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Deadlines and Fiscal Information

Deadline Description
July 1 Assurances, debarment, and lobbying forms are signed by district authorizer
August 30 Title I, Part A application due to DPI
August 30 ESEA/ESSA End-of-Year Report of demographic information due to DPI
September 30 Last date for submission of the final claim for the previous school year
Fall DPI loads final ESEA/ESSA carryover into WISEgrants
October 31 Comparability Report due to DPI
May 1 New Title I Schoolwide applications are due for the next school year
Spring DPI loads preliminary allocations for the next school year into WISEgrants

Resources

Supplement Not Supplant Requirement

The Title I supplement not supplant requirement under the Every Student Succeeds Act (ESSA) provides flexibility for schools to use Title I funds to implement comprehensive and innovative programs. This flexibility supports educational equity and safeguards Title I funding to help ensure that a school’s Title I funds are used to meet student needs more effectively than could be done with state and local funds alone.

The Title I supplement not supplant provision states that every Local Educational Agency (LEA) receiving Title I funds must use those funds to supplement the amount of funds that would, in the absence of these federal funds, be made available from state and local sources for the school. In other words, Title I funds may not be used to supplant (take the place of) state and local funds.

ESSA requires LEAs to demonstrate compliance with the supplement not supplant requirement by documenting the methodology used to allocate state and local funding to Title I schools, demonstrating that each school still received the same amount of state and local funding it would have if it were not participating in Title I. ESSA no longer requires any determination that individual costs are supplemental.

Sources

Every Student Succeeds Act (ESSA) of 2015 §1118(b) [Fiscal Requirements]. 2017. 20 USC 6321(b).

US Department of Education. 2019. “Supplement not Supplant Under Title I, Part A of the Elementary and Secondary Education Act of 1965, as Amended by the Every Student Succeeds Act.”

Methodology Requirement and Exemptions

LEAs must document the methodology used to allocate state and local funding to Title I schools, demonstrating that each school still received the same amount of state and local funding it would have if it were not participating in Title I (20 U.S.C. 6321 (b)(2)).

A methodology is a set of rules that are applied consistently. If an LEA is required to have a methodology, documentation is submitted as part of the ESEA monitoring and auditing processes.

Exemptions

Most LEAs in Wisconsin are either completely exempt from having a methodology or may only need to have a methodology for certain grade spans.

An LEA may not be required to have a methodology for all grade spans. A grade span is exempt if it contains:

  • one school,
  • only non-Title I schools, or
  • only Title I schools.

An LEA is not required to have a methodology if:

  • it has only one school,
  • it has only Title I schools, or
  • all of its grade spans are exempt.

Source:

US Department of Education. 2019. “Supplement not Supplant Under Title I, Part A of the Elementary and Secondary Education Act of 1965, as Amended by the Every Student Succeeds Act.

Steps to Ensure Compliance

To comply with the supplement not supplant requirement and ensure compliance for a required audit or ESEA monitoring, LEAs should follow these steps:

  • Determine if one or more grade spans is exempt from needing a methodology.
  • Examine the methodology currently used to allocate state and local funds to schools to determine whether or not it meets the supplement not supplant requirement. Make adjustments as necessary to ensure compliance.
  • Document the methodology.
  • When state and local allocations are determined for schools, verify and document that the methodology was followed.
  • Attest to compliance each year by signing the Elementary and Secondary Education Act (ESEA) consolidated application assurances in WISEgrants.
  • Make documentation available for fiscal audits and ESEA consolidated monitoring.

LEAs may consider posting the methodology on their website.

Source:

US Department of Education. 2019. “Supplement not Supplant Under Title I, Part A of the Elementary and Secondary Education Act of 1965, as Amended by the Every Student Succeeds Act.

Acceptable Methodologies

An LEA’s methodology for allocating state and local funds is a local decision. LEAs may use different methodologies for different grade spans or school types (e.g. charter schools). An LEA may use any methodology that is Title I neutral.

A methodology is Title I neutral if:

  • it allocates state and local funds to schools without regard for Title I status. This ensures that the LEA did not reduce state and local funds made available to a Title I school due to its Title I status; and
  • it “does not use a proxy for Title I status, such as a school’s number or percentage of students in poverty or vague terms such as ‘educational need,’ that would result in a Title I school receiving fewer State or local funds than it would have received if it were a non-Title I school (USDE 2019).

Note: It is allowable to provide more funding to a school based on Title I status.

A methodology may take any of the following factors into consideration:

  • Grade span (e.g., high school, middle school, elementary)
  • School size
  • Specific student needs (e.g., English learners, newly arrived, special education)
  • School model (e.g., CTE, magnet, IB)
  • Other factors not based on Title I status

The intent under ESSA in creating a less burdensome process for showing compliance with the supplement not supplant requirement is to give more flexibility to LEAs both in allocating state and local funds, and in using Title I funds to implement comprehensive and innovative programs. This flexibility further supports educational equity by giving LEA’s the freedom to direct local funds to the students most in need.

DPI encourages LEAs to choose a methodology that promotes equity, helping to ensure that every student has access to the resources and educational rigor they need at the right moment in their education, across race, gender, ethnicity, language, disability, sexual orientation, family background, and/or family income. Allocating resources based on student need is one example of an equity-driven methodology. LEAs are encouraged to be innovative in their thinking when developing methodologies that best serve students most in need.

Excluding Certain Funds

An LEA may exclude from its methodology those supplemental state and local funds expended in any school for programs that meet the intent and purpose of Title I, Part A (20 USC 6321(d)). For example, any State Achievement Gap Reduction (AGR) funds received by a school may be excluded. Programs meet the intent and purpose of Title I, Part A if they meet the criteria outlined in the US Code of Federal Regulations (34 CFR § 200.79).

Updating the Methodology

LEAs should review their methodology annually and revise as necessary, but they do not need to adjust their allocation of state and local resources in response to changes during the school year.

Sources:

Council of Chief State School Officers. 2019. “Leading for Equity: Opportunities for State Education Chiefs.”

Exclusion of supplemental State and local funds from supplement, not supplant and comparability determinations. 2017. 34 CFR § 200.79.

US Department of Education (USDE). 2019. “Supplement not Supplant Under Title I, Part A of the Elementary and Secondary Education Act of 1965, as Amended by the Every Student Succeeds Act.

Methodology Examples

In each example below, the methodology is used for both Title I and non-Title I schools.

Example 1: Distribution Based on Student Characteristics

(“Weighted Per Pupil” Allocation)

Methodology:

  • Allocation per student: $7,000
  • Additional allocation per student from a low-income family: $250
  • Additional allocation per English learner: $500
  • Additional allocation per student with a disability: $1,500
  • Additional allocation per preschool student: $8,500

Applying the Methodology:

The following calculation is for a school with 450 students, including 200 students from low-income families, 100 English learners, 50 students with disabilities, and 20 preschool students.

Category Calculation Amount
Allocation/student 450 x $7,000 $3,150,000
Additional allocation/student from a low-income family 200 x $250 $50,000
Additional allocation/English learner 100 x $500 $50,000
Additional allocation/student with a disability 50 x $1,500 $75,000
Additional allocation/preschool student 20 x $8,500 $170,000
Total Non-Federal Funds   $3,495,000

Example 2: Distribution Based on Staffing and Supplies

Methodology:

  • Allocation per teacher (1 teacher per 22 students): $65,000
  • Allocation per principal (1 principal per school): $120,000
  • Allocation per librarian (1 librarian per school): $65,000
  • Allocation per guidance counselor (2 guidance counselors per school): $65,000
  • Allocation per student for instructional materials and supplies (including technology): $825

Applying the Methodology:

The following calculation is for a school of 450 students.

Category Calculation Amount
1 principal 1 x $120,000 $120,000
1 librarian 1 x $65,000 $65,000
2 guidance counselors 2 x $65,000 $130,000
21 teachers 21 x $65,000 $1,365,000
Instructional materials and supplies 450 x $825 $371,250
Total Non-Federal Funds   $2,051,250

Examples derived from:

US Department of Education (USDE). 2019. “Supplement not Supplant Under Title I, Part A of the Elementary and Secondary Education Act of 1965, as Amended by the Every Student Succeeds Act.”

Supplement not Supplant and Comparability

Supplement not supplant requires examination of the process for allocating state & local (non-federal) funding to schools. Comparability looks at the outcomes of that allocation process. These provisions work together to ensure that schools receiving Title I, Part A funds continue to receive the state and local funding to which they are entitled. These protections support educational equity by allowing schools to use Title I funds to directly serve students with the greatest needs.

  • Title I Supplement not Supplant prohibits LEAs from using federal funds as a substitute for state and local funds (20 USC 6321(b)).
  • Title I Comparability ensures that, within an LEA, schools in the same grade span receive comparable levels of non-federally-supported services (20 USC 6321(c)).

An at-a-glance summary and comparison of Title I fiscal requirements is available in the resources section of this webpage.

    Determining Allowable Costs

    The supplement not supplant provision under ESSA provides LEAs with some funding flexibility, but it does not mean all costs are allowable. Multiple policies, regulations, and legal requirements impose restrictions on the use of Title I funds. Certain budget items, or costs, are not allowable. The questions below can help determine whether budget items are allowable. If the LEA answers “yes” to all of the questions that pertain to it, the cost is likely allowable.

    Key Questions to Determine Allowability

    School Level Expenditures for Schools in Grade Spans Required to have a Methodology:

    • Did the LEA’s allocation methodology ensure the school received its full share of state and local funds?
    • Does the cost:
      • align with the school’s schoolwide or targeted assistance plan,
      • address the needs of Title I students, and
      • adhere to the Uniform Grant Guidance, EDGAR, and LEA policies (Allowable Costs Checklist)?

    School Level Expenditures without Methodology:

    An LEA must conduct school-level activities supported by Title I funds in a manner that does not take into account a school’s Title I status. A school must receive all the of the state and local funds it would have received in the absence of Title I funding.

    • Did the school receive all of the state and local funds it would have received in the absence of Title I funding?
    • Does the cost:
      • align with the school’s schoolwide or targeted assistance plan,
      • address the needs of Title I students, and
      • adhere to the Uniform Grant Guidance, EDGAR, and LEA policies (Allowable Costs Checklist)?

    District Level Expenditures (Reservations)

    An LEA must conduct district-wide activities funded by Title I in a manner that does not take into account a school’s Title I status.

    • Did the LEA allocate state and local funds for district-wide initiatives without regard for Title I status?
    • In other words, the LEA should not have reduced the amount of state and local funds made available for district-wide initiatives to a Title I school because it is a Title I school.
    • Does the cost:
      • support Title I students identified with the greatest need, and
      • adhere to the Uniform Grant Guidance, EDGAR, and LEA policies (Allowable Costs Checklist)?

    Carryover

    Title I-A formula funds are awarded annually to LEAs. The awards are aligned to the state’s fiscal year (July 1 - June 30), meaning that funds are available to use beginning July 1 of the year listed on the grant award if DPI has received the LEA’s application in substantially approvable form. (For example, the 2021-22 fiscal year runs from July 1, 2021 to June 30, 2022. Title I-A funds awarded for FY21-22 are available beginning July 1, 2021.)

    However, LEAs are not required to expend all of their Title I-A funds by June 30 of that fiscal year. Title I-A funds are available for 27 months from the date the funds are awarded to the LEA (GEPA section 421 U.S.C. 1225). For example, Title I-A funds that are awarded to an LEA on July 1, 2021, are available to the LEA until September 30, 2023. This 27-month period that LEAs have to expend their funds is referred to as the Tydings period.

    LEAs therefore may “carry over” unspent Title I-A funds into the next fiscal year. These funds are referred to as carryover funds. Under Title I, there are certain restrictions placed on carryover funds, depending on an LEA’s Title I-A allocation amount. These restrictions are detailed in the table below:

    LEAs with Allocations* Less than $50,000 LEAs with Allocations* Greater than $50,000
    • No restriction on the amount of funds that can be carried over each year, provided that funds are expended within the Tydings period..                                                                                        
    • May carry over up to 15% of the total allocation in unobligated funds into the next fiscal year.
    • May carry over more than 15% of the total allocation if they receive a waiver from DPI. This is only allowed once every three years. DPI will contact LEAs that need to complete a carryover waiver form.
    *Allocation amounts include the share for private school equitable participation and any funds transferred from Title II-A and/or Title IV-A.

    LEAs should track their carryover amounts. Carryover amounts are displayed on the “View/Edit Funding” screen in WISEgrants. DPI also posts a spreadsheet with finalized carryover amounts on this webpage every fall.

    WISEgrants will send a notice to an LEA if carryover amounts are greater than 15% and the LEA may take the following actions:

    • Reduce the percentage of funds to be carried over by spending funds on allowed activities between July 1 and September 30. This document, Reducing Carryover Amounts between July 1 and September 30, provides step-by-step instructions for this process. If you have questions, please contact Ryan Egan, Title I accountant, at (608) 266-1723.
    • If the LEA hasn’t received a carryover waiver in the two prior fiscal years, it may request a carryover waiver in WISEgrants. .  
    • If the LEA received a carryover waiver from DPI in one of the last two fiscal years, it may request a special ED Flex waiver from DPI. This website provides instruction for this process: https://dpi.wi.gov/esea/waiving-essa-requirements.

     

     

    Comparability Reporting

    ESSA requires districts receiving Title I, Part A funds to conduct an annual review of their local and state expenditures to ensure Title I and non-Title I schools receive a distribution of those funds on an equivalent basis. Districts must maintain documentation of the results, as well as any action taken to remedy findings of non-comparability, for future monitoring visits and audits.

    Districts with only one school per grade span are exempt from this requirement.

    Comparability Reporting Resources

    • Department of Public Instruction Title I and School Support. 2018. "Comparability Reporting." A short video presenting an overview comparability reporting (More videos are available on the Title I Shorts page.)
    • Department of Public Instruction Title I and School Support. 2018. "Comparability Reporting." A PowerPoint overview of comparability reporting
    • Department of Public Instruction Title I and School Support. 2018. "Title I Comparability Reporting." A technical assistance document providing instructions for entering data and submitting the report in WISEgrants

    See the calendar of deadlines on this page for current report due dates. Contact your Title I Consultant if you have questions.