Deadlines and Fiscal Information

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.”

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.”

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.”

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.

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.

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 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.