiences for secondary students. The TEA will not provide direct services to students with STEP grant funds. As part of achieving both priorities, the TEA will create two complimentary programs: (1) Recruit, Retrain & Retain Educators (R3E); and (2) Modern Youth Apprenticeship Academies (MYAA), keystone secondary-level programs under the Career Readiness Education Program offerings. Information on how potential beneficiaries of the Tribe’s Career Readiness Education programming may fully participate in the R3E or MYAA design and implementation process will be provided during and after grant implementation.

Primary Activities: Recruit/retain teachers; Work-based learning experiences.

Knik Tribe seeks to develop its Tribal Education Agency. The recent adoption of a code of ordinances establishing the Knik Tribal Educational Agency, and a memorandum of agreement with the state and local education agencies, puts the Tribe in an excellent position to serve our American Indian/Alaska Native (AI/AN) students. The Tribe remains focused on improving educational opportunities for the AI/AN population by building capacity among teachers and staff to further operationalize our recently created work-based learning program framework and partnerships. The Tribe aims to increase the availability of work-based learning experiences by developing additional job shadowing opportunities and developing new career exploration opportunities such as pre-apprenticeships and internships in high-demand industry occupations for the secondary students we serve. Additionally, the Tribe is ready to develop a Tribally operated charter school. Knik Tribe will conduct administrative planning, development and coordination required to complete and submit the state’s first charter school application from a federally recognized Tribe. In the third year of the grant, the Tribe will open a new charter school with the goal of promoting culturally relevant curriculum and pedagogy to better address the academic aspirations and career and technical course opportunities of AI/AN students.

Primary Activities: Recruit/retain teachers; Work-based learning experiences

The Mashpee Wampanoag Tribal Education Agency (TEA), in partnership with the Mashpee School District (LEA) and Massachusetts Department of Elementary and Secondary Education (SEA), seeks to significantly improve the academic achievement of American Indian/Alaska Native (AI/AN) students through increased collaboration, capacity building and culturally responsive strategies. In meeting this objective, the TEA will collaborate with the LEA on the monitoring of selected SEA grant programs in Title I and Title II. Data-sharing agreements between the LEA and the TEA, with parent permission, will be a tool used to monitor the success of students and the impact of supplemental academic services offered by the TEA. Professional development opportunities designed to increase cultural competency of LEA and SEA staff will be delivered across the three-year project period, as will resources for improving student understanding of Native history and culture in the school district curriculum. The TEA will work toward expanding partnerships to offer more STEM-based internships and career building opportunities to Native students, along with supplemental academic support in reading and math, and afterschool programming to help students achieve their academic and post academic goals. The TEA will also attend technical assistance opportunities offered by the LEA and SEA to build its own capacity to better serve students. Lastly, this project will fund two language professionals at the Mashpee Middle and High School to offer two additional Wôpanâak Language courses in all three years.

Primary Activities: Recruit/retain teachers; Work-based learning experiences.

Objectives: The two goals of this three-year Virginia STEP Capacity-Building Project are to administer and coordinate education programs to (1) recruit/retain educators equipped to meet the needs of Virginia Native students, and (2) promote the availability of work-based learning experiences for Virginia Native students served by the TEA that align with in-demand industry sectors or occupations, without providing direct services.

Outcomes: Notable outcomes of the Virginia STEP Capacity-Building Project will include (a) co-produced and supported facilitation for a suite of professional development materials to assist local education agencies (LEAs) in recruiting and retaining educators versed in Virginia Tribal languages, culture and history, particularly within the subject areas of history and social studies; (b) form and coordinate the activities of local collaboratives to develop work-based learning strategies and activities linked to statewide and national resources but designed and managed by the local collaboratives; (c) plan and provide materials and support for organized Tribal community and family engagement activities, provided in conjunction with their LEAs, to enhance efforts associated with educator recruitment and retention and work-based learning strategies and activities; and (d) design and demonstrate a replicable model to serve the educational interests of small, resource-poor Tribes aspiring to implement a TEA. Virginia STEP Capacity-Building Project performance measures are goal aligned.

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FY 2019

Blue Lake Rancheria proposes to establishment of a Tribal Education Agency (TEA). Objective 1 of phase 3 is the establishment of a TEA, Board of Education (BOE), and an Education Code (hereafter “Code”). Project staff will contract with LEAs for training on the establishment a BOE, and Code. This will begin immediately, and a BOE will be elected during the Tribe’s general election in December. With the BOE established, policies and procedures for the implementation of educational programming to improve the academic achievement of Indian children and youth and codify them.

Chugachmiut proposes to create a Tribal Education Agency (Chugachmiut Education Department) and work with current and future partners to support systemic change in the education of preschool through adult education programs serving Alaska Native/American Indian tribal members who are beneficiaries of Chugachmiut services. The proposed activities include a range of issues such as enhancing Self-Determination in education by improving the infrastructure of Chugachmiut to meet the educational needs of all tribal members; increasing Alaska Native/American Indian student achievement by continuing partnerships with four school districts and the Alaska Pacific University; promoting sustainability through community engagement; and developing new collaboration opportunities to support systemic change in the education of preschool and adult education programs that serve Alaska Native/American Indian tribal members who are beneficiaries of Chugachmiut services.

Knik Tribe proposes to develop and operate an education agency to secure relationships with each of the 39 schools and developed curriculum to integrate culture into classrooms of all the core subjects, for elementary, middle school, and high school. Also proposed are developing Native educational code to guide Native education in Matsu and to provide the framework for addressing STEM/CTE hands-on education through implementing a robust after-school program for youth and parents.

Tribal Education Departments National Assembly (TEDNA) proposes to stablish and build the capacity of the Virginia Tribal Consortium consisting of five federally-recognized Tribes in Virginia that do not have a Tribal Education Agency (TEA): Chickahominy Indian Tribe, Chickahominy Indian Tribe – Eastern Division, Monacan Indian Nation, Pamunkey Indian Tribe, and the Upper Mattaponi Indian Tribe. TEDNA proposes to serve as the Tribal Education Agency for the member Tribes, promote Tribal self-determination in education among Tribes in Virginia, improve the academic achievement of Indian children and youth, and promote the coordination and collaboration of participating Tribes with the Virginia Department of Education (VDOE), Local Educational Agencies (LEAs), and other entities. TEDNA proposes to manage the Virginia STEP Project and provide expertise on the formation and operation of a Tribal Education Agency (TEA) in partnership with the Native American Rights Fund (NARF) and the Academic Development Institute (ADI) by providing key initiatives that include: TEA Governance Training, TEA Management Training, Virginia Tribal Consortium Outreach Seminar, Virginia Education Resources Training, Strategic Performance Management (SPM) Training, Educating Native Youth for Success, and Tribal Sovereignty and Education Code Training. The project will also produce a Virginia Tribal Consortium Guidebook and Virginia Tribal Consortium Website.

Winnebago Tribe of Nebraska proposes to develop a Tribal Education Agency (TEA) to improve education needs for children and youth (PreK-12) who attend school within the boundaries of the Winnebago Indian Reservation. The goals are to promote tribal self-determination in education; improve academic achievement of Indian children and youth; promote the coordination and collaboration of Tribal Education Agencies (TEAs) with State Education Agencies (SEAs) and Local Education Agencies (LEAs); and meet the unique educational culturally related academic needs of Indian students.

Objective: To formulate and develop the Winnebago Tribal Education Agency, enhance collaboration with Local Education Agencies, and the State Education Agencies (SEAs) within a 12-month period.

General Resources

• STEP Annual Performance Reporting (APR) Webinar 2024: This webinar provides guidance, tools, and resources for completing annual performance reporting for STEP grantees.
• All Program Talking Circle — March 2024: This video provides an overview and discussion period of Executive Order 14112.
• New Grantee Budget Workshop: November 2023: This workshop was provided for all new FY23 grantees to discuss fiscal basics, managing grant budgets, and developing budget revisions.
• All Program Talking Circle — May 2024: This Talking Circle discusses ways to share data to various audiences, to tell a grant program's story.
• STEP Talking Circle — August 2023: This Talking Circle covers APR updates, grant award notifications and preparing for the upcoming year.
• STEP Talking Circle — May 2023: This Talking Circle discusses APRs and budget revisions, providing grantees and opportunity to review their recently submitted APRs. Grantees also had an opportunity to share program activities with other grantees and discuss what the plan to do next.
• STEP Annual Performance Reporting (APR) Webinar 2023: This webinar provides guidance, tools, and resources for completing annual performance reporting for STEP grantees.
• STEP Talking Circle — January 2023: This Talking Circle allowed grantees to share any implementation challenges and connect with their peers.

Logic Models and Data-Driven Decision Making

Data Sharing Agreements — October 2021: This webinar walks through important considerations for developing collaborative partnerships and developing data sharing agreements including a general data sharing agreement template.

Day 1: Logic Models — June 2021: The first session in this three part series provided an introduction to logic models, walks through how to create one, and provides a number of models and templates.

Day 2: Logic Models — June 2021: The second session in this three part series provided an opportunity to work through creating a logic model and how the logic model fits into program evaluation.

Day 3: Data-Driven Decision Making — June 2021: The third session introduced the concept of data-driven decision making, how to integrate this into program planning and implementation, and how it works with logic models and evaluation.

Trauma and Resiliency

Trauma and Resilience in Tribal Communities: Part 1: An introduction to research on trauma as it relates to AI/AN people and tribal communities, including trauma types, brain science, developmental and behavioral effects, and the interconnected nature of historical and current traumas. Also includes practice scenarios and significant attention to resilience strategies. This is Part 1 of a two-part series.

Trauma and Resilience in Tribal Communities: Part 2: An introduction to research on trauma as it relates to AI/AN people and tribal communities, including trauma types, brain science, developmental and behavioral effects, and the interconnected nature of historical and current traumas. Also includes practice scenarios and significant attention to resilience strategies. This is Part 2 of a two-part series.

Frequently Asked Questions

1. What is the purpose of the STEP Program?
2. What do we mean by "SEA-type functions" and what are examples of SEA-level responsibilities that a TEA might assume as part of this grant program?
3. For purposes of STEP, what is an LEA, what are LEA-type functions, and what are examples of LEA-level responsibilities that a TEA might assume as part of the STEP project?
4. Does the Department have any prohibitions on the SEA-type or LEA-type functions a TEA may adopt?
5. Which ESEA formula grant programs could TEAs and SEAs or LEAs include under STEP?
6. How can a TEA include the title VII, part A Indian Education formula grant program in a project?
7. Can a TEA propose to include in its STEP project only the title VII, part A Indian Education formula grant program?
8. What is meant by "capacity-building" as part of the STEP grant program?
9. Who must comply with the ISDEAA hiring preference?
10. What are the ways in which the parties can share ESEA formula grants funds, or STEP funds?
11. Will the Department provide TEAs with State-administered formula grant program funds to distribute to the affected LEAs under the STEP program?
12. Will a TEA receiving a STEP grant become the agency responsible to the Department for ensuring compliance with statutory and regulatory requirements?
13. If a TEA decides to undertake joint functions with either the SEA or the LEA, such as monitoring or providing technical assistance, would that count as the TEA assuming administrative functions?
14. Does the Family Educational Rights and Privacy Act (FERPA) prohibit a TEA from collecting or receiving data on students as part of its agreement with the SEA?
15. What does the Department expect to see in a Preliminary Agreement between a TEA, an SEA, and an LEA?
16. Which parties must sign the Preliminary and Final Agreements?
17. Will an application be reviewed if it is missing required signatures on the Preliminary Agreement?
18. What does the Department expect to see in a Final Agreement between a TEA, an SEA, and an LEA?
19. Are TEAs required to identify the participating schools in their applications?
20. Can a TEA choose to work with only one school? Is a TEA required to make an agreement with two different LEAs?
21. Can a TEA apply if one or more selected schools serve students from multiple tribes?
22. Can a TEA choose to work with only BIE schools?
23. What additional requirements apply to applicants that include BIE-funded schools?
24. Can STEP funds be used for BIE schools if BIE-funded schools are included?
25. What is the purpose of permitting applicants to include Bureau of Indian Education (BIE)-funded tribally-controlled schools in STEP projects?
26. What are the audit requirements for STEP applicants? Is the TEA required to have an audit?
27. What are examples of costs that are not allowable under STEP?
28. How does the Department review proposed project budgets before an award is made?
29. Must a TEA submit a current indirect cost rate (ICR) agreement as part of its application?

1. What is the purpose of the STEP Program?
 

The purpose of the STEP program is to: (1) promote increased collaboration between Tribal Education Agencies (TEAs) and the State educational agencies (SEAs) and local educational agencies (LEAs) that serve students from affected tribes, and (2) build the capacity of TEAs to conduct certain SEA-type or LEA-type administrative functions under certain Elementary and Secondary Education Act (ESEA) formula grant programs for eligible schools, as determined by the TEA, SEA, and LEA.

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2. What do we mean by "SEA-type functions" and what are examples of SEA-level responsibilities that a TEA might assume as part of this grant program?
 

Depending on the statutory authorization of the particular ESEA formula grant program, SEA-level functions may include developing policy; providing technical assistance to subgrantees; monitoring for compliance; collecting, analyzing, and reporting performance information; and evaluating programs. SEAs also make subgrants (either competitively or by formula) to LEAs and other subgrantees, but a TEA cannot take on an SEA's subgranting function. A TEA can, however, agree to take on any of the other functions, under agreement with the SEA, consistent with State procurement laws.

For example, SEA-level responsibilities that a TEA might carry out through the STEP grant include:

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3. For purposes of STEP, what is an LEA, what are LEA-type functions, and what are examples of LEA-level responsibilities that a TEA might assume as part of the STEP project?
 

An LEA is an entity that meets the definition of "local educational agency" in section 9101(26) of the ESEA, (i.e., a school district that is recognized by the State as an LEA). This can include a charter school that is a stand-alone LEA, but not a charter school that is part of a larger LEA. A charter school that is part of a larger LEA can only participate as a school in a STEP project. Similarly, BIE schools can be included as participating schools in a STEP project, but are not considered LEAs for purposes of the STEP program.

Activities that LEAs typically conduct include supervision and direction for educational services to students, grant implementation, and data submissions, as well as school district curriculum development and staff professional development pursuant to State guidelines.

For example, LEA-level responsibilities that a TEA may carry out through the STEP grant include:

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4. Does the Department have any prohibitions on the SEA-type or LEA-type functions a TEA may adopt?
 

A TEA may choose any SEA-level or LEA-level functions, as long as all parties agree to each function in the preliminary and final agreements. However, if a TEA performs both SEA-level and LEA-level functions for a single ESEA program, the parties must ensure there is no conflict between these functions. A TEA cannot perform both LEA-type and SEA-type functions for the same ESEA formula grant program if the result would be that the TEA is monitoring itself. For example, if a TEA includes the title II-A formula grant program in its STEP project, the TEA could not perform both the LEA function of providing professional development to schools and the SEA function of monitoring the delivery of professional development, because then the TEA would be monitoring itself.

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5. Which ESEA formula grant programs could TEAs and SEAs or LEAs include under STEP?
 

ESEA State-administered formula grant programs are programs for which States: receive ESEA formula funding; subgrant funds to LEAs or other entities (in accordance with statutory allocation formulas or other criteria); and oversee the use of those funds by subrecipients.

TEAs may include the following SEA-administered programs in a STEP grant application:

TEAs may include the following LEA-administered program in a STEP grant application:

Title VII is a direct grant to LEAs; it is not a State-administered grant. Projects that include title VII grants must also include at least one State-administered ESEA formula grant program. (See question 7 below for more information). TEAs can still choose SEA-type or LEA-type functions for the State-administered ESEA formula grant.

Projects cannot include Impact Aid grants. Impact Aid funds are intended to replace local tax revenues and are generally treated by LEAs as part of the general fund budget. There is no required use of Impact Aid funds by LEAs. Thus, unlike the other ESEA formula programs, there are not required LEA functions for Impact Aid that would be relevant to the STEP program.

Additionally, the schools included in the partnership agreement must be recipients of grant funds or services under the particular ESEA formula grant program chosen. It is possible for a project to include one ESEA program for one school (e.g., title VII for a public school), and a different ESEA program for another school (e.g., title I for a BIE-funded school).

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6. How can a TEA include the title VII, part A Indian Education formula grant program in a project? 
 

A TEA interested in assuming administrative functions for the title VII, part A Indian Education formula grant program has two options:

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7. Can a TEA propose to include in its STEP project only the title VII, part A Indian Education formula grant program?
 

No. If a TEA includes title VII, part A in its STEP project, it must also include at least one State-administered ESEA formula grant. STEP's dual purpose is to build TEA capacity and to build relationships between the TEA and the relevant LEAs and SEA; if a proposed project only included title VII, part A, there would be no State role in the project. However, for each State-administered program, the TEA can still choose to propose either LEA-type or SEA-type functions.

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8. What is meant by "capacity-building" as part of the STEP grant program?
 

Capacity-building refers to activities that strengthen the knowledge, skills, and abilities of individuals or groups to perform specific activities or functions that lead to strengthening communication, cooperation, coordination and collaboration between and among individuals or groups. Regardless of which ESEA programs or functions are selected, we expect that capacity-building will be a focus of each grant proposal. For example, to build the capacity of the organization, applicants may conduct a needs assessment, develop a technical assistance plan, and implement the technical assistance plan.

We expect that a major component of both the preliminary and final agreements will be descriptions of capacity-building activities to be conducted by and for the TEA, SEA, and LEA. By "capacity-building activities," we mean activities intended to increase the capacity of the:

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9. Who must comply with the ISDEAA hiring preference?
 

STEP grants that are primarily for the benefit of members of federally-recognized tribes are subject to the provisions of section 7(b) of the Indian Self-Determination and Education Assistance Act (Pub. L. 93-638). That section requires that, to the greatest extent feasible, a grantee—

A TEA from a federally-recognized tribe that receives a STEP grant is subject to the hiring preference. If such a TEA shares STEP funds with an SEA or LEA or any other entity, that entity would be subject to the hiring preference when using STEP funds. However, a TEA from a State-recognized tribe generally would not be subject to this hiring preference.

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10. What are the ways in which the parties can share ESEA formula grants funds, or STEP funds? 
 

There are several ways applicants could share funding. The applicant could: (a) share the STEP grant award only; (b) share the STEP grant award and the SEA's or LEA's formula grant administration funds; (c) share the SEA's or LEA's grant administration funds, but not the STEP grant award; or (d) share no funds. The ultimate goal of the distribution of funds should be to support the objectives of the program.

To enable the TEA to assume certain ESEA administrative functions, SEAs or LEAs can provide a portion of their formula grant administration funds to the TEA, in accordance with applicable State laws. If the TEA and the SEA or LEA agree to share formula grant administrative funds, the TEA must detail the fund distribution in the budget submitted to the Department with the grant application, and the TEA, SEA, or LEA should describe the plans to share these funds in the preliminary and final agreement.

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11. Will the Department provide TEAs with State-administered formula grant program funds to distribute to the affected LEAs under the STEP program?
 

No. The Department will not grant formula funds to TEAs as a part of this grant program. No changes have been made to the ESEA that would permit the Department to change the designated grantee under any ESEA program. STEP grant funds to successful applicants will consist only of discretionary funds appropriated for this competition. However, a TEA, SEA and LEA may distribute funds according to the options listed in question ten.

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12. Will a TEA receiving a STEP grant become the agency responsible to the Department for ensuring compliance with statutory and regulatory requirements?
 

No. SEAs that participate in the STEP program will continue to subgrant ESEA State-administered formula funds to eligible LEAs in the State, including to LEAs with schools involved in the STEP grant program. SEAs will continue to have the responsibility and authority to ensure subrecipient compliance with the applicable laws and regulations governing all ESEA State-administered formula grant programs. The Department will continue to monitor the performance of the SEA as the agent required to comply with the requirements of Federal laws and regulations related to the administration of the ESEA.

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13. If a TEA decides to undertake joint functions with either the SEA or the LEA, such as monitoring or providing technical assistance, would that count as the TEA assuming administrative functions?
 

Yes. A TEA's assumption of SEA-level or LEA-level responsibilities under an agreement could include carrying out responsibilities jointly with the SEA or LEA. Alternatively, TEAs could take on an activity alone, on behalf of the SEA or LEA. Under either option, SEAs retain legal responsibility to the Department, as discussed above. The types of SEA-level or LEA-level functions that a TEA will perform will depend on the terms of the agreement reached by the TEA and SEA, or TEA and LEA.

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14. Does the Family Educational Rights and Privacy Act (FERPA) prohibit a TEA from collecting or receiving data on students as part of its agreement with the SEA?
 

FERPA does not prohibit data-sharing with TEAs if required steps and safeguards are followed. FERPA generally prohibits the disclosure of personally identifiable information from students' education records without parental consent; however, an SEA or an LEA could release student information in non-personally identifiable form to a TEA. In addition, an SEA or an LEA may designate an Indian tribe or TEA as its authorized representative to audit or evaluate Federal or State-supported education programs, under the conditions set forth in the Department's regulations. See 34 CFR 99.3, 99.31(a)(3), 99.35. For further information, see resources from the Department's Family Policy Compliance Office and Departmental regulations. Also, review the requirements for the preliminary and final agreements, as detailed in the application package.

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15. What does the Department expect to see in a Preliminary Agreement between a TEA, an SEA, and an LEA?
 

A TEA must submit a preliminary agreement between the TEA, SEA, and LEA with its application. The preliminary agreement must document the commitment of the TEA, SEA, and LEA to work together and must include all of the elements required in the application package.

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16. Which parties must sign the Preliminary and Final Agreements?
 

The preliminary and final agreements must be signed by the TEA, the SEA, and at least one LEA. Letters of support will not be accepted as a substitute.

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17. Will an application be reviewed if it is missing required signatures on the Preliminary Agreement?
 

No. The signatures in the preliminary agreement are evidence of a commitment between the TEA, SEA and LEA to fulfill the requirements in the proposed application.

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18. What does the Department expect to see in a Final Agreement between a TEA, an SEA, and an LEA?
 

By March 30, 2016, each TEA grantee must submit to the Department a final agreement that builds on the preliminary agreement and details a feasible, sustainable plan for how the TEA, SEA, and LEA will work together to administer selected ESEA formula grant programs for identified schools. The final agreement must contain all required elements listed in the application package.

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19. Are TEAs required to identify the participating schools in their applications?
 

Yes. Applicant TEAs are required to list the participating schools in the preliminary agreements that they submit with their applications.

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20. Can a TEA choose to work with only one school? Is a TEA required to make an agreement with two different LEAs? 
 

A TEA cannot work with only one school; it must work with a minimum of two schools, at least one of which is a public school. However, the TEA is not required to make an agreement with two different LEAs. For example, a TEA may work with two schools within a single LEA, such as an elementary school on the reservation, and a high school off the reservation; it could not choose, however, to include only the single elementary school. The TEA could also work with one school that is part of an LEA and one BIE school. This does not require that a TEA make an agreement with two different LEAs. (Please refer to the LEA definition in question three).

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21. Can a TEA apply if one or more selected schools serve students from multiple tribes? 
 

Yes. We expect TEA grantees to serve students from all tribes who attend schools participating in the STEP project. For schools that have students from multiple tribes with a presence in the community, we would encourage a TEA planning a STEP application to first consult with other affected tribes. One option for the TEA would be to form a consortium and include the affected TEAs as its consortium partners. Another option is for all tribes in the community to agree that one TEA will serve as the sole applicant, without forming a formal consortium.

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22. Can a TEA choose to work with only BIE schools?
 

No. If a project includes a BIE school, the TEA must include at least one public school as well, in order to promote better communication and collaboration between the tribe and the SEA and LEA.

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23. What additional requirements apply to applicants that include BIE-funded schools?
 

Applicants that include one or more BIE schools in a proposed project are required to transmit a copy of the application to the Bureau of Indian Education. Applicants may transmit this application through email to stepapp@bia.gov
, fax the application to (202) 208-3312, or send the application to Dr. Charles M. Roessel, Director, Bureau of Indian Education, 1849 C Street, NW, MS-4657-MIB, Washington, D.C. 20240. In submitting the application to the Department, these applicants must include as an attachment evidence of the submission to BIE (e.g., copy of dated email transmission or fax receipt).

This will allow the Department and BIE to consult as to whether the TEA will be required to enter into an agreement with BIE that details the respective responsibilities of each entity. Applicants proposing to assume SEA-type functions in a BIE-funded school will be required to enter such an agreement. If the TEA is not able to reach an agreement with BIE by the time of award, the TEA must remove the proposed BIE school from its project and adjust its budget accordingly. A TEA that proposes to assume only LEA-type functions with respect to BIE-funded schools will not be not required to enter into an agreement with the BIE.
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24. Can STEP funds be used for BIE schools if BIE-funded schools are included?
 

STEP funds can be used to build communication between BIE-funded tribally-controlled schools and public schools. However, STEP funds cannot be used on activities that are already funded by BIE. For example, a TEA may work with a BIE-funded tribally-controlled preschool and the LEA to promote kindergarten readiness and ensure that student goals are aligned across the programs. The STEP funds could not be used, however, to hire additional teachers for the BIE-funded school.

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25. What is the purpose of permitting applicants to include Bureau of Indian Education (BIE)-funded tribally-controlled schools in STEP projects?
 

BIE-funded tribally-controlled schools are administered by the tribe. These schools serve students that may move between BIE-funded schools and public schools. By including BIE-funded tribally-controlled schools, we promote better communication between the BIE-funded schools and public schools, coordinated through the TEA whose member students are affected by the systems serving the community.

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26. What are the audit requirements for STEP applicants? Is the TEA required to have an audit?
 

Under 2 CFR 200.500-512, all entities that expend $750,000 or more annually in total Federal awards must have a current audit. If an entity does not comply with the Federal audit requirements, the Department has the option of awarding the STEP grant with special conditions or not funding an application. Note that, as applicable, TEAs may meet this requirement through an audit of the whole tribe; if the tribe expends $750,000 or more annually, the tribe is required to have a current audit. A late audit or an audit with findings for the tribe may have an impact on the TEA's application status.

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27. What are examples of costs that are not allowable under STEP?
 

Direct services are not allowable costs under STEP. For example, a grantee cannot hire teachers for a school using STEP funds. In addition, costs must be aligned to the scope of the application, the project purpose, and the general purpose of the STEP program. Additionally, the general government-wide cost principles apply, which prohibit use of funds for most purchases of food, any entertainment expenses, incentives, prizes, or other items identified by the Office of Management and Budget's (OMB) Cost Principles at 2 CFR 200. For more information, please read the FAQs about the Cost Principles.

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28. How does the Department review proposed project budgets before an award is made? 
 

The Department's pre-award review of a proposed budget will focus on whether the proposed budget supports the goals and objectives of the grant program and whether those costs are allowable, reasonable, and allocable. The Department eliminates amounts for unallowable or unreasonable expenditures; thus the actual grant amount may be less than the amount in the applicant's proposed budget. For information on allowable costs, see references in question 27

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29. Must a TEA submit a current indirect cost rate (ICR) agreement as part of its application?
 

If a TEA has a current ICR agreement and intends to charge indirect costs to the STEP grant, the TEA must submit a copy of the ICR agreement as part of its application. The ICR agreement must be negotiated with and approved by the grantee's cognizant agency, i.e., either (1) the Federal agency from which it has received the most direct funding, subject to indirect cost support; (2) the Federal agency specifically assigned cognizance by OMB; or (3) the State agency that provides the most subgrant funds to the grantee (if no direct federal awards are received). For federally-recognized tribes, the Department of Interior (DOI) is the cognizant agency.

An applicant selected for funding that has an expired ICR agreement and intends to charge indirect costs to the STEP grant must follow the Department's regulations at 34 CFR 75.560. Those rules permit an applicant to use a temporary rate of 10 percent of budgeted direct salaries and wages while it negotiates a rate with its cognizant agency (e.g., DOI); the applicant must then submit an ICR proposal to its cognizant agency within 90 days after the Department issues the grant award notification. 34 CFR 75.560.

Applicants with no previous ICR can use a de minimis rate of 10 percent of modified total direct costs (MTDC); these TEAs do not need to negotiate for this rate. Should such an applicant decide to use this MTDC as its ICR, it must use this rate for a full fiscal year; it cannot negotiate for a different rate. 2 CFR 200.414(f).

Please note that, in accordance with OMB's Cost Principles at 2 CFR 200, applicants that have an expiring ICR agreement can apply to the cognizant agency for a one-time extension of up to four years. 2 CFR 200.414(g). If a successful applicant has an expiring ICR agreement, after the expiration date of the original agreement, the grantee will be required to submit evidence to the Department that its cognizant agency granted an extension of the ICR agreement in order to charge indirect costs to the STEP grant at the approved rate.

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