2017 Fall Regional

Workshop
Division of Federal
Programs
PA Department of Education
Division of Federal Programs

333 Market St. 7th Floor

Division of Federal Programs
Harrisburg, PA 17126

Tel : (717) 783-2193

Fax : (717) 787-8634

www.education.state.pa.us
Then follow these links to find our page:

• Teachers and Administrators

• More…
• Federal Programs

2
Fall Regional Workshop Agenda

 Appropriately State Certified

 Contracts
 Fiscal
 Uniform Grants Guidance
 ESSA
 Monitoring
 DFP structure

 If you are getting monitored this year, stay

after for a Preparing for Monitoring session

3
Proposed State Plan Updates

 CSI/TSI
 Future of School Improvement
funding
 Link to plan -
http://www.education.pa.gov/K-
12/ESSA/Pages/default.aspx#tab-1
 State Plan summary for highlights

4
Allocation Highlights
2017-2018
• 1st year under ESSA – All LEAs required to
contribute to increased 7% statewide set
aside (previously 4%) for School
Intervention
• Large (unexpected) increase in state Title I
allocation total from USDE (approx. $45
million) helped to offset some major
individual LEA losses
• Title IIA overall reduction from USDE, along
with new set aside, resulted in an
approximate 11.5% reduction in total Local
allocations statewide, when compared to
final 2016-17
2018-2019
• For 2nd year under ESSA and all subsequent
years, “special rule” regarding SI set aside
contributions by LEA is reinstated
• Current Title I USDE estimate is that PA will
receive approximate $20 million reduction
from PY state allocation
• Title IIA zeroed out on current USDE tables
(as of 9/13/2017)—could be reinstated
during budget negotiations. Stay tuned.
HQT Change to ASC in ESSA
 Highly Qualified Teacher requirements gone
effective August 1, 2016
― Must hold appropriate State certifications for
teachers working in a Title I and Title II
program
 Emergency permits are not considered Appropriately
State Certified for federally funded positions
― Must send out four week parent letter
 Updated FAQ that addresses these common questions
― PDE 425 no longer required

6
ASC Paraprofessionals in ESSA
 ALL Instructional Paraprofessionals working in
Schoolwide schools need to meet one of the
requirements below (a-c). Instructional
Paraprofessionals in Targeted Assistance schools paid
with Title I funds must also meet one of the
requirements below (a-c).
― a. Have completed at least two years of postsecondary study.
― b. Possess an associate degree or higher.
― c. Meet a rigorous standard of quality as demonstrated through a
State or local assessment.
 Special Education requirements for paraprofessionals
remain
― Instructional paraprofessionals, each school year, shall provide
evidence of 20 hours of staff development activities related to
their assignment.

7
Parent Right to Know

 Parent Right to Know letter regarding teacher qualifications

― Parents should be directly notified of this information no later than 2
weeks after the start of the school year.
― Website posting is insufficient.
― Pertains to all teachers in any Title I school.

 Notification to parents informing them that their child’s

teacher is not “appropriately state certified.”
― Parents should be directly notified on an as-needed basis after 4
consecutive weeks.
― Pertains to all students that will have a teacher that is not appropriately
state certified participating in a Title I program.
 SWP – all teachers
 TA – Title I teachers

― Keep a copy of the letter even though it does not need to be sent out.
8
Contracting under UGG
 What is a contract?
― A contract provides goods/services as needed
by the program
― Contractors (aka vendors) are NOT responsible
for carrying out the responsibilities of the
federal program
 Contractors carry out terms of their contracts
― Non-federal entities must have a contract
administration system to ensure contractors
are complying with the terms of the contract

9
Subgrant vs. Contract

 Subgrantee:
― Determines who is eligible to participate in the
federal program
― Measures performance against objectives of
the federal program
― Is responsible for programmatic decision-
making
― Is responsible for complying with federal
program requirements
― Uses federal funds to carry out the program
(not just provide specific goods/services)
10
Subgrant vs. Contract
 A contractor:
― Provides goods/services within normal business hour
operations (after-school hours count)
― Provides similar goods/services to different purchasers
― Operates in a competitive environment
― Provides goods/services ancillary to operation of federal
program
― Is NOT subject to compliance requirements of the federal
program ****
 e.g. - performance reporting – includes goals set for Non-
public programs

11
Subgrant vs. Contract

 Each program statute sets out when

an entity can subgrant funds to
eligible entities
 LEAs are subgrantees of SEAs
― Subrecipient monitoring has to occur
when there is a subgrant
― LEAs may not subgrant a subgrant

12
Contracting

 If an LEA cannot provide goods/services,

it may enter into a contract to provide
the necessary goods/services for the
program
 Non-federal entities must maintain
oversight to ensure that contractors
perform in accordance with the terms,
conditions, and specifications of the
contract

13
Contracting

 There must always be an agreement

― Subgrant (PDE and LEA)
― Contract (LEA and contractors – IUs, Third-
party providers, Companies, etc.)
 Includes agreements with other LEAs or
IUs to provide services
― Must document the use of funds for
accountability and allowability purposes

14
FISCAL
UGG Requirements
 Emphasis on IMPLEMENTING LEA policies and
procedures
― Conflict of Interest policy
― Travel Reimbursement policy
― Allowability of Costs procedures
― Cash Management procedures
― Procurement procedures – REFER TO MAY GUIDANCE
DOCUMENTATION
 Must be implemented by July 1, 2017
 Federal Programs Monitoring
― Will result in a “Not Met” and Corrective Action Plan will
need to be developed.
16
 Allowability of Costs
 In order to determine if a grant cost is allowable for federal
grants, the following three tests must be taken into
consideration:
― Costs must meet the following general criteria in order to be
allowable under Federal awards: (a) be necessary and reasonable
for the performance of the Federal award and be allocable thereto
under these principles (2 CFR 200.403 ).
― Necessary costs are those that are required in order to carry out the
program and activities contained in an approved grant application.
― Reasonable costs. A cost is reasonable if, in its nature and amount it
does not exceed that which would be incurred by a prudent person
under the circumstances prevailing at the time the decision was
made to incur the cost. … Consideration must be given to: (a)
whether the cost is of a type generally recognized as ordinary and
necessary for the operation of the subgrantee or the proper and
efficient performance of the Federal award (2 CFR 200.404)
― Allocable costs. (a) A cost is allocable to a particular Federal award
or other cost objective if the goods or services involved are
chargeable or assignable to that Federal award or cost objective in
accordance with relative benefits received (2 CFR 200.405). 17
UGG Procurement
 UGG promotes full and open competition for the
costs of goods and services, including nonpublic
services, for federal grant programs.
― See Procurement Thresholds for Federal Funds handout
 When procuring goods and/or services from an IU
or another LEA, you must document that UGG
procurement requirements were followed (bids,
quotes, etc.)
― See PDE Guidance for Intergovernmental Agreements
(IGAs) handout
 Because each LEA has unique procurement
procedures, consult with your LEA Solicitor to
ensure that your procedures are being followed
and that your process complies with UGG
requirements.
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Procurement Goods/Supplies *Services & Requirements
Method 200.320 Exempt Items *

Micro-purchase ≤$3,500 ≤$3,500 • Consider price to be

reasonable
(Informal; no quotes
required)
Small Purchase >$3,500 but <$19,700 >$3,500 but • Obtain price/rate quotes
from reasonable number
Procedures <$150,000 of sources (at least 3 per
(Relatively simple and 24 PS 8.807.1) -
informal) documented

Sealed Bids $19,700 or more $150,000 or more • Bids are publicly solicited
• firm fixed price contract
(Formal advertising)
awarded to the
responsible bidder lowest
in price

Competitive Proposals $19,700 or more $150,000 or more • conducted with more than
one source submitting an
(Formal RFPs)
offer
• price is not used as sole
selection factor
• fixed price or cost-
reimbursement type
contract is awarded

Noncompetitive Appropriate only when these circumstances apply: • solicitation from only one
• Available only from a single source source
proposals • must maintain records
(Sole source) • Public exigency or emergency
sufficient to detail the
• Expressly authorized by awarding history of the procurement
19
• After soliciting a number of sources, competition process used
is deemed inadequate • used only when qualifying
circumstances apply
Procurement manual

 Developed by PDE
 Used by all PDE Programs and Offices
 Provide consistent and comprehensive
guidance for grantees regarding
procurement policies and procedures
for all grant funds.

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Additional Procurement Extension

 In the Spring, LEAs received notification

allowing the option of delaying the UGG
procurement requirements for another year
(December 31, 2017).
 If this option was chosen, the LEA must have
documentation they are electing to delay the
UGG requirements.
 Documentation must be made available to
auditor
 If not UGG procurement, LEAs must follow
more restrictive pre-UGG requirements under
A-87

21
Performance Goals
 Every federal grant needs
performance goals (UGG) that meet
the intent of the grant.
 LEAs must report on progress
toward meeting the performance
goals established and approved in
their grants in the Fall of 2017.
― Separate reporting tool

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Performance Goal Report
 Will be released in eGrants
― Opens October 2nd
― Due January 5th
 Reporting period will be October to December.
 LEAs must report progress toward meeting the
goals established in each grant application using
the data sources that are listed in the
performance goals section.
 Based on last approved grant application goals,
yes/no response.
 If performance goals are not met, must explain
why and what will be done differently next year to
help ensure goals are met.
23
PIMS Data Collection

 Title I Staff and Student Participation Data

for the 2016-17 School Year
― Submitted through PIMS
― Collection Window - October 2 through October
17, 2017
― Follow up, review and editing window - October
20 through November 1, 2017
― Correction Window - November 2 through
November 15, 2017
― Accuracy Certification Statement (ACS) due
date - December 6, 2017
24
PIMS Resources

 Title I Staff and Student Participation

collection appears on:
― 2017-18 PIMS Collection Calendar available on
PIMS website: www.education.pa.gov
 Select“Teachers & Administrators” >> PIMS >>
Data Reporting Dates>>Elementary/Secondary
Data Collection Calendar 2017-18
― PIMS Manual: www.education.pa.gov
 Select“Teachers & Administrators” >> PIMS >>
PIMS Manuals (links for Vol. 1 or Vol. 2 as needed)
 PIMS Help Desk:
― 1-800-661-2423
25
Title III PD Survey

 “Long-term and job-embedded PD”

is one of the only statutorily
established mandates within Title
III.
 This requirement pertains to any EL
portions of a Title III award. It is
not a required spending area for
IMM portions of Title III.

26
Title III PD Survey

 16-17 professional development

information is reported in October
2017 via the PIMS upload labeled
“District Fact Template”.
 This data is reported at the LEA
level. This means that if an LEA is a
member of a consortium they will
need to obtain this data from the
program consortium lead.
27
Supplement Not Supplant

 Statutory language eliminated use of 3

presumptions of supplanting for Title I part A
― An LEA used Title I funds to provide services that the
LEA was required to make available under federal, state
or local law.
― An LEA used Title I funds to provide services that the
LEA provided with nonfederal funds in the prior year.
― An LEA used Title I funds to provide services for
children participating in Title I program that the LEA
provided with nonfederal funds to children not
participating in Title I.
 Only applies to Title I.
 Title II, III, and IV supplanting rules stay the
same. 28
Supplement Not Supplant
 At its most basic, supplement not supplant means
that Title I, Part A funds should “add to”
(supplement) not “replace” (supplant) state and
local funds.
 This federal policy objective – to lessen the
compliance burden and to encourage the use of Title
I funds for comprehensive and innovative programs
for Title I students – could provide important context
for SEAs as they revise their SNS oversight processes.
 The ESSA law does not require LEAs to use the same
methodology for each school; instead it only requires
that the LEA demonstrate its methodology does not
deprive a Title I school of state/local funds because
of its Title I status.
 In short, the methodology should be Title I-neutral.
Supplement Not Supplant
NCLB Schoolwide Program School SNS
Test
A school participating in a schoolwide
program shall use funds available to
carry out this section only to
supplement the amount of funds that
would, in the absence of [Title I, Part
A] funds, be made available from non-
Federal sources for the school,
including funds needed to provide
services that are required by law for
children with disabilities and children
with limited English proficiency
[emphasis added]
ESSA Title I SNS Compliance Test
To demonstrate compliance . . . a local
educational agency shall demonstrate
that the methodology used to allocate
State and local funds to each school
receiving assistance under this part
ensures that such school receives all of
the State and local funds it would
otherwise receive if it were not
receiving [Title I, Part A] assistance
[emphasis added]
Supplement Not Supplant
SIMPLE EXAMPLE FROM ED 2015 SWP GUIDANCE ON SNS (p.10)
Assume:
 1 teacher per 22 students ($65,000/teacher)
 1 principal/school ($120,000)
 1 librarian/school ($65,000)
 2 guidance counselors/school ($65,000/guidance counselor)
 $825/student for instructional materials and supplies (including technology)
In a school of 450 students, the school would be expected to receive $2,051,250
in non-Federal resources based on the following calculation:

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
Materials, supplies 450 x $825 $371,250
$2,051,250

To meet the [NCLB schoolwide program SNS test, known as the] supplemental funds
test, an LEA would need to distribute non-Federal resources according to the
assumptions above to all of its schools, regardless of whether a school receives Title
I funds and operates a schoolwide program. This example does not, however,
suggest that non-Federal funds must be used to support the activities in the table
31
above; rather, Title I funds may be used to support any activity identified by the
comprehensive needs assessment and articulated in the comprehensive schoolwide
plan.
Comparability
 General Rule - 1120A (c)
― An LEA may receive Title I Part A funds only if it uses state
and local funds to provide services in Title I schools that,
taken as a whole, are at least comparable to services
provided in non-Title I schools
― If all are Title I schools, all must be “substantially
comparable”
― If only one building per grade span, exempt
 Opens October 2nd
 Assurances due November 15
 Late submission will receive points on Subgrantee
Risk Assessment
32
Comparability
(Teacher/Student Ratio)
 Compare each Title I school to average of all non-
Title I schools (Current Year 17-18)
Or
 Compare higher poverty Title I schools to lower
poverty Title I schools
 Excluded staff
― Bus drivers
― Consultants
― Crossing guards
― Maintenance staff
― Security staff
― Federally paid staff
― Title I like staff 33
Comparability Submission
 STEP 1 – Setting Up
 Go to: pa.ESSAComparability.com
 You may use any browser
– Access is not granted immediately, a DFP Administrator
must approve the account
– Once the DFP Administrator approves the account the
requester receives an email to create their password and
login

 STEP 2 – Group Comparisons

 Districts complete the comparability wizard
– At the last step they print, sign and upload the
compliance document
34
Comparability Submission, cont.

 STEP 3 – Compliance
 Districts must complete Student to Staff Ratio
method
― if you have questions contact your regional coordinator
or glhart@pa.gov.
 Districts manage where they are in the process
― Signed up for access
― Completed the assurance wizard
― LEAs signed and uploaded their assurance documents
 This includes Charters and LEAs that are exempt

35
Maintenance Of Effort (MOE)

 The combined fiscal effort per student or

the aggregate expenditures of the LEA
― from state and local funds
 Collected from Annual Financial Report (AFR)
― from preceding year must not be less than 90%
of the second preceding year
 LEAs are notified September/October
― Letters sent to Superintendent/CEO

36
MOE Consequences
 SEA must reduce amount of allocation in the
exact proportion by which LEA fails to
maintain effort below 90%.
― Calculate using total expenditures and per
pupil
― The amount of the reduction would be the
lesser penalty of the two calculations
― Affects final 2017-18 allocation
 (NEW) LEA is not subject to reductions for
failing to maintain 90% effort for one year
provided it has not failed to meet MOE for
one or more of five immediately preceding
fiscal years

37
MOE Waiver

 USDE Secretary of Education may waive

MOE if:
― Exceptional or uncontrollable circumstances,
such as a natural disaster; or
― (NEW) a change in the organizational structure
of the LEA; or
― A precipitous decline in the financial resources
of the LEA.

38
Reports – Due Dates – 2017-2018

 Comparability
– Submitted electronically
– http://pa.essacomparability.com/Login.aspx
– Opens October 2
– November 15

 Neglected and Delinquent Counts

– Submitted electronically via 3048 form
– https://www.ndprogramspa.com/
– closes December 20
39
 Fiscal Reports

 Final Expenditure  Quarterly Reports

Reports – Submitted online via the
― Submitted online via PDE Web Portal/FAI System
eGrants – PDE website
 Grant Applications – Submitted to the Labor,
 Consolidated
Education Comptroller’s
Application
 Click on Subprojects
Office

― Questions? Contact * Failure to submit on time

your Administrative will stop payments
Technician in DFP

40
Admin and Indirect Costs
 Administrative costs – costs associated with
administering a component of a grant
program
― Administrative costs for non-public equitable
services (reasonable and necessary out of Title I
non-public set-aside)
 Indirect costs – general costs for running an
agency that can be prorated across various
funding sources
― Electricity, rent for office space,
administrative/clerical salaries when they supports
various grants, etc.

41
Time and Effort
 All employees paid with Federal funds
must maintain documentation showing
that their salaries are allocable to a
federal program
 Documentation must be based on records
that accurately reflect the work
performed

42
Time and Effort Documentation
 Semi Annual Certifications
― If an employee works on a
single cost objective or a
pro-rated fixed schedule:
 After the fact
 Account for the total
activity
 Signed by employee OR
supervisor
 Every six months (at least
twice a year)
 Personnel Activity Report
― If an employee works on
multiple cost objectives:
 After the fact
 Account for total activity
 Signed by employee
 Prepared at least monthly
and coincide with one or
more pay periods
43
TITLE I
School Improvement

 Focus and Priority designations

remain for 2017-18
 2018-19 designations will be Targeted
Support Intervention (TSI) and
Comprehensive Support Intervention
(CSI)
 TSI and CSI criteria will be
established according to the State
plan
45
School
Improvement/Intervention

 Comprehensive Support is the most

severe designation and is initially
comprised of two groups of buildings:
― (1) The lowest performing 5% of Title I
schools across the Commonwealth.
― (2) Any High School – Title I AND non-Title I –
with a graduation rate below 67%.

46
School
Improvement/Intervention
 Targeted Support schools based on specific
subgroups that are consistently underperforming
― Title I AND non-Title I schools
― oversight is primarily at the LEA-level
 The four established sub-groups are:
― economically disadvantaged, race, EL, and IEP.
 Those buildings that are originally designated as
“Targeted Support” but fail to achieve established
benchmarks after three years
 It is yet to be determined if non-Title buildings
would move into a Comprehensive Support
designation. 47
Targeted Assistance
model
-vs-
Schoolwide model
Eligible Title I Students -
Targeted Assistance
 Student eligibility:  Automatically Eligible:
― Multiple; ― If student in the
previous 2 years
― Educationally received services in:
related; and  The Head Start
program;
― Objective criteria
 The literacy program;
developed by LEA. and
 NEW: If preschool-  Migrant Children.
grade 2, criteria, ― If the student is
including objective currently eligible under
criteria, established  Neglected or
Delinquent;
by the LEA and
 or Homeless.
supplemented by the
school 49
Targeted Assistance and
Schoolwide
 Title I, Part A funds can support a wide
range of activities to help Title I students
meet state academic standards. This
includes:
― Providing eligible students with a well-
rounded education,
― Instructional supports,
― Non-instructional supports like behavior and
mentoring supports, and social and
emotional learning, and
― Improving school quality.
Spending options in a
Targeted Assistance Program
 A. Expanding learning time for eligible students
 B. Providing early intervening services to eligible
students
 C. Providing eligible students with extra supports
aligned to the school’s regular education program
 D. Providing professional development to teachers,
principals, other school leaders, paraprofessionals
 E. Implementing strategies to increase the involvement
of parents of eligible students
 F. Secondary TA schools may use Title I funds to provide
dual and concurrent enrollment program services to
eligible children.
Spending options in a
Schoolwide Program
 Depending on its needs, a schoolwide program
school could use Title I funds to support:
― A. High quality preschool or full-day kindergarten
― B. Recruitment and retention of effective teachers
― C. Instructional coaches
― D. Increased learning time
― E. Evidence-based strategies to accelerate the
acquisition of content knowledge for English learners
― F. Activities designed to increase access and prepare
students for success in high-quality advance
coursework
Spending options in a
Schoolwide Program (cont.)
 G. Career and technical education programs
 H. Counseling, school based mental health programs,
mentoring services
 I. School climate interventions
 J. Equipment, materials, and training
 K. Response to intervention strategies
 L. Activities that have shown to be effective at increasing
family and community engagement in the school, including
family literacy programs
 M. Devices and software for students to access digital
learning materials
 N. Two-generational approaches that consider the needs of
both children and parents in the design and delivery of
services and programs to support and improve economics,
health, safety, and issues that address intergenerational
poverty.
Interested in going
Schoolwide for 2018-19?
 Complete the “Intent to Plan schoolwide form” and
send it to shegraves@pa.gov
 Form found in our webpage or request one to
shegraves@pa.gov
― If the school has less than 40% poverty (based on free
and reduced numbers) then the narrative, 2nd page of
the intent to plan form, must be completed.
― School Level Plan will be accessible to schools that
send in the intent to plan form.
― Document-Keep agendas and sign-ins to document
the 1) plan development, 2) plan monitoring, and 3)
plan revision process.
 Title I Parent and Family
Engagement
 Required:
– LEA Parent and Family Engagement Policy, update
annually
– School Parent and Family Engagement Policy, update
annually
– Parent/School Compact, updated annually
– Annual Title I Parent Meeting
– Parent Notifications:
• Right-To-Know Letter – Teacher Qualifications (annually)
• Right-To-Know Letter – Not appropriately certified
Teacher (as needed)
– LEAs receiving over $500,000 (Title I) must set aside 1%
for Parent Engagement
• 90% of the 1% must be spent at the building level and
with the approval of the parents
55
LEA/School Parent and Family
Engagement Policies
 Each LEA that receives Title I, Part A funds must
develop a written Parent and Family Engagement
(PFE) policy that establishes the LEA’s
expectations for parental involvement.
― Must be updated annually with parent involvement
― Must be disseminated to all Title I parents annually
 The school level PFE policy must align with the
district policy but be unique to the school.
― Must be updated annually with parent involvement
― Must be disseminated to all Title I parents annually
 Charter Schools must complete both an LEA and
School level policy
56
 Parent and Family
Engagement
 If an LEA receives $500,000 or more in Title I funds,
must use set aside on one of the following:
― Professional development re: parent and family
engagement strategies
― Reaching parents and family at home, in the community
and at school
― Disseminating info on best practices
― Collaborating (or providing subgrants to schools to
collaborate) with others who have a record of success in
improving and increasing involvement
― Activities consistent with Parent and Family Engagement
Policy
 Must be included in the Parent and Family
Engagement Policy 57
Additional Parent Requirements
 Program Information
– How to monitor child’s progress
– How to work with teachers to improve achievement

 Parent Training and Materials, e.g.

– Promoting family literacy
– How to use technology
– Parenting skills

 Train teachers, pupil services personnel and principals

with the assistance of parents
– Value and utility of parent contributions
– How to reach out to and communicate with parents
– How to work with parents as equal partners
– How to implement and coordinate parent programs

 Parents provide input on LEA professional development

– Surveys, professional development team
58
SPAC skits
 State Parent Advisory Council (SPAC) created four skits
― Good example of a Parent/Teacher Conference
― Bad example of a Parent/Teacher Conference
― Good example of a Welcoming Environment
― Bad example of a Welcoming Environment
― Four new skits, not yet available
 Skits can be used to meet the requirement to train staff with
the assistance of parents
― Just need skits, agenda and sign in sheet from staff PD
 Here is the link:
― http://www.spac.k12.pa.us/parentinvolvement.htm

59
Neglected and Delinquent
Youth
 Now requires SEA plans to focus on State-
established outcomes, prioritize
attainment of high school diploma,
reentry for students exiting juvenile
justice or residential programs
 2017 Neglected & Delinquent Leadership
Symposium, Seven Springs Mountain
Resort, Champion, PA, November 13 – 15,
2017
 Pennsylvania's Neglected and Delinquent
Advisory Committee
http://www.ndprogramspa.com/

60
Break time
Educational Stability for
Foster Care Youth
 Key protections formalized under the
Every Student Succeeds Act
 Educational stability protections found
under Title I, Part A
 Places responsibilities on LEAs to ensure
educational stability for foster care youth
 Provisions implemented December 10,
2016
Educational Stability for
Foster Care Youth
 Key protections include:
― Youth have the right to remain in their
current school (“school of origin”) if in
their best interest
― Youth have the right to transportation to
remain in their school of origin
― Youth changing schools must be
immediately enrolled into a new
school and records must be transferred
swiftly.
Title I, Part A Foster Care
Assurances

 LEA assurances found in consolidated

application:
― LEAs develop and implement transportation
plans to ensure transportation is provided,
arranged, and funded for foster youth
― Plans include collaboration with County
Children and Youth Agencies (CCYAs) they
work with frequently
― LEAs designate a foster care point of contact
(POC)
Technical Assistance for LEAs

 PA Statewide Education Point of Contact:

Matthew Butensky
Educational Stability for Foster Care Youth
Center for Schools and Communities
(717) 763-1661 ext.171 │ mbutensky@csc.csiu.org
Foster Care Youth Regional Coordinator Offices

R1: School District of R5: Midwestern IU 4

Philadelphia R6: ARIN IU 28
R2: Berks County IU 14 R7: Luzerne IU 18
R3: Lincoln IU 12 R8: Bucks County IU 22
R4: Allegheny IU 3
2017 Foster Care Regional
Trainings
 “Because You Were There: Working Together for
Educational Stability”
― October 19, PaTTAN, Malvern
― October 26, PaTTAN, Harrisburg
― November 9, PaTTAN, Pittsburgh
 Open to school and child welfare personnel
 Registration found at www.pafostercare.org
 Email pafostercare@csc.csiu.org for more
information or questions
Homeless

 Children Experiencing Homelessness

 PDE has a new RA account for
general questions about Homeless
Education:
― RA-EDHomeless@pa.gov
Title I Non-Public 2017-18
Ombudsman
 PDE Ombudsman ESEA sections 1117(a)(3)(B) and
8501(a)(3)(B)
― Glenn Hart glhart@pa.gov
 Point of contact between PDE, private school
officials, and LEAs
 Responding to and resolving any complaints
regarding equitable services.
― Lynn Calvello lcalvello@pa.gov
 Developing monitoring protocols under title
programs requiring equitable services.
 Monitors to enforce equitable service requirements
under Titles I and VIII
69
Title I Non-Public 2017-18
Consultation
 LEA must provide consultation
 Goal: Provide equitable and effective
programs agreed upon by the LEA and Private
Schools
 The goal of all parties should be to reach an
agreement. Sec. 1117(a)(1) and 8501(c)
 The nonpublic does not need to agree with an
LEA’s decision to have their application
approved by the State, however, the guidance
is clear in that the results following
consultation must be transmitted to the
ombudsman (ESEA sections 1117(b)(1) and 8501(c)(1), (5).)

70
Title I Non-Public 2017-18
Obligation of Funds - Carry over

 Funds must be obligated in the fiscal year

for which the funds are received by the
LEA. (ESEA sections 1117(a)(4)(B) and 8501(a)(4)(B).)
 Exception for extenuating circumstances
 Funds may remain available for the
provision of equitable services under the
respective program during the subsequent
school year.
 The LEA must also consult with appropriate
private school officials. (ESEA sections 1117(b) and
8501(c).)

71
Non-public Transferability

 Title I equitable share is based off the total amount of

the Title I allocation prior to the transfer of funds. ESSA
Sec. 1117(a)(4).
 If you transfer into Title I, Part A, do you include the
transferred amounts in the equitable services
calculation?
 Conflicting guidance on this issue, but NO!
 Sec. 1117(a)(4) says equitable services calculated before
any transfers. Sec. 5013 says follows rules under which
program is transferred to.
 LEA must discuss with the nonpublic during consultation
 LEA has the final say on transferability decision
Title I Non-Public 2017-18
Complaint Procedures

 Complaint Process for Participation of Private

School Children – Time Limit (ESEA section
8503.)
 The timeframe that PDE has for responding to a
complaint from parents, teachers, or other
individuals concerning violations of ESEA section
8501 regarding the participation by private
school children and teachers is 45 days. In
addition, the Secretary must investigate and
resolve an appeal of SEA’s resolution of a
complaint within 90 days.

73
TITLE III
Title III Allocations

 Title III allocations are derived using data

from the previous school year.
 October 2017 PIMS upload data will be
used to inform 2018-19 Title III awards.
 Title III allocations are derived using EL
(English Learner) and IMM (Immigrant)
data.

75
Title III Allocations

 EL headcounts are used in a direct

manner and applied against a state-wide
uniform per pupil.
 IMM allocations are based off of an influx
of immigrants and as such an allocation is
not always derived even when an IMM
count is provided.

76
Title III Allocations

 Nonpublic headcounts for both EL and IMM

are also required.
 The Nonpublic headcount for both
categories is pulled from the entire
population, but only from nonpublic
schools within a school district’s
geographic boundary.

77
Title III Allocations

 For assistance with the identification of

EL and IMM students at both the public
and nonpublic level please to contact Bob
Measel (romeasel@pa.gov and/or 717-
783-6595) or Eugenia Krimmel
(ekrimmel@pa.gov and/or 717-787-5482).

78
Title III Allocations

 The PIMS upload window is from October

2nd through October 17th. A correction
window follows in November.
 The public EL and IMM counts are
reported in the “October Student
Snapshot” and the nonpublic EL and IMM
counts are reported in the “District Fact
Template”.

79
Title III ESSA Update

 Under NCLB two statutory-based

requirements existed.
 #1. The use of Title III funds for
supplemental language instruction.
 #2. The use of Title III EL funds (in part)
for professional development.

80
Title III ESSA Update

 ESSA has added a new statute-based

requirement:
 “To provide and implement other
effective activities and strategies that
enhance or supplement language
instruction educational programs for
English Learners, which –”
 (a) “shall include parent, family, and
community engagement activities; and”
 (b) “may include strategies that serve to
coordinate and align related programs”

81
Title III ESSA Update

 How is this new area to be addressed?

 #1. The first step is a needs assessment.
What kind of parent, family, and/or
community engagement activities are
needed or would be beneficial?

82
Title III ESSA Update

 #2. The supplement not supplant (SNS)

analysis for Title III expenditures and
activities is the same under ESSA as it was
under NCLB. An LEA must ensure that
when activities are potentially
established via the needs assessment that
those activities are not required under
state, local, or other federal laws, in
particular Title I or any relevant Civil
Rights legislation.

83
Title III ESSA Update

 #3. Make sure that potential activities,

once established via needs assessment
and once passing SNS analysis, are
evidence-based.
 #4. The established activities should thus
tie back to the intent of the legislation
which mandates supplemental EL support
and also now includes Parent and
Community Engagement activities.

84
Title III Accountability

 NCLB: Required adoption of English

language proficiency (ELP) under Title III.
 ESSA: Adoption of ELPS is now required
under Title I, section 1111(b)(1)(F).
 NCLB: Required States to establish a
definition of proficiency.
 ESSA: Requires definition of proficiency
to include multiple proficiency levels.

85
TITLES IV AND V
 Title IV, Part A
 Student
Support and Academic
Enrichment Grants: Section 4101
― ESSA created a new grant program in Title IV,
Part A to:
― Provide all students access to a well-rounded
education
― Improve school conditions for student
learning, and
― Improve the use of technology to improve
the academic achievement and digital
literacy of all students

87
 Title IV, Part A Continued

 LEA Uses of Funds: Sections 4106(2), 4107-4109

― LEAs may reserve up to 2% for direct administrative
costs
― LEAs that receive $30,000 or more must use:
 20% of allocation for activities to support well-
rounded educational opportunities
 20% of allocation for activities to support safe and
healthy students
 Some of allocation for activities to support the
effective use of technology

88
 Title IV, Part A continued
 Activities to support well-rounded educational opportunities
― college and career guidance and counseling programs,
― music and arts programs, and
― STEM subjects.
 Activities to support safe and healthy students
― drug and violence prevention,
― school-based mental health services,
― supporting a healthy, active lifestyle, and
― preventing bullying and harassment.
 Activities to support the effective use of technology
― providing school personnel with professional learning tools,
― building technological capacity and infrastructure,
― innovative strategies for delivering specialized or rigorous academic
courses through the use of technology
89
Title IV, Part A continued
 Spending on purchasing technology infrastructure is
limited to 15% of the portion of the funds budgeted for
Effective use of technology, regardless of total
allocation.
― Technology infrastructure – devices, equipment, and
software applications to address readiness shortfalls,
blended learning technology software platforms, digital
instructional resources, initial PD activities, and one time
IT purchases
 15% limit on technology infrastructure applies to the Non-
pub share if the funds are spent under Effective use of
technology

90
Transferability
 Title V authorizes transferability
― Allows LEA to transfer all funds under Title IIA, IVA, or
section 4204c3 between those provisions and into but
not out of Title I parts A, C, or D, Title IIIA
― No cap, unlimited
― Can’t transfer out of Title I
 LEA has final transferability decision after
consultation with Non-publics
 In regards to Title II and Title IV, LEAs must
calculate equitable service shares based on the
total amount of funds available under a
program after transfers
91
2017-18 Monitoring
 All Priority schools will be monitored for
Priority status at the school level
 All Focus schools not monitored in 2016-17
will be monitored for Focus status at the
school level
 All LEAs and Charter Schools that fall
under the “high risk” and “medium risk”
category, based on DFP’s Subgrantee Risk
Assessment, will be monitored this year
 Cycle 2 LEAs from four year cycle will be
monitored
92
Subgrantee Risk Assessment

 Divided all LEAs Schools into 3 categories:

― “high risk”
― “medium risk”
― “low risk”
 Not a federal designation just a category
based on the components of our
Subgrantee Risk Assessment

93
Subgrantee Risk Assessment Factors

 Factors included in DFP’s Subgrantee Risk

Assessment:
― Monitoring Findings
 Fiscal
 Programmatic
 Excessive (five or more)

― Timely submission of required documents

 PIMS
 Comparability
 Quarterlies
 FERs
 Consolidated Application/Funding Adjustments/Amendments
 Monitoring Corrective Action
94
Subgrantee Risk Assessment
Factors, cont.
 Excessive Carryover
 Suspension of payments for any reason
 Amount of Federal Funds allocated
 New Entity (Charter School/LEA)
 Federal funds returned to PDE
 Not meeting MOE

95
Top 10 Monitoring Findings
of 2016-17

96
Top Ten Monitoring Findings of
2016-17

10. Parent Involvement - Title I schools have

coordinated and integrated parent
involvement programs and activities with
other programs (Head Start, public
preschools, parent resource centers, early
childhood programs), to encourage and
support parents in more fully participating
in the education of their children, and
parents have participated in the
development of the Transition Plan. (39)

97
Top Ten Monitoring Findings of
2016-17

9. Parent Involvement - Title I schools

conducted an annual evaluation of the
effectiveness of school parental involvement
activities. (40)

98
Top Ten Monitoring Findings of
2016-17
8. Performance Goal Reporting Verification
- LEA has documentation/data to support
the status of goals reported in the
Performance Goal Report. (44)
7. Parent Involvement - Schools receiving
Title I funds have a written school-parent
compact and evidence that it has been
updated annually and has been distributed
to parents. (44)

99
Monitoring Findings of
2016-17
6. Parent Involvement - Title I schools
educate instructional staff, with parental
assistance, in the value and utility of
contributions of parents, how to reach out
to and communicate with and work with
parents as equal partners, implement and
coordinate parent programs and build ties
between parents and schools. (49)

100
Top Ten Monitoring Findings of
2016-17

5. Fiscal Requirements - The LEA and Title I

school maintain semi-annual certifications
for all employees funded 100% from a single
cost objective (52)
4. Schoolwide Programs – Updated
Schoolwide Plan (65)

101
Top Ten Monitoring Findings of
2016-17

3. Fiscal Requirements - The LEA and Title I

School maintain a building level budget
demonstrating appropriate Title I
expenditures (77)
2. School Parent Involvement Policy -
Schools receiving Title I funds have a written
Parent Involvement Policy/Plan aligned with
the District policy and evidence that it is
updated annually and has been distributed
to parents (114)
102
Top Ten Monitoring Findings of
2016-17

1. Appropriately State Certified - Parents

(in Title I schools only) are notified if their
child is assigned to or being taught for four
or more consecutive weeks by a teacher
who is not appropriately state certified in a
core academic subject. (114)

103
DFP Contacts
Fax: 717.787.8634

Division Administration
Susan McCrone 717.783.9161 smccrone@pa.gov
Alison Mosher 717.783.9161 amosher@pa.gov
Kelly Gallatin 717.783.3403 kgallatin@pa.gov

Team 1 (IUs 2, 26)

Erin Derr 717.787.7815 jder@pa.gov
Lynn Calvello 717.783.9164 lcalvello@pa.gov
Karen Trissler 717.787.7278 ktrissler@pa.gov

Team 2 (IUs 1, 3, 8, 16, 11, 24)

Jesse Fry 717.783.6829 jefry@pa.gov
Erin Oberdorf 717.783.1330 eoberdorf@pa.gov
Phil Cooper 717.783.6907 phcooper@pa.gov
Lennette Wilson 717787.7372 lwilson@pa.gov

104
DFP Contacts
Team 3 (IUs 10, 17, 18, 19, 4, 7, 27, 28)
Don McCrone 717.783.6902 dmccrone@pa.gov
Tucker McKissick 717.783.3381 tmckissick@pa.gov
Glenn Hart 717.783.6901 glhart@pa.gov
Tracy Rapisarda 717.787.7177 trapisarda@pa.gov
Melanie Novak 717.787.8632 melnovak@pa.gov
Team 4 (IUs 22, 23, 25, 12, 13, 15)
Cindy Rhoads 717.783.9167 crhoads@pa.gov
vacant 717.783.6829
vacant 717.783.7777
Angie McGeehan 717.783.6908 amcgeehan@pa.gov
Team 5 (IUs 14, 20, 21, 29, 5, 6, 9)
Maria Garcia 717.783.6904 mariagarci@pa.gov
Ken Krawchuk 717.787.7135 kkrawchuk@pa.gov
Reba Kansiewicz 717.783.6903 rkansiewic@pa.gov
Sheri Graves 717.787.8631 shegraves@pa.gov 105
 Program Contacts
 Title I of ESSA

― Title I, Part A All RCs

― Title I, Part D Ken Krawchuk

― Title I, Neglected Ken Krawchuk

― Title I, Homeless/Foster Maria Garcia

 Title II, Part A Don McCrone

 Title III – EL Fiscal Jesse Fry

 Title IV, Part A Erin Oberdorf/Cindy Rhoads

 Rural Education Achievement Program Tucker McKissick

 Monitoring Erin Derr

 Parent and Family Engagement Erin Derr/Ken Krawchuk

 Nonpublic Schools Lynn Calvello/Glenn Hart

 Schoolwide Programs Maria Garcia

 School Improvement Grant (SIG) Erin Oberdorf

 School Intervention Grant Jesse Fry

 Ed-Flex Waivers Don McCrone

 Community Eligibility Program Jesse Fry

106
 Uniform Grants Guidance Cindy Rhoads
ISP/PAFPC Conference
 Improving School Performance Conference–
Sheraton Station Square, Pittsburgh
– January 28th – January 31st
– If interested in presenting the Call for Session Proposals
can be found on the PAFPC website at:
www.pafpc.org/.
– PDE pays for 2 presenters per team.
 PA Federal Programs Conference – Hershey,
PA
― April 29th – May 2nd

107
Trainings/Conferences
 November 13 - 15, 2017 - Neglected and Delinquent
Symposium, Seven Springs, PA
 January 28 – 31, 2018 – Improving School
Performance Conference (ISP), Pittsburgh, PA
 February 8 – 11, 2018 – National Association of State
Title I Directors (NASTID), Philadelphia, PA
 March 18 – 21, 2018 – National Association of
Federal Education Program Administration
(NAFEPA), Washington, DC
 April 29 – May 2, 2018 - 2018 Annual Pennsylvania
Association of Federal Program Coordinators
Conference (PAFPC), Hershey, PA

108
QUESTIONS??