FY22 Federal Programs Handbook

For System and School Administrators

Title I, Part A – Disadvantaged Children

Title I, Part C – Migrant Education Program

Title I, Part D, Neglected and Delinquent

Title II, Part A – Teacher and Leader Quality

Title III and English to Speakers of Other Languages – ESOL

Title IV – Student Support and Academic Enrichment

Title V, Part B – Rural and Low Income

IDEA – Individuals with Disabilities Education Act

Dr. Phil Williams, Superintendent

The vision of Trion City Schools is that all students embrace learning,

strive for excellence, and become responsible, self-sustaining citizens.

Purpose of This Handbook

The purpose of Federal education program funding under the Every Student Succeeds Act (ESSA) is to provide LEAs and their schools with supplemental financial resources and assistance in order to ensure equitable access to a high quality education, regardless of student economic status or other equity factors.

The purpose of this handbook is to provide a systematic approach to managing the rules and guidelines of all federal programs to ensure consistent compliance. Staff should use the provided information to ensure that all federal programs are being implemented accurately and effectively.  

Federal Programs Staff

Federal Programs 

Angie Bowman, Ed.S.

Director of Curriculum and Federal Programs

Title I, Title II, Title III, Title IV, Title V, McKinney-Vento Program

angie.bowmam@trionschools.org

Angie Thomas

Parent and Family Engagement Specialist

angie.thomas@trionschools.org

Katherine Navarro

Family Engagement Assistant

katherine.navarro@trionschools.org

Jessica Bramlett, Ed.S.

Federal Programs, Support Services Director

jessica.bramlett@trionschools.org

Heather Stewart

Student Support Services Parent Mentor

heather.stewart@trionschools.org

Table of Contents

Federal Programs Calendar

Timeline for Monitoring of Schools

May – July

• May-July- Meet with Principals of all Schools following any updates or webinars provided by GA DOE to provide updates on any new guidelines and to provide guidance for principals.

Sessions will include representation from the following programs to provide training and support: Title I, Part A (Disadvantaged Students), Title I, Part C (Migrant Education Program), Title II, Part A (Teacher and Leader Quality), Title III and English to Speakers of Other Languages (ESOL), IDEA (Individuals with Disabilities Education Act), Title IV (Student Support and Academic Enrichment) and Title X, Part C (McKinney-Vento Education for Homeless).

• Review system Ethics, Fraud, Waste, Abuse and Corruption Procedures and Complaint Procedures
• Homeless Protocol Updates
• Migrant Educational Program, SIS and Occupational Survey Updates
• Budget Statements are reviewed at the end of the month by program directors. Review listed expenditures for accuracy and review progress in spending.
• Develop and submit budget
• Plan, Prepare Title I Digital Family Engagement Packet which includes:

• School Parent Compact
• Combined District/School Family Engagement Plan

• Submit CLIP
• Finalize District Needs Assessment

                Title I / Title IIA

• Complete evaluation of previous year’s school improvement plan to determine success of previous year’s Title I School Wide Program
• Complete Comprehensive Needs Assessment from current school and testing data
• Review and revise School Improvement Plan using Comprehensive Needs Assessment data with Leadership. Parent Participation is expected.  
• Complete School Wide Plan Checklist
• Update Family Engagement Plan using Family Engagement Survey results. Include parents on planning committee.
• Complete Family Engagement Checklist
• Update School/Parent Compact
• Complete Compact Checklist
• DRAFT School Improvement Plan due to the Central Office.
• Family Engagement Plan due
• School Parent Compact due
• Title I Digital Family Engagement Packet will be edited for website publication
• Submit names of federally paid employees

IDEA

• Budget completion reports deadline
• Pre-K exit data submission
• Post-Secondary Outcomes submission
• Timelines: Child Find and Early Transition Childhood submission

August

• Homeless Liaison monitor Homeless Program and needs
• Migrant Educational Program, SIS and Occupational Survey Updates
• Budget Statements are reviewed at the end of the month by program directors. Review listed expenditures for accuracy and review progress in spending.

Title I

• Draft of School Improvement Plan and approved Family Engagement Plans are shared with staff during pre-planning.  Staff comments are reviewed and considered.

• Title I Schools train staff on Family Engagement
• Post and share directions on how to access digital versions of Family Engagement Packet. Offer and provide hard copies of packet upon request. School Improvement Plans should be available for all parents and members of the community to review.
• Final version of School Improvement Plan will be placed on school website.
• Parents are made notified of their right to know the qualifications of their child’s teacher.
• Letters are sent to parents for teachers who do not me PQ requirements within 20 days.
• Plans developed for each teacher who do not meet PQ requirements  
• Hold Family Engagement activities and meetings.
• Hold Professional Learning activities according to plan.
• Annual Title I Meeting window begins and extends until October 31st 
• Annual Homeless Survey completed

• Notify parents of Parent Resource Room

Title IIA:

• When Trion City School District receives Title IIA funds, the funds will be transferred into Title I and will monitored according to Federal Programs Monitoring guidelines.

Title III:

• ESOL teachers review Home Language Surveys and screen students for whom a language other than English is indicated
• Parent notification of services are sent to parents.
• ESOL teachers schedule meetings to notify parents of eligibility for services
• Within first two weeks of school, input from classroom teachers regarding EL-M students and documentation of monitoring forms.
• ESOL teachers notify ESOL Coordinator regarding any changes/additions to ESOL roster
• ALL Parent Waivers must be approved by ESOL Coordinator
• ESOL teachers attend training on Instructional and Testing Accommodations
• ESOL teachers attend training on Data Entry for EL students.
• ESOL teachers complete Can-Do Descriptors for all EL and EL-M1 students; copies provided to classroom/content area teachers
• ESOL teachers meet with classroom/content area teachers to (1) review Can-Do Descriptors, and (2) to determine and document appropriate Instructional and Testing Accommodations, present ESOL Strategies for Instruction; copies provided to (1) classroom teacher(s),  (2)school’s testing coordinator, (3) ESOL Coordinator
• Document meetings with parents
• Instructional and Testing Accommodations and Test Participation documents to be completed by ESOL classroom teachers for all EL Students

Title IV:

• When Trion City School District receives Title IV funds, the funds will be transferred into Title I and will monitored according to Federal Programs Monitoring guidelines.

IDEA

• Verify all SWD class schedules reflect they are receiving services as indicated by their IEP
• Meet with principals regarding PD of Student Support Services Staff
• Begin faculty/staff review of Student Support Services Staff
• Begin faculty/ staff review of Student Support Services Manual review- continues each month until completed
• Provide new teacher training regarding policies and procedures of  
• Student Support Services department 

             September

• Budget Statements are reviewed at the end of the month by program directors. Review listed expenditures for accuracy and review progress in spending.
• Homeless Liaison monitor Homeless Program and needs
• Migrant Educational Program, SIS and Occupational Survey Updates
• Complete Private School Worksheet
• Verify addresses of students
• Utilize ESP4 to invite Private Schools to participate in meeting to discuss shared Federal Programs funding

                Title I

• Hold Annual Title I Am meeting with parents before October 31st. Save sign-in sheets and detailed agenda)
• Notify parents of the existence of the Family Engagement Resource Room.
• Hold Family Engagement activities and meeting according to plan. Save sign-in sheets and agendas.
• Hold Professional Learning activities according to plan. Save sign-in sheets and Agendas.
• School Council Training

Title III

• ESOL Coordinator updates ESOL roster
• Document meetings with parents

IDEA

• Evaluate instructional strategies and co-teaching models in each co-teaching classroom
• Grant period ends for IDEA grants
• High School Parent Project meeting- Parent Mentor

October

• Budget Statements are reviewed at the end of the month by program directors. Review listed expenditures for accuracy and review progress in spending.
• Homeless Liaison monitor Homeless Program and needs
• Migrant Educational Program, SIS and Occupational Survey Updates
• Work in conjunction with Student Information Director to ensure correct data for FTE
• Work in conjunction with Human Resources to ensure correct data for CPI

Title I

• Hold Family Engagement activities and meeting according to plan. Save sign-in sheets and agendas.

• Hold Professional Learning activities according to plan. Save sign-in sheets and Agendas.

Title III

• ESOL Coordinator updates ESOL roster
• Monitor progress of ELL-Ms at 9 weeks grading period
• Document meetings with parents

IDEA

• Budget Submission deadline
• Budget Completion Report deadline

November

• Hold first meeting with interested Private Schools

• Budget Statements are reviewed at the end of the month by program directors. Review listed expenditures for accuracy and review progress in spending.

• Complete Neglected Survey
• Homeless Liaison monitor Homeless Program and needs
• Migrant Educational Program, SIS and Occupational Survey Updates

Title I

• Hold Family Engagement activities and meeting according to plan. Save sign-in sheets and agendas.

• Hold Professional Learning activities according to plan. Save sign-in sheets and Agendas.
• Parent Engagement Month

Title III

• ESOL Coordinator updates ESOL roster
• Document meetings with parents

IDEA

• Transition Planning Surveys begin

              December

• Budget Statements are reviewed at the end of the month by program directors. Review listed expenditures for accuracy and review progress in spending.
• Complete Comparability Report
• Homeless Liaison monitor Homeless Program and needs
• Migrant Educational Program, SIS and Occupational Survey Update

Title I

• Hold Family Engagement activities and meeting according to plan. Save sign-in sheets and agendas.

• Hold Professional Learning activities according to plan. Save sign-in sheets and Agendas.

Title III

• ACCESS for ELLs Training
• ESOL Coordinator updates ESOL roster
• Monitor progress of ELL-Ms at 2nd 9 weeks period
• Document meetings with parents

January

• Hold Mid-Year Reviews with each Title I school administrator

• Discuss checklist and documentation that has been sent in
• Identify items that need more information provided

• Discuss implementation of plan and identify any areas where support is needed
• Discuss preliminary budget and possible effects with administration

• Completion of Periodic Certification form #1
• Budget Statements are reviewed at the end of the month by program directors. Review listed expenditures for accuracy and review progress in spending.
• Homeless Liaison monitor Homeless Program and needs
• Migrant Educational Program, SIS and Occupational Survey Updates

              Title I

• School Improvement Mid-Year Review – discuss progress with the strategies included in your School Improvement Plan and budget, student data update and monitoring of Title I documents and corrections that are needed.  Questions will be answered.
• Periodic Certification # 1 for all fully funded 100% Title I and Title II staff due to the Central Office
• Hold Family Engagement activities and meeting according to plan. Save sign-in sheets and agendas.

• Hold Professional Learning activities according to plan. Save sign-in sheets and agendas.

Title III

• ACCESS Testing
• ESOL Coordinator updates ESOL roster
• Document meetings with parents

IDEA

• Parent Survey Opens
• Excess Cost Calculation submission

           February 

• Budget Statements are reviewed at the end of the month by program directors. Review listed expenditures for accuracy and review progress in spending.
• Federal Programs Needs Assessment to all stakeholders (principals, teachers, paraprofessionals, and parents.  
• Begin meeting/planning for Title II Needs Assessment and Prioritization of Need

• Homeless Liaison monitor Homeless Program and needs
• Migrant Educational Program, SIS and Occupational Survey Updates
• Work in conjunction with Student Information Director to ensure correct data for FTE
• Work in conjunction with Human Resources to ensure correct data for CPI

Title I

• Hold Family Engagement activities and meeting according to plan. Save sign-in sheets and agendas.

• Hold Professional Learning activities according to plan. Save sign-in sheets and agendas.

Title III

• ACCESS Testing
• ESOL Coordinator updates ESOL roster
• Monitor progress of ELL-Ms
• Document meetings with parents

IDEA

• Post-Secondary Outcomes Opens for downloading
• Evaluate accommodations received by all SWD in grades 3-12

March 

• Budget Statements are reviewed at the end of the month by program directors. Review listed expenditures for accuracy and review progress in spending.

• Federal Programs Survey
• Begin meeting/planning for Title II Needs Assessment and Prioritization of Need
• Homeless Liaison monitor Homeless Program and needs
• Migrant Educational Program, SIS and Occupational Survey Updates

Title I

• SPENDING DEADLINE/ ENCUMBRANCE PLAN.  All materials should be purchased according to Budget Plan.  The only expenditures that will be allowed after this time will be for professional development stipends/subs, tutoring, Family Engagement food purchases and contracted services.  

• Hold Family Engagement activities and meeting according to plan. Save sign-in sheets and agendas.

• Hold Professional Learning activities according to plan. Save sign-in sheets and agendas.

Title III

• FTE count-ESOL teachers will work with school personnel to input this data
• ESOL Coordinator updates ESOL roster
• Monitor progress of EL-Ms
• Document meetings with parents

IDEA

• MOE reconciliation deadline

April 

• Parent Survey made available to parents/community
• Parent Letter sent to schools for distribution to parents about the availability of the survey
• Update Title I Handbook
• Budget Statements are reviewed at the end of the month by program directors. Review listed expenditures for accuracy and review progress in spending.

• Homeless Liaison monitor Homeless Program and needs
• Migrant Educational Program, SIS and Occupational Survey Updates
• Communicate with Neglected Facility and provide support and technical assistance

Title I

• Hold Family Engagement activities and meeting according to plan. Save sign-in sheets and agendas.

• Hold Professional Learning activities according to plan. Save sign-in sheets and agendas.

Title III

• ESOL Coordinator updates ESOL roster
• Monitor progress of ELL-Ms
• Document meetings with parents

IDEA

• Vocational Rehabilitation Meeting for parents and students of upcoming seniors

May

• Annual Title I Workshop and Materials Distribution

• Distribute Monitoring Notebooks for collection of Federal Program compliance documents

• Schoolwide checklist and expectations
• SW Plan from previous year
• Principal’s Attestation
• Budget for upcoming year
• Information about purchasing, personnel
• Family Engagement Survey Results distributed
• Revised Title I Handbook
• Training PPT

• Begin CLIP revisions
• Begin revision of District PI Plan
• Budget Statements are reviewed at the end of the month by program directors. Review listed expenditures for accuracy and review progress in spending.

• Homeless Liaison monitor Homeless Program and needs
• Migrant Educational Program, SIS and Occupational Survey Updates

Title I

• SPRING Duties.

• Physical Inventory completed. Inventory form dated and signed by the principal.
• Family Engagement Report Card listing all Family Engagement activities completed, meeting the Six Required Components to Build Parent Capacity.
• Parent Activity Evaluations that have been collected throughout the year at parent activities are included.

• School Improvement Planning Training of staff to complete data analysis, goal setting, plan revision and budget preparation.

• Hold Family Engagement activities and meeting according to plan. Save sign-in sheets and agendas.

• Hold Professional Learning activities according to plan. Save sign-in sheets and agendas.

• Parent evaluations of parent activities are turned in with SPRING Notebook

Title III

• ACCESS test results reviewed; eligibility determined.
• ESOL teachers meet with EL parents to discuss ACCESS scores, eligibility, or exit
• ELL and ELL-M student folders updated with ACCESS and other test results
• Roster updates provided to ESOL Coordinator
• Exit meeting with ESOL Coordinator
• ESOL teachers meet with ESOL Coordinator on exit criteria and records maintenance
• Update roster to include Milestones Scores, or EOCT or GHSGT ELA score, retention information

IDEA

• Parent Survey Window closes
• Post-Secondary Outcomes Window opens for submission

June

• Schools meet with Leadership teams and parents to revise their Family Engagement Plan and their Schoolwide Plan
• Attend annual Federal Programs Conference in Atlanta
• Complete Homeless Survey
• Homeless Liaison monitor Homeless Program and needs
• Budget Statements are reviewed at the end of the month by program directors. Review listed expenditures for accuracy and review progress in spending.

• Migrant Educational Program, SIS and Occupational Survey Updates

              Title I / Title IIA/ Title III

• School Improvement Planning and Budget Workshop for Administrators
• Federal Programs Webinar Updates
• Periodic Certification # 2 for all fully funded 100% Title I and Title IIA staff due to the CO

IDEA

• Final submission of all IDEA amendments
• Final SWD record submission

Ongoing Throughout Entire School Year

• Review plans and budgets to ensure funds are spent according to plan
• Review Title I Payroll expenditures
• Reconcile Federal Program accounts with school finance software monthly
• Participate in GaDOE Federal Program webinars, regional meetings, and trainings
• Update system and school websites with Federal Program information
• Add qualifying purchased items to inventory as ordered/received
• Monitoring of Homeless, Neglected, and Migrant programs
• Ongoing review of school improvement data and plans in conjunction with other staff.

Monitoring Process & Procedures

The following procedures have been created and designed to provide reasonable assurance regarding the achievement of objectives in the effectiveness and efficiency of operations.

The Georgia Department of Education requires that the Trion City School System monitor the implementation of federal programs and the expenditure of all funds associated with each program. The specific requirements are as follows:

1. Federal Program Directors will conduct self-monitoring of its schools and programs sufficient to ensure compliance with requirements, including Title I, Part A (Disadvantaged Children), Title I, Part C (Migrant Education Program), Title I, Part D (Neglected and Delinquent), Title II, Part A (Teacher and Leader Quality), Title III (English Learners & Immigrant Students), Title IV, Part A (Student Support and Academic Enrichment) and Title X, Part C (McKinney-Vento Education for Homeless),Individual Disabilities Education Act (IDEA).
2. Federal Program Directors will undergo training from GaDOE and other sources to maintain proficiency in program compliance requirements.
3. Federal Program Directors will provide technical assistance to local schools.
4. Federal Program Directors’ self-monitoring will include monitoring all program expenditures to verify that all expenditures comply with program requirements.
5. Federal Program Directors will maintain all documentation the LEA may need for future auditing/monitoring.
6. In years when LEA does not receive an on-site visit, Federal Program Directors will complete the Self-Assessment Checklist and submit it to the Georgia Department of Education (GaDOE) as requested.
7. LEA will undergo monitoring by GaDOE on a published cycle. LEA Federal Program Directors will participate in training and technical assistance updates as provided by GaDOE prior to monitoring visits.  
8. After the on-site monitoring visit, the LEA will receive a comprehensive monitoring report, which will contain recommendations, findings, and required actions that together provide an analysis of the implementation of the LEA’s federal programs. If a Corrective Action Plan is required, the LEA Federal Program Directors will respond in a timely manner with a Corrective Action Plan, which must be approved by GaDOE. The appropriate GaDOE Program Specialist will monitor implementation of the Corrective Action Plan.

Monitoring by the Georgia Department of Education (GaDOE) consists of four major components:

• Monitoring of Expenditures – Local educational agencies (LEAs) must submit for approval an annual budget through the Consolidated Application process.  GaDOE Program Specialists review each application and budget to ensure that expenditures are appropriate for the program area before approving LEA budgets.  Once budgets are approved, GaDOE Education Program Specialists track how well LEAs are requesting funds for expenditures to ensure that LEAs are likely to meet the expenditure requirements for each federal program.
• Single Audit – LEAs with single audit findings are flagged for technical assistance.
• On-site Monitoring – A GaDOE on-site Cross-Functional Monitoring Team visits the school system to apply the criteria included in a GaDOE monitoring document. 
• Self-Monitoring Checklist – LEAs not receiving an on-site visit complete the Self-Assessment Checklist and submit it to the Georgia Department of Education (GaDOE) as requested.

The following procedures are followed for the on-site monitoring visit:

• Selection of LEAs to be monitored.

• LEAs are currently cross functionally monitored on a four-year cycle. 
• LEAs were initially randomly selected from each of Georgia’s service areas. 
• LEAs with audit or monitoring findings requiring a return of monies or receiving a high number of stakeholder complaints are monitored within the year of the LEA audit or monitoring report and the written complaint.  In addition, on-site monitoring outside of the scheduled cycle may be arranged as needed if an LEA evidence serious or chronic compliance problems. 

Monitoring is an essential component of ensuring that all facets of federal programs are being implemented as prescribed by every Student Succeeds Act (ESSA) under the Elementary and Secondary Act (ESEA). It is a process of systematically providing technical assistance and collecting data to provide information that can guide program implementation.  

Each federal program in the Trion City School System makes use of monitoring as a means of regular observation and recording of activities taking place in participating schools. Critical to this process is the feedback provided to schools that can assist in improving student academic achievement. District monitoring addresses the following:

• Ensuring that all activities are carried out in accordance with federal compliance guidelines
• Monitoring inventory and equipment usage
• Attainment of academic achievement school improvement goals
• Compliance with budgetary guidelines

Positions Responsible for Implementation and Monitoring of Procedures

The Directors of Federal Programs will coordinate and provide support to each school receiving federal funds. The Directors implement and monitor the procedures contained in this handbook. 

Frequency of Monitoring (Timeline) 

• June-September - Provide a technical assistance session for all participating schools following the GaDOE Federal Programs Conference to update principals on any new guidelines and to provide guidance for new principals. Sessions will include the following topics: budgets, ordering, compliance, parental involvement, professional learning, meeting the needs of students, schoolwide programs, monitoring, academic achievement, inventory, scheduling, ethics, fraud and waste, and complaint procedures. Sessions will include representation from the following programs: Title I, Part A (Disadvantaged Students), Title I, Part C (Migrant Education Program), Title II, Part A (Teacher and Leader Quality), Title III (English Learners & Immigrant Students), Title X, Part C (McKinney-Vento Education for Homeless), Individuals with Disabilities Education Act (IDEA). Monitor implementation of school improvement plan initiatives using instructional rounds.
• June/July - Work with principals on annual revision of compacts and school improvement and Family Engagement plans and budgets. All Federal Program Directors will review plans and budgets to ensure that funds are being spent according to plans and that plans have all the necessary components.
• July/August - Notify any schools if required to provide intervention services because of needs improvement status, assist schools with creating and mailing any required notifications to parents.
• August to June – Meet quarterly with principals.  Provide additional training as needed.
• August to December - Inventory items purchased with federal funds. Monitor schools, provide feedback.
• August to June – All federal programs are monitored by the appropriate program directors.  Ongoing review of school improvement data and plans in conjunction with members of the Teaching & Learning Department
• October-December - Conduct fall progress checks on progress toward attainment of school improvement goals and action steps.
• January/February – Conduct on site progress checks and/or monitoring visits.
• February/March - Federal program staff attends GCEL conference
• Ongoing - Budgets are reviewed at least monthly and each purchase order is examined by federal program staff to ensure purchases are allocable, reasonable, and necessary and that items purchased are supporting strategies contained in the system and/or school improvement plans.
• February/March – Conduct annual comprehensive needs assessment. Data is provided to system and school leaders so each can compile data to determine prioritized needs for the following year. 
• Ongoing – Federal Program Directors provide technical assistance and meet regularly with principals.

List of Documentation to Verify Monitoring of Title Programs

Federal Program Directors will document meetings with school leaders using sign-in sheets, checklists, and agendas. Regular meetings and/or communication will occur to review required documents and offer technical assistance. A Federal Programs School Monitoring Checklist will be maintained and reviewed with school leaders indicating that required programs components have been met.

Needed Corrective Actions at Schools (Identified by LEA)

The corrective actions listed within the Federal Programs School Monitoring Checklist must be addressed by school leaders because of technical assistance provided by Federal Program Directors and other district leaders. Professional learning is provided based on needs. In addition, professional learning is used as a preventive measure to ensure that all personnel have a clear understanding of all expectations for every facet of the various federal programs. Federal Program Directors, along with other district level staff and outside consultants, provide ongoing training as a means of ensuring that the system and schools always comply. A reasonable timeline for addressing corrective actions will be agreed upon by school and district leaders and adhered to by all parties.

Verification of Corrective Actions at Schools

Corrective actions, findings, areas of concern, and recommendations received through monitoring feedback are discussed with principals to assist them in understanding the critical need for compliance with federal guidelines. Verification of corrective action will be determined through ongoing technical assistance provided to the school and documented on the Federal Programs School Monitoring Checklist.

District Review of Applicable Federal Program Budgets

The federal directors, in collaboration with school principals, develop and submit federally funded budgets that align to needs identified in school/district improvement plans. The Federal Program Directors ensures that all funds budgeted are allowable per funding source. The Federal Program Directors analyzes budget summary reports at least quarterly. Completion reports are annual reports required by Georgia Department of Education (GADOE) for all grant funds. Reports are due thirty days after the end date for each grant. Prior to preparing the completion report, the general ledger report for each grant will be reviewed to ensure that all expenditure postings are correctly recorded.

Identification of High-Risk Schools

The Federal Programs School Monitoring Checklist will be used to identify schools that are at high risk of not properly operating various federal programs. Any school failing to achieve check off on ten or more required components will be considered at risk and will be required to develop a more comprehensive short-term corrective action plan with specific dates for accomplishing corrective action steps.

IDEA Procedures for Monitoring Schools and Programs Student Support Teams

The District RTI Coordinator, school level RTI coordinator, District Administrative Systems Manager, and the School Psychologist monitor procedural compliance regarding tiered interventions. The District RTI Coordinator conducts random RTI/SST file compliance checks throughout the school year to review plans for compliance and fidelity. They also completes quarterly SST audits and reports findings to the school level RTI coordinator. The District Administrative Systems Manager generates weekly RTI plan and activity reports that she shares with the schools for checks and balances. School psychologists reviews files and provide support and guidance regarding progress monitoring. All administrators at the school level are expected to be an integral part of the RTI/SST process and remain actively involved with all aspects of the process including professional learning, monitoring meetings, implementation of research-based practices, etc.

Schools that are found to be out of compliance are provided intensive one-on-one technical assistance and support from the District RTI Coordinator. Staff members who are found out of compliance will be provided with continued professional learning and/or one-on-one assistance by the school level RTI coordinator. When staff members continue to have trouble after technical assistance has been provided, the District RTI Coordinator will be responsible for determining the next steps in support.

Child Find

The Preschool Program Coordinator holds meetings during which Child Find procedures for Preschool age children are continually monitored through a referral list that is updated weekly. Universal screeners are completed at the elementary, middle, and high school levels to aid in Child Find; students demonstrating areas of need are then referred to the RTI/SST committee which monitors student progress.

If Child Find Procedures are blatantly not followed, additional training and technical support will be provided by the Director of Special Education, District Special Education Coordinators, Program

Specialists and/or designated school staff (e.g., assistant principals, special education department chairs, counselors, etc.). Evaluation/Re-evaluation

Professional Learning

Existing TCS Special Education Teachers: District Special Education Coordinators and the School Psychologists, will provide ongoing professional learning for special education policies and procedures regarding Evaluations and Reevaluations throughout each school year. The Director of Special Education provides up-to-date training and information regarding evaluations. Furthermore, the Director of Special Education provides training to building-level administrators during regular, instructional district leadership meetings. School Psychologists provide supplementary professional learning to teachers regarding referral packet requirements, the Initial Timelines Calendar and the 120-Day Calendar, progress monitoring procedures, and the administration of achievement measures, behavior rating scales and adaptive behavior assessments. Moreover, the District RTI Coordinator provides professional learning to Assistant Principals and school-level RTI Coordinators, who then train the staff on compliant RTI practices.

New TCS Special Education Teachers: Teachers new to the Trion City School System are trained in special education policies and procedures related to evaluations and reevaluations through a new teacher training provided by the Special Education Director at the beginning of each school year. They also participate in ongoing professional learning that is provided for existing teachers, as described above, as well as professional learning that is provided by administration and other support staff. Additionally, new Special Education Teachers are assigned a veteran mentor teacher in their school building to provide support and guidance regarding evaluations and reevaluations throughout the school year.

Evidence of Training

Professional learning will be documented through agendas, sign-in sheets, and end of year policy and procedure checklists. This documentation will be stored electronically on the Google Drive and originals will be housed in the Special Education Administrative Assistant’s office.

Supervision and Monitoring

Monitoring Procedures: At the beginning of the school year, School Psychologists review all initial referrals to prioritize them. They collaborate on the Yearly Special Education Timelines Report, documenting initial evaluations, allowing them to monitor all initial timelines for the TCS. The School Psychologist also pull a report of the Reevaluation Data Reviews that are due during the current school year, share that information with school-level Department Chairs, and monitor these throughout the year.

The Special Education Director monitors the GO-IEP Dashboard for eligibility timelines routinely and follow-up with Department Chairs when students are approaching critical timelines. If a concern arises, Special Education Director will conference with the teacher(s) to provide support in adhering to compliant evaluation practices. Special Education Teachers are also asked to monitor their GO-IEP Dashboard weekly, so they are continuously aware of timelines related to evaluations and reevaluations. Additionally, teachers are asked to sign off on the TCS Special Education Policy and Procedure Checklist, verifying understanding of their responsibilities as it pertains to evaluations and reevaluations throughout the school year.

Technical Assistance

Teachers who require additional technical assistance with policies and procedures related to evaluations and reevaluations will be provided with technical assistance and support through trainings, one-to-one conferences, webinars, and/or professional learning plans from the Director of Special Education. If teachers continue to have difficulty despite the technical assistance they receive, building-level administrators will be notified so they may determine next steps to ensure remediation and compliance.

Eligibility

The Director of Special Education monitors Eligibility and Categories of Eligibility by reviewing the associated data and their trends. The Director of Special Education collaborates with the Director of Student Data and Services, as well as other district leaders by reviewing eligibility data and their trends for students with disabilities. If concerns arise, the Special Education Director will meet with the district leadership team and/or school-level administration to provide technical assistance.

Teachers who require additional technical assistance with policies and procedures regarding Eligibility Determination and Categories of Eligibility will be provided with technical assistance and support through trainings, one-to-one conferences, webinars, and/or professional learning plans. If teachers continue to have difficulty despite the technical assistance they receive, building-level administrators will be notified so they may determine next steps to ensure remediation and compliance.

Discipline

The Director of Student Data and Services monitors district and individual school compliance with discipline policy and procedure by reviewing the associated data and their trends. The Director of Special Education collaborates with the Director of Student Data and Services, as well as other district leaders, by reviewing discipline data and their trends for students with disabilities. If concerns arise, the Special Education Director will meet with the district leadership team and/or school-level administration to provide technical assistance.

Consolidated LEA Improvement Plan

Procedures for Creation, Review, and Approval

Trion City’s designated administrators are responsible for conducting an annual review of the Consolidated LEA Improvement Plan (CLIP) components, at which time revisions are made. The Trion City School System is committed to cultivating and sustaining partnerships with parents and community stakeholders, and encourages their participation in the development, implementation, review, and evaluation of its CLIP and all the components therein. All parents of Trion City School System’s students are provided multiple opportunities to be involved in the development and revision of the system’s CLIP. These opportunities include access to the components of the CLIP during various meetings, at a district-wide parent meeting held in the fall, and at spring school-based Title planning meetings.

• To ensure stakeholder input and timely submission to the GaDOE, the following timeline will be followed:
• August through July - The newly approved CLIP is made available on the district website. A feedback form is provided on the web.
• August through July – The newly approved CLIP is made available to parents in a parent information notebook at the front office of each school. A printed feedback form is provided in each notebook.
• August-October – The current CLIP is made available during a district parent meeting.
• February-April – The current CLIP is made available during school Title I Am planning Meetings and opportunities are provided on paper and online for feedback. Survey responses will be collected as part of the annual Comprehensive Needs Assessment.
• April-June – Changes are made to the CLIP based on feedback obtained from multiple means and stakeholders.
• May-June – The CLIP is uploaded for GaDOE approval.

Resolution for Unapproved CLIP

If the GaDOE requests revisions to any portion of the CLIP (CLIP Questions, Family and Parent Engagement Policy, and/or Foster Care Transportation Plan, the Directors of Federal Programs will retrieve the requested changes from the Audit Trail in the SLDS portal. The Directors of Federal Programs will then communicate with the appropriate school or district-based personnel to ensure that requested changes are completed. The Directors of Federal Programs will provide technical assistance as appropriate, make corrections and/or approve corrections to the appropriate CLIP components and then resubmits the plan. This process is continued until the plan has been approved by GaDOE.

Selection of Evidenced-Based Action Steps in the CLIP

Evidenced-based action steps are addressed in the system’s Consolidated LEA Improvement Plan The system has adapted the GA DOE’s Systems of Continuous Improvement and the following improvement planning steps: Examine Progress; Identify Needs; Create Goals and Select Evidenced Based Interventions; Plan Implementation; Implement the Plan. The following information is included as part of creating goals and selecting evidenced based interventions: “Schools will then create goals and evidence based action steps to address the prioritized overarching areas in need of improvement using a provided schoolwide improvement plan template. Schools must indicate in their improvement plans the extent to which their interventions are evidenced based by selecting Strong, Moderate, Promising, or Rationale and linking to appropriate supporting documentation. Schools are encouraged to focus on three to five goals and approximately five high impact action steps per goal that will improve Tier 1 instruction for all students, as well as identify Tier 2-4 action steps that will be taken to provide additional support for students, including subgroups, who are not academically successful after Tier 1 action steps have been implemented.

Schoolwide Improvement Plans

Creating, Reviewing, and Approving School wide Plans

School Improvement/Schoolwide Plans are updated each summer for the following school year. Each school leadership team conducts a meeting at which representatives from each grade level, content area, and department, as well as school administration and parents meet to develop a plan. They proceed through a complete review of school data to determine areas of strength and need and determine the prioritized needs of the school.  Using these identified needs, the school leadership team decides on instructional strategies, parental involvement initiatives, and professional development activities that will meet the academic needs of the students. Assistance is also provided to schools in their use of school improvement funds to accomplish initiatives in their school improvement and schoolwide plans. System leaders also support schools in developing, revising, implementing, and coordinating school improvement and schoolwide plans during administrative meetings. During the meetings, data is analyzed to identify and develop solutions to challenges related to instructional strategies, Family Engagement, professional learning, and budgets. Additionally, system leaders conduct progress checks to evaluate the extent to which improvement plan goals are being met. Parents are sent information inviting them to participate in the revision process at annual Title I Planning meetings held at each school during the spring. Once revisions are made, the plan is placed on the system and each school’s website. Paper copies are also available in the office at each school.  All plans are reviewed using the School Improvement Plan Checklist.

Selection of Evidenced-Based Action Steps

Definition

The term ‘‘evidence-based,’’ when used with respect to a state, local educational agency, or school activity, means an activity, strategy, or intervention that demonstrates a statistically significant effect on improving student outcomes or other relevant outcomes based on:

• strong evidence from at least one well-designed and well-implemented experimental study; or
• moderate evidence from at least one well-designed and well-implemented quasi-experimental study; or
• promising evidence from at least one well-designed and well-implemented correlational study with statistical controls for selection bias; or
• demonstrates a rationale based on high quality research findings or positive evaluation that such activity, strategy, or intervention is likely to improve student outcomes or other relevant outcomes and includes ongoing efforts to examine the effects of such activity, strategy, or intervention Implications

During the planning of the school/district improvement plans, leadership teams identify and record the extent to which the activities, strategies, and/or interventions contained in their school improvement/schoolwide plans meet the various levels of qualifying as being evidence based: strong, moderate, promising, or rationale if sufficient research can be located to substantiate the use of the program or strategy to impact instruction. If sufficient research cannot be located, a logic model will be developed that includes a rationale for using the program or strategy and what evidence will be collected to determine impact of the program or strategy. This information will be documented in each school improvement plan.

Resolution for Unapproved Schoolwide Plans

Schoolwide improvement plans are maintained in SLDS. This provides access to all appropriate stakeholders and allows for opportunities to collaborate. If the plan needs revision, comments are placed on the plan. Once all comments have been resolved satisfactorily, the plan is accepted by the Federal Program Directors and given to the superintendent for final approval.

Private Schools

Section 1120 of ESEA requires that local educational agencies (LEA) provide to eligible private school students, their teachers, and their families, services that are equitable to the services being provided to similar students, their teachers, and their families, attending public schools.  Services for private school students must be developed in meaningful consultation with private school officials. Services provided to private school students by an LEA must be secular, neutral, and non-ideological.

For Title I, Part A purposes, eligible private school children are those who:

• Reside within the attendance area of a participating public school, regardless of where the private school they attend is located.
• Are identified through consultation with the private school as failing, or most at-risk of failing, to meet high student academic achievement standards.

For IDEA, Title I, Part C, Title I, Part D, Title II, Part A, Title III, Title IV, Part A, and Title X, Part C purposes, eligible private school students are those who:

• Attend a private school within the district’s geographic boundaries.

Section 1120 of ESEA requires that local educational agencies (LEA) provide to eligible private school students, their teachers, and their families, services that are equitable to the services being provided to similar students, their teachers, and their families, attending public schools. Federal support services for these children must be developed in meaningful consultation with private school officials. Services provided to private school students by an LEA must be secular, neutral, and non-ideological.

To ensure meaningful consultation occurs, invitations for private schools to consult in the participation of federal programs the following calendar year are sent in the fall, usually September, via ES4PS provided by GA DOE in SLDA. The invitation includes the specific date and time of the statewide private school initial consultation that district representatives plan to attend. Upon receipt of an intent to participate form, which is provided to private school officials, a meeting will be held to discuss plans and the required components of IDEA, Title I, Part A (Disadvantaged Children), Title I, Part C (Migrant Education Program), Title I, Part D (Neglected and Delinquent), Title II, Part A (Teacher and Leader Quality), Title III (English Learners and Immigrant Students), Title IV, Part A (Student Support and Academic Enrichment), and Title X, Part C (McKinney-Vento Education for Homeless). Follow-up consultation meetings are then scheduled with officials from participating private schools. After each consultation, public and private school officials sign a form indicating whether meaningful consultation occurred. Educational services and other benefits provided under this section for private school children, teachers, and other educational personnel shall be equitable in comparison to services and other benefits for public school children, teachers, and other educational personnel participating in the program and shall be provided in a timely manner.

Procedures for Children with Disabilities in Private Schools or Referred by Trion City Schools (State Rule: 160-4-7-.13)

If the Individualized Education Program (IEP) team, including the parent, decides that the most appropriate placement for a student is in a private school:

● Trion City Schools continues to be responsible for making sure that the student receives the special education and related services included in the student’s IEP and that those services are provided at no cost to the parent.

● TCS should make sure that the education provided at the private school meets the standards that apply to other students with disabilities and that the student and parent continue to have all the same rights that other students with disabilities and their parents have. A district representative must visit the private school at least annually. TCS remains responsible for ensuring free appropriate public education (FAPE) when the student is placed in the private school.

● The IEP team, with all the appropriate members including the parent, private school or facility staff, and district representative will develop the IEP for the child. IEP team members may participate in the meeting through a conference call or other means. The district will ensure that the parent can attend at no cost to the parent. The parents will also notify the school system in writing, at least 10 days prior to removing the child from public school, that they disagree with the IEP and placement and want the school system to reimburse them for the private school tuition. Districts may apply for grant funds if the child is placed in a private school or facility that is approved by the Georgia Department of Education (GaDOE). If the private school is out of the state, it must be on the approved list of the state where the school is located. If a parent or private school staff suspects a child of having a disability, which has not already been identified, TCS will conduct an evaluation within established legal guidelines.

• The child must pass hearing and vision screening. TCS can conduct a hearing/vision
• screening at the home school (with consent), or parents may obtain hearing/vision screening from the child’s physician or the health department.
• The parent will also be asked to provide information about the child on the
• Confidential Background Information Questionnaire and to sign the Consent for Evaluation along with providing some feedback on checklists.
• Parents and private schools are asked to provide documentation of interventions
• tried prior to referral. The feedback will help the evaluator identify the student’s
• deficits in the area(s) of suspected disability.

Once a request for an evaluation is received, the referral packet is mailed to the parent. When all items of the packet are returned, including interventions attempted and Consent for Evaluation is signed, the school psychologist schedules the evaluation. TCS will evaluate private school/home school students within the Georgia Department of Education sixty (60) day timeline requirement.

Once testing is complete:

The Administrative Assistant of Student Support Services is notified so an   Eligibility/IEP meeting can be scheduled

• If the student is eligible for Special Education services, the IEP team will develop an IEP (if the student is a resident within the district) and offer these services if the parent enrolls the student into TCS.
• If the parent chooses to enroll the child, the IEP team will project the implementation date of the IEP forward to a date when the child will be enrolled
• If the parent chooses to continue the student’s placement in a private school, then the IEP minutes will reflect this decision. When students are placed in private or home school, the school district may consider some services
• TCS has agreed to use its private/home school allocation to provide technology to those students found eligible for Speech/Language services, for as long as the funding for the allocation is available for the current school year budget
• TCS is not required to pay for the cost of education, including Special
• Education and related services for the child parentally placed at a private school if the district made FAPE available for the child.

Private school placement may occur in three circumstances:

• First, when the public school determines that it cannot provide free appropriate public

education (FAPE), the public school must identify and pay for a private school to provide services. This is at no cost to the parent.

• Second, a parent may remove the child from public school at any time and enroll the child

in private school. Under certain circumstances, the parent may request reimbursement from

the school district to pay for the private placement. The parents must tell the IEP team they

disagree with the proposed IEP and placement and want the school district to reimburse

Them. The parents will also notify the school district in writing, at least 10 days prior to removing the child from public school, that they disagree with the IEP and placement and want the school district to reimburse them for the private school tuition. If the public school asks to evaluate the child during the 10-day period and the parents refuse, then reimbursement may be denied. If the parents want to be reimbursed for all the costs of private school and the district does not agree to it, the parties must go before a due process hearing officer to determine whether the public school provided FAPE.

• Third, the parent may choose to use a private school instead of public school at the parent’s

expense, in which case, FAPE is not an issue.

When the student is in private school by parent choice, the student and the parent lose their individual rights to Special Education services.

When students are placed in private or home school, the school district may consider some services. Georgia offers a Special Needs Scholarship Program that allows eligible students to transfer to another public school or to use a state-funded scholarship to attend an approved private school.

The parents may also notify the school district in writing, at least 10 days prior to removing the child from public school, that they disagree with the IEP and placement and want the school district to reimburse them for the private school tuition.

Reimbursement for Private School Placement

If the parents of a child with a disability, who previously received Special Education and related

services in a local educational agency/school system enroll the child in a private preschool,

elementary school or secondary school without the consent of or referral by

TCS, a court or an administrative law judge (ALJ) may require the school system

to reimburse the parents for the cost of that enrollment if the court or ALJ finds that the school

system had not made a FAPE available to the child in a timely manner prior to that enrollment and that the private placement is appropriate. A parental placement may be found to be appropriate by an ALJ or a court even if it does not meet the state standards that apply to education provided by the State or local education agency.

The cost of reimbursement described above may be reduced or denied if:

• At the most recent IEP Team meeting that the parents attended prior to the removal of the child from the local education agency, the parents did not inform the IEP Team that they were rejecting the placement proposed by the school system to provide a FAPE to their child and did not state their concerns or their intent to enroll the child in a private school at public expense.
• At least 10 business days prior to the removal of the child from the local education agency, the parents did not give written notice to the school system  that they were rejecting the placement proposed by the school system to provide a FAPE to the child and did not state their concerns or their intent to enroll the child in a private school at public expense
• If, prior to the parent's removal of the child from the school system, the system informed the parents through the notice requirements of its intent to evaluate the child, including a statement of the purpose and scope of the evaluation that was appropriate and reasonable, but the parents did not make the child available for evaluation.    
• Upon a judicial finding of unreasonableness with respect to actions taken by the parents

Exception to Limitation of Reimbursement:

• The cost of reimbursement must not be reduced or denied for a parent's failure to provide the notice to the local education agency described above, if:
• The school prevented the parents from providing the notice.
• The parents had not been provided a copy of the parent's rights under IDEA
• and, therefore, had not been notified of the requirement to provide the notice
• described in above; or
• The provision of notice would likely result in physical harm to the child.
• The cost of reimbursement may, in the discretion of the court or administrative law judge, not be reduced or denied for a parent's failure to provide the notice to the school system described above, if:
• The parents are not literate or cannot write in English; or
• The provision of notice would likely result in serious emotional harm to the child.

Children who live within the school district and are home-schooled are also considered parentally placed private school students. It is the responsibility of Trion City Schools to locate, identify, and evaluate all private schools’ children with disabilities enrolled by their parents in private (including religious, elementary, and secondary) schools located within the school district.

TCS consults with appropriate representatives of private school children with disabilities to carry out Child Find activities. These activities are like those undertaken for the public-school children and completed in a time comparable to that for children attending public schools. TCS is required to carry out child find activities to locate, identify, and evaluate children attending the private schools within the jurisdiction of the district. The district must consult with representatives of the private school to complete Child Find activities. These activities must be like activities undertaken for the children in the district and must be completed in a timely manner comparable to other children attending the district. Child Find activities include any parentally placed children who attend a private school within the jurisdiction of the district, even if the student resides in a different district or in a state other than Georgia. TCS always accepts responsibility to conduct Child Find for any of its residents. When a child is enrolled in a private school in another district, then both districts have an obligation, and they work together so as not to delay access to the Child Find activities.

When the student is in private school by parent choice, the student and the parent lose their individual rights to Special Education services; however, to the extent consistent with their number and location in the state, provisions are made for the participation of private school children with disabilities in programs provided under Part B of the Individuals with Disabilities Education Act (IDEA) by providing children with Special Education and related services in accordance with this section. No parentally placed private school child with a disability has an individual right to receive some or all the Special Education and related services that the child would receive if enrolled in a public school.

Consultation Process

The consultation process is important to ensure the provision of equitable services. Consultations with the representatives of private schools, parents of private school students, and parents of home-schooled students must be timely and meaningful. Consultation requirements include:

• how parentally placed private school children suspected of having a disability can participate equitably in the Child Find process.
• how the parents, teachers, and private school officials will be informed of the Child Find process.
• how the determination of the proportionate share of federal funds available to serve the children with disabilities was calculated.
• how the process will operate throughout the school year.
• how, where, and by whom the Special Education and related services will be provided.
• how funds will be approved if funds are insufficient; how and when those decisions will be made; and how the district will provide to the private school officials a written explanation of the reason why it chose not to provide services directly or through a contract.

Consultation Process for Private School Families and Home-Schooled Families

• Child Find letters are sent yearly
• Information and contact numbers/email addresses are accessible from the Student Support Services Administrative Assistant
• Home Schooled Reports are kept by Title I and shared with the Student Support Services office
• Letters are mailed to parents of private/home school students inviting them to participate in TCS planning meetings
• Services provided with Proportionate Share funds are shared at the meeting.
• How the process will operate throughout the school year is shared at the meeting, as well as, how, where, and by whom the Special Education and related services will be provided; how funds will be apportioned if funds are insufficient; and how and when those decisions will be made
• TCS will initiate and conduct the meetings to develop, review, and revise service plans
• All service plans must contain a statement of the Special Education and related services, and supplementary aids and services, to be provided to the child; be in effect at the beginning of each school year, and be developed, reviewed, and revised periodically, but not less than annually, in accordance with Georgia Rules

The district must obtain a written affirmation signed by the representatives of the participating private schools as documentation of the consultation process and must be prepared to submit this documentation to the GaDOE upon request.

If the private school officials believe that the district did not engage in the consultation in a meaningful or timely manner or did not consider the views of the private school officials, it may submit a complaint through the Formal Complaint Process to the GaDOE. If the private school is not satisfied with the decision of the GaDOE, they may submit the complaint to the United States Department of Education (USDOE).

When the Individual and subsequent Individual Service Plans are developed, TCS will ensure

that a representative of the private school attends the meeting. If the representative cannot attend,

TCS shall use other measures to ensure participation, including individual or conference telephone calls.

• No parentally placed private school child with a disability has an individual right to receive some or all the Special Education and related services that the child would receive if enrolled in the district.
• For children ages 3-21, TCS is required to expend an amount that is the same proportion of its total Part B of IDEA flow-through funding as the number of private school children with disabilities, ages 3-21, residing in its jurisdiction is to the total number of children with disabilities, ages 3-21, in its jurisdiction
• For children ages 3-5, Trion City Schools is required to expend an amount that is the same proportion of its IDEA preschool funding as the number of private school children with disabilities, ages 3-5, residing in its jurisdiction is to the total number of children with disabilities, ages 3-5, in its jurisdiction.
• If a private school/homeschool student is found to be eligible for Speech/Language services, an Individual Service Plan (ISP) will be developed to provide Speech/Language services. Services will be provided at the private school. The Individual Service Plan (ISP) will be reviewed annually.  An Individual Education Plan (IEP) will be offered if the student intends to enroll in TCS, and if the student does not enroll, a new Service Plan will be written if the student remains eligible. When the Individual and subsequent Individual Service Plans are developed; TCS will ensure that a representative of the private school attends the meeting. If the representative cannot attend, TCS shall use other measures to ensure participation, including individual or conference telephone calls.

Equitable services will be provided. Services provided to private school children with disabilities will be provided by personnel who meet the same standards as personnel providing services in the public schools, except the personnel are not required to meet the highly qualified definition.

However, parentally placed private school children with disabilities may receive a different amount of services than children with disabilities in public schools.

TCS works with private schools and parents to determine most appropriate options to provide a student with FAPE.

The Student Support Services Director of TCS will work with the parent and private school to determine options for locations of services and transportation. Services may be provided at the private school or children may be transported to the public school or community seeking to receive services.

Transportation may be provided by the system but cannot transport the child from home to the private school. Transportation costs will be included in calculating whether the system has met the requirements of proportionate funding.

TCS controls and administers the funds used to provide Special Education and related services and holds title to and administers materials, equipment, and property purchased with those funds. The system ensures that the equipment and supplies placed in a private school are used only for Special Education purposes and can be removed from the private school without remodeling the private school facility. The school district will ensure all materials purchased for private school use will remain secular in nature, neutral, and non-ideological. Equipment and supplies may be removed from a private school by TCS if they are no longer needed for Special Education purposes or the removal is necessary to avoid their unauthorized use for other than Special Education purposes.

To meet the requirements for provision of services to parentally placed private school children, TCS follows these guidelines:

• For children ages 3-21, the district must expend an amount that is the same proportion of the district’s total Part B of the IDEA flow-through funding as the number of private school children with disabilities, ages 3-21, attending private and home schools in its jurisdiction is to the total number of children with disabilities in its jurisdiction.

• For children ages 3-5, the district must expend an amount that is the same proportion of the district’s preschool funding as the number of private school children and home-schooled children with disabilities, ages 3-5, attending private and home schools in its jurisdiction is to the total number of children with disabilities, ages 3-5, in its jurisdiction.

If the district has not expended all the funds required by the end of the fiscal year, the district must carry over funds for a period of one additional year to be used for proportionate share.

The district must consult with representatives of the private school in deciding how to conduct the annual count of the number of private school children with disabilities who reside in its jurisdiction.

The district must ensure that the child count is done on October FTE-1 of each year since this count is used to determine the amount the district must spend in the following fiscal year.

Parentally placed private school provisions are to be applied to preschool-aged children only when these children who are eligible for a service plan attend private nonprofit elementary school (grades K and higher).

Preschool students who attend private preschools within their district of residence are served by the district through an IEP.

Parentally placed private school preschool students who attend private preschools (that are not

considered elementary or secondary schools) outside their residential district are not entitled to

services from that district.

Each district must maintain records and report to the GaDOE the following information related to

parentally- placed private school children:

• The number of children evaluated
• The number of children determined to be children with disabilities
• The number of children served

Monitoring of Proportionate Share Funds

Service Plans will be developed and implemented for each private school student with disabilities who will receive services from the school district. TCS will initiate and conduct the meetings to develop, review, and revise service plans.

• All service plans are written in GO IEP
• The Student Support Services Director of TCS will attend all private school meetings, read, and provide feedback on all service plans and will monitor all plans.
• The Student Support Services Director will remain in close contact with the SLP for updates on all students.
• During each fiscal year, at the end of March, Proportionate Share fund balances are reviewed
• If materials are purchased with Proportionate Share funds, materials/equipment are marked as such
• If TCS has not expended all the funds required by the end of the fiscal year, the
• district must carry over funds for a period of one additional year to be used for Proportionate Share
• TCS will ensure that the Child Count is completed and accurate in October FTE-1 of each year.

Monitoring and Professional Learning

The Student Support Services Director will provide ongoing professional learning for policies and procedures for serving students in private schools. Teachers will be administered monthly Compliance Modules to assist with monitoring and assess understanding. Teachers who receive a score below 80% proficiency will receive technical assistance. Those who continue to have difficulty with procedures and policies will be reported to the building administrator and placed on a Corrective Action Plan. Yearly TKES evaluations will be impacted for those teachers who continue to have difficulty, after technical assistance has been provided, with policies and procedures for serving students in private schools.

Fiduciary Responsibility

Maintenance of Effort for ESSA and IDEA

GADOE compares the fiscal effort of the preceding year to the second preceding fiscal year and makes the maintenance of effort determination available to the system through a marked “met” or “unmet” on the Consolidated Application. The calculation in the GaDOE portal determines which funds should be excluded from the calculation. Documentation for MOE is only required for districts that do not meet the required maintenance of effort. Program Directors will pull the MOE information from the Consolidated Application each school year for documentation purposes.

Comparability

The Federal Program Directors annually completes the Comparability of Services utility in the GaDOE portal. To date, TCS has always provided comparable services. If comparability is not met, the Federal Program Directors will work with school system and school leaders to re-assign personnel to ensure comparability of services to students in all Title I Schools. The system has a current RAMP in place to ensure that comparability is met.

Resource Allocation and Management Plan (RAM/P)

Trion City Schools is a public Strategic Wavier School System in Georgia pursuant to O.C.G.A. §20-2-81.  As a SWSS, the district and its schools have developed a five-year strategic plan for improving the performance of its schools. The local board has proposed a contract reflecting its strategic plan for each of its schools including components for flexibility, accountability, and consequences as contemplated by state law.  In exchange for this flexibility and waiver, the district intends to demonstrate high academic achievement and student performance.

The Trion City School System currently has one elementary school, one middle school, one high school, thus no RAM/P is required.

Assessment Security and Reporting of Accountability

The Trion City School System takes the ethical responsibility to provide secure and appropriate testing environments for its students very seriously. In all tests, including state or federally mandated test the Trion City School system requires its employees to act in accordance with specific guidelines mandated by the testing agency and the general guidelines of the Georgia Department of Education. For every administration of a high stakes assessment the following guidelines will be followed.

• The district test Directors will stay current on appropriate testing rules and practice by viewing required DOE webinars and reading all manuals and memorandums associated with the test.
• All school test Directors will be appropriately trained by the system Directors within a two-week period prior to the assessment window opening.
• School test Directors will in turn provide mirrored training to all test examiners and proctors who will be taking part in the test.
• Records of participation and sign-in sheets of each of these meetings will be maintained in a centralized location for a minimum of five years.
• Trainings at every level will include a segment covering testing ethics and ethical behavior in testing environments.
• Test materials, when on site, will be continuously maintained in a secured and locked room with access limited to only those who are functioning as school test Directors or assistant test Directors.
• School campuses will be quiet and organized on the day(s) of testing.
• Any irregularity or anomalous event taking place in a school during testing will be promptly and fully reported to the district test Directors.
• Irregularities involving possibly illegal or unethical actions on the part of an employee will be reported to the Georgia Professional Standards Commission.
• If the anomaly rises to the level of an irregularity, it will be promptly reported to the Georgia Department of Education.
• When test results are returned, they will be disseminated to students and parents in a reasonable time frame.
• Assessment results will be communicated to the public via press releases, sections of the school website, and other means, as necessary.
• Assessment practices and security measures will be communicated to the public via school newsletters in the month prior to the testing window.

Consequences for Violations Related to Assessment Security

Any employee who suspects a breach in assessment security must immediately report the breach to their immediate supervisor. Failure to report suspected breaches in assessment security can have negative implications upon an employee. In addition, any investigation that results in a determination of guilt related to violations of assessment security can result in loss of employment and a report filed with the Georgia Professional Standards Commission, which may result in loss of a teacher’s certificate.

Internal Controls

Code of Federal Regulations

The Trion City School System operates their federal grants in accordance with the Code of Federal Regulations.

Cost Principles

Allowability of Costs (CFR 200.302(b)(7))

Any purchases made with federal funds must follow the guidelines for allowable costs. Trion City School System Office of Federal Programs will follow guidelines as detailed in EDGAR, OMB Circulars (such as A-87), and applicable memos, letters, handbooks, and/or communication regarding allowable/unallowable purchases provided by the Georgia Department of Education. The appropriate program Directors will direct any questionable expense to the GaDOE Area Program Specialist for that program for further clarification.

Federal funds cannot be used to purchase incentives for students, teachers, or to entice participation in professional learning activities. Food for Family Engagement activities must be considered “light refreshments.”  Trion City Schools does not utilize federal funds for this purpose though.

Financial Management ~ Process to Review Expenditures to Determine Allowability

The following procedures must be followed to ensure the proper handling of federal funds:

1. Each budget is reviewed by the Federal Program Directors to ensure alignment to system (CLIP) and school improvement plans (SIPs), revised as necessary, and approved by the program Directors.  Once the system or school makes the necessary changes and the budget is submitted and approved by the GaDOE, each department or school completes a requisition(s).  
2. Requisitions must include:

1. Complete vendor information including phone number (and fax number if applicable)
2. Ship to information including the address for the delivery location
3. Appropriate account number assigned by the Federal Program Directors based on the budget sheets
4. Sufficient detail to determine if each cost item is allocable, reasonable, and necessary.
5. If a requisition is between $3,500 and $4999, two quotes must be obtained and attached to the requisition. If a requisition is between $5,000 and $9,999, threes quotes must be obtained and attached to the requisition.
6. If the requisition is over $10,000 three or more written bids must be obtained and must be reported to the Board of Education by the Federal Program Directors.
7. If the requisition is over $25,000 the requisition must be approved by the Board of Education.

3. No purchase or contract shall be divided into parts for the purpose of avoiding the above requirements.  
4. The Federal Program Directors reviews the requisition to assure that the purchase is included in the Schoolwide/School Improvement Plan and that the expense is allocable, allowable, reasonable, and necessary.
5. If approved, the Federal Program Directors then signs off on the requisition which forwards the requisition to the Finance Directors for approval.
6. If approved, requisitions are then issued a purchase order by the administrative assistant and the order is then placed.
7. If rejected, the requisition is returned with reasoning. It can then be corrected and sent back through the process again or filed as unpurchased.
8. When the ordered item arrives, the school or department compares what is received with what was ordered and acknowledges receipt of the item or items. Any disputes are reconciled between the Federal Program Directors and the vendor.

Invoices

The following procedures are followed for invoices:

• Receipt of Invoice: Invoices are received by the administrative assistant.
• As stated above, the school/department will match the order as he or she receives it with the purchase order and acknowledges receipt of the item or items and sends it to the administrative assistant. The purchase order cannot be paid unless the item is received in the system.
• The administrative assistant compares vendor invoices to purchase orders. If these items match, the invoice is entered as an account payable. If not, the administrative assistant alerts the Federal Program Directors who work together to determine a solution.

 Payment of Invoice:

The following procedures are followed for payment of invoices:

• The administrative assistant charges the expenditures to the proper fund/program designated on the purchase order by the Federal Program Directors in the system financial software, PC Genesis.
• If invoices received that are charged to a federal program exceed the amount of purchase orders, the administrative assistant alerts the appropriate Federal Program Directors who works to determine a solution.
• Disbursement is not made until the invoice is validated as owned by the district and received by the system by receiving individuals.
• Open purchase order reports are noted on monthly expenditure reports provided to the appropriate Federal Programs Directors or upon request to determine if goods or services have in fact been received but not invoiced by the vendor. Contact is made with the vendor to secure an invoice if such instances are noted.  

Segregation of Duties (CFR 200.303(a))

The Trion City School System (TCSS) requires the following segregation of duties associated with cash management to prevent errors and fraud.

Finance Director

Under the supervision of the Superintendent, the Finance Director will carry out the following duties:

• Prepare monthly and annual financial statements for inspection by the Board of Education.
• Establish accounting procedures to ensure that proper internal controls are maintained for the district business office
• Manage cash flow and investment of available funds.

• Assist the Superintendent in preparation of financial data for the tax digest, state allotments, and other financial areas.
• Open all bank accounts and reviews prior to reconciliation. Approves reconciliations of other staff members.
• Oversee the reconciliation of all accounts.
• Supervise operation of finance office to include payables and payroll.
• Compile annual budget for board approval and submit to the Georgia Department of Education.
• Coordinate accounting procedures to ensure that central office and local school administrators follow proper procedures in the budgeting, record keeping, and expending of program funds for which they are responsible.
• Oversee, approve and post monthly and year-end adjustments, run and balance reports.
• Oversee and assist with the preparation and submission of year end and interim financial reports to the Georgia Department of Education.
• Manage funds for SPLOST, Capital Projects, and Debt Service.
• Ensures a yearly audit is completed and submitted to the Department of Audits and Accounts.
• Compile data for audit, work with state auditors during audit, and prepare MD&A for audit report.
• Perform other duties as assigned by the Superintendent.
• Assist in the implementation of accounting procedures by maintaining accurate records and internal controls throughout the system and ensuring compliance with all applicable regulatory requirements.
• Perform journal entries, budget adjustments, and bank reconciliations.
• Close books at month and year end.
• Compile data for audit, work with state auditors during audit,
• Perform payroll accruals and reversals.
• Oversees internal audits.
• Assist with any duties required for annual audit preparation.
• Complete 1099’s.
• Request federal and state grant reimbursements.
• Submit annual completion reports on all federal and state grants.
• Process receipts.
• Record school lunchroom deposits.
• Compile data for audit and work with state auditors during audit.
• Ensure drawdowns are based on actual expenditures and minimizing the time between the transfer of funds.

HR Directors

Under the supervision of the Finance Directors, the HR Directors will carry out the following duties:

• Process monthly payroll and reporting for all system employees.
• Invoice for any payroll reimbursements.
• Prepare year-end reporting, including W-2’s.
• Calculate sick leave for retirement.
• Assist with budget preparation.
• Calculate salary adjustments
• Records Management
• Oversees verification of employment
• Prepare quarterly tax reporting.
• Compile data for audit, work with state auditors during audit

Administrative Assistant

• Prepare invoices.
• Pay invoices as they become due
• Enter vendors into the accounting software
• Compile data for audit, work with state auditors during audit

Federal Program Directors

Under the direction of the Superintendent, the Federal Program Directors will carry out the following duties:

• Coordinate, monitor, and provide technical assistance to schools for federal programs
• Monitor all purchases to ensure that expenditures are allocable, reasonable, and necessary. Ensuring all system policies for purchasing, expending funds, and inventorying equipment are followed to avoid fraud, waste, abuse, and corruption. No items will be purchased without prior approval, and all items purchased must be a part of the approved budget.
• Approve each purchase requisition/order, travel expense statement and professional learning (PL) leave that is funded through federal funds. Meet with the administrative assistant, HR Directors, and Finance Directors as needed and request financial reports to ensure alignment and balance on at least a monthly basis. Meet with and/or email principals or designees to ensure accuracy of school budgets.
• Ensure system and school inventories are maintained electronically and kept up to date.
• Complete a physical inventory check at each facility each year. Purchase Orders are pulled from object codes 615 and 616 to verify if each item is included in each school’s and the central office’s inventory.
• Ensure each employee is trained on his/her responsibility regarding fraud and the channels to report it if suspected annually.
• Monitor each object code by encumbering the money, balancing each object code, and matching invoices to the posted encumbered monies.
• Maintains accurate records and internal controls (e.g. ledgers) ensuring compliance with all applicable regulatory requirements and accuracy of fund balances (object codes).
• Assists the administrative assistant with processing purchase requisitions, verifying available funds for accounts charged to system accounts, and payment of invoices.
• Reviews financial information for potential budget variances and ensures fund balances are accurate.
• Maintains a wide variety of financial records to ensure compliance and the availability of documentation.
• Reviews purchase requisitions, travel expense statements, and registration payments for compliance and accuracy.
• Manages the Consolidated Application budgets.
• Assists auditors by providing supporting documentation and/or information on internal processes (including financial documents, professional learning documentation, equipment inventory, and all Title IA cross functional monitoring documents)
• Grants final approval on all professional learning is completed by the Assistant Superintendent for Teaching and Learning who ensures that all activities are research-based.
• Assists auditors by providing supporting documentation and/or information on internal processes (including financial documents, professional learning documentation, and all Title III, Migrant, Immigrant, Homeless cross functional monitoring documents).

Procurement (CFR 200.319(c))

All procurement transactions for the acquisition of property or services required under a Federal award shall following Georgia Procurement guidance. Micro-purchases, those less than $5,000, shall be made with effort to provide the least expense to the District with micro-purchase thresholds at $10,000. Purchases shall be based on one or more oral quotations, when possible, to determine best price. Services, supplies or equipment estimated to cost $5000 to $10,000 will require three written quotes or website references. Evidence of the quotes must be attached to the purchase order/requisition in the financial software program. All services, supplies or equipment estimated to cost over $10,000 must use a bid or request for proposal and will be posted on the District website and the Georgia Procurement website. Evidence of the Bid or RFP must be attached to the purchase order/requisition in the financial software program. Grantee must have and use documentation procurement procedures which include the following methods: (a) informal procurement methods include micro-purchases and small purchase procedures (b) Formal procurement methods include sealed bids and proposal. If purchases are made through RESA, compliance with the above procedures is not required. The price must be considered reasonable based on research, experience, and purchase history or other information. The documentation must be on file accordingly.

Competitive proposals or bids twenty-five thousand dollars ($25,000) or greater shall be approved by the Board of Education. Competitive proposals or bids ten thousand dollars ($10,000) or greater shall be approved by the Board of Education if the low bid is not recommended. Purchases between $10,000 and $25,000 shall be reported to the Board at its next meeting. In compliance with Section 2 CFR 200.319, any purchases more than $150,000 including contract modifications will require a cost or price analysis, sealed bids, and/or competitive proposals. Cost analysis means evaluating the separate cost elements that make up the total price, including profit. Price analysis generally means evaluating the total price.

Sole source bids may be used only when one or more of the following circumstances apply:

1. The item is available only from a single source.
2. The public emergency for the requirement will not permit a delay resulting from competitive bidding.
3. The federal awarding agency or pass-through entity expressly authorizes noncompetitive proposals in response to written requires from non-federal entity.
4. After soliciting several sources, competition is determined inadequate.

No purchase or contract shall be divided into parts for the purpose of avoiding the competitive bid process.

All noncompetitive procurement can only be awarded in accordance with 200.32(c).

The Federal Program Directors checks Georgia’s System for Award Management (SAM) website, https://www.sam.gov/portal/SAM/##11 prior to approving any purchase equal to or more than $25,000 to ensure the vendor is not on the list of suspension and debarment. The resulting check must be printed, signed, dated, and uploaded to the requisition/purchase order.

Technical Evaluations of Competitive Proposals and Selecting Recipients (CFR 200.320(d)(3))

Trion City School System shall ensure that the process of procuring goods and services is fair and equitable by taking the following measures:

• Incorporating a clear and accurate description of the technical requirements for the material, product, or service to be procured. The description must not, in competitive procurements, contain features which unduly restrict competition. The description may include a statement of the qualitative nature of the material, product or service to be procured and, when necessary, must set forth those minimum essential characteristics and standards to which it must conform if it is to satisfy its intended use.
• Avoid providing detailed product specifications.
• When it is impractical or uneconomical to make a clear and accurate description of the technical requirements, a “brand name or equivalent” description will be used to define the performance or other salient requirements of procurement. The specific features of the named brand which must be met by offers will be clearly stated.
• Identify all requirements which the offers must fulfill and all other factors to be used in evaluating bids or proposals.
• Ensure that all prequalified lists of persons, firms, or products which are used in acquiring goods and services are current and include enough qualified sources to ensure maximum open and free competition. Also, the school system will not preclude potential bidders from qualifying during the solicitation period.

The Board of Education may reject any or all bids. The Board may in its judgment consider such factors as service, location, and timeliness of delivery; therefore, they may accept the bid that appears to be in the best interest of the school system even if it is not the lowest bid. The Board reserves the right to waive any formalities in or reject any or all bids or any part of any bid. Any bid may be withdrawn prior to the scheduled time for the opening of bids.

Contracts binding the school district can be made only by the Board or the Superintendent or approved agent.

Conflict of Interest (CFR 200.318(c))

Standards of Conduct: Employees of the Trion City School System who are engaged in the selection, award and administration of contracts shall abide by the following:

• No employee, officer, or agent may participate in the selection, award, or administration of a contract supported by a federal award if he or she has a real or apparent conflict of interest.
• Definition: such a conflict of interest would arise when the employee, officer, or agent, any member of his or her immediate family, his or her partner, or an organization which employs or is about to employ any of the parties indicated herein, has a financial or other interest in or a tangible personal benefit from a firm considered for a contract.
• No employee, officer or agent may participate in selection, award, or administration of a contract supported by a federal award if he/she has a real or apparent conflict of interest.
• Officers, employees, and agents of the Trion City School System may neither solicit nor accept gratuities, favors, or anything of monetary value from contractors or parties to subcontracts.
• Violation of these standards will result in reporting of said personnel to the Superintendent of Schools and if appropriate, local authorities. Any misconduct could result in suspension, loss of employment, and any other consequences that are applicable by law.
• Any violation of these procedures must be disclosed in writing, in a timely manner. All violations of federal criminal law involving fraud, bribery, or gratuity violations potentially affecting the federal award must be reported as failure to make disclosures can result in (remedies for noncompliance, including suspension and debarment).

Chain of Command for Reporting Potential Conflicts of Interest

Anyone who becomes aware of a potential conflict of interest related to the use of federal funds should report their suspicion to their immediate supervisor. If at the school level, it should be reported to the principal. The principal should report the suspected conflict of interest to the superintendent.

Definition of Nominal Items

Nominal items are those items that are less than $100 in cost.

Best Practices for Avoiding Conflicts of Interest

The following best practices will be used to avoid conflicts of interest:

• Ensuring that all purchases follow the guidelines outlined in this document.
• Checking with supervisors when in doubt if a conflict of interest may occur.

The following will be used to avoid conflict of interest by board of education members:

Board Member Conflict of Interest, Policy BHA

The Trion City Board of Education shall adhere to these Conflict of Interest provisions, as set forth in state law.

Financial Governance

1. No Board member shall use or attempt to use his or her official position to secure unwarranted privileges, advantages, employment for himself or herself, any of his or her immediate family members, or others.
2. No Board member shall act in his or her official capacity in any matter in which he or she, any of his or her immediate family members, or any business organization in which he or she has a material financial interest, that would reasonably be expected to impair his or her objectivity or independence of judgment. Compliance with Code Section 20-2-505 shall not constitute a violation of this paragraph.
3. No Board member shall solicit or accept or knowingly allow any of his or her immediate family members or any business organization in which he or she has an interest to solicit or accept any gift, favor, loan, political contribution, service, promise of future employment, or other thing of value based upon an understanding that the gift, favor, loan, contribution, service, promise, or other thing of value was given or offered for the purpose of influencing that board member in the discharge of his or her official duties. This paragraph shall not apply to the solicitation or acceptance of contributions to the campaign of an announced candidate for elective public office if the local board of education member has no knowledge or reason to believe that the campaign contribution, if accepted, was given with the intent to influence the local board of education member in the discharge of his or her official duties. For purposes of this paragraph, a gift, favor, loan, contribution, service, promise, or other thing of value shall not include the items contained in subparagraphs (a)(2)(A) through (a)(2)(J) of Code Section 16-10-2.
4. No Board member shall use, or knowingly allow to be used, his or her official position or any information not generally available to the members of the public which he or she receives or acquires in the course of and by reason of his or her official position for the purpose of securing financial gain for himself or herself, any of his or her immediate family members, or any business organization with which he or she is associated.
5. No Board member or any of his or her immediate family members or any business organization in which he or she has an interest shall represent any person or party other than the local board of education or local school system in connection with any cause, proceeding, application, or other matter pending before the local school system in which he or she serves or in any proceeding involving the local school system in which he or she serves.
6. No Board member shall be prohibited from making an inquiry for information on behalf of a constituent if no fee, reward, or other thing of value is promised to, given to, or accepted by the local board of education member or any of his or her immediate family members in return therefor.
7. No Board member shall be deemed in conflict with these provisions if, by reason of his or her participation in any matter required to be voted upon by the local board of education, no material or monetary gain accrues to him or her as a member of any profession, occupation, or group to any greater extent than any gain could reasonably be expected to accrue to any other member of that profession, occupation, or group.
8. No Board member may also be an officer in any organization that sells goods or services to that local school system, except as provided in Code Section 20-2-505 and excluding nonprofit membership organizations.
9. No Board member shall be deemed in conflict with these provisions if, by reason of his or her participation in any matter required to be voted upon by the local board of education, no material or monetary gain accrues to him or her as a member of any profession, occupation, or group to any greater extent than any gain could reasonably be expected to accrue to any other member of that profession, occupation, or group.
10. No Board member shall sell to any county board any supplies or equipment used, consumed, or necessary in the operation of any public school in this state unless there are fewer than three sources for such supplies or equipment within the county; provided, however, that any purchase pursuant to this subsection for supplies or equipment that is equal to or greater than $10,000.00 shall be approved by a majority of the members of the board in an open public meeting. Any member violating this shall be guilty of a misdemeanor.
11. No local board may do business with a bank or financial institution where a Board member is an employee, stockholder, Directors, or officer when such member owns 30% or more stock in that institution.
12. No Board member may have a financial interest in school buses, bus equipment or supplies, provide services for buses owned by the Board, or sell gasoline to the Board from a corporation in which the Board member is a shareholder.
13. No Board member shall accept a monetary fee or honorarium in excess of $101.00 for a speaking engagement, participation in a seminar, discussion panel, or other activity which directly relates to the official duties of that public officer or the office of that public officer. Actual and reasonable expenses for food, beverages, travel, lodging, and registration for a meeting which are provided to permit participation in a panel or speaking engagement at the meeting shall not be monetary fees or honoraria.

Conduct as A Board Member

1. No Board member shall disclose to or discuss with any information which is subject to attorney-client privilege belonging to the local board of education to any person other than other Board members, the Board attorney, the local school superintendent, or persons designated by the local school superintendent for such purposes unless such privilege has been waived by a majority vote of the whole Board.
2. No Board member shall vote on the employment or promotion of any of his or her immediate family members. No immediate family member of a Board member may be employed or promoted unless a public, recorded vote is taken separately from all other personnel matters.
3. No Board member may be employed in any position in the school district in which they serve.
4. No Board member shall hold another county office.
5. No Board member shall be employed by the State Department of Education or serve concurrently as a member of the State Board of Education.
6. No Board member shall serve on the governing body of a private elementary or secondary educational institution.

Each member of this Board understands and acknowledges that no person shall be eligible for election as a member of a local board of education unless he or she:

(1) Has read and understands the code of ethics and the conflict of interest provisions applicable to members of local boards of education and has agreed to abide by them; and

(2) Has agreed to annually disclose compliance with the State Board of Education's policy on training for members of local boards of education, the code of ethics of the local board of education, and the conflict of interest provisions applicable to members of local boards of education.

Each person offering his or her candidacy for election as a member of a local board of education shall file an affidavit with the officer before whom such person has qualified for such election prior to or at the time of qualifying, which affidavit shall affirm that he or she meets all of the qualifications required pursuant to this subsection. This subsection shall apply only to local board of education members elected or appointed on or after July 1, 2010.

Personal Compensation

Payroll

Federal Program Directors work with the HR Director and Finance Director to ensure payroll reports are accurate. In addition, each program Directors ensures that the number of federally funded employees is consistent with the approved application. Monthly payroll reports, expenditure summary and detail reports, and substitute reports will be used to ensure that each object code is accurate.

Contracted Services

Federal Programs Directors work with the HR Director and Finance Director to ensure compliance and accuracy. Each program Directors ensures that contracts are fulfilled, budgeted correctly, and that services were provided in accordance with the purchased services contract.

Time and Effort

Charges to a federal fund for salaries and wages must be based on records that accurately reflect the work performed by all employees who salaries or other compensation are paid in whole or in part with federal funds. A time sheet must be maintained by any employee who provides supplemental instruction outside of school hours. The appropriate Federal Program Directors will ensure that an annual periodic certification or personnel activity report will be maintained for all employees paid with federal funds.

Periodic Certification

An annual periodic certification will be maintained for any employee who worked on one federal grant or one cost objective (job). These certifications will be completed after-the-fact and must account for the total activity performed. The certification will be completed at the end of June (or on the last contracted day of the school year for employees who do not work year-round) and will be completed on one form per work site. The forms are signed, collected, and kept on file in the office of the appropriate federal fund Directors.

Personnel Activity Report (PAR)

A PAR will be maintained for any employee who works on more than one federal grant and more than one cost objective (job). Split-funded personnel paid with federal funds are required to maintain monthly time logs that coincide with one or more pay periods that must account for the total activity performed. The logs are shared among the employee, his or her supervising administrator, and the appropriate Federal Program Director always. Logs will be signed by the employee and the employee’s immediate supervisor. The appropriate Federal Program Director is responsible for checking monthly to ensure logs are being maintained. Additionally, the Directors will work with the employee to complete reconciliation and appropriate adjustments will be made prior to the end of the school year.

Stipends (GA 160-3-3-.04)

Stipends will be paid to certified personnel for having successfully completed previously approved learning opportunities that have occurred at any time during the fiscal year outside of the employee’s normal contract hours at the agreed upon rate per hour. The Trion City School System does not pay stipends for work on an award for performance. Any stipends awarded must be reasonable and necessary to the federal program.

Stipends will only be awarded if the following conditions exist:

• There is evidence that the knowledge, skills, practices, and dispositions gained from the professional learning activity are aligned to an approved individual plan, or a school or LEA initiative and/or product, and/or specific goals; and
• There is evidence that the knowledge, skills, practices, and dispositions developed through participation in or facilitation of professional learning have been implemented/ demonstrated in the classroom/work setting; and
• Participation occurs beyond regular contract hours, days, or school year.

State and federal funds designated for professional learning shall not be used to pay stipends to school board members or to school council members who are not employees of the LEA. The appropriate Federal Program Directors will maintain the appropriate paperwork to ensure employees are adequately compensated.

Leave Policy

This policy shall apply to all benefits-eligible employees of the Trion City Board of Education (“the Board”). All employees are required to follow the appropriate work calendar established by the Board for their positions and may take leave from work only in accordance with this policy or other leave policies enacted by the Board. Unless otherwise provided by the Board, principals and other supervisors are not authorized to rearrange the work calendars of employees. Deductions in pay will be made for absences not covered by this policy.

Accrual of Sick Leave and Absence for Medical and Related Reasons

Each benefits-eligible employee of the Board shall be allowed to earn sick leave, with full pay, computed based on one and one-fourth (1 1/4) working days for each completed month of service. All employees may accumulate unused sick leave from one fiscal year to the next up to a maximum of one hundred and thirty (130) days, although the Teacher Retirement System of Georgia allows participating employees to accumulate an unlimited number of unused sick leave days for credit toward retirement.  Sick leave accumulated by a certificated employee or bus driver is transferable from one school system to another, up to a maximum of forty-five (45) days. When employees transfer to the Trion City School System from another public-school system, any transfer of leave must take place within one year of separation from the previous position. It is the employee's responsibility to request and confirm this transfer from the former system. Accumulated leave earned by a certificated employee must be forfeited if such employee withdraws from service for twelve or more consecutive months, but such forfeited leave may be reinstated in accordance with the provisions of O.C.G.A. § 20-2-850. Accumulated leave earned by a bus driver under O.C.G.A. § 20-2-1110 must be forfeited if the driver withdraws from service for twenty-four (24) or more consecutive months.

Sick leave may be used upon the approval of the Superintendent or designee for absence due to personal illness or injury, exposure to contagious diseases, or for absences necessitated by illness or death in the employee's immediate family.

For any absence in which sick leave is used, the Superintendent or designee may require a physician's certificate stating that the employee is ill and is unable to perform his or her duties. If sick leave is used to care for a member of the immediate family, the Superintendent or designee may require a physician's certificate stating that the employee is needed to care for the sick family member. If an employee is absent for three (3) consecutive days of sick leave, a physician's certificate may be required at the discretion of the Superintendent or designee.

For the purposes of absences for medical and related reasons, members of the immediate family are defined as spouse, children, parents, siblings, in-law equivalents of the same, grandparents, grandchildren or any dependent as shown in the employee's most recent tax return.

Family and Medical Leave Act (FMLA)

See board Policy GBRIG.

Unpaid medical Leave

This benefit is provided to employees who:

1. have been employed with the school district for at least twelve (12) school months; and
2. are unable to return to work due to a personal medical necessity or that of a spouse or child; and
3. are at the end of an approved FMLA leave, or are not FMLA-eligible; and
4. have exhausted all paid leave; and
5. provide appropriate medical documentation.

If the unpaid medical leave is granted, the leave will be from the system and not from a specific job assignment.

Any benefits-eligible employee who meets the above criteria may request unpaid medical leave. Unpaid medical leave may be granted for a period of time up to one hundred and thirty (130) scheduled work days or until the end of the school year, whichever occurs first, and shall be inclusive of any previously used FMLA, sick or other TCSS leave by the employee.

The employee on unpaid medical leave may continue as an active employee of the school district with all rights afforded to active employees with the exception of benefit premium payments, which must be paid by the employee and is inclusive of both the employee premium and any appropriate employer subsidy rate or employer contribution.  Failure to make such payments will result in a lapse and forfeiture of the benefit in question.

Upon designation of unpaid medical leave status, the employee’s previous position will be declared a vacant position and may be filled.

Prior to returning to work, employees on unpaid medical leave will be required to submit a health care provider’s certification that verifies the employee’s ability to return to work and perform the essential functions of his/her position.

An employee who has been granted unpaid medical leave may return to active employment upon written request for reassignment and contingent upon a vacancy for which he/she is qualified. Requests should be submitted as soon as an employee knows that he/she plans to return to work.

An employee granted unpaid medical leave will be considered for any vacancy for which he/she is qualified. Return to work may be delayed until the beginning of a semester or fiscal year as deemed appropriate by the school system.  Classified employees who are unable to return to work at the end of the unpaid medical leave may be separated from employment. Certificated contract employees who are unable to return to work at the end of the unpaid medical leave shall have whatever rights due process provides for such employees.

Personal and Professional Leave

During any school year, personnel may utilize up to a maximum of three days of any accumulated sick leave for personal or professional reasons if prior approval of their absence is given by the local school superintendent or his authorized representative; provided, however, that the absence is not in conflict with a local board of education policy concerning school days on which the presence of the personnel requesting absence is essential for effective school operation. Such leave will not be approved during system-mandated testing. Leave requests during the first and last week of school should be made for emergency situations only.

No grant of approval for an absence permitted under this section shall be conditioned upon disclosure of the specific purpose for which such absence is sought, nor shall any such grant of approval be withheld or denied because of the failure or refusal of personnel to disclose the specific purpose for which such an absence is sought; provided, however, that personnel may be requested to state whether the absence is sought under the category of "personal" or "professional" absence.

Professional leave taken at the request of the school district or when required in conjunction with the district's routine professional development or training activities will not be charged against the employee's sick leave.

Observance of Religious Holidays

Employees may use personal leave and vacation leave for the observance of recognized religious holidays. If an employee desires to take leave for the observance of recognized religious holidays in excess of the days allowed for personal leave or vacation leave, the employee may take unpaid leave for such purposes, provided that such leave is not excessive and does not interfere with fulfilling the obligations of his or her job.

Jury and Witness Leave

Each employee shall be allowed leave with pay for the purposes of serving as a juror in any court or when attending a judicial proceeding in response to a subpoena or other court order or process that requires the employee's attendance at the judicial proceeding in a work-related matter. Jury and/or witness leave shall not be deducted from an individual's accumulated personal, professional, or sick leave. No employee utilizing jury or witness leave shall be required to pay the cost of employing a substitute to serve during his or her absence for such leave. Employees who serve on juries or who are subpoenaed to attend a judicial proceeding in a work-related matter may keep any jury/witness pay they receive.

Military Leave

All employees are entitled to paid leave not to exceed eighteen (18) days in any one federal fiscal year for the purpose of complying with ordered military duty with the armed forces of the United States or State of Georgia, including duty as a voluntary member of the National Guard or any reserve component of the United States or State of Georgia.  Employees are entitled to leave not exceeding thirty (30) days in anyone (1) federal fiscal year if ordered to duty because of the declaration of any emergency by the governor or appropriate officials of the United States Armed Forces.  Employees who have military commitments shall inform the Superintendent or designee annually, provide a copy of the official military orders, and cooperate to the extent possible in scheduling such leave so as to minimize the disruption in those employees' duties and the mission of the Board of Education.

Bereavement Leave

In the event of a death in the immediate family of an employee, up to three (3) days of sick leave per death will be granted. Bereavement leave will be charged against the employee's accumulated sick leave. Employees may use personal leave for absence due to death of individuals other than immediate family members upon approval of the Superintendent or designee. If the employee desires to take bereavement leave more than the days allowed for personal leave, the employee may request to take vacation leave or unpaid leave. For the purposes of bereavement leave, members of the immediate family are defined as spouse, children, parents, siblings, in-law equivalents of the same, grandparents, grandchildren or relatives living in the employee's household.

Disclaimer

To the extent that any provision in this policy conflicts with or is superseded by the Family and Medical Leave Act ("FMLA"), the regulations promulgated thereunder, or any other federal or state law, the provisions of the applicable law or its regulations, as the case may be, shall control.

Substitutes for Teachers and/or Paraprofessionals

Schools must provide documentation monthly verifying the names of substitutes, teachers, or paraprofessionals names for whom the substitutes are working, time, date, and the type of leave for the teacher and/or paraprofessional absence.

Job Descriptions

Job descriptions have been developed, maintained, and provided to the GaDOE for approval for all positions paid with federal funding.

Travel Policy (CFR 200.474(b))

Costs incurred by employees and officers for travel, including costs of lodging, other subsistence, and incidental expenses, must follow the Georgia Statewide Travel policy set by the State Accounting Office, as well as the school system’s written reimbursement policies. Costs must also be considered reasonable and otherwise allowable only to the extent such costs do not exceed charges normally allowed by the Trion City School System in its regular operations as the result of the school system’s written travel policy. In addition, if these costs are charged directly to a federally funded source, documentation must justify that:

• Participation of the individual is necessary to the federal award; and
• The costs are reasonable and consistent with non-federal entities’ established travel policy or follow GSA 48 CFR 31.205-46a.
• A conference is necessary for the project by inclusion of an agenda.

The following procedures are intended to ensure that charges are reasonable and consistent.

• Principal approves the requests. Federal Program Directors must pre-approve any applicable federally funded PL before payment will be allowed.  
• A travel expense form must be completed in its entirety to receive reimbursement for expenses.
• Employees are responsible for ensuring that expenses claimed in the travel expense report are proper, accurate, and incurred for official business. A traveler who knowingly presents a false or fraudulent claim may be subject to penalties under criminal statutes.
• Employee completes and sends the “Travel Expense Statement” to the administrator for approval. The Federal Program Director verifies the information on the form and once deemed accurate, it is signed off on by the Finance Director, who in turns sends the request to the administrative assistant who enters the information into the system financial software. Failure to request reimbursement within 45 days of travel may result in a loss of or reduction of funds.
• Purpose of the trip must be included on the expense report.
• Attendees are responsible for maintaining and providing upon request information related to registration and dues and fees to include agenda, sessions attended, and proof of attendance.

Transportation

Mileage must be documented on a “Travel Expense Statement”. From the State Travel Regulations,

“Reimbursement for business use of a personally-owned vehicle is calculated per mile, from point of departure after deduction for normal commuting mileage, based on the current reimbursement rate.”

 Employees may be reimbursed for the mileage incurred from the point of departure to the travel destination but NOT for their normal commuting mileage. During the normal workweek, the point of departure will be either the employee's residence or headquarters; whichever is nearer to the destination point. If leaving from the residence you must deduct the normal commuting mileage to and from the worksite.

Employees traveling by personal vehicles and requesting reimbursement must record the actual odometer readings on the expense statement. Parking fees and tolls paid may be reimbursed and employees are expected to obtain receipts for these expenses. If it is not possible to obtain a receipt, a written explanation should be included on the expense statement.

Lodging

To receive reimbursement for lodging expenses, the following guidelines must be followed:

• Lodging must be documented on a “Travel Expense Statement”.
• Employees are responsible for making their own reservations and guaranteeing them.
• Employees are responsible for submitting a copy of the tax exemption form for state and local hotel/motel excise taxes if staying at a hotel in Georgia. Any tax paid, must have an explanation of why it was not waived, for example, paid with personal credit card, state does not allow or $5 State Hotel Motel Fee, no exemption allowed.
• Employees must travel more than 50 miles.
• Employees should use the least expensive rates for lodging. Any rates above this requires written authorization prior to the trip.
• Expenses must be broken down by date. Receipts are required.
• Any out-of-state travel must first receive the superintendent’s approval.

Subsistence

The following guidelines must be followed for the reimbursement of meals:

• Meal reimbursement cannot exceed the following: Breakfast - $6.00; Lunch - $7.00; Dinner - $15.00. Meals in Chatham, Cobb, DeKalb, Fulton, Glynn, and Richmond counties cannot exceed the following: Breakfast - $7.00; Lunch - $9.00; Dinner - $20.00.
• Meal reimbursement for out of state overnight travel are generally eligible for per diem amounts designed to cover the cost of three (3) meals per day for all days on travel status other than the day of departure and the day of return.
• Expenses must be broken down on the expense report per meal.
• Taxes and tips are allowed and should be included in the total. However, this total should not exceed the per meal rate.

Expense Reimbursement

• To receive expense reimbursement, the following guidelines must be followed:
• Employees must submit expense reports within 45 calendar days of completion of travel.
• The Trion City School System prefers and strongly urges all receipts to be attached to the travel expense report for verification and for future audit needs.
• Travel expense reports may be selected for audit at any time and all required receipts must be retained by the traveler for three years after the travel date if not attached to the expense report.
• All source documentation must be included.

Suspension & Debarment (CFR 180.220 & CFR 200.213)

Each Federal Program Directors and/or department head must check the System for Award Management (SAM) website, prior to approving any contract or subcontract expected to equal or exceed $25,000 to ensure the vendor is not on the list of suspension and debarment. Our district cannot and does not purchase from any vendor or contracted person/company identified on this website as being suspended or debarred. Evidence of the verification will be in the form of a search result screenshot printed, signed, dated, scanned, and attached to the requisition/purchase order.

Equipment Management (CFR 200.313(d))

An inventory of tangible personal property having a useful life of more than one year will be maintained at the system and/or school level. This includes all items purchased under state object codes 615 (expendable equipment) and 616 (expendable computer equipment).

Acquisition of Equipment

All newly acquired equipment must support initiatives in the district and/or a school’s improvement plan. Procurement procedures as outlined in this document must be followed to obtain equipment.

Method of Entering Information into the LEA’s Inventory Management System

Inventories will be maintained by designated individuals at each site on a spreadsheet hosted on Google Drive that at minimum includes the following: description of property, serial number or other identification number, funding source, FAIN number (on grant award), acquisition date, purchase price, location of asset, current condition, disposal date, sale price of property. Equipment must be entered within 30 days of equipment being received.

All equipment purchased is monitored by the appropriate system-level Federal Program Directors and school-level administration or their designee(s). All equipment purchased by schools must be properly labeled with an identification number and documented on the inventory sheet on Google Drive.

Off-site Use of Equipment

Every precaution must be taken to ensure that equipment used off-site by personnel and students is used for academic purposes and that the equipment is returned at the end of use free of damage and in good working order. Detailed records must be maintained on the equipment, its location, to whom it is checked out, and when it is returned.

Physical Inventory

District-level fall physical inventory: The appropriate Federal Program Directors of each funding source or designee will complete a physical inventory check at each facility annually, beginning in the fall and completed prior to the end of December. Purchase orders will be pulled from object codes 615, 616 to verify each item having a useful life of more than one year is included in the inventory, is located as assigned, and is being used for the intended purpose. The appropriate Federal Program Directors of each funding source will summarize with each principal and school level inventory contact(s) the results of the inventory monitoring check.

Equipment Disposition

The following guidelines must be followed:

Once a piece of equipment that was purchased with federal funds is no longer being used or capable of being used for its originally intended purpose, it can be designated as surplus. Once designated as surplus, the item can be used for a different purpose outside of federal funds guidelines. School-based representatives must request approval from both the principal and the appropriate program directors before items are designated as surplus so that a consensus is reached that the original purpose or intent has been met. An email is sufficient to achieve this.

• Items that are no longer usable will be disposed of.
• Equipment costing <$5,000 at the time of purchase and more than three years old can be retained, sold, or disposed, with no obligation to GaDOE. Equipment costing $5,000 or more at the time of purchase may be retained or sold with the awarding agency (GaDOE) having rights to the state’s share at $500 or 10 percent of sales.
• A disposition form must be completed by the site inventory contact for any item that is declared surplus because it has met its originally intended purpose or because it is no longer usable. Disposition forms can be obtained from the appropriate Federal Program Director.
• The date of disposition must be entered on the inventory sheet on Google Drive.
• Once a disposition form has been completed and the disposition date has been entered onto the inventory form, the item can be repurposed or disposed of. However, the item must remain on the inventory sheet for five years from the date of disposition before it can be removed from the inventory spreadsheet.

Safeguards Related to Loss, Damage, or Theft of Equipment

Every effort must be made to prevent loss, damage, or theft of equipment. The first strategy to safeguard equipment is to maintain an up to date inventory. In addition, all items must have an inventory/asset tag or other labeling approved by the appropriate Federal Program Directors. An annual inventory will be completed each fall by Federal Program Directors. Principals are encouraged to complete a second inventory each spring.

In the event equipment or technology purchased with federal funds is intentionally damaged or stolen, the following procedure will be followed:

1. File an incident report with the School Resource Officer (SRO).
2. Attach the incident report to a Disposal Form and upload in the appropriate folder on Google Drive.
3. Make corrections to the inventory on Google Drive.
4. Send an email notifying the appropriate Federal Program Directors that the inventory has been updated.

Safeguarding Funds, Property, and Assets from Unauthorized Use or Disposition

Materials purchased for use in federal programs will be properly labeled and utilized in the capacity for which it was purchased. Any equipment, materials and/or supplies purchased with federal funds are considered solely for the use of that program until such time the equipment is no longer needed to meet the original purpose for which it was purchased. Proper procedures must be followed before equipment disposal.

Equipment Use for Title I, Part A Targeted Assisted Programs

The school system does not have any targeted assistance schools. If the district should open a targeted assistance school, procedures will be established and implemented to ensure that any equipment purchased is used to benefit only those students who qualify based on Free/Reduced Priced Meal eligibility.

Equipment Use for Private Schools

Private schools requesting equipment must facilitate the purchases through the school system. The same internal controls will be followed to create requisitions and inventory and maintain equipment. If equipment is designated for student use, it can only be used by eligible students as determined through a mutual agreement between the LEA and private school within federal program guidelines. The appropriate Federal Program Directors will work cooperatively with private school officials to ensure equipment is properly maintained and is safeguarded from theft, damage, loss, and abuse.

Maintenance Procedures to Keep Property in Good Condition

Federal Program Directors will ensure that equipment is maintained on an inventory sheet on Google Drive as outlined in this document. Additionally, each Federal Program Director works cooperatively with the system’s Technology Department to ensure that equipment is properly maintained to ensure longevity. Accurate records will be maintained about the current condition of equipment purchased with federal funds. When equipment is not functioning, members of the Technology Department are responsible for making necessary repairs or service.

Process for Disseminating Inventory Procedures

Federal Program Directors are responsible for ensuring that principals and teachers are knowledgeable about allowable procedures for the use of federal program equipment and established procedures for maintaining an accurate inventory of equipment. These procedures will be shared annually during an administrative meeting. In addition, the Federal Programs Handbook, containing these procedures, will be shared with all personnel.

Cash Management (CFR 200.302(b)(6)) (CFR 200.305) & Drawdown of Funds (CFR 200.305(b)(3))

Funds are drawn down based on actual program expenditures. It is the responsibility of the appropriate Federal Program Directors and the Finance Director to work cooperatively to review all expenditures monthly after budget approval before funds are drawn down from GAORS. Moreover, the following practices are observed:

• Directors for each federal program must reconcile their respective budgets monthly to ensure that all expenditures charged to their program are allowable.
• The Finance Director will perform periodic reviews of the general ledger, including federal accounts and fund sources.
• The Finance Director runs a monthly expenditure report out of the financial software. The Federal Programs Director reconciles the account and returns a copy to the Finance Director that is signed, verifying the accuracy of the report.
• Funds are drawn down after reconciliation on actual expenditures and on a reimbursement basis only.  
• The Finance Director provides the Federal Programs Director with a copy of the DE1047, documenting the monthly drawdown.
• There is no cash involved as all drawdowns are directly deposited into the system’s bank account.
• Federal Program Directors ensure that equipment/supplies are purchased and received during the period of performance of the grant award.
• The school system does not request advance payments for federal fund disbursements, only reimbursements.
• All reporting documentation is kept in system’s central office and is available for review upon request.

At year end reconciliation for GAORS grants, a report is printed from the accounting software Federal Program Directors reviews and acknowledge that the completion report may be entered. After data is entered, the reports are given to the Finance Director for review and approval, who then submits it to the GADOE. The original is kept on file in the system’s central office and a copy is made for the Federal Program Directors’ file for monitoring.

Consultants, Contracts, Purchased Services for Federal Funds

Contracts are required for all consultants and purchased services.  Agreements are entered into between the Trion City School System and the consultant.  Each contract contains the following:  

• Contracts are generated by appropriate Federal Program Directors.
• Specific duties are specifically spelled out for each contract.
• The person must also submit to be fingerprinted if they are working with students.
• If the contract is with a TRS retiree, the individual must be approved yearly through the HR Department prior to beginning services.
• The contract includes the number of hours to work and the rate of pay.

Each contract is signed by the following: contractor, principal (if school-based), and the appropriate Federal Program Directors. The Federal Program Directors provide oversight in ensuring that all contractors’ work is complete and that sub-recipient requests have been evaluated before funds are released for reimbursement. Artifacts, daily sign in sheets, and completion of all workshops are kept on file by the appropriate Federal Program Directors. The appropriate Federal Program Directors signs off on all invoices/contracts prior to the issuance of payment for services. These contracts must be maintained and kept by the appropriate Federal Program Directors.

Period of Performance Flexibility (2 CFR §200.77, 200.309, 200.403(g); 34 CFR §76.707)

The intent of federal funds is to benefit students, teachers, and school leaders in that fiscal year

through the grant period as indicated on the Grant Award Notice (GAN). The GAN is the period of performance reflects the total estimated time interval between the start of an initial Federal award and the planned end date.  Regarding purchases that cross grant periods (software, computers, equipment):

• Cost must be incurred during the approved budget period. The Federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to 200.308 (e) (3).
• Purchases may extend beyond one year to take advantage of cost reductions, IF the students, teachers, and school leaders in the current fiscal year receive benefit from the purchase.
• Leases and licenses – All instructional software subscriptions must be purchased prior to January. If instructional software subscriptions are purchased later in the school year, the LEA will provide explanation within the budget description indicating how students in the current fiscal year will benefit from the purchase.
• Professional Learning registration – To maximize cost efficiency, the LEA may take advantage of “early bird” professional development registration where early registration occurs in the original grant period and the actual professional development occurs in the carryover period.
• Supporting documentation will be kept on file.
• Every effort should be made to align all purchases to the original grant period as much as possible.
• Period of performance may include one or more budget periods, but the identification of the period of performance does not commit funding beyond the currently approved budget period.

Grant Development and Budget Process

Each federal fund program Directors prepares a yearly budget showing the distributions for district, per school and /or per program/function/object code. Federal Program Directors ensure that all funds budgeted are allowable per funding source. The budget is forwarded to Business Services after the GaDOE approves the budgets in the Consolidated Application. The Finance Director enters the budget into the system financial software using the Consolidated Application budget as the source.

Supplement Not Supplant

The following guidelines will be used for Title I Schoolwide Programs and Targeted Assistance Programs:

• Equitable distribution of non-Federal funds requires that a schoolwide program shall use Title I funds only to supplement the amount of funds that would, in the absence of the Title I funds, be available from non-Federal sources for the school, including funds needed to provide services that are required by law for students with disabilities and English Learners.
• Supplemental activities are determined by the Trion City School System such that non-federal funds are distributed to all schools across the district in equitable ways. Furthermore, per pupil allocation by grade band will be used to equitably distribute Title I funds.
• To demonstrate compliance with supplement not supplant, the school system updates and submits to the GaDOE yearly a Resource Allocation and Management Plan (RAMP) that ensures that each Title I school receives all of the state and local funds it would otherwise receive if it were not receiving Title I funds.

The following three-prong test will be used for Title II and Title III in determining whether a fiscal expenditure supplements and not supplants. A positive response to any of the three prongs indicates that an expenditure would be supplanting.

• Test I - Required – is the program or activity that the district wants to fund required under state, local or another federal law?
• Test II - Equivalency – Were state and local funds used in the past to pay for this program or activity?
• Test III - Non-Title I Programs- Are the same programs or activities being implemented in other schools that do not receive Title I funds AND are these programs and activities being paid for with state or local funds?  

Transferability

LEAs are provided the opportunity to transfer funds under Every Student Succeeds Act. Trion City School System does exercise this flexibility. The system transfers Title II, Part A and Title IV funds into Title I and follows all federal and state guidelines related to transferability.

Accounting Records (CFR 200.302(b)(3))

The following internal controls have been created and designed to provide reasonable assurance regarding the achievement of objectives in the reliability of reporting for internal and external use.

Copies of completion reports for the previous fiscal year will be kept on file in the Finance Department. Accounting records to support the results of outlays (expenditures indicated in the completion report will be kept on file in the Business Services Department). Copies of expenditure (cumulative through) reports for the respective quarter for total expenditures reported to GaDOE will be kept on file in the Finance Department. Federal Program Directors will examine budget summary and detailed expenditure reports for their respective budgets.

Completion reports are annual reports required by Georgia Department of Education (GADOE) for all grant funds. Reports are due thirty days after the end date for each grant. Prior to preparing the completion report, the general ledger report for each grant will be reviewed to ensure that all expenditure postings are correctly recorded.

General ledger reports will be generated for each grant by function and object codes.

The Business Services Department completes these steps in the system financial software:

1. The Finance will run an account activity summary report in the system financial software for all related expenses for the grant (July thru September of current year for grants ending on September 30th or previous July thru June for grants ending on June 30th).
2. The Finance Director will send the summary Federal Program Directors for sign-off.

Monitoring and Reporting Program Performance (CFR 200.328)

The Trion City School System undergoes regular monitoring and audit visits as scheduled by the State of Georgia. Corrective action plans are created to reconcile any findings received. The school system will maintain the appropriate documentation to indicate that corrective actions have been completed and any findings have been cleared.

Steps to Audit/ Monitoring Resolutions:

Once the audit/ Cross-Functional Monitoring report is received, the appropriate Federal Program Directors will review all items. The Cross-Functional Monitoring report will be retrieved from the GaDOE website under the Consolidated Application.

• Each item will be examined carefully, and a team of system-level staff will determine the best means of corrective action.
• Items are gathered, and a report is written by the appropriate Federal Program Directors.
• The report is submitted to the Superintendent.
• The completed report is then sent to the GaDOE state auditors as a means of resolution.
• The district has 30 days from the receipt of the findings to respond to the GaDOE.

Necessary, Reasonable and Allocable Costs (CFR 200.403-200.405)

The following internal controls have been created and designed to provide reasonable assurance regarding the achievement of objectives in the compliance with applicable laws and regulations.

• Expenditure of federal funds must meet the clause of “allocable, reasonable, and necessary.”  When considering a purchase with federal funds, ask:
• Is the cost of goods or services chargeable or assignable to the federal award in accordance with relative benefits received (allocable)?
• Do I have the capacity to use what I am purchasing (reasonable)?
• Did I pay a fair rate, and can I prove it (reasonable)?
• Does this expenditure 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 (reasonable)?
• Is the proposed cost consistent with the underlying needs of the program (reasonable)?
• Do I really need this (necessary)?
• Do I need to spend these funds to meet the purposes and needs of the program (necessary)?
• Is this expenditure related to an identified area of need in an improvement plan (necessary, allowable)?
• Would I be comfortable defending this purchase (allocable, reasonable, and necessary)?          

Capital Expense Funds (CFR 200.439)

The Trion City School System does not use federal funds to budget items under object code 700 (capital expense).

Ethics and Fraud, Waste, Abuse, and Corruption

The Federal Programs Directors reviews ethics and fraud, waste, abuse, and corruption policies as it relates to Title programs, including Title I, Part A (Disadvantaged Children), Title I, Part C (Migrant Education Program), Title I, Part D (Neglected and Delinquent), Title II, Part A (Teacher and Leader Quality), Title III (English Learners and Immigrant Students)), Title IV, Part A (Student Support and Academic Enrichment), Title X, Part C (McKinney-Vento Education for Homeless), and Individuals with Disabilities Education Act (IDEA), with all staff members at the annual back to school. An agenda and sign in sheet will be kept to document this has been completed.

Standard 5: Public Funds and Property - An educator entrusted with public funds and property shall honor that trust with a high level of honesty, accuracy, and responsibility. Unethical conduct includes but is not limited to:

1. Misusing public or school-related funds.
2. Failing to account for funds collected from students or parents.
3. Submitting fraudulent requests or documentation for reimbursement of expenses or for pay (including fraudulent or purchased degrees, documents, or coursework).
4. Co-mingling public or school-related funds with personal funds or checking accounts; and
5. Using school property without the approval of the local board of education/governing board or authorized designee.

The Trion City School System takes the responsibility of responsibly managing federal funds seriously. Any individual who suspects that funds have been misused with any Title program, including Title I, Part A (Disadvantaged Children), Title I, Part C (Migrant Education Program), Title I, Part D (Neglected and Delinquent), Title II, Part A (Teacher and Leader Quality), Title III (English Learners and Immigrant Students), Title IV, Part A (Student Support and Academic Enrichment), Title X, Part C (McKinney-Vento Education for Homeless), and Individuals with Disabilities Education Act (IDEA) should report the waste, fraud, abuse, or corruption using the following guidelines:

Purpose: to ensure the reporting of suspicion of fraudulent activity, the Trion City Schools provides employees, clients, and providers with confidential channels for such reporting.

Definitions: Fraud: A false representation of a matter of fact, whether by words, by conduct, or by concealment of that which should have been disclosed, that is used for the purpose of misappropriating property and/or monetary funds.

Statement of Administrative Regulations: Trion City Schools thoroughly and expeditiously investigates and reported cases of suspected fraud to determine if disciplinary, financial recovery and/or criminal action should be taken.

Confidentiality: All reports of suspected fraud must be handled under the strictest confidentiality.  Only those directly involved in the investigation should be provided information regarding the allegation.  Informants may remain anonymous but should be encouraged to cooperate with investigators and should provide as much detail and evidence of alleged fraudulent acts as possible.

Procedures and Responsibilities:

1. Anyone suspecting fraudulent activity should report their concerns to the Trion City School System Superintendent or Director of Federal Programs and Teaching and Learning 706-734-2363.
2. Any employee with the Trion City Schools (temporary staff, full-time staff, and contractors) who receives a report of suspected fraudulent activity must report this information within the next business day.
3. Employees have the responsibility to report suspected fraud. All reports can be made in confidence.
4. The Trion City Schools Board of Education shall conduct investigations of employees, providers, contractors, or vendors.
5. If necessary, the person reporting will be contacted for additional information.
6. Periodic communication through meetings should emphasize the responsibilities and channels to report suspected fraud.

(TCSS BOE Policy DIE)

The School System (“System”) shall not tolerate fraud of any kind and has an established system for the reporting of suspicious activities.

“Fraud” is defined as a false representation of a matter of fact, whether by words or by conduct, or by concealment of that which should have been disclosed, that is used for the purpose of misappropriating property and/or monetary funds from federal, state, or local grants and funds.

Employees and parties maintaining a business relationship with the System who suspect fraud, whether it pertains to federal, state, or local programs, should report their concerns to the Superintendent or his/her designee. If fraud is suspected by the Superintendent, such allegations should be reported to the Chair of the Board of Education.  

All reports of suspected fraud shall be handled under the strictest confidentiality allowed under the law. Informants may remain anonymous as allowed by law but are encouraged to cooperate with investigators and to provide as much detail and evidence of the alleged fraudulent act as possible.

All reports of suspicious activity and/or suspected fraud will be investigated. Results of an investigation shall not be disclosed to or discussed with anyone other than those individuals with a legitimate need to know until the results become subject to public disclosure in accordance with state and/or federal law.

Complaint Procedures

Any complaints issued as a result of federal programming, including Title I, Part A (Disadvantaged Children), Title I, Part C (Migrant Education Program), Title I, Part D (Neglected and Delinquent), Title II, Part A (Teacher and Leader Quality), Title III (English Learners and Immigrant Students), Title IV, Part A (Student Support and Academic Enrichment), Title X, Part C (McKinney-Vento Education for Homeless), and Individuals with Disabilities Education Act (IDEA) must be filed according to the system complaint procedures policy. The school system will use the Tracking Form for Resolution of Complaints (Appendix B) to ensure that complaints are resolved in a timely manner. This form is maintained at the office of the Director of Federal Programs and Curriculum in the system’s central office. See ‘Appendix A: Complaint Procedures’

Title I, Part A Improving the Academic Achievement of the Disadvantaged

Within District Allocation Procedures

Targeted Assistance Programs

Local educational agencies (LEA) serving schools that are either ineligible for a schoolwide program or that choose not to operate a schoolwide program, may use Title I funds only for programs that provide services to eligible children identified as having the greatest need for special assistance. The Trion City School System does not have a Targeted Assistance Program in any of its schools. All schools receiving Title I funds conduct Title I Schoolwide Programs.

Required Set Asides Reservation of Funds

After receiving notification of the Title I, Part A grant amounts from GADOE, reservations in each budget are set aside for required components such as Family Engagement, professional learning, neglected and delinquent, private school per pupil and equitable services, and homeless students. Administrative costs are also part of the reservations, which are not part of the schools per pupil amounts. The remainder of Title I funds are allocated to schools based on per pupil allocation, as determined by the percentage of students qualifying for free and reduced-price meals.

Parent and Family Engagement

Required 1% Set Aside for Parental Involvement: Principals have the option of expending their 95% portion of the required 1% set aside in Family Engagement funds or submitting them back to the system level.  Principals, with input from parents, typically decide to direct those funds to a system level Family Engagement activity/project by signing a District-wide Parent Activity Assurance form. The funds are used at the system level to fund a Family Engagement Specialist who serves all schools. Title I parents are informed about the 1% set aside during the Fall Annual Meeting and participate in the discussion regarding this requirement each Spring during Title I planning meetings held at each school. If the total 1% is not expended, the difference must be carried over to the following fiscal year. Trion City School is not required to set aside Title I funds for Parent and Family Engagement.

Homeless Children and Youth

The Trion City School System does not receive direct funding from the McKinney Vento Homeless Program. Trion City School uses Method 1to determine the set aside. The system Homeless Liaison trains school personnel to identify children in homeless situations.  The Student Residency Statement is also used to identify homeless students. The system Homeless Liaison is consulted if any staff member suspects that a student qualifies for homeless services. The Homeless Liaison then investigates the situation and makes the ultimate determination on whether students qualify. When a student does qualify, the appropriate information is sent to the Student Information Services Director to be entered into the Student Information System. Set aside funds are used to purchase needed supplies and for tutoring services for identified homeless students on an as needed basis. Transportation is also provided to students on an as needed basis. Title I, Part A funds are also reserved to benefit the education of homeless students. Funds are allocated based on an annual analysis of student needs.

Neglected and Delinquent Children

The Trion City School System does not currently have any centers that serve neglected and/or delinquent children. Therefore, no funds are reserved for these purposes. If centers for neglected and/or delinquent children locate in Trion City in the future, funds will be served as directed by the GaDOE in the Title I, Part A allocation letter and worksheet. Additionally, if centers do locate in Trion City in the future, an Annual Survey of Local Institutions for Neglected and Delinquent will be completed based on the number of children residing at the home for 30 consecutive days with at least one day being in October.

Private Schools

The Trion City School System currently has no Private Schools that have chosen to participate in the Title I program. If the Trion City School System ever has a Private School that chooses to participate, all Title I regulations for private school participation will be followed.

Calculating Parent and Family Engagement Carryover

Trion City School is not required to set-aside funds for Family Engagement. If it ever occurs, a worksheet would be provided by the GaDOE to determine the amount of parent and family engagement carryover from the previous fiscal year. The Title I Directors would complete and upload this worksheet, along with detailed expenditure report for family engagement for the previous year to the Consolidated Application Attachments tab.

Family Engagement

Family Engagement Policy Overview

The Trion City School System has an ongoing commitment to Title I parents. Parental involvement is defined as the participation of parents in regular, two-way, and meaningful communication involving student academic learning and other school activities. Our goal is to ensure that Title I parents and their children receive extraordinary services and assistance that will lead to improved academic achievement. The district recognizes that parents are an integral part of a child’s success in school, starting with the concept of being the child’s first teacher. As a conduit for their children’s success, the district will assist parents of all socioeconomic levels in solidifying their ongoing commitment to their child’s success.  

Technical Assistance to Schools

LEA Technical Assistance to Schools on Family Engagement Requirements and Best Practices

The LEA provides technical assistance to schools in the following ways:

• Professional learning sessions during administrative and curriculum meetings.
• One-on-one meetings held between the Title I Director and/or Family Engagement Specialist and school leaders.
• The creation and sharing of a Federal Programs Handbook.
• Technical assistance with planning, organizing, and conducting parent meetings.
• Ongoing emails and phone calls.

Parent Notifications

Communication in an Understandable Format

Upon enrolling their child(ren) in the Trion City School System, every parent indicates their household’s preferred communication language as a standard part of the registration process. To the extent practical, efforts are made to provide either written support or support through an interpreter when a parent indicates a language other than English. A district translator is available for meetings and translation of documents.  Furthermore, all parent communication is written in a format so that the content is easily understandable.

School Designation Status

Should Trion City Schools have a school identified as needing Comprehensive or Targeted Support Interventions they will receive the support of the LEA and/or School Improvement Division of the GaDOE as appropriate. Parents will be notified of each school’s designation status using multiple means of communication.

Parent Right to Know

In accordance with ESSA, all schools are required to notify parents at the beginning of each school year of their “Right to Know” the professional qualifications of their student’s classroom teachers and paraprofessionals. Before the beginning of each school year, the appropriate Federal Program Director sends to the principals of every school/program a list of Required Notifications for Student Handbooks/Agendas. On this list is the Parent’s Right to Know Teacher’s Training and Credentials. The notification uses the language of the law and occurs within 30 calendar days from the start of school or upon enrollment.

School principals are responsible for providing a copy of the student-parent handbook containing the Parent’s Right to Know to the appropriate Federal Programs Director as evidence of parental notification of their Right to Know. If a school omits the notification from their student handbook, the Federal Program Director will notify the principal that he/she is required to notify each parent of their Right to Know via 1st class mail before the end of the first week of school. In this case, a copy of the notification letter will be provided to the director. Responses to parent requests will be made within one week. The Parent Right to Know notification will also be posted on the District webpage.

20 Day Notification of Professional Qualifications

In accordance with ESSA all schools are required to provide timely notice to parents when students have been taught for four or more weeks by a teacher who does not meet applicable state certification or licensure requirements at the grade level and subject area in which the teacher has been assigned. Notification requirements apply to all teachers in all schools/programs. Notifications will be sent within ten business days following the four consecutive weeks. For verification purposes notifications must contain: day, month, and year of notification; the name of the teacher who has not met PQ, the name of the school and district; and a statement that the teacher has not met state certification or the district’s charter waiver PQ requirements for the grade and subject in which the teacher is assigned. The notification will be sent in a format that ensures parents can receive the information. This may include: first class mail, parent link communication and/or email blast. To the extent practicable, the notification will be in a language the parent will understand. This applies to all teachers in all schools/programs.  

Regular Education Teachers:

Notification must be sent when students have been taught for four or more consecutive weeks by a teacher who does not meet the district’s PQ requirements at the grade level and subject area in which the teacher has been assigned.

Special Education Teachers:

Special Education teachers who do not issue grades:  20-day notifications must be disseminated if the teacher does not hold special education certification.

Special Education teachers who do issue grades:  20-day notifications must be disseminated if the teacher does not hold special education certification and content certification or equivalent as aligned with ESSA in-field.

Notifications are not required for paraprofessionals, substitutes, or lack of a clearance certificate.

Upon placement, the Principal will contact the appropriate Federal Program Director. Who in turn will indicate the need to send a 20-day notification to parents and review the requirements?  Prior to the 20-day mark, a draft letter will be sent to the Federal Program Director for review. The Director will approve the content and have the letter translated, if necessary. Within ten business days following the four consecutive weeks, the notification will be sent to parents. Evidence of dissemination will be kept on file in the Planning and Personnel office.

Family Engagement Policies/Plans

Title I, Section 1118 of the Elementary and Secondary Education Act of 1965 (ESEA) requires that each school receiving Title I, Part A funds develop jointly with, agree on with, and distribute to parents of participating children a written parental involvement policy.

Trion City School System is committed to cultivating and sustaining partnerships with parents and community stakeholders, and encourages their participation in the development, implementation, review, and evaluation of its parental involvement policy/plan. This written policy/plan focuses on improving academic achievement and school performance and outlines how the LEA will coordinate, provide technical assistance and other support to schools in planning and implementing effective parental involvement activities, trainings, and workshops.

The LEA, school, parents, and community stakeholders will jointly develop and agree on the Parental Involvement Policy/Plan which will describe the means for carrying out Title I, Part A requirements. The policy/plan will be made available to the local community and parents of students enrolled in the Trion City School System using multiple means. The policy/plan will be available on the Title I page of the district’s website (www.trionschools.org, in the Title I Informational Handbook, in hard copy format in office of the Family Engagement Specialist.

District and school Family Engagement plans are reviewed and revised annually with parents and other stakeholders (teachers, principals, administrators, and other school personnel). Schools hold individual meetings for review of the district and school Family Engagement Plans. All Title I parents, teachers, administrators, and other school personnel in the district are invited to the meetings to provide input.  Notices will be posted for stakeholders containing the meeting dates. Parents and other stakeholders will be notified by invitation sent by each individual school. Parents who cannot attend the meetings will be given the opportunity to obtain a copy from the Family Engagement office of each school and submit input before final revisions are approved. The Title I Directors will be responsible for collecting the required information (agendas, meeting notes, and sign in sheets). Meetings will be held in the Spring to revise plans for the next school year. The LEA Family Engagement Policy checklist will be applied to district and school plans. Revision dates will be clearly marked on each plan. The Family Engagement Specialist and/or the Title I Directors will review plans before or during on-site monitoring visits. Plans include activities/workshops that have been identified and requested through the previous year’s annual Family Engagement survey.  School improvement and Family Engagement plans are posted on the website, available in the Family Engagement office of the school, and hard copies provided in the Title I Informational Handbook upon enrollment at the school.

Each school in the Trion City School System holds an annual open house or parent orientation. These meetings give parents the opportunity to review and provide feedback on system-wide and school student data, parent activities, district, and school Family Engagement Plans, Schoolwide Title I Plans, School Improvement Plans. Parents are notified about this opportunity through advertisements in local media, school-level flyers, social media websites and by using the system automated phone calling system and the system web site. The school district uses the comments provided by parents during the annual review/revision of documents at parent workshops and other advisory meetings. After the school system review/revision process, district and school Family Engagement Plans are made available to parents on the district website and on Title I schools’ websites. Copies are also available in parent resource centers. Parents are also given the opportunity to provide feedback about Title I programs by completing annual parent surveys. These comments are used by the district and Title I schools when planning parenting programs.

Plans are shared with faculty, staff, students, parents, and community members on school websites and the district Federal Programs website located at: www.trionschools.org. Plans include district and school improvement/schoolwide plans, Family Engagement policies, school compacts, comprehensive LEA improvement plan, parents’ right to know, complaint procedures, and policy on ethics and fraud, waste, and abuse. Many of these plans are included in student handbooks. Parental input into the content of each plan is solicited during multiple meetings throughout the school year but especially at Title I planning meetings conducted each Spring.

School/Parent Compacts

The Trion City School System will share responsibilities for high student academic achievement with all parents and students enrolled in the school system and will develop, in collaboration with parents and students, a school-parent compact that outlines how parents, school staff, and students will share the responsibility for improved student academic achievement. The school-parent-student compact will also describe how the school, parents, and students will build and develop a partnership to ensure student mastery of the GA DOE’s high academic content standards.

All Title I schools are required to have school-parent compacts. It is the responsibility of the Principal, in coordination with the school system Family Engagement Specialist, to make sure that all compacts are reviewed and revised annually. The review and revision will occur in the Spring of the year at annual Title I Parent Planning Meetings, school leadership meetings, and parent workshops. Revision dates will be clearly marked on each compact. An invitation will be sent home to all parents in the school and meeting dates will be publicized in school newsletters, local newspapers, and on each school’s web site. The Family Engagement Specialist will be responsible for coordinating with the school to schedule meetings and collect required information (agenda, meeting notes, and sign in sheets). Parent compacts will include responsibilities for the teachers, parents, and students. Compacts will be distributed to all parties involved for signatures each fall. Copies of the signed parent compacts are kept on at the school level. The Trion City School System Board of Education believes that the public schools belong to the people who create them and that student educational goals should reflect the goals of the community. We affirm and assure the rights of parents to participate in the development of the goals and objectives of the public schools and encourage involvement in all areas of their children’s educational experiences.

Annual Title I Meeting

All Title I schools are required to hold an annual meeting at the beginning of the school year. It is the responsibility of principals in coordination with the Family Engagement Specialist to arrange meeting times and invite all stakeholders to the meetings. The Family Engagement Specialist will be responsible for collecting and submitting documentation of the required Title I Annual Meeting, including copies of sign in sheets, agendas, and minutes to the Title I Directors. Meetings are publicized via flyers sent to parents, web sites, community bulletin board, an automated call system, and signs at each school.

Annual Evaluation of Parental Involvement

Process to Collect: An annual survey is conducted each spring. The survey is conducted online. However, parents are informed of the availability of a paper survey if they so desire. Advertisement of the survey and requests for completion occur through newsletters, district and school websites, and automated phone calls. The survey is collected and compiled, and the following year’s Family Engagement activities are built from the responses.  

Process to Review: The results of the survey are shared among several groups of stakeholders, including, but not limited to, parents, school and central office employees, and community members. School Leadership Teams and those attending Annual Title I Meetings. The results of the survey are used to review and revise schoolwide and Family Engagement plans and components.

Actions Taken by LEA to Improve the Quality and Effectiveness of Family Engagement Policies and Practices: The Title I Directors and Family Engagement Specialist review the annual spring survey results, as well as all feedback received during the annual needs assessment process. Additions/deletions/ revisions are discussed and agreed upon during this meeting. Formatting and revisions are made after the meeting and then provided to stakeholders for review and suggestions.

Family Engagement workshops and activities are planned for the following year based on information gained during the annual needs assessment process. Materials are also purchased for parent resource centers based on expressed needs. Many opportunities are provided for building strong parent capacity. The purpose is to ensure effective parental involvement and to support a partnership among schools, parents, and the community to improve student academic achievement, through the following activities: annual meetings; conferences; e-mail communications; phone calls; parent workshops and activities; family nights; Volunteering; Parent advisory meetings; Open Houses; Annual notification of school designation; newsletters/flyers/brochures; website information; School Leadership Team meetings; and Board of Education meetings.

Capacity for Family Engagement

Information is provided to school personnel and parents on how to build parent capacity through presentations made during meetings, through response to parent needs on surveys, through information received from the GADOE Family-School Partnership Program, and through student handbooks, newsletters, and flyers.

The Family Engagement Specialist considers, and plans based on the six requirements for building capacity by answering the following questions:

1. What strategies/materials have been offered to parents on understanding academic content standards?
2. What training has been offered to parents related to literacy and the use of technology?
3. How have faculty and staff been encouraged to communicate with and involve parents in their child’s education?
4. What efforts have been made to foster parental involvement in prekindergarten programs?
5. What attempts have been made to communicate parental involvement information to parents using language parents can understand?
6. What other support do parents receive for parental involvement activities?  

Trion City School System builds parent capacity to impact student achievement by offering virtual meetings and a Google Classroom dedicated to Family Engagement. Once on-site meetings can resume, Trion Elementary School plans to implement Teachers Educating Academic Mindsets (TEAM) to promote and build family engagement.  

Parent Resource Center

Trion Elementary School (TES) maintains a parent resource center. A variety of materials and resources are available to parents for use at the school for checkout, or as handouts. Books, tapes, videos, DVDs, and a variety of other materials have been purchased for the parents.  any purchases are based upon parent requests on the parent engagement surveys (i.e., helping with homework, information regarding bullying). TES is required to notify parents of the availability of the resources in the parent resource center. This is typically achieved through a flyer and/or websites and includes information on the types of resources available in or through the resource center.

English Learners Participating in Title I or Title III Supplemental Language Programs

No later than 30 calendar days after the beginning of the school year (or within the first two weeks of an EL being placed in a program), the Title I Department will notify parents of English Learners if their child is participating in a supplementary language program. The notification will be provided in a language parents can understand. Initial letters will be mailed home to the parents of students receiving supplemental services. Subsequent letters will be generated by the student’s ESOL teacher and sent home with the student.

Schoolwide Program

Overview

A schoolwide program is a comprehensive reform strategy designed to upgrade the entire educational program in a Title I school. The purpose of schoolwide Title I programs is to improve the entire educational program in a school which should result in improving the academic achievement of all students, particularly the lowest achieving students. The goal of such a program is to assist those students with demonstrating proficiency on academic standards.  A school is eligible to be a schoolwide program:

• If the local educational agency (LEA) determines that the school serves an eligible attendance area.
• If for the first year of the schoolwide program, the school serves a school attendance area in which not less than 40 percent of the students enrolled in the school are from low income families.
• If the school consults with stakeholders and makes decision to become schoolwide.

Schoolwide Title I programs must:

• Conduct a comprehensive needs assessment.
• Identify and commit to specific goals and strategies that address those needs.
• Create a comprehensive plan; and
• Conduct an annual review of the effectiveness of the schoolwide program and revise the plan annually or as necessary.

Adopting this strategy should result in an ongoing, comprehensive plan for school improvement that is owned by the entire school community and tailored to its unique needs. Schoolwide programs are not required to identify specific students as eligible. They must supplement (enhance) rather than supplant (take the place of) the services participating students would receive if they were not participating in the schoolwide program.

Components of a Schoolwide Program

Each schoolwide program must create a plan to address the following components of the GaDOE Schoolwide Program Checklist:

1. Comprehensive Needs Assessment
2. Schoolwide Reform Strategies
3. Schoolwide Plan Development
4. ESSA Requirements for Schoolwide Plans

In addition, the school providing a schoolwide program must also evaluate its plan by reviewing, on an ongoing basis, the progress of all children. If necessary, the school must adjust its plan to provide additional assistance such as an extended school year, before and after school programs, summer programs, and training for teachers on how to identify students requiring additional assistance and how to implement student achievement standards in the classroom.

All Title I schools within the Trion City School System conduct Schoolwide Programs. This allows all children in these schools and their parents equal access to all related Title I assistance. Schoolwide Plans are updated and verified using a checklist during a school leadership meeting. Parents are also invited to a system level Parent Advisory Council meeting. All schools will notify stakeholders in multiple ways, notice of the meeting dates will be placed on each school's display signs, in each school newsletter and on the web site, parents and other stakeholders will be notified by invitation sent from each individual school and all stakeholders will be notified using each school phone messaging system. Parents who cannot attend the meeting will be given the opportunity to obtain a copy from each school and submit input before the final revisions are approved. Revision dates will be clearly marked on each plan. The system Family Engagement Specialist will be responsible for collecting required documentation (agenda, meeting notes, and sign in sheets). At these meetings, parents and other stakeholders are given an opportunity to provide input on the Schoolwide Title I Plan/School Improvement Plan, Parent/Student/Teacher Compacts, Family Engagement Plans, and the Comprehensive LEA Improvement Plan.

LEA Guidance

On-site meetings are held with principals to discuss the status of their plans regarding checklist components. Missing or items in need of revision are marked on the checklist and then rechecked when the revised plan is submitted. As previously stated, system leaders support schools in developing, revising, implementing, and coordinating school improvement and schoolwide plans during regularly scheduled administrative and Instructional Coach meetings. During the meetings, data is analyzed to identify and develop solutions to challenges related to instructional strategies, Family Engagement, professional learning, and budgets. The district also conducts a workshop each June to provide schools with technical assistance on finalizing their plans.

Schoolwide Program Plan Development

School Improvement Plans are updated each spring for the following school year. Each school leadership team conducts a spring meeting at which representatives from each grade level, content area, and department, as well as system and school administration and parents meet to develop a plan. During school leadership meetings, instructional strategies, parental involvement initiatives, and professional development activities are planned after a careful analysis of various data. Assistance is also provided to schools in their use of school improvement funds to accomplish initiatives in their school improvement plans. School administrators then present their school plans at the annual system leadership summit as they work with other schools, system leaders, and parents to develop a system improvement plan. It is through this process that the LEA oversees the development of school improvement plans.

Consolidation of Funds

The Trion City School System does not consolidate federal funds.

Rank Order

Trion Elementary School is the only Title I school in the systems. If more schools were to participate, schools would be placed in rank order using the percentage of students that qualify for free and reduced priced meals according to grade span grouping.

Carryover

As Trion Elementary is the only school utilizing Title I funds, all carryover is allocated through their budget. Should more school participate, carryover funds would be allocated in one of two ways: (1) to schools by increasing the per pupil amount or (2) the funds are allocated back to all the schools on an equal basis, giving each school an opportunity to spend the funds. Either way, schools must submit a written description of the expenditure requests. Equitable services are also re-calculated depending on an allocation of funds for district level activities.

Monthly budget sheets are monitored regularly throughout the year and calculations are made from these near the end of the school year to determine that no more than 15% will be carried into the following year.  The Title I Directors tracks the spending of each program/school throughout the year via budget sheets. At the end of the school year, carryover information is updated and reviewed.        

Monitoring and Oversight of School Improvement

All Title I schools within the Trion City School System conduct Schoolwide Programs. This allows all children and all parents an opportunity to have equal access to all related Title I assistance. The LEA will utilize district members of the school system to build capacity and support the school improvement process in schools identified as needing comprehensive or targeted support interventions. All schools identified as needing comprehensive or targeted support interventions within the LEA will be involved in school improvement efforts through the work of the LEA, RESA, and GaDOE.  Members of the system will work with these schools to implement practices that have proven effective with improving schools. Members of the Teaching & Learning Department, along with the GaDOE, will establish clear expectations for personnel as they systematically support continuous improvement in all schools. However, more intensive support will be provided by LEA and GaDOE School Improvement Specialists in any schools within the Trion City School System that are designated as needing comprehensive or targeted support interventions. The Title I Directors will conduct a yearly evaluation of school improvement efforts for all Title I schools using the Trion City School System Federal Programs School Monitoring Checklist. Members of the Teaching and Learning Department will conduct progress checks to determine the extent to which school improvement plans have been implemented. These checks will occur quarterly.

Review and Approval of School Improvement/Schoolwide Plans

School Improvement Plans are updated each spring for the following school year. Each school leadership team updates the plans using representatives from each grade level, content area, and department, as well as district and school administration and parents. During school leadership meetings, instructional strategies, parental involvement initiatives, and professional development activities are planned after a careful analysis of various data. Assistance is provided to schools identified as needing comprehensive or targeted support interventions in the use of school improvement funds to accomplish initiatives in their school improvement and schoolwide plans. School administrators then present their school plans at the annual system leadership retreat as they work with other schools and system leaders to develop a system improvement plan. All school improvement plans must be signed off as completed by the system Title I Directors and the Superintendent. The Professional Learning Plan for each school must have final approval by the Title II-A Directors. It is through this process that the LEA oversees the development of school improvement and schoolwide plans.

Budgeting Procedures

The Title I Directors will meet with school leaders at each school served under this grant to jointly develop a budget based on the prioritized needs identified during a comprehensive needs assessment. The Title I Director will continually communicate with each school to review and provide recommendations for ongoing budgeting decisions. 

Monitoring and Reviewing Schoolwide Plans 

System leaders in the Teaching & Learning Department support schools in developing, revising, implementing, and coordinating school improvement and schoolwide plans during regularly scheduled meetings of administrators and instructional coaches. During the meetings, data is analyzed to identify and develop solutions to challenges related to instructional strategies, Family Engagement, professional learning, and budgets. Each school, including those identified as needing comprehensive or targeted support interventions, must submit a school based plan for professional development to be reviewed and approved after recommendations by the Title I Directors and other members of the Teaching and Learning Department. Plans are due each August and must generally be approved by the end of September.

Title I, School Improvement (1003a) Grant

The Trion City School System does not currently have any participating schools in this grant.

Title I, School Improvement 1003(g) Grant

The Trion City School System does not currently have any participating schools in this grant.

McKinney-Vento Program (MVP)

Education of Homeless Children and Youth

Introduction

The Trion City School System will follow the requirements of the McKinney-Vento Homeless 

Education Assistance Improvements Act of 2001 to ensure that all children and youth receive a free appropriate public education and are given meaningful opportunities to succeed in our schools.

Definitions

• Children and youth experiencing homelessness means children and youth who are otherwise legally entitled to or eligible for a free public education, including preschool, and lack a fixed, regular, and adequate nighttime residence, including children and youth who:

• are sharing the housing of other persons due to loss of housing, economic hardship, or a similar reason.
• are living in motels, hotels, campgrounds, or trailer parks due to lack of alternative adequate accommodations.
• are living in emergency or transitional shelters.
• are abandoned in hospitals.
• are awaiting foster care placement.
• have a primary nighttime residence that is a private or public place not designed for or ordinarily used as a regular sleeping accommodation for human beings.
• are living in a car, park, public space, abandoned building, substandard housing, bus or train station, or similar setting; and
• are migratory and living in a situation described above.

• A child or youth shall be considered to be experiencing homelessness for as long as he or she is in a living situation described above and to the end of the school year in which the student moves into permanent housing.
• Unaccompanied youth means a youth not in the physical custody of a parent or guardian, who is experiencing homelessness as defined above. The more general term youth also includes unaccompanied youth.
• School of origin means the school the child or youth attended when permanently housed, or the school in which the child or youth was last enrolled.
• Liaison is the staff person designated by a Local Education Agency (LEA) as the person responsible for carrying out the duties assigned to the liaison by the McKinney-Vento Act.
• Immediate means without delay.

Identification

In collaboration with school personnel and community organizations, the liaison or designee will identify children and youth experiencing homelessness in the district, both in and out of school, and maintain access to data regarding homeless students. The liaison or designee will train school personnel on possible indicators of homelessness, sensitivity in identifying families and youth as experiencing homelessness, and procedures for forwarding information indicating homelessness to the liaison. The liaison will also instruct school secretaries to offer homeless education information upon the enrollment and withdrawal of every student, and to forward information indicating homelessness to the liaison.

School Selection

Each child and youth experiencing homelessness has the right to remain at his or her school of origin, or to attend the appropriate school that serves students who live in the attendance area in which the child or youth is actually living. Therefore, in selecting a school, children and youth experiencing homelessness shall remain at their schools of origin to the extent feasible, unless that is against the parent's or youth's wishes. Students may remain at their schools of origin the entire time they are experiencing homelessness, and until the end of any academic year in which they become permanently housed. The same applies if a child or youth loses his or her housing between academic years.

Enrollment

Consistent, uninterrupted education is vital for academic achievement. Due to the realities of homelessness and mobility, students experiencing homelessness may not have school enrollment documents readily available. Nonetheless, the school selected for enrollment must immediately enroll any child or youth experiencing homelessness. Enrollment may not be denied or delayed due to the lack of any document normally required for enrollment. Unaccompanied youth must also be immediately enrolled in school. They may either enroll themselves or be enrolled by a parent, non-parent caretaker, older sibling, or the LEA liaison. If complete records are not available, IEP teams or other committees or school officials, as appropriate, must use good judgment in choosing the best course of action, balancing procedural requirements and the provision of services. In all cases, the goal will be to avoid any disruption in appropriate services.

Transportation

Transportation shall be provided to and from the school of origin for a child or youth experiencing homelessness. Transportation shall be provided for the entire time the child or youth has a right to attend that school, as defined above, including during pending disputes. Parents and unaccompanied youth must be informed of this right to transportation before they select a school for attendance. In addition to receiving transportation to and from the school of origin upon request, children and youth experiencing homelessness shall also be provided with other transportation services comparable to those offered to housed students.

Services

Children and youth experiencing homelessness shall be provided services comparable to services offered to other students in the school selected. School personnel must also inform parents of all educational and related opportunities available to their children and provide parents with meaningful opportunities to participate in their children's education. All parent information required by any provision of this policy must be provided in a form, manner, and language understandable to each parent.

Disputes

If a dispute arises over any issue covered in this policy, the child or youth experiencing homelessness shall be immediately admitted to the school in which enrollment is sought, pending final resolution of the dispute. The student shall also have the rights of a student experiencing homelessness to all appropriate educational services. The school where the dispute arises shall provide the parent or unaccompanied youth with a written explanation of its decision and the right to appeal and shall immediately refer the parent or youth to the liaison. The parent or unaccompanied youth shall be given every opportunity to participate meaningfully in the resolution of the dispute.

Credit for Full or Partial Coursework

Students experiencing homelessness will be provided credit recovery options so as not to cause the loss of partial or incomplete credits. The following methods will be used:

• After school credit recovery
• Awarding of half and full units of credit where appropriate through after school programs

Training of Personnel

The Homeless Liaison or designee annually conducts training and sensitivity/awareness activities to heighten the awareness of the following personnel of the specific needs of unaccompanied and homeless youth: principals, assistant principals, federal program administrators, transportation employees, registrars, school secretaries, school counselors, custodians, school nurses and teachers. The liaison obtains from every school the name and contact information of a building liaison. The liaison maintains documentation (agendas and sign-in sheets) of these meetings.

Coordination

The liaison shall coordinate with and seek support from the State Directors for the Education of Homeless Children and Youth, public and private service providers in the community, housing and placement agencies, the pupil transportation department, liaisons in neighboring districts and other organizations and agencies.

Notification to Stakeholders of the Homeless Liaison Contact

Posters related to the Homeless Program that include the name and contact information of the Homeless Liaison are posted at each school and at various community centers. This same information is also available on the system website. Information related to all federal programs, including MVP and the Homeless Program is provided to all faculty and staff annually via email.

Preschool

Preschool education is an especially important element of later academic success. Children experiencing homelessness have experienced many difficulties accessing preschool opportunities. Our system will ensure that children experiencing homelessness receive assistance in locating preschool programs.   

Children with disabilities who are experiencing homelessness will be referred for preschool services under the Individuals with Disabilities Education Act (IDEA). Children under age three with disabilities who are experiencing homelessness will be referred for at-risk services under Part C of IDEA and screened to determine if referrals for additional Part C services are appropriate. The liaison will collaborate with Head Start and Even Start programs and other preschool programs to ensure that children experiencing homelessness can access those programs.

Protocols

The following protocols associated with the McKinney-Vento Program shall be followed:

1. Student is identified as potentially eligible for MVP services and is in one of the following circumstances.

1. Student is a new enrollee.
2. Student is currently enrolled in a Trion City School.
3. Student is residing in Trion City but has a school of origin in another school system.

2. School system staff (school counselor, Title I Family Engagement Specialist, registration staff or other school system personnel) gather information related to potential MVP eligibility and submit to district homeless liaison (DHL) for MVP status determination.  
3. DHL determines MVP eligibility.
4. If the student is residing within the boundaries of Trion City and seeks to attend a Trion City public school, the DHL identifies the school placement of the student (school of origin for currently enrolled students or attendance zone school for new enrollees) and notifies applicable school staff including school nutrition Directors, school-based liaison, school administrator.
5. If the student does not reside within the boundaries of Trion City but seeks to remain in the school of origin in Trion City the School Selection Feasibility Committee will convene to determine the school, the student will attend.
6. If the School Selection Feasibility Committee determines the best placement to be the school of origin the DHL will notify the appropriate school personnel.
7. If the School Selection Feasibility Committee determines the best placement of the student to be in the attendance zone school, then the committee will notify the school of origin and DHL of the placement decision. The school of origin will notify the parent guardian of the enrollment decision and appeal rights using the designated paperwork.  
8. If the school that is selected denies the enrollment decision, they must provide the parent with the written enrollment decision and appeal process paperwork.

1. A copy of this enrollment decision is forwarded to the DHL.
2. If parent disputes this decision, then students stays in selected school.

9. If parent or guardian disputes the written enrollment decision, then the first appeal will be made to the District Homeless Liaison.
10. The decision of the DHL will be presented to the parent/guardian in writing along with instructions on how to appeal this decision.
11. If the parent disputes the decision of the DHL, then an appeal may be made to the Superintendent of Trion City Schools. The Superintendent will inform the parent/guardian of his/her decision in writing along with a copy of the Georgia Appeals process.    
12. If the parent appeals, then the student may remain in the school originally selected.

Services for Neglected and Delinquent Children

The purpose of Title I, Part D is to improve educational services for children and youth in local and State institutions for neglected or delinquent children and youth so that such children and youth have the opportunity to meet the same challenging State academic content standards and challenging State student academic achievement standards that all children in the State are expected to meet. The purpose is also to provide such children and youth with the services needed to make a successful transition from institutionalization to further schooling or employment and to prevent at-risk youth from dropping out of school, and to provide dropouts, and children and youth returning from correctional facilities or institutions for neglected or delinquent children and youth, with a support system to ensure their continued education.

The Trion City School System currently has no centers or agencies in its geographical boundaries that serve neglected or delinquent students.

Foster Care Transportation Plan

Planning

Real time coordination will occur between Case Managers, Education Support Monitor, Homeless Liaison, Foster Parents, and Court Appointed Special Advocates, regarding foster children entering and exiting care; changing placements; enrollment and withdrawal; and making best interest determinations.  When transportation is an issue, those parties will collaborate to develop a transportation plan that meets the needs of the individual child.

Transportation Plan

Trion City Schools Homeless Liaison also acts as the Foster Care Point of Contact for Trion City Schools. The Foster Care Transportation Plan is in the Federal Programs Director office at TCS central office, shared annually with the local child welfare agency, and uploaded as part of the system’s CLIP.

Title I, Part C - Migrant Education Program (MEP) Services

Identification and Recruitment

Migrant students are identified through the occupational survey, which is a portion of the student enrollment packet. When migrant students are identified, a comprehensive needs assessment and delivery plan will be developed.

The Migrant Education Coordinator is responsible for maintaining, updating, and properly coding all required enrollment, education, and health data in Trion City School’s System’s Student Information System on migrant eligible students and shares this information on an intra-district and interstate basis. The MEP Coordinator will provide training and resources to the schools, administrators, and the Central Office/Registration.

The MEP Coordinator meets throughout the year with the MEP Area Specialist to coordinate Migrant enrollments and to ensure the identification and recruitment services are provided.

Identification and Recruitment

The Trion City School System MEP Coordinator forwards all the completed Parent Occupational Survey forms whenever a parent or guardian indicates a positive response to questions related to moves into the District for occupational reasons and the nature of such employment.  These forms are forwarded to the area MEP Specialist. The MEP Specialist utilizes this information to help identify and recruit migrant students. The MEP Specialist also conducts in-District Identification and Recruitment activities to further identify potentially eligible families. Contact is then made with each potentially eligible family to determine case-by-case eligibility and needs. The appropriate Federal Program Director works closely with the MEP Specialist to ensure enrollment and SIS information is updated and accurate. Students who meet certain critical criteria are also identified with the assistance of the Ga DOE MEP as Priority for Services.  

The Occupational Survey is sent home with every child in the district. During each summer, updated Occupational Survey Forms are sent to all schools for inclusion in Registration Packets for all new students. Data from completed Occupational Survey Forms are collected from the Family/guardians, entered the SIS by the schools’ attendance clerks, and then sent to the Migrant Program Coordinator at the Central Office.  These forms are forwarded to the MEP Specialist/ Recruiter who will schedule a visit with the student’s Family/guardians to determine eligibility.  

Cross-checking Migrant Data

The Migrant Program Coordinator codes the students in the Student Information System to ensure accurate data reporting to the State when the Migrant Education Agency has identified a student as Migrant. Monthly reports are received through the ConAp, showing our qualifying Migrant students. The data is checked for accuracy and verified in the student information system.

Priority of Services

The appropriate Federal Program Director verifies services of identified students by using grade reports in the student information system.

Services for MEP Students

Currently, Trion City Schools is in the Migrant Consortium.  Students identified as migrant are monitored throughout the year when interims and reports cards are issued. Students who are not performing on grade level are offered tutoring services through the school. Should these not be sufficient, the consortium would be contacted to see if funding is available for additional tutoring.

Services to those students determined to be PFS are be regularly tracked and submitted to the GaDOE MEP using the PFS Student Report. Migrant students are evaluated academically the same as other students in the system to determine academic needs. The MEP Specialist coordinates and tracks services to all MEP students utilizing the Supplemental Services Tracking Form. All migrant students are eligible for Title I services and receive appropriate Title I services. In addition, a referral is made to student services to indicate that additional services may be needed from that department. Additionally, specific activities to address the needs of migratory families are provided. Such activities shall include informing children and families of, or helping such children and families gain access to other education, health, nutrition, and social services.  

Parental Involvement

Should we ever receive funding, a Migrant Education Parent Advisory Council (PAC) program would be provided in conjunction with other District Family Engagement Programs. Parent outreach is always provided in a language that is understood by the family. Family are presented information on ESOL, Special Education, Gifted, and other educational programs. Information on health, nutrition and social services is presented using materials from the Migrant Education Department of the US and GaDOE.

Funding

Should we ever receive funding, TCS would implement a MEP Comprehensive Needs Assessment Committee to review academic and nonacademic data to determine the most appropriate use of Title I-Part C funds and this information leads directly to the development and submission for approval by the GaDOE MEP of the District MEP Implementation Plan(s).  

Evaluation

Should we ever receive funding, the MEP Specialist would observe the actual delivery of the IPs and reports the results of that evaluation to the GaDOE MEP.  Each Implementation Plan is evaluated in terms of effectiveness at its completion, and this evaluation is also submitted to the GaDOE MEP.  

Translation and Interpretation

The Trion City School System believes that ALL Families need access to district and school information. We encourage our families to contact us when they have a question or need for language assistance in terms of understanding district and school information. Interpretation services are available through school/district personnel for families whose native language is not English. Translated district and school’s information are available in Spanish to meet the needs of our families.

Title II, Part A - Teacher and Leader Effectiveness

Purpose

Purpose: The purpose of Title II, Part A is to increase academic achievement by improving teacher and leader quality. For FY22, Trion City Schools transferred all Title II, Part A funds and carryover funds to Title I, Part A.

Equity Belief Statement

The Trion City School System believes all students should have equitable access to quality instruction. The Trion City School System strives to recruit, prepare, train, and support high-quality teachers, paraprofessionals, and leaders in our school system. We are also focused on developing school and district level improvement plans with measurable objectives that will ensure that all teachers are and remain highly effective.

Needs Assessment

Each spring, the Trion City School System begins the needs assessment process by surveying all leaders, teachers, and paraprofessionals.  Once survey results are tallied and summarized by school and system leaders, the results are shared with each school. The needs assessment process at each school includes examining student achievement data, perception data from stakeholder surveys, professional learning plans, teacher recruitment and retention data, highly effective teacher and paraprofessional data, class size data, peer walkthrough data, TKES data, and verbal input from stakeholders.

Once the input is collected from the schools, a series of meetings are then held at the district level to consider all the prior stakeholder input and data and to make decisions regarding prioritized needs and equity concerns.

The results of this needs assessment determine any areas of inequity and guide the development of plans and expenditure of funds.

Equity Plan

The Equity Plan addresses where our district is in meeting the challenge of each equity indicator to assure that all students are receiving the best possible educational opportunities available in an equitable manner.  The Equity Plan serves as the plan detailing professional learning and effective equitable practices among teachers.  TCS determines equity needs as part of the needs assessment process.

The areas for assessing equity include looking at the relationship of our district compared to the state for all schools, high poverty schools and high minority schools in the following:

• CCRPI data
• First Year Teachers
• Teacher Experience
• Out of Field Teaching Assignments
• Teacher Absenteeism
• Teacher/Leader Retention
• Graduation Rate
• Discipline Data
• Student Growth

To develop our Equity Plan we do the following:

• Equity data is provided by the Georgia Department of Education Teacher and Leader Effectiveness Division.
• School administrators, curriculum coordinators, student services and other district office leaders work with the school improvement team to analyze equity data during district data meetings.  
• The Equity data analysis is shared during district data meetings and suggestions for activities that will help us overcome any equity gaps are shared.
• Title II funded activities to address equity gaps are shared with stakeholders during stakeholder meetings and feedback is requested.
• The Equity Plan is revised based on feedback and submitted with the CLIP.
• The Equity Plan is reviewed annually and may be revised and adapted as needed.  Sign-in sheets and agendas are maintained as evidence and documentation of stakeholder involvement in the process.

The Federal Programs Director monitors the implementation of all activities included in the Equity Plan. The Federal Programs Director collaborates with each person responsible for each activity to monitor the timeliness of each activity.  As each activity is completed all source documentation is collected and maintained by the Federal Programs Director.

Prioritized Needs

Based on the TCS Needs Assessment, priorities are identified for the district and identified in the ConAPP

Effectiveness Plan

TCS is not required to submit and Effectiveness Plan, as funds are transferred into Title I, Part A.

Professional Learning

Professional Learning in Trion City is standards based, results-driven, and job-embedded. It is designed to improve student achievement by enhancing teacher content expertise and developing appropriate pedagogical skills. Professional Learning needs are assessed during the Comprehensive Needs Assessment process. Student achievement data, graduation data, and performance data are analyzed, and desired outcomes are stated. The Professional Learning Directors reviews the combined data to develop plans for professional learning that are both school and system based. Once plans are designed and approved by the Principals, School Governances Teams and Professional Learning Directors, the focus becomes the implementation of quality professional learning. Evaluations of professional learning training sessions and the analysis of the evaluations are ongoing. Adjustments in content and skills to be addressed are continuous. Assessing, applying, and sustaining content knowledge and skills that educators need to improve student learning are priorities.

Professional learning will focus on increasing the ability of the teaching staff and administration to help all students achieve high academic standards and eliminate the achievement gap that separates low-income and minority students from other students. The Trion City School System will provide training to enable teachers, paraprofessionals and administrators to address the needs of students with different learning styles, particularly students with disabilities, students with special learning needs (including students who are gifted and talented), and students with limited English proficiency; improve student behavior in the classroom and identify early and appropriate interventions to help students; involve parents in their child's education; and understand and use data and assessments to improve classroom practice and student learning.

Professional Qualifications of Teachers and Paraprofessionals

The Trion City School System seeks to hire qualified teachers, paraprofessionals, and administrators. Vacancies are posted on www.teachgeorgia.org.  A job description is included as well as job requirements. This ensures that the applicants have met the minimum qualifications to meet the required professional qualifications. Qualified applicants are then eligible to interview with principals. Principals make recommendations to the Superintendent, who in turn presents the candidate to the school board for approval. After board approval, candidates are fingerprinted and complete other paperwork.

Parents are informed of their rights to know the qualifications of their children’s teacher.  Before the beginning of each school year, the appropriate Federal Programs Director sends to the principals of every school a list of Required Notifications for Student Handbooks/Agendas. Within this list is the Parent’s Right to Know Teacher’s Training and Credentials. School principals are responsible for providing a copy of the student-parent handbook containing the Parent’s Right to Know to the Directors of Planning and Personnel as evidence of parental notification of their Right to Know. If a school omits the notification from their student handbook, the Federal Programs Director will notify the principal that he/she is required to notify each parent of their Right to Know via 1st class mail before the end of the first week of school. In this case, a copy of the notification letter will be provided to the Federal Programs Director.

If a student has been assigned to or has been taught for four or more consecutive weeks by a teacher who does not meet professional qualifications, parents will be provided a timely notice. All notices and information required must be in a uniform and understandable format, including alternative formats upon request and, to the extent practicable, in a language that parents understand.  Parents may request and receive information regarding:

• Whether the teacher has met state qualifications for the grade levels and subject areas in which the teacher teaches.
• Whether the teacher is teaching under emergency or other provisional status.
• The baccalaureate degree of the teacher and any other graduate certification or degree held by the teacher and the field or discipline of the certification or degree.
• Whether the student is provided services by paraprofessionals.
• Parent notification is not required for the following:
• For teachers who do not teach core academic subjects.
• For paraprofessionals who are not highly qualified.

Any Trion City School System teacher or paraprofessional who does not meet the district’s professional qualifications or who holds a non-renewable certificate will have an individualized remediation plan to meet the professional qualifications or gain a clear renewable certificate. The remediation plan will be developed collaboratively with the teacher, principal, and the appropriate Federal Programs Director at the time of hire or when non-PQ status or non-renewable certificate is determined. All remediation plans are monitored quarterly.

To maintain qualified teachers and paraprofessionals, a Principal training is held each spring. All principals and district staff are trained on the requirements to meet professional qualifications and the placement of teachers and paraprofessionals.

Parents’ Right to Know 

At the start of school, every school principal must notify parents of their right to request the professional qualifications of their child’s teachers and paraprofessionals using the District's template. This should be sent home in the student handbook and posted to the District webpage. Students enrolling after the beginning of school receive a letter of their rights upon enrollment. Receipt of the letter is recorded by a parent/ guardian signature.

Title III and English to Speakers of Other Languages (ESOL)

Purpose

The purpose of the state funded ESOL program is to assist students to develop proficiency in the English language, including listening, speaking, reading, and writing, sufficient to perform effectively at the currently assigned grade level. The purpose of the federally funded Title III supplemental program is to ensure that English learners (ELs) and immigrant students develop English proficiency and meet the same academic content and academic achievement standards that other children are expected to meet.

Trion City Schools does not receive Title III funding and does not participate in a Title III Consortium. Students at Trion City Schools are EL eligible are still identified, provided services, monitored, and participate in state mandated testing. TCS is responsible for meeting OCR requirements for all students.

Student Assessment, Identification, and Enrollment Procedures

Parents/guardians of all students enrolling in the Trion City School System are surveyed via a Home Language Survey (HLS) to determine the student’s first-learned, primary, and home language(s). For students with a language reported on the HLS other than or in addition to English, eligibility for ESOL services is determined using the Kindergarten ACCESS, WIDA Screener, or transfer records demonstrating current eligibility for language assistance services. ELs are assessed annually on the appropriate state-adopted English proficiency measure (ACCESS for ELLs 2.0, Kindergarten ACCESS for ELLs, or Alternate ACCESS) to determine continued eligibility or readiness to exit English language assistance services.

The district notifies parents/guardians annually of their child’s eligibility for ESOL. Such notification is made within the first thirty days of school for students continuing in the ESOL program and within two weeks of the date of eligibility determination for newly identified students. Parents/guardians have the right to decline ESOL services, as outlined in the annual notification. Upon their request, the ESOL teacher will contact the parents/guardians to ensure a clear understanding of the services offered and the educational implications of declining participation in the ESOL program. If the parents/guardians affirm their desire for their child be removed from the ESOL program, the school will provide a waiver form. Upon receipt of a signed parent waiver, the student will be removed from the ESOL program. The school must provide language assistance services through alternate means as outlined in the district procedures for indirect language assistance services. The student remains eligible for classroom and testing accommodations and must participate in the state-mandated annual English proficiency assessment until meeting exit criteria. Parents/guardians continue to be notified annually of their child’s eligibility until such time that the student meets exit criteria, and a new waiver must be collected annually. At any time, the parents/guardians may request reinstatement of ESOL services for their child.

Exit Guidelines

According to GaDOE guidelines, a kindergarten student must score a Composite Proficiency Level (CPL) of 5.0 or higher, a Writing sub-score of 4.5 or higher, and no other individual domain score less than 5.0 to exit the ESOL program. Students in grades 1-12 who score a CPL of 5.0 or higher are considered English proficient and are exited from English language assistance services in accordance with GaDOE guidelines. As allowable under State ESOL program guidelines, TCSS also elects to exit all students in grades 1-12 who achieve an overall score of 4.7-4.9 and to conduct classification Review meetings to determine readiness to exit for all students in grades 1-12 who score a CPL of 4.5 or 4.6.

An ESOL teacher monitors each exited student’s academic performance for two calendar years following exit from English language assistance services. If an exited student transfers to the district during the two-year period following attainment of English proficiency criteria, the student is monitored for the remainder of the two-year period. ESOL teachers further collaborate with regular education teachers when the data indicates students may be struggling in one or more areas. If needed, additional academic supports may be implemented through RTI. If a reasonable period of intervention and monitoring is unsuccessful and the student’s difficulties appear to be related to English proficiency rather than academic deficits or disability, the RTI team may recommend considering to redesignation to EL status with direct ESOL services. The district reviews and responds to the disaggregated data for Formerly EL students.

Funding

The Trion City School System does not receive direct funding for the Title III and ESOL programs to purchase instructional materials, provide professional learning, conduct parent outreach, and to hire the necessary personnel to ensure that the needs of English Learners (ELs) are met. Needs are met through the state and local resources and funding.  

Professional Learning

Every teacher of EL students, counselors, and administrators participate annually in job-embedded, ongoing professional learning relevant to ELs. The results of the annual comprehensive needs assessment guide school and district professional learning plans. ESOL teachers communicate students’ current English Language Proficiency (ELP) scores to staff members and assist their colleagues with identifying appropriate scaffolding techniques and instructional strategies based on these scores.

Parent Outreach

The district carries out an annual Title III event for families of EL students to inform parents of ways to assist their students academically, including understanding English Language Proficiency (ELP) scores as well as other assessments in which their children participate and their implications. School programs, resources, and activities are also shared with parents in these meetings, and parents are provided an opportunity to provide feedback and input. Each school also plans and carries out additional family outreach events throughout the school year to further assist parents, such as Teachers Educate Academic Mindset (TEAM), and the district’s Translation and Interpretation Services Plan supports schools’ efforts to ensure that the activities are accessible to parents of English Learners who need assistance in another language. Rosetta Stone and/or Mango accounts are made available to parents of ELs who have a need and desire to improve their English proficiency to increase their capacity to help their children succeed in school.

The TCSS Translation and Interpretation Services Plan guides district staff in supporting parents in need of language assistance. Upon registration, the district asks parents to indicate their preferred language for oral and written communications. To the extent practicable, communications are provided in the parent’s preferred language. Resources available to assist with translations and interpretation include Language Line, a phone-based interpretation service with over 180 language options; a district translator/interpreter (Spanish); a district-maintained list of approved interpreters and translators (trained and vetted according to procedures established in the TCSS Translation and Interpretation Services Plan); and wireless interpretation equipment for use in large meetings (includes interpreter transmitters and parent headsets).

Supporting the Unique, Non-linguistic Needs of Immigrant Students

Immigrant students who qualify for English language assistance services are supported through the ESOL program. Regardless of English proficiency, immigrant students often arrive with myriad non-linguistic needs. Supplemental instructional materials and/or tutoring are provided to address academic gaps. Assistance with foreign transcript evaluation is provided to students entering with high school credits from another country. Counselors and social workers connect families with district- and community-based services to support non-academic needs such as health, counseling, food, housing, etc.

Program Evaluation and Accountability 

The success of the ESOL instructional program and Title III supplemental programs and initiatives will be measured by analyzing the results of English Language Proficiency (ELP) assessments, academic assessments, and other available measures. As a result of this analysis, programmatic and instructional adjustments are implemented as appropriate. A biennial Title III program evaluation will be conducted, and a report of findings completed. The report will describe the progress EL students have made in language acquisition and meeting specified annual content goals for EL subgroups, including ELs, monitored students, former ELs, and ELs with disabilities.

Title IV, Part A Student Support and Academic Enrichment

Purpose

Title IV, Part A, Student Support and Academic Enrichment (SSAE) grants are intended to improve students’ academic achievement by increasing the capacity of States, LEAs, schools, and local communities to:

• provide all students with 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. (ESEA section 41​01).

Use of Funds

Title IV funds are transferred to Title I.

Individuals with Disabilities Act

IDEA procedures, including those for SST, Child Find, Parent Engagement, Procedural Safeguards, Identification Process, Evaluation/Re-evaluation, Eligibility, Supports and Services, College and Career Readiness, Student Progress, Discipline, and Local Policies and Procedures can be found in the Trion City School System’s Student Support Services Department Manual.

Appendix A: Complaint Procedures

A. Grounds for a Complaint

Any individual, organization, or agency (“complainant”) may file a complaint with the Trion City School System if that individual, organization, or agency believes and alleges that TCSS is violating a federal statute or regulation that applies to a program under the Title I, Part A of the Elementary and Secondary Education Act of 1965 (ESEA). The complaint must allege a violation that occurred not more than one (1) year prior to the date the complaint is received unless a longer period is reasonable because the violation is considered systemic or ongoing.

B. Federal Programs for Which Complaints Can Be Filed

• Title I, Part A: Disadvantaged Children, Academic Achievement Awards, Schoolwide Programs
• Title I, Part C: Migrant Education Program
• Title II, Part A: Teacher and Leader Effectiveness
• Title III, Part A: English to Speakers of Other Languages
• Title X, Part C: The McKinney-Vento Homeless Act

C. Complaints Originating at the Local Level

As part of its Assurances within the ESEA program grant applications and pursuant to Section 9306 within the Title I, Part A of the Elementary and Secondary Education Act of 1965 (ESEA), an LEA accepting federal funds must have local written procedures for the receipt and resolution of complaints alleging violations of law in the administration of covered programs. Therefore, a complaint should not be filed with the Georgia Department of Education until every effort has been made to resolve through local written complaint procedures.  If the complainant has tried to file a complaint with the Trion City School System to no avail, the complainant must provide the Georgia Department of Education written proof of their attempt to migrant the issue with the Trion City School System.

D. Filing a Complaint

A complaint must be made in writing and signed by the complainant. The complaint must include the following:  

• A statement that the Trion City School System has violated a requirement of a Federal statute or regulation that applies to an applicable program.  
• The date on which the violation occurred.
• The facts on which the statement is based, and the specific requirement allegedly violated (include citation to the Federal statute or regulation).
• A list of the names and telephone numbers of individuals who can provide additional information.
• Whether a complaint has been filed with any other government agency, and if so, which agency.
• Copies of all applicable documents supporting the complainant’s position.
• The address of the complainant.  

The complaint must be addressed to Angie R. Bowman, Director of Federal Programs and Curriculum Director. angie.bowman@trionschools.org or 706-734-2363

E.  Investigation of Complaint

Within ten (10) days of receipt of the complaint, the Trion City School System will issue a Letter of Acknowledgement to the complainant that contains the following information:  

• The date the Trion City School System received the complaint.  
• How the complainant may provide additional information.  
• A statement of the ways in which the Trion City School System may investigate or address the complaint.
• Any other pertinent information.

If additional information or an investigation is necessary, TCSS will have sixty (60) days from receipt of the information to complete the investigation and issue a Letter of Findings. If the Letter of Findings indicates that a violation has been found, a timeline for corrective action will be included. The sixty (60) day timeline may be extended if exceptional circumstances occur. The Letter of Findings will be sent directly to the complainant, as well as the other parties involved.    

F.   Right of Appeal

If an individual, organization, or agency is aggrieved by the final decision of the Trion City School System, that individual, organization, or agency has the right to request review of the decision by the Georgia Department of Education. For complaints filed pursuant to Section 9503 (20 U.S.C. 7883, complaint process for participation of private school children), a complainant may appeal to the Georgia Department of Education no later than thirty (30) days from the date on which the complainant receives the Letter of Findings. The appeal must be accompanied by a copy of the Trion City School System’s decision and include a complete statement of the reasons supporting the appeal.  

Appendix B: Tracking Form for Resolution of Complaints

Trion City School System

Federal Program

Tracking Form for Resolution of Complaints