Frequently Asked Questions About Equitable Services

Where can I find data about non-public enrollment of students residing in our district?

Ed Sight maintains data from the ED159 reports on non-public school enrollment and staff counts. This information may be accessed by going to the main page and selecting Students > Enrollment > Non Public Enrollment, or by accessing the web link Nonpublic School Enrollment and Staff Counts. An overview of how to use these reports is available in the Report Notes - Nonpublic Enrollment and Staff Counts. This information may be helpful when identifying and coordinating timely and meaningful consultation with non-public schools that may have eligible students. Data is available by school town, resident town, and by grade band or individual grade levels.

What information should the LEA provide to the non-public schools prior to timely and meaningful consultation?

Providing non-public schools with explicit information about which schools in the LEA you have identified as Title I schools will be critical to determine student eligibility, and the grade bands applicable to those schools. If there are multiple schools within the same grade band, information on the geographic areas where students attending these schools reside.  For more information on school districts, visit the CT Public Schools and Districts Map | Connecticut Data.

What are appropriate uses of Title I funds for non-public schools?

Title I funds are meant to help students “receive a fair, equitable, and high-quality education and to close educational achievement gaps”. As such, equitable services funds can be used to provide services including, but not limited to:

• Instructional supports;
• Non-instructional supports like behavior and social and emotional learning;
• Services like counseling, specialized instructional support services, mentoring services, preparation for postsecondary; education and the workforce, behavioral supports, early intervention services, and other activities; and
• Professional learning or family engagement activities related to program goals.

What are allowable measures of poverty to determine Title I, Part A proportionate share?

The LEA is required to determine an accurate count of children from low-income families who attend private schools and reside in participating public school attendance areas. The ESEA permits an LEA, based on timely and meaningful consultation, to use:

1. The same measure of poverty used to count public school children (e.g. FRPL data) If the LEA and non-public officials agree that this will yield an accurate count of private school students, the Department of Education recommends use of the same measure.
2. Comparable poverty data from a survey An LEA may use a survey to obtain poverty data, and need only send survey forms to families with children who reside in participating private school attendance areas. To the extent possible, the survey must protect the personally identifiable information (PII) of families and students and comply with all applicable state and federal law for protecting student records and PII.¹ The LEA should not require that private school officials give the names of low-income families. The only information necessary for an LEA to collect from such a survey of private school children is:
   1. Verification of residence in a participating Title I public school area;
   2. Grade level and age of each child; and
   3. Household income.
3. Comparable poverty data from a different source. An LEA may use poverty data for private school children that are from a different source from the data it uses for public school children so long as the income threshold is generally the same. For example, an LEA uses FRPL data, but private school students do not participate in the National School Lunch Program (NSLP). However, the private school may provide the LEA with a count of children from low income families using other comparable poverty data such as eligibility for means-tested scholarship programs or fee waiver applications following the Income Eligibility Guidelines set by the United States Department of Agriculture (USDA) Food and nutrition service
4. Proportionality An LEA may apply the low-income percentage of each participating Title I public school attendance area to derive the number of private school children from low-income families.
5. An equated measure

Who is eligible for Title I services?

Although poverty data is used to determine the allocation, poverty is not a criterion for eligibility of services. Once it is determined that a non-public school is eligible for Title I funds and proportionate share is calculated, the following students may be served:

• Students with demonstrated academic need as determined by an objective measure during consultation²
• A student with a 504 or IEP is eligible to receive Title I equitable services
• Publicly placed students whose tuition is paid for with state and/or local funds.
• Foster students may be eligible based on the address of the foster family (if residing in a served area).

If a non-public school is eligible for Title I, but does not wish to provide services, can the funds be used just to buy supplies?

 Unfortunately, no. Instructional supply purchases are allocable to Title I Part A only if they are necessary to deliver services to students participating in a Title I program. In some cases, the allocation may not be sufficient to implement services. In this case, non-public schools may work with your LEA to plan family engagement or professional learning activities that will support the goals of Title I Part A.  This should be done in a timely manner to ensure students benefit from these funds.

Can a non-public school be reimbursed for payroll or expenses directly?

Reimbursements directly to non-public schools are strictly prohibited.

Where can LEAs find data about non-public enrollment of students residing in the district?

Ed Sight maintains data from the ED159 reports on non-public school enrollment and staff counts. This information may be accessed by going to the main page and selecting Students > Enrollment > Non Public Enrollment, or by accessing the web link” Nonpublic School Enrollment and Staff Counts. An overview of how to use these reports is available in the Report Notes - Nonpublic Enrollment and Staff Counts. This information may be helpful when identifying and coordinating timely and meaningful consultation with non-public schools with potentially eligible students. Data is available by school town, resident town, and by grade band or individual grade levels.

A school plans to use Title I Equitable Services funds for tutoring. Is the person or person(s) delivering tutoring services considered an employee of the non-public school, or the LEA?

Anyone providing services paid through Title I will be considered employees of the LEA and must meet all requirements thereof. Services may also be provided by an approved external vendor. In some cases, an existing employee of your school provides additional (i.e. after school) support. In this case, this person would need to go through the LEAs hiring process, and all work related to the grant must be outside of their scheduled work hours for which they are compensated.

Who ultimately owns supplies purchased with Title I funds?

All supplies purchased with federal funds are owned by the LEA and should be labeled as such. If the non-public school no longer requires the materials, or materials are no longer useful, the non-public shall coordinate for return or disposal based on board of education policies and procedures.

What if the LEA and the private school cannot come to an agreement?

If the LEA and the non-public school have difficulty coming to an agreement, there is a state Ombudsman for monitoring private school student participation who can be reached to support consensus between LEAs and private entities. In such cases, please reach out to Adrian.Wood@ct.gov and copy your Consolidated grant contact.

What if non-public schools do not respond to our attempts to communicate?

First and foremost, log all attempts to communicate with non-public schools. See sample communication log.

If non-public schools have not responded by your established deadline, follow up with three more communications in multiple formats on non-consecutive days. Record these communication efforts, including the date, time, method, and result. This communication log may be uploaded in lieu of participation form for private schools that are unresponsive, if it indicates that several attempts to communicate have been made over non-consecutive days. LEAs should maintain documentation of any written communication in accordance with federal, state, and local records policy.

What information does a non-public school need to provide the LEA about the planned use of funds, and identified budget items?

We recommend that the LEA and non-public agree on the identified needs, the strategy to address those needs, and the various expenses associated with implementing that strategy before concluding consultation. All expenses must comply with grant requirements and should be secular, neutral, and non-ideological. To expedite approval of the LEA application, the LEA and non-public school should agree upon the following, and include this information in the application:

• What (describe the item, service, or position to be funded. Include vendor details or websites if requesting to purchase additional materials)
• Who (describe the audience and the impact for that audience)
• How (parameters- quantity, time, etc.)
• Why (evidence base & link to identified need/ SIP)
• Where/ When Where the services will be provided or delivered, and by whom. Include evidence that the expense is secular, neutral, non-ideological.

Are there recommendations for how to input information about equitable services budget items in the Electronic Grant Management System?

Below is an example of a budget item properly entered into EGMS. We recommend you tag to specific schools, because this makes monitoring and analysis more streamlined by supporting available reports in EGMS. As always, you should comply with Generally Accepted Accounting principles (GAAP) and code things to the proper object code and purpose. This also supports your finance office when downloading budget data from EGMS to populate the financial management system.

What if there is a new non-public school with enrolled students not listed in the grant application?

If you identify an organization not listed in your application, first confirm that this is a not-for-profit organization, as only non-profits are eligible for federal funding. If non-profit, reach out to your CSDE grant contact to coordinate adding this organization to associated non-public schools in the system.

What happens during timely and meaningful consultation?

To ensure timely and meaningful consultation, the district shall consult with appropriate private school officials during the design and development of the district’s programs under the Every Student Succeeds Act (ESSA).  The district and private school officials shall both have the goal of reaching agreement on how to provide equitable and effective programs for eligible private school children, the results of which agreement shall be transmitted to the ombudsman designated under subsection (a)(3)(B).  Such process shall include consultation on issues such as:

1. How and when the district will make decisions about the delivery of services, including a thorough consideration and analysis of the views of the private school officials on the provision of services through a contract with potential third-party providers. (If the district disagrees with the views of the private school officials on the provision of services through a contract, the district will provide in writing to such private school officials an analysis of the reasons why the district has chosen not to use a contractor);
2. The size and scope of the equitable services to be provided to the eligible private school children, teachers, and other educational personnel, the amount of funds allocated for such services and how that amount was determined (including the method or sources of data that were used to determine the number of private school children from low-income families in Title I participating school attendance areas who attend private schools);
3. How the children’s needs will be identified and what services will be offered;
4. How, where, when, including the approximate time of day, services will be provided and by whom.
5. How the services will be academically assessed and how the results of that assessment will be used to improve those services;
6. Whether to provide equitable services to eligible private school children by pooling funds or on a school-by-school basis; and
7. Whether to consolidate and use funds available for Title I equitable services in coordination with eligible funds available for equitable services under programs covered under section 8501(b) to provide services to eligible private school children in participating programs.

Such consultation shall include meetings of agency and private school officials and shall occur before the district makes any decision that affects the opportunities of eligible private school children to participate in programs under this part.  Such meetings shall continue throughout implementation and assessment of services provided under this section.