Title I Funding - Frequently Asked Questions
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Q. Will all districts get additional Title I, Part A funds under the American Recovery and Reinvestment Act (ARRA)?
A. No. To be eligible for additional Title I Part A funds under ARRA, a district must have 5% poverty.
Q. How is the district poverty rate calculated? Who calculates it?
A. The calculation is based on an annual adjustment (2007) of the most recent census (2000) plus non-census data such as the number of children in neglected or delinquent institutions, children in foster homes, and children in families receiving TANF assistance. The poverty rate is calculated by the United States Education Department (USDE).
Q. When will our district be notified that it will receive additional Title I, Part A funds under ARRA?
A. Title I, Part A ARRA allocations will be posted on our website by the end of April. At that time districts will be able to access the funds through their ESEA Consolidated Application. Fiscal Year (FY) 2009 allocations for the regular Title entitlement will an estimate only.
Q. When do the Title I ARRA funds need to be spent by?
A. Title I, Part A ARRA funds are considered FY 2009 funds. An LEA must obligate at least 85% of the ARRA funds by September 30, 2010. Any remaining FY 2009 Title I, Part A ARRA funds will be available for obligation until September 30, 2011.
Q. Do comparability and maintenance of effort requirements apply to the use of these funds?
A. Yes, all comparability and maintenance of effort requirements apply. Waivers will be available to include State Fiscal Stabilization Funds in determining maintenance of effort. DPI is awaiting further guidance.
Q. Our district is considering allocating Title I ARRA funds to the middle school next year. This school has not received Title I funding in the past. The school has missed AYP for several years and has been designated a School Identified for Improvement (SIFI). If the school becomes Title I next year must we reserve 20% of our allocation to implement the federal sanctions?
A. No. The DPI has recently received further clarification on this issue from the US Education Department. According to federal Title I officials, schools that are Title I for the first time do not have to implement sanctions. A school must miss AYP for two years as a Title I school before Federal sanctions are implemented.
Q. When completing the Title I ARRA application must the LEA apply the same rank order, serving and eligibility requirements that apply the Title I basic application?
A. Yes. Title I regulations and guidelines apply to the Title I ARRA application.
However, there are some additional issues to consider with the Title I ARRA eligibility screen. When looking at the two applications together, an LEA needs to ensure that their schools are in rank order. In other words, an LEA can allocate a higher per pupil amount to a school with lower poverty as long as, when per pupil amounts are added together between the Title I basic and ARRA screens, schools with higher poverty have an equal or higher per pupil amount than schools with lower poverty.
The same schools will be eligible for Title services on a LEAs Title I basic and Title I ARRA screens. It is permissible to serve additional eligible schools with your Title I ARRA funds. For more information, see the Maintaining Rank Order with ARRA Funds Audio PowerPoint.
Q. Do I need to submit a program plan with the ARRA application?
A. Yes.
Q. How will the ESEA Consolidated Application change?
A. The ARRA funds will be accessed through the district’s ESEA Consolidated Application. Information on the ESEA Consolidated Application will be shared in a Mediasite presentation, which will be available on April 27.
Q. Some districts have used local funding to hire additional Title I teachers in targeted assistance schools because Title I allocations have declined or have not been sufficient to serve all eligible students. Now with additional Title I funding under ARRA, these districts have enough federal funds to pay for all Title I teacher salaries. May they do so?
A. Yes. Recent guidance on supplement not supplant from Education Department officials indicates that the district may use Title I funding to pay salaries of Title I teachers in targeted assistance schools formerly paid with local funding when the district allocation is large enough to do so. It is important to keep complete records that demonstrate that these are in fact Title I teachers working only with Title I students in those targeted assistance schools.
Q. Do the supplement not supplant requirements apply to Title I, Part A ARRA funds?
A. Yes, all supplement not supplant provisions apply.
Q. How can my district avoid supplanting when allocating Title I funds?
A. To determine if your district is in danger of supplanting when allocating Title I funds, ask the following questions:
- Does the district use Title I funds to provide services that the district is required to make available under state, local or other federal law?
- Does the district use Title I funds to provide services that it provided in the prior year with non-federal funds?
- Does the district use Title I funds to provide services for children participating in a Title I program or in a Title I school that it provides with non-federal funds to children in non-Title I schools?
If you answer yes to any of these questions, your district is at risk of supplanting. Consult with your assigned
DPI Title I consultant before proceeding.
Q. May Title I, Part A ARRA funds be used to support activities that were previously supported with non-Federal funds without violating the supplement, not supplant requirement?
A. A district can overcome a presumption of supplanting if it is able to show that it would not have been able to provide the services in question with state or local funds had the federal funds been unavailable. Consider the following guidance when deciding whether or not to use federal funds to pay for services or positions that were previously paid for with state or local funds:
- LEAs should maintain evidence of a funding reduction which shows the reduced amount, or lack of state and local funds available to pay for the position or services. Examples of helpful evidence include budgetary documents, accounting ledgers, payroll documentation (including sources of salary funds), legislation and statutes showing reduced funding allocations from year to year.
- Documents evidencing the LEA Board’s decision to eliminate the position or services had federal funds not been available, and the reason for that decision should be retained. This includes any evidence demonstrating that the Board was not simply shifting the funding source so that non-federally funded activities became federally funded activities. For example, LEAs should retain minutes from board meetings, internal memoranda, board resolutions and proposals, as well as other documentation explaining the LEA’s reasons for eliminating the position if it was to be supported with state and local funds.
- LEAs should keep records documenting that the obligated costs are for an allowable activity or service. Suitable records may include program statutes detailing allowable uses of funds, descriptions of employee responsibilities, time distribution records, contracts, purchase orders and invoices and other documentation detailing the procurement process.
Q. What are the reporting requirements for the Title I, Part A ARRA funds?
A. Districts will be required to submit quarterly reports on expenditures of ARRA funds and program outcomes. The reports will include the following information:
- the total amount of recovery funds received;
- the amount of recovery funds received that were expended or obligated to projects or activities;
- a detailed list of all projects or activities for which recovery funds were expended or obligated, including—
•the name of the project or activity;
•a description of the project or activity;
•an evaluation of the completion status of the projector activity
•an estimate of the number of jobs created
•the number of jobs retained by the project or activity
Q. How may Title I funds be used to support Response to Intervention (RtI) in a targeted assistance school?
A. Title I funds in a targeted assistance school must be used to provide supplemental education support to a select group of students determined eligible through multiple measures of achievement. These parameters on Title I funding still exist in targeted assistance schools even if the school is implementing RtI. Title I funds must still be used to provide additional educational support to a select group of eligible students and may not be used to provide the basic, core instruction available to all students.
Q. In a targeted assistance school, can the Title I teacher participate in RtI?
A. Absolutely. Title I services are one piece of the continuum of services available to students. Title I teachers should still be providing supplemental educational support to a select group of students determined as Title I eligible by a review of multiple measures of academic progress. The school should have explicit criteria for when students enter the Title I program and explicit criteria for when students exit the Title I program. Title I teachers collaborate with regular classroom teachers in identifying Title I students. Title I teachers may consult with regular classroom teachers to design classroom interventions that the teacher would implement before a student is identified as Title I eligible. However, the Title I teacher should not be delivering those interventions as they are designed for non-Title I students. Title I teachers should never be used to deliver the core instruction provided to all students even if that instruction is differentiated. Title I teachers deliver education services over and above the core instruction. Title I services should never reduce a student's access to the core instruction.
Q. How may Title I funds be used to support RtI in a schoolwide school?
A. Schoolwide programs, allowable in buildings with at least 40% poverty, are designed to serve the educational needs of all students within the school. Therefore, Title I funds, pooled with other resources may be used to fund any aspect of RtI in a schoolwide school.
Q. Is RTI subject to the comparability and supplement, not supplant provisions of the Title I law?
A. Yes.
Q. Can Title I funds be used to purchase instructional materials for RtI?
A. If the district is purchasing particular materials for all schools in the district, those materials must be purchased with state or local funds in both Title I and non-Title I schools. In a targeted assistance school, Title I funds may only be used to purchase instructional materials for Title I students in the Title I program. In a schoolwide school, funds may be pooled and instructional materials may be purchased for all students in the school. Title I funds may never be used to purchase instructional materials in non-Title I schools.
Q. How does the three tiered system, common in many RtI models, work within the Title I targeted assistance programming? What parameters do we need to be aware of as we implement RtI?
A. When implementing RtI in a targeted assistance school, staff must ensure that the students served by Title I teachers and the services those teachers provide are consistent with Title I law. In a targeted assistance school, Title I teachers work only with Title I eligible students and the services they provide are supplemental to the core instructional program. This must be foremost in consideration when determining which “tier” Title I services should best be placed. While some districts choose to use a tiered model it is not required by the DPI.
Q. Who can participate in professional development in schools receiving Title I funds?
A. In Title I schoolwide programs, all staff may participate in Title I funded professional development. In targeted assistance programs, Title I professional development must be only for staff that work with Title I eligible students and must be focused on how to better serve eligible students.
Q. We wish to hire a teacher to provide home visits with the parents of our Title I students to encourage communication between school and home, while also providing assistance on how to read with their child and homework skills. If we paid for this position with Title I money, does this teacher have to be reading certified or elementary teacher certified?
A. A 316 reading teacher license is not required to work with parents.
Q. If we allocate ARRA funding to a new Title I school, and part of those funds are used to purchase equipment, can the school keep the equipment in future years when it is no longer a Title I school?
A. It depends. Because the equipment was purchased with Title I money, once the school is no longer a Title I school, the district must determine if any of the remaining Title I schools are in need of that equipment. If they are, then the equipment must be moved to the Title I school. However, if none of the Title I schools need the equipment, it may stay in the non-Title I school.
Q. Our district lacks a comprehensive, coordinated plan for literacy instruction in the elementary grades. Can the ARRA funds in Title I and IDEA be used to consolidate and coordinate literacy programming in all elementary schools? One school does not qualify for Title I services, one school qualifies as a Targeted Assistance school and the remaining schools operate schoolwide programs.
A. The project described involves improving the quality of the core instructional program and therefore would not be fundable under Title I or IDEA. Both of those funding sources are designed to provide additional support over and above the core program. However, the maintenance of effort provision in IDEA could help free up local dollars that could be used for such a project. When a district gets an increase in IDEA flow-through funding, the “50% rule” allows a district to reduce their local costs for Special Education programs by 50% of the amount of the IDEA flow-through increase. The local special education costs are moved to the federal IDEA grant and the freed up local funds may be used to support the cost of developing a comprehensive, coordinated literacy program. For additional information regarding IDEA and its maintenance of effort requirements, view documents under IDEA flow-through and preschool entitlement resources at http://www.dpi.wi.gov/sped/lpp-budgets.
Title I and Coordinated Early Intervening Services (CEIS) funds may be used to plan for and support the interventions for struggling learners who need additional support beyond the core program. Title I dollars may only be used in Title I schools, CEIS funds may be used in any school.
Q. Is hiring a new teacher an allowable use of the ARRA dollars?
A. Yes, a district may hire teachers with Title I stimulus dollars. If the Title I dollars are being used in a targeted assistance school, then the teachers must be Title I teachers. Funds allocated to schoolwide schools may be used to hire additional teachers in the areas consistent with the schoolwide plan and needs assessment. Teachers must meet the definition of highly qualified under NCLB. Federal dollars must be used to supplement the staffing levels provided by state and local funds. The stimulus dollars are subject to all the same regulations as your regular Title I allocation, so if you would normally use Title I money for that activity, you can feel secure in budgeting stimulus funds for it as well.
Q. May Title I Funds be used to hire staff other than teachers and paraprofessionals, such as pupil services personnel, program coordinators and reading specialists?
A. Yes, with conditions.
Title I schoolwide schools must conduct an annual needs assessment to determine the greatest needs of low achieving students. Based on the needs assessment a schoolwide plan is developed, implemented and evaluated annually. The needs assessment results in the identification of schoolwide reform strategies that 1) provide opportunities for all children to meet the State's proficient and advanced levels of student academic achievement, 2) use effective methods and instructional strategies that are based on scientifically based research and, 3) include strategies to address the needs of all children in the school, but particularly the needs of low-achieving children and those at risk of not meeting the State student academic achievement standards. If pupil services personnel are employed to meet one or more of these objectives, they may be funded by Title I funds so long as those funds do not supplant state or local dollars.
In a targeted assistance school, pupil services personnel may be considered only under the following conditions:
- The school is implementing programs that provide supplemental services only to eligible children identified as having the greatest need for special assistance;
- The school provides opportunities for professional development with Title I funds and, to the extent practicable, from other sources, for teachers, principals, and paraprofessionals, including, if appropriate, pupil services personnel, parents, and other staff, who work with participating children in programs;
- The school provides strategies to increase parental involvement such as family literacy services;
- The pupil services personnel paid with Title I funds work only with students receiving Title I services and;
- Title I funds do not supplant state or local dollars.
Title I Coordinator positions are considered an administrative cost and should be budgeted as such in the Title I application. District requests to use Title I funds for pupil services staff are reviewed on a case by case basis. For further information, contact your DPI Title I consultant.
Q. Can a district allocate Title I, Part A ARRA funds to eligible schools that are not currently being served?
A. Yes. A district may allocate Title I, Part A ARRA funds to eligible schools, such as middle or high schools, that are not currently being served. A targeted assistance school may also consider expanding services to include students or grade levels not previously served with Title I funds.
Q. Does a district have to set aside one percent of its Title I, Part A allocation for parent involvement?
A. Yes. Districts whose total FY 2009 (Title I Basic and ARRA) allocation is greater than $500,000 must set aside a minimum of one percent of their total allocation for parent involvement activities. 95% of the funds reserved for this purpose must be distributed to schools.
Q. If a school’s poverty threshold falls below 40 percent in any subsequent year, may the school continue as a schoolwide program?
A. Yes. If the population of a school that operates a schoolwide program drops below the required poverty threshold in any subsequent year, the school may continue to operate as a schoolwide program as long as the school remains Title I eligible.
Q. Must every school spend an entire year planning before implementing a schoolwide program?
A. In general, every school that plans to operate a schoolwide program is required to spend an entire year conducting the planning process. However, an exception to this general rule can be made if the school district determines, in consultation with DPI, that the school needs less time to develop and implement its schoolwide program.
Q. How does the district obtain approval from DPI to waive the full planning year requirement?
A. All new schoolwides are required to submit the Schoolwide Assurances and Narrative, PI 9551 form (Rev. 04-09), which provides information on the planning process that took place in preparation for this new service delivery model. DPI will review this document and advise district representatives on the status of their request. More information regarding this process, as well as a link to the PI 9551 form, may be found at the Title I Schoolwide web page.
For questions about this information, contact Mary P. Kleusch (608) 267-3163
Last updated on 12/22/2009 8:54:36 AM
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