Renaissance Mayflower Hotel
Washington, D.C.
November 3, 1997
PARTICIPANTS:
WENDY JO NEW
Education Program Specialist,
Title I Programs, Office
of Elementary
and Secondary Education
Department of Education
SANDY BROWN
Title I Programs, Office
of Elementary
and Secondary Education
Department of Education
KAY RIGLING
Title I Program Attorney
Office of General Counsel
Department of Education
* * * * *
Table of Contents:
- Introduction
(MS. NEW)
- Overview
- State To District (LEA) Allocations (MR. BROWN)
- Overview
- Allocations to Schools within Districts (MS. NEW)
- Question #1
- Can you talk about how the money must be used in the school
more specifically?
- Questions #2
- Can schoolwide program money be used to pay for the salary
of a first-grade teacher, or does that have to be a supplemental
program?
- Questions #3
- Do you require any kind of assessment as to how the money is
spent?
- Questions #4
- If we're a school that is within an LEA, are there forms that
we have to fill out, Title I applications, or has that already
been done by the school district?
- Questions #5
- How much money are we talking about?
- Questions #6
- Are the monies supposed to be given in one lump sum, or are
they distributed on a "Mother, may I?"
- Questions #7
- Our district would like to call us "a nonpublic school,"
and insists that we count our population based on where that child
would reside in the district, if they were going to one of the
regular or board of education schools. Is that allowed?
- Questions #8
- If we are a first-year charter school right now, when do they
apply, how do they get the application? Are they on some kind
of mailing list to make sure they will get an application? When
is the deadline to apply, and when does the money come?
- Questions #9
- Are Title I funds restricted to children, aged 5 to 17?
- Questions #10
- If we're an LEA, and we're drawing, say, for the entire city,
is the entire city's population the basis of your count, or is
it the actual school that you're enrolled in?
- Questions #11
- If the child leaves the district, does the money go to another
district?
- Questions #12
- If you are not an LEA, but you're not sponsored by a school
district, you're sponsored by an institution of higher ed, like
a community college, how do you figure out this whole thing?
- Questions #13
- Do Title I funds have to come through the state?
- Questions #14
- Do you have a telephone number to reach you?
P R O C E E D I N
G S
Introduction
MS. NEW: Good afternoon.
I'm Wendy Jo New,
and I work on Title I policy at the U.S. Department of Education.
Next to me is Sandy Brown, who also works on Title I policy,
and primarily focuses on allocation. And next to Sandy is Kay
Rigling, who is our Title I program attorney in our Office
of the General Counsel.
Today's session is on Title
I, primarily Title I allocations, and its relationship to charter
schools.
I'm going to give a fairly
broader review of what this session will focus upon, and then,
turn it over to Sandy to explain how the federal level of money
gets to the states, and the states' money, in turn, gets to districts.
And then, I'll pick it up from districts to schools.
Different state charter school
legislation is drafted differently. Some states designate charter
schools as Local Educational Agencies (LEAs), which are districts
unto themselves. In other states charter schools are within a
district. So there are two main, different issues that we're
going to be dealing with, with respect to allocations and Title
I.
Title I, overall, for those
of you who don't know, is the largest federally-funded
elementary and secondary education program that the government
funds. At this point, there are about $7.2 billion in Title I
funds. I'm going to make reference to a larger document, which
is our Title I guidance on allocations.
I'm going to turn it to Sandy
right now, who's going to deal with a state to district. He's
going to give a brief overview of how the federal government at
least gets funds down to the state and then the state is able
to do allocations.
State To District (LEA)
Allocations
MR. BROWN: Basically, the
Department allocates funds to counties based on essentially census
poverty data adjusted for each state's per pupil expenditure.
Once we figure out county allocations, Title I county allocations,
then the state, in turn, suballocates the county amounts to school
districts within each county.
Now, as I indicated, we primarily
use census poverty data plus the state's per pupil expenditure
to figure out allocations to the county level. The state, when
it makes its allocations, has a little bit more flexibility. It
may use best available data on poverty to suballocate funds to
school districts.
The poverty measure, as I
say, is the choice of the state, and whatever they choose has
to be used consistently across the state. Based on these poverty
data or the poverty measures that the state selects--it could
be census, it could be AFDC, it could be free and reduced price
lunch--it then allocates funds to school districts that are eligible.
To be eligible for basic
grants, a school district including a charter school's district,
has to have at least 10 formula children -- poor kids -- and the
number of those children, poor children, has to equal at least
2 percent of the school district's 5 to 17 population. That's
our basic grants.
I might add, that's an "and."
It has to meet both criteria. For example, if you have 12 formula
kids apply, and the number of formula kids is less than 2 percent
of the total population (the total 5 to 17 population), the school
district wouldn't qualify.
For concentration grants,
which is the other funding formula, those funds flow to school
districts that have at least 6,500 poor kids, or formula kids,
or the number of those formula children equals at least 15 percent
of the total 5 to 17 population in the school district. That's
an either/or. So if you don't qualify on one, say, the 6,500,
which would be the case of most charter schools, but you meet
the 15 percent threshold, you qualify.
As I say, there is some flexibility
in the use of data. One of the things that the guidance attempts
to indicate is some of the areas of flexibility that a state does
have. In many instances, the poverty measure that the state has
available to it is usually collected, say, in October of the prior
school year. For example, when the state announces allocations
for a regular school district for the '97, '98 school year, it
often depends on data collected in, say, October of the prior
school year.
In many instances, charter
schools, which aren't in existence at that particular time, the
state has the option of collecting the same data but on a different
date. Say, for example, the charter school may have data in May
of the prior school year, they could use that, as long as it's
the same database.
In other instances, the state
may use a poverty measure such as census poverty, which is not
available to charter schools. In a situation like that, the state
may equate census data with a known poverty source that's available
in the charter schools, such as free and reduced price lunch in
order to derive a data source that's consistent across the state.
I see a lot of you taking notes. We try to address some of these
options in the guidance here.
I think one of the most important
issues -- the primary issue that seems to be facing us -- concerns
timing. And in many instances, the problem occurs when the data
are not available for charter schools at the time that the state
has to determine allocations for school districts. And we encourage
state educational agencies to be as flexible as possible, with
respect to deadlines for submitting data.
The Department's position
at this point is that it is still reasonable. The SEA may indeed
establish a reasonable cutoff point in which LEAs must submit
the data necessary to make the Title I allocations. That being
said, we have tried to, at least, urge the state to be as flexible
as possible in addressing this issue. For example, the state
may reserve an amount from the state's Title I allocation in advance
that it believes is sufficient to fund eligible charter school
LEAs.
We also make available, or
allow for states to distribute available reallocation funds to
eligible charter schools, if the regular data are not available.
And also, we enabled state educational agencies to use their
administrative funds to make funds available to charter school
districts if the data are not available.
One of the problems is getting
over that first year, that first-year hump, because a lot of times
school districts -- the charter schools -- don't have the data
available, and the state is obligated to, at least, begin the
allocation process so that LEAs can plan and hire staff for the
coming school year.
Allocations to Schools
within Districts
MS. NEW: The other part
of this is for schools that are within school districts. I'm going
to go over pretty much district to school ranking and how distribution
of funds go under Title I. I will not address every option that's
provided to districts, that is addressed in our thicker document,
and our regulations. We won't have time. But I'm going to give
a fairly detailed overview of this, because we've received many
questions over the phone from different charter schools in states
that designate charter schools as schools within a district.
The districts do have --
within fairly tight parameters -- they do have a lot of flexibility.
Which depending on what options the districts choose to use,
might have a charter school even though it might be a high-poverty
school, not necessarily get Title I funds. I'm going to raise
it at the front, but I'll go through how it works.
Title I is not an entitlement
program. It's a formula grant program that makes assistance available
to those high poverty schools. And, in turn, those schools provide
services to those students who are most at risk of failing to
meet high standards.
So when it comes to the child
level of who's actually served, it has nothing to do with poverty.
It's the student's achievement. But to get the money down to
the school level and down to the schools, poverty is a factor.
So let me start from the
beginning. A district receives an allocation from a state, which
Sandy gave the overview on. It then is permitted by law to use
four different poverty factors, or a combination of any of them.
One is, free and reduced price lunch eligibility; another
is eligibility for Medicaid; another is AFDC data;
another is census, or a combination of any of those.
Most tend to use free and
reduced price lunch data; many use AFDC, and some use a combo.
The other two, if at all, we've not heard of them, census especially.
So I'll lead the discussion and use the example of free and reduced
price lunch just for discussion purposes, but those options are
available to districts.
Whatever the district chooses
to use, it has to use for everyone, all the schools including
charter schools. Timing, we know, is a dilemma. I'll get at
that in a few minutes. What the district has to do is rank all
of its schools in the district by poverty, from high to low.
From that, it determines what the district-wide average of poverty
is, or it could choose 35 percent. The law allows a 35 percent
poverty cut. Whichever option the district chooses -- 35 percent
or district-wide average poverty, those schools that have a poverty
rate at or above that are eligible for Title I. It doesn't mean
they're going to get Title I because they're more steps involved,
but at least they've been deemed eligible.
Once that step is taken,
the district then, with its allocation that it has, starts with
the very top-ranked school. And the way money flows down to schools
now, is different than in the past. The district is required
to provide an amount per poverty student in the school, and it
has to go in rank order of poverty, starting with the highest-ranked
school. And then I'll get to some options later. But it is based
on the number of poor children.
It used to be -- for those
of you who are in districts that have had Title I, or you worked
with Title I in the past, or Chapter I as it was before -- that
the district could distribute money based on the numbers and needs
of the children in the school. It wasn't based on a formula per
child.
It is now based on the number
of poor children in the school. So with that said, the district
would start with the highest-ranked school and distribute an amount
per poor child, starting with the top-ranked school and work its
way down. It can't skip. There are skipping provisions, but
there are conditions attached.
I'm not going to go into
that for this discussion, assume they haven't exercised the skipping
provision because it's sort of hard to do. They can work their
way down, but they must, if they're going to serve any schools
below the 75 percent rate of poverty, they must at least serve
every school above that before it can even go lower.
That's a marked difference
from past law. And it also was an attempt with the new legislation
that took effect in July of '95, to better target the monies to
the most impoverished area regardless of the grade levels that
are served, at least at that very high level.
So whether you're a middle
school, high school, elementary school, if you're in that range
and the district is able to get money down, at least at the 75
percent mark, your school must receive money before the district
could go down any further.
Once the district has been
able to do that, and it might run out of money before it gets
there, or it might choose to focus all of its money -- Title I
money -- on the very highest schools. And it can set that wherever
it wants. There's nothing that requires a district to serve every
eligible school, but there are some requirements on how it gets
down to the lower-ranked schools.
Once it's able to get down
to 75 percent, the district could, if it wants to, just continue
straight on down that ranking until the money runs out, or until
it chooses not to give any more. Or it could exercise a grade
span grouping option, where it can then, once it got down to 75
percent, break the district into grade spans, the way the district
naturally is set up. For example, elementary, middle, high.
And focus all the rest of its money that's available on the elementary
grade school, for example, the elementary grade span.
Within that grade span, it
still has to go in rank order, unless it uses the skipping provisions. But it could choose to do that and not necessarily
serve the middle school grade span and high school grade span,
even though there might be schools with high poverty in those
grade spans. It does have those options. So you could see where,
even though you might fall into the initial pool of eligible,
you're not necessarily going to get -- just like any other school
in the district -- Title I funding.
If you, though, are at a
higher rank, let's say, above 75 percent, and you're a charter
school, and you have the data available at the time the district
was looking at everyone else's data, you are to be treated --
and we state this very clearly -- you must be treated by the district
as any other public school in the district. So just because you're
a charter school, doesn't mean the district could bypass you,
assuming you've had the data that's available and the district
was able to include you at that time.
Now, I'm going to get to
the timing issue. There are several, other special rules that
I won't go into now because they're, "If you do this, then
the district doesn't assist with us." Well, that's the basic
way funds could go down into Title I. If, though, when districts
figure out their allocations and which schools are going to get
services, the charter school didn't have an enrollment yet, or
you're just opening up, or you didn't have the data, we've provided
in the guidance some options to consider.
One is, and it would be in
the ideal world, the state and district have made clear to everyone
in the state and district of what the district does in terms of
allocation, when it needs the data, what data it uses. We know
that's not the instance, based on the calls we get, and also the
state of where charter schools are. Some states have brand new
legislation. Other districts haven't had a charter school yet
open up.
Quite often, a charter school
doesn't know, for example, the free and reduced price lunch data
because it doesn't have an enrollment, or know who's going to
come to school the coming year until maybe in May. And that's
an early date. Yet, the district, when it determines which schools
are going to get the Title I funding and how much those schools
will get, tend to do that earlier in the year for lots of other
reasons.
The main one is for planning,
so that schools know that, one, they're going to get Title I funds
and, in general, how much they're going to get so they could design
their program and get a planning process underway.
Another factor which, you
know, in a practical world is probably the bigger factor, is union
contracts and the way those are set up for teacher hiring, restaffing,
switching staff and so on. And those, in many places, in March,
that determination needs to be made, or everyone gets a pink slip,
so that the district is covered legally, and then rehire staff.
But for staffing purposes,
Title I allocations are made known to schools, and then the process
is done between March, April, May, so schools can plan. Also
equipment, supplies and everything else need to be ordered, including professional development. It's a huge undertaking,
and Title I is a supplement to the regular school program. So
this is going on at the time the schools are also looking at everything
else that's going on.
In the instance where a charter
school knows its enrollment may be in May, yet the district used
October or December data free and reduced price lunch for the
prior year, and we state this, the district may use a later date
of data for the charter school, as long as it's the same or comparable
data.
So free and reduced price
lunch is used, and they used an October date, but the charter
school knows it was eligible for free and reduced price lunch
in comparison to its total population, the district could use
that, and plug the charter school in where it fits in the ranking.
And then, make an allocation accordingly.
We do know because charter
schools don't even know this oftentimes until September when school's
starting, or even after school is starting. And there is the
dilemma that the district has, they've already made their allocations.
The district is running, the new schools are functioning, and
the other schools got the allocations that the charter schools
didn't know.
We've also provided some
other options -- I should step back one. There's another option
at the later date, like May. If free and reduced price lunch
isn't a program that the charter school is going to have, it's
the eligibility for free and reduced price lunch that is the poverty
factor. So the school could do a survey of its families to determine
who would be eligible for free and reduced price lunch based on
the USDA guidelines, and plug
that in, and that would be deemed to be the same data.
There are also other poverty
factors that might be available for it that the charter school
has that isn't free and reduced price lunch, and it can be equated
to the free and reduced price lunch. And we give some examples
of how to do that. So there are ways to do that if the data is
available.
For those interested, and
we'll get to the September-October now, where it's not available,
and the district had already distributed its allocations, we give
a few other options that the district may consider.
One of those is if you're
eligible and at the ranking where you're going to get funding,
depending on how the district did its ranking -- its selection
of schools -- the district could use carryover funds, if
it has any. Carryover funds are those funds that, from the prior
year, out of Title I funds, that for some reason, were not expended
as were thought to happen the prior year.
There's a 15 percent limitation
that the district could carryover of Title I funds, most tend
to have carryover funds. That's one option the district may use
to, at least, for the first year, get money down to the charter
school, that's to be the participating school. The next year it's
plugged in with all the other schools because it will know, it's
treated just like all the other schools have.
Another, if there is no carryover
money, or even the carryover was already obligated to other schools
(because the charter school didn't have data in time), a charter
school or a district on behalf of the charter school could apply
to the state for state Title I reallocation monies. And
those are the extra monies at the state level that were not used
by different districts throughout the state. You could apply
for those, and the state may give those.
And the other is for the
district. If it has a good guesstimate that a charter school is
going to be opening -- or more than one -- in September, then
they have an idea of how many, what the poverty rate might be,
how many poor kids are going to be in there, and where probably
it will rank. If it's going to be a Title I school, it could
hold a portion of the Title I allocation when it does its allocations
for everyone else.
And when the school does
open, and they determine what the real poverty is, then assuming
it's eligible to be a participating school, from that held money,
provide to that charter school a Title I amount. It's just done
at a later time.
So there are different ways
it could be done. That's it in a nutshell of how district fundings
are gotten. Now, remember the district does have a lot of options
available to it, and every place will have its own specific situation.
We do recognize that in many places the complete explanation
or word hasn't gotten down to different schools of how Title I
allocations work, and what Title I even is.
There are others where the
district may have done their allocation process perfectly correctly,
yet the full understanding of how allocations are done isn't yet
known. So this is an attempt to get at those.
We do recognize the fact
-- and the last audience was much more vocal from the very start
-- this is a strongly encouraged option available.
We do, first, state that
states and/or districts must treat charter schools as LEAs or
schools, whatever they have to be, just like they do others.
It's with respect to the timing and when allocations are made
for the first year of operation of charter schools that becomes
the problem. And at this point, it's not guidance that's written
in mandatory terms because of the way the statute -- the Title
I statute -- currently is doesn't provide the authority to mandate
this.
Question #1
PARTICIPANT: Can you
talk about how the money must be used in the school more specifically?
Our school district has a very complicated booklet on the requirements
used in the system, computer system, about how budgets are to
be allocated and whatnot. How does the money have to be used?
MS. NEW: Well, I'll address
this in two levels. There are -- under Title I -- schools are
either targeted assistance schools, or they're schoolwide programs. I'll start with targeted assistance schools.
Targeted assistance schools
are those that use the funds, supplemental funds, to provide supplemental
services to those students that the school has identified to be
most at risk of failing to meet the high standards. So they are
very specifically identified Title I participants, only those
students are served with those resources.
How those resources are used
and what strategies are used, there is no specific requirement.
The school, depending on the needs of the children and why they
were selected, designs strategies that will best meet the needs
of those students to improve their achievement. There's nothing
that requires the school, for example -- and we've heard this
a lot -- to only focus on reading, or use a particular reading
strategy. There's nothing in the federal law that has any requirements.
The law, in fact, is structured
even much more clearly than it had been in the past. It provides
a lot of authority and responsibility at the school level to determine
what strategies would be best to meet the needs of those Title
I participants in the school, to help them to meet the high standards
that the states are establishing for all the children.
Schoolwide programs are
programs that for schools that have 50 percent poverty or more,
they have the option to become a school wide program. Now, first
they have to be a Title I participating school and getting Title
I money, that's a given. They don't have to become a school wide
program, but that opportunity is in the law.
And what it allows schools
to do is to use their Title I resources, and most every other
federal education program resource in that school, if it chooses
to, in combination with its local and state resources for free
public education, to completely upgrade the effectiveness of the
entire school program, with the ultimate result being of improving
the achievement of our lowest achieving target populations that
are in that school.
So it's a different strategy,
it's a different approach to using Title I, but with the ultimate
goal being the same. The rationale behind that was -- it started
a long time ago that poverty rate was even higher, was that where
there's a very high concentration of poverty, the likelihood of
a great degree of educational need is also in that school, or
environment. Not a one-for-one match poor kid to poor achievement,
but in total, there is a great deal of education needed, most
cases, in high poverty schools.
So instead of, let's say,
in a school where 80 percent of the kids are identified to be
Title I participants if it were targeted, and providing them supplemental
help at some time during the day or after school, or the weekend,
when the entire school really needs to be improved, the idea was
to, why not, overhaul the school and build in every strategy that's
necessary to help all kids, including those low-achieving kids.
Question #2
PARTICIPANT: Can school
wide program money be used to pay for the salary of a first-grade
teacher, or does that have to be a supplemental program?
MS. NEW: The money is in
a total pot with whatever money they chose to combine. There is
no requirement to track that funding to particular children or
to prove that its being used, for example, for supplemental reading
help. It's money that's used in conjunction with local and state
funding to run the school. Whatever that total pot buys: teachers,
equipment, supplies, professional development, parental involvement
activities, you name it. Title I is part of that pot. That's
it in a nutshell.
What strategies they employ,
what reading assistance, what science curriculum --that's purely
up to the school, in consultation with the school district and
other things that might be parameters within a state.
Question #3
PARTICIPANT: Do you require
any kind of assessment as to how the money is spent? In other
words, you said there was a lot of flexibility, that the money
can be used for teachers' salaries or whatever. Do you require
some feedback from the districts as to how they used it, and whether
student achievement was really boosted as a result of your money?
MS. NEW: In Title I, there
are fairly lengthy compliance standards and assessment provisions.
With respect to report of how or what they spent the money on,
we don't do an assessment of that. In terms of Title I requirements,
it's not a requirement.
However, standards and assessment
development is.One of the annual requirements, in terms of Title
I, is that schools have to look at student performance based on
the state assessment system, with respect to performance on measuring
how students are doing in terms of the standards that the states
have developed. And states have to look at the districts in terms
of how their schools are doing.
I'm not going to get into
the details of the assessment issue, it's a huge issue. It's very
different than in the past, but there are assessment, accountability,
and program improvement requirements in Title I.
PARTICIPANT: So the money
is tied back?
MS. NEW: The ultimate goal
is to have participants achieve, and make progress. Now the way
the law is structured, it takes a look at the school: how is the
school enabling students to meet those high standards.
And it also takes a look
at the districts: how is the state enabling districts to enable
the schools to enable the kids to meet the standards.
PARTICIPANT: Do they get
the money if they don't meet it?
MS. NEW: They still get
their money. The formula is based on poverty. In fact, if they
need it, all the more to get the money. But it's based on formula.
So whether they're really improving, or they really need a lot
of improvement, the money goes.
Question?
Question #4
PARTICIPANT: If we're
a school that is within an LEA, are there forms that we have to
fill out, Title I applications, or has that already been done
by the school district?
MS. NEW: The question was,
for those who can't hear, whether a school within a district has
specific application forms to complete for the district, to provide
certain statistics. It doesn't exactly work that way. There might
be -- the district needs information. It needs enrollment, and
it needs poverty data associated with that enrollment. How the
district gets that information varies, I think, from district
to district across the country, or at least from state to state.
In the Title I law, there's
not a school application for Title I funds. The district is the
subgrantee, and is required to then distribute money to schools.
So however your district handles that, would be what you also,
just like any school, would want to provide information through.
The mechanisms vary.
Question #5
PARTICIPANT: How much
money are we talking about? In Washington, D.C., for example,
what amount comes from Title I?
MS. NEW: Well, let's start
with D.C. D.C. is unique, in that it has a very specific formula
for providing Title I funding to charter schools. It's different
than other states, it was written specifically for charter schools
in D.C. In general, it's unique. We were asked this in the last
session as well.
Overall, we know how much
money there is in total for Title I. And we know how many formula
children -- the count of that for the Department to be able to
make allocations to counties. And then the state, in turn, takes
that money and distributes it to districts. That's one number.
So you divide into the total and get a number. Which comes out
to what? What did you say, a thousand?
MR. BROWN: A little less
than a thousand.
MS. NEW: But put that number
aside. That's one number for that calculation. It varies very
greatly from district to district, what an amount per child is,
and then from school to school. There isn't a particular amount
per child that would be a true number that you could work with
to even make some decisions. You might know within your district
about what they're giving per child. Or you might know, within
your state, about what they're giving per child in the district,
but it doesn't necessarily translate down to the school level
that way.
It's fairly complex, because
there are so many different factors that are used in carrying
out the formula, to a certain extent. And then once districts
distribute money to schools, there are also a lot of factors in
discretion that can be taken as to how. And I'll do a school
example, and Sandy will give district issues.
A district gets money, a
Title I allocation. And it might have 15 schools that are eligible
for Title I. Yet it chooses and it's allowed to do this, to focus
all of its money on the top-ranked school. This is a gross example,
but technically, they're allowed to do this. So they would put
a certain amount in per poor child, and that's what the amount
would be per poor child.
It's not the same as, maybe,
down the street at a different district, what they're giving out
per poor child. So it really can range very greatly, depending
on how the district distributes money to schools.
And also, what they take
off the top to administer the program, and with other reservations,
they're authorized to take, for example, for parental involvement
activities, or professional development. If there are preschool-level
students, and they're not at the schools, there are mechanisms
for that. So it's hard to give a number. It really is. And
Sandy can give a complication that says here, "We're trying
to give a number for district level, because of how the formula
works."
MR. BROWN: Right, because
of the hold harmless. But let's take your example, D.C., I mean,
D.C. gets -- well, we're taking about $7.2 billion for Title I
overall.
MS. NEW: In the country.
MR. BROWN: In the country,
nationally. Well, that's $7.2 billion, if I recall. D.C. gets
about 23 to 24 million in basic and concentration grants, if my
memory serves me right. So that's money that the D.C. has available
for the district, for the district school. And, of course, within
the district, based on the D.C. appropriations, the charter school,
in a sense, is like a separate school district within the D.C.
Say they have 90 percent
or 95 percent of the poor kids, and then the other 5 percent of
the other poor kids are distributed across 1, 2 or 3, or however
many charter schools may be in the district. And then you do
the allocations based on that. It would be based, however, on
the number of poor children that you have. So obviously, you
would get basically the same amount per child, as the D.C. public
school.
PARTICIPANT: Do you know
what they got last year?
MR. BROWN: I don't. It
was around 23 million, as I recall. Don't quote me on that, but
it's right in that neighborhood.
MS. NEW: One other thing
I want to raise with the question that comes in of how much a
child -- we're talking about how the allocations are done, which
is based on poor children.
However, the students that
are served aren't necessarily those kids, upon which that money
was distributed. In a school wide program, for example, all the
kids in the school are served, along with all the money. It's
just money to run the school programs.
There are many more targeted
assistance schools throughout the country, yet where there are
school wide programs, that's where a big chunk of the money is
because they're in the higher poverty, big urban districts primarily.
In targeted assistance schools, although the poor students drove
the money to the school, that's not the pot of students necessarily
benefiting from the funds. It's the students who are achieving
well.
There might be some overlap,
that's coincidental. So that's a completely different figure
that you would be looking at, and that also varies very greatly
depending on the strategies employed, and how many kids at each
school. So it is hard to give a number.
Yes?
Question #6
PARTICIPANT: Are the monies
supposed to be given in one lump sum, or are they distributed
on a "Mother, may I?"
MS. NEW: Neither.
MR. BROWN: Well, what happens
is that the -- even a school district or a state, you know, they
have a certain allocation. They don't get that money right up
front. That's kept in the Treasury, and they draw down on the
money on an as-need basis.
In fact, there's a whole
series of regulations with the Treasury Department as to how you
draw down on the money. I mean, the idea is that you cannot,
for example, draw down on all the money in advance, put it in
the bank, and earn interest on it. That just won't make it.
The feds will not allow you to do that. But there's an electronic
transfer that you draw down, the district and ultimately, the
school draws down on the money on an as-need basis.
PARTICIPANT: So it is the
"Mother, may I?"
MR. BROWN: I'm not sure
I would characterize it that way, but I suppose, yeah.
MS. NEW: Well, it's not
"Mother, may I?" because they could not say, "No.
This month we're deciding not to give you Title I money."
MR. BROWN: Right, it's not
that arbitrary.
MR. BROWN: So once the entitlement
or your allocation is figured out, mother cannot say you can't
have the money.
MS. NEW: Yes?
Question #7
PARTICIPANT: Our district
would like to call us "a nonpublic school," and insists
that we count our population based on where that child would reside
in the district, if they were going to one of the regular or board
of education schools. Is that allowed?
MS. RIGLING: Does your state
law make you a public LEA, I mean, a public school?
PARTICIPANT: Yes.
MS. NEW: Then you're a public
school.
MS. RIGLING: Then they can't
make you a private school.
PARTICIPANT: So they must
treat us as they do every one of the --
MR. BROWN: Absolutely.
MS. NEW: As your charter
school legislation specifies, and if it specifies you're a public
school within a district, you are to be treated like a public
school within that district.
Yes?
Question #8
PARTICIPANT: If we are
a first-year charter school right now, when do they apply, how
do they get the application? Are they on some kind of mailing
list to make sure they will get an application? When is the deadline
to apply, and when does the money come?
MS. RIGLING: Those are really
questions for your own state.
MS. NEW: If you're a district
charter school, that's a question to ask your state. If you're
a school within a district, you need to ask your district. It's
not a discretionary program, so there's a formula and a process
to get funds down. Well, depending on your situation, if you're
a district or a school, what the procedures are in the state,
and you'll have to ask them.
PARTICIPANT: Well, for instance,
time line?
MS. NEW: That's the state.
MS. RIGLING: One of the
things you should do -- and I know it's hard because you are often
in adversarial positions -- but try to find out as much as you
can about what your state's procedures are, and what your LEA's
procedures are, if you're within an LEA, about when they make
the decisions about who's eligible, and when they're asking for
applications, if you're an LEA.
We make money available on
July 1st to states, but usually the application process
from a local to a state occurs in the spring. We will probably,
if we're lucky, announce preliminary allocations as early as January
to the states. That might be a little bit later, but we're hoping.
Usually, we try to do that early, so that the state knows the
money that it's dealing with.
So the more you can find
out about how your state operates, and how your local operates,
the better off you'll be in order to try to influence that process.
And make sure that your kids get their fair share.
Question #9
PARTICIPANT: Are Title
I funds restricted to children, aged 5 to 17? The reason
I ask is that our charter school is allowed 18- to 21-year-old
former high-school dropouts, and we're all in the category of
students who are most likely to leave, failing to meet the standards.
MR. BROWN: Are you an LEA?
PARTICIPANT: Yes, we're
an LEA.
MR. BROWN: Unfortunately,
if you're an LEA, the only kids you could count are children who
are 5 to 17. The law is very specific about that. Now, you know,
in a school district, they get money based on their 5- to 17-year-olds.
But if they have 18- and 19-year-olds who have not graduated
from high school, who are still, you know, getting elementary
and secondary education services, they could be served even though
they're not generating money.
PARTICIPANT: How about if
our enrollment is specifically 18 to 21? Is this a waivable issue
in terms of the federal waivers?
MS. NEW: I have to check
on that.
MS. RIGLING: Yes?
Question #10
PARTICIPANT: If we're
an LEA, and we're drawing, say, for the entire city, is the entire
city's population the basis of your count, or is it the actual
school that you're enrolled in?
MS. NEW: It's your students.
MR. BROWN: It will be your
poor students.
MR. BROWN: So, in other
words, you will use the number of poor students that you have,
and then you will divide that by your enrollment to see whether
you meet the 2 percent, or the 15 percent threshold. And then
you get -- then you're allocated funds accordingly.
Question #11
PARTICIPANT: If the child
leaves the district, does the money go to another district?
MR. BROWN: In a situation
like this, what happens is that the state will allocate the money
to the school district based on where the poor kids live, okay,
where they reside. Now, if those kids who reside in one school
district move to another school district, or is served by another
school district, then the state can make an -- after they've done
the allocations -- they can then make an adjustment for those
poor kids who happen to go from school district 1 to school district
2, where they're served. And give school district 2 some additional
money, and take that away from the sending school district.
They can make that adjustment;
they're authorized to do that.
MS. NEW: Yes?
Question #12
PARTICIPANT: If you are
not an LEA, but you're not sponsored by a school district, you're
sponsored by an institution of higher ed, like a community college,
how do you figure out this whole thing?
MS. NEW: Your state law,
and I don't know if this is the case for every state's charter
school legislation, even though you might be sponsored by an IHE
or something else, the state laws have designated your schools
as either schools or districts. Which is separate from what your
sponsoring agency is, in most cases that we've heard.
MR. BROWN: I mean, I think
what we're trying to say is that it doesn't make any difference
who the sponsoring agent, agency is. If it's defined, you know,
if the law defines you as a school within a school district, then
you should be treated as a school within a school district. If
the law defines you, or recognizes you as a charter LEA, then
you're an LEA, I would think.
Question #13
PARTICIPANT: Do Title
I funds have to come through the state?
MS. NEW: At this point,
yes.
PARTICIPANT: The reason
I'm saying that, in our state right now, it's friendly through
our state government. But in any given election year, that could
change, like next year. And it gets very political, and to get
in on the school district, and other variations.
MS. NEW: Are you districts?
PARTICIPANT: We're our own
district.
MS. NEW: So then, regardless
of the political tenor, and like or disdain for charter schools,
if you are eligible as a district, you get your money based on
a formula. It's not a discretionary kind of thing, it's a formula
grant program.
PARTICIPANT: And they can't
make it difficult?
MR. BROWN: Well, they could
make it difficult.
MS. NEW: They could make
it difficult.
MR. BROWN: They can always
make it difficult.
MS. NEW: That's a different
question.
MR. BROWN: Right. I mean,
if you have -- if you're eligible --
MS. NEW: They're not supposed
to make it difficult.
MR. BROWN: If you have the
requisite number of formula children -
MS. NEW: You're just given
an allocation.
MR. BROWN: Then -- and you're
eligible.
MS. NEW: There's very little
room for a state, particularly for a district, a charter school
district, the state doesn't have much room to play. You're either
eligible and you get money, or you don't. It's a formula.
MR. BROWN: And the only
problem, you know, that's notwithstanding the timing issue, of
course, which is what this is all about. But the first year is
always a problem.
PARTICIPANT: We've already
gotten it for this year.
MR. BROWN: Well, then, you're
kind of in the cycle, so you should be in pretty good shape, theoretically.
Question #14
PARTICIPANT: Okay. Do
you have a telephone number to reach you?
MS. NEW: Sandy and I work
in the same office. We're going to give our general number, so
you could ask for either of us, (202) 260-0826. That's the Title
I office.
MS. RIGLING: Thank you very
much.
MS. NEW: Thank you.
(Whereupon, at 4:48 p.m.
the SESSION was adjourned.)
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