LEAs should take the following questions into account before deciding to make a transfer.
- Are the costs that the LEA would pay for with the transferred funds allowable under the source grant (Title II, Part A or Title IV, Part A)?
- Has the transfer been discussed with the business manager and, if appropriate, the district administrator?
- Will the transfer improve educational equity for the students with the greatest needs?
- How will this transfer impact the LEA Plan or school improvement plans?
- If the LEA transfers funds into Title I, Part A, will this transfer impact the amount of carryover that would be available for the next year? (There are carryover limitations for Title I, Part A.)
- What will the impact be on the private schools participating in ESEA services?
When is it necessary to transfer funds from Title II to Title I?
A transfer is necessary if the LEA needs to cover one or more of the following costs for their Title I program and serve eligible Title I students. (These costs are not allowed under Title II, Part A.)
- Salaries for the following positions: paraprofessionals, parent liaisons, guidance counselors, psychologists, school nurses, school social workers, director of curriculum/director of learning if she/he does not provide professional development, library/media specialist, dean of students, teachers for before/after school interventions.
- Employee transportation for staff providing Title I instructional services to eligible Title I students in private schools.
- Pupil transportation for Title I services.
- Pupil transportation for students who are in out-of-home care (foster care) or experiencing homelessness in order for them to attend their school of origin.
- Light snacks and supplies for Title I services such as Title I family engagement events.
- High quality instructional materials such as textbooks, instructional media, instructional software, supplies, etc.
- Pupil dues and fees.
- Site rental for instruction.
- Classroom furniture.
Is the transfer from Title II to Title I always necessary?
No, transfers are not always necessary. If an LEA needs funds for the following activities, a transfer is not needed. (These costs are allowed under Title II, Part A.)
- Salaries for the following positions: teachers in core academic areas, substitute teachers in order to release the regular teacher for professional development funded by Title II program, instructional coach, literacy coach, mathematics coach, RtI coordinator, Educator Effectiveness coordinator, director of curriculum/director of learning if she/he provides professional development, school improvement facilitator, teacher recruiter, data analyst, and reading specialist.
- Professional development activities for Title I teachers.
- Transportation for the purposes of professional development activities for both private and public school staff.
- Site rental for professional development.
- Software for the purpose of professional development activities in academic areas.
- Supplies for the purpose of professional development activities in academic areas.
Is a transfer from Title IV-A necessary?
No, transfers from Title IV-A are rarely necessary. Title IV-A can be used as an extension of other Title funds and may even offer greater flexibility than other Titles. Note that the eligibility requirements of a Title IV-A needs assessment (for LEAs receiving >$30,000) and stakeholder feedback (all Title IV-A allocations) must be met prior to initiating a transfer.
Who should LEAs contact if they want to discuss allowable costs or transfers using Title II, Part A?
Abdallah Bendada, Education Consultant, at 608-267-9270.
Who should LEAs contact if they want to discuss allowable costs or transfers using Title IV, Part A?
Emily Holder, Education Consultant, at 608-267-9170.
Who should LEAs contact if they want to discuss the Title I, Part A carryover provisions?
Ryan Egan, Accountant, at 608-266-1723.