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2025-2026 Fall Equitable Participation Universal Monitoring Supports

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Reminders

Please …

Remain muted unless prompted, and in those cases, raise your hand;
Engage in audience activities;
Identify questions and concerns that go unanswered, there will be space to lift them up, as time permits.

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ESEA Equitable Participation

Local Educational Agencies (LEAs) are responsible for ensuring that services agreed upon during consultation are provided to eligible, participating private schools and that the funds for such services are obligated in the fiscal year for which they are received.

DPI is responsible for ensuring LEAs provide equitable services as required by the Elementary and Secondary Education Act (ESEA).

Under the Elementary and Secondary Act (ESEA), LEAs are responsible for ensuring that services agreed upon during consultation are provided to eligible, participating private schools and that the funds for such services are obligated in the fiscal year for which they are received. DPI holds oversight responsibility to ensure equitable services are provided and federal funds are being utilized appropriately. As part of DPI’s monitoring of equitable participation, LEAs that used less than 10 percent of a grant’s private share in the prior school year are identified for universal supports. The required action for this identification is to attend this webinar, where we aim to provide detailed information and support around equitable participation requirements. We hope this webinar helps your LEA grow its foundational knowledge around the provisions to more seamlessly navigate the many components of equitable participation with your private schools.

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Objectives

Support LEAs’ efforts to successfully meet equitable participation requirements by providing:

A detailed overview of the consultation process, including the requirements that drive it;
A summary of how equitable shares are calculated;
An understanding of the needs assessment process; and
An overview of services and benefits that are allowable.

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LEA Equitable Services Self-Assessment�

Please take the next 10 minutes to complete the provided self-assessment (link posted in the chat)
The survey will help us gauge LEAs varying levels of compliance when implementing equitable participation requirements.
This will identify areas in which additional supports, awareness, and technical assistance is necessary.

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Consultation

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Consultation is a mandatory process that involves meaningful discussions between the LEA and private school representatives on key issues relating to the participation of eligible private school children in federally funded equitable services.

Consultation

ESEA section 1117(b)(3) and 8501(c)(1)

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Consultation

Timely, meaningful, and ongoing.
Agreement between LEA and private school on how best to provide effective equitable services for private school children, their teachers, and families.

Certify the agreement by completing the private School Affirmation Form after all consultation topics have been discussed.
DPI’s ESEA Affirmation Form

ESEA section 1117(b)(3) and 8501(c)(1)

LEAs must consult with private school officials to provide eligible children, their teachers, and families with Title services equitable to those provided to public school students.

Consultation is mandatory and must be timely and meaningful.

Timely: Consultation occurs before the LEA makes any final decisions on the type of services to be provided.
Meaningful: Allows for private school partners to have purposeful input to foster collaboration.
Ongoing: It doesn’t end after the Affirmation of Consultation form is signed – it is ongoing and requires that there be touch points throughout the year.

Purpose of consultation is to reach an agreement on what Title programs the private school wishes to participate under and how best to provide services and benefits to the private school students, their teachers, and families in accordance with the specific program. Decisions and agreements should be affirmed by the signing of the Affirmation of Consultation form.

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Consultation: Who Should be Involved?

ESEA Title Coordinator

Teacher Representative(s)

Fiscal Staff

LEA

Private School

Private School Leader

Teacher Representative(s)

These same staff should be in communication throughout �the year to ensure services are provided as planned throughout the year, enabling the LEA to budget and claim.

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Consultation Timeline

LEAs should hold initial consultation in early spring prior to the start of the next school year.

The ESEA Private School Affirmation Forms screen typically opens for the next fiscal year in late March.
LEAs are unable to access their next year’s Title applications until signed affirmation forms are accepted for each of their private schools.

During initial consultation, LEAs should select dates throughout the year for ongoing communication with private school representatives.

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Consultation: Required Topics

Method or sources of data used to determine low-income status
How student needs will be identified
Size and scope of equitable services, the proportion of funds allocated for such services, and how the proportion is determined
Pooling (school-by-school, within LEA, across LEAs)

Services to be provided – how, when, where, who?
Process for evaluating services
Coordination of funds across programs
Public Control of Funds

ESEA section 1117(b)(1), 1117(a)(4)(A)(ii) and 8501(a)(5)(c-d)

LEAs are required to consult on and reach agreement in regards to several specific topics prior to the signing of the affirmation form. You can find these topics on the first page of the Affirmation form. The form should not be signed by a representative from either entity until after all these topics have been addressed and decisions agreed upon.

An important note on pooling - the decision on whether to pool must be agreed upon by the LEA and private school officials; the LEA cannot make a unilateral decision to pool funds.

Pooling Options:

No pooling
Pooling Title funds among private schools within a single LEA - Essentially, multiple PS in the district, e.g., multiple PS within the Madison school district ( in this instance there would be one rank and srvde student list of all the students in the PS).
Pooling Title funds among private schools across LEAs - Essentially means a district is paying another districts to provide the services. This can happen w/o pooling
School by School pooling would be like two or more PS want to pool together but not with a third.

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Consultation: Required Topics

Any decisions made by the LEA that may affect the private proportional share

Administrative and Indirect Costs
Family Engagement
Carryover
Transferability of ESEA Funds

Public Control of Funds (an LEA’s role in fiscal management)

ESEA section 1117(a)(4)(A)(ii), (b)(1) and 8501(a)(5)(c-d)

The LEA must explain how much funding is available under each Title, and how the amounts are calculated. This includes an explanation of any difference between the amount of funding available for services and the total amount of the equitable share. For example, will the LEA use a portion of funds for direct and indirect administrative costs necessary for coordinating services to the private school? Is there anticipated carryover from the prior year? Does the LEA plan to transfer funds from one Title to another? The LEA and private school should also discuss the Public Control of Funds provision, ensuring the private school understands that the LEA must maintain all control of Title funds, and any materials, equipment, or property and that the ESEA prohibits private schools from obligating or receiving federal funds. The LEA should communicate their process for ensuring compliance with this provision.

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Ensuring Consultation is Meaningful

Put students’ welfare first
Include both program and fiscal staff in the discussions
Be prepared and plan ahead – provide advance notice for dates and required data elements

Email Template for Initial Consultation for Private Schools

Start early in the year to allow for genuine discussion and additional meetings if necessary
Cover all required topics and ensure private school has time to ask questions/voice concerns
Use deadlines to ensure compliance with requirements (i.e. student data, or details needed to ensure services are not delayed)

In order for consultation to be considered meaningful, both the LEA and private school must be given a genuine opportunity to provide input on the required topics. It is a best practice to include both program and fiscal staff at consultations. Consultation should start early in the year with ample time to meet in case multiple meetings are necessary to cover all required topics. If there are multiple private schools located in your LEA, consider meeting with each one individually at least once. When inviting private schools to consult, consider what information can be shared with them ahead of time and what technical assistance you can include in your initial outreach. The DPI has several resources available that describe the roles and responsibilities of both the LEA and private school, overviews of each ESEA Title program like this slide here, guidance on and examples of what data will be required (enrollment, poverty, and assessment); and several sample templates for streamlining the consultation process. Using deadlines throughout the year when meeting certain requirements, like the collection of data from the private school, helps ensure the LEA meets the obligation of funds requirement as well as encourages active participation from the private school. Lastly, always consider what is best for students when making decisions on what services will be provided.

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Working Together for Impact

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Brainstorm! Use chat or volunteer to share �(raise your hand✋)

You reached out to your private school to schedule a consultation meeting. The private school only replied back with a signed affirmation form. What are your next steps?

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Enrollment and Poverty Data

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Enrollment Data

Drives the amount of funding available to support private school students, their teachers, and families under each grant.
LEAs are required to collect private school student enrollment data as part of the consultation process.
Title II and IV includes all students that attend a private school.
Title I requires LEAs to identify private school students who reside within their public school attendance areas.

ESEA section 1117(b)(1), 1117(a)(4)(A)(ii) and 8501(a)(5)(c-d)

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Title I-A Private School Enrollment

ESEA requires additional data collection from private schools electing to participate under Title I, Part A due to the requirement that a private school student is only potentially eligible for Title I services if they reside in a participating Title I public school attendance area; and because the Title I-A funding calculation’s dependency on low-income status.

Section 1117(a)(4)(A)

Enrollment and Poverty Data relies on:

Consistent Count Date
Poverty Measure
Addresses & Grades of Students �(supports identification of public school attendance area)

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Count Date

The same “Count Date” must be used to collect enrollment date for public and private schools.

If the same date can’t be used, the data must be as close as reasonably possible.

Section 1117(a)(4)(A)

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Poverty Data for Title I

During consultation, the LEA must determine what poverty data the private school has available and discuss what poverty measure will be used.

If available, the same poverty measure must be used that is being used for the public school.
LEA has final authority to determine the measure used.

Process can be completed every year or once every two years.

Must be consistent among the private schools.

ESEA section 1117

As mentioned, Title I private school enrollment requires additional information, including poverty data. Poverty data is essential for driving the Title I proportional share calculation. Without this data, no determination can be made regarding the amount of funding available to support a private school’s eligible students.

Things that you as an LEA need to keep in mind:

It’s required that the LEA and private school discuss what poverty data is available during consultation and what measure will be used.
If the same measure (FRL) is available that needs to be used.
The LEA has final authority to determine the poverty measure used.
A private school is not required to participate in the Free and Reduced Priced Lunch Program or have the same poverty measure in order to participate in Title I.

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Poverty Data for Title I

Poverty Measure and Poverty Threshold are different.
The poverty measure is the poverty data available.
Poverty threshold is the income level for identifying a student as low-income.

Example: 185% of poverty is the threshold for eligibility in Free & Reduced Priced Lunch.

20 U.S.C. 6320(b)(1)(F)

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Poverty Measures for Title I

Option A	Option B	Option C	Option D	Option E
Using the same measure of poverty used to count public school children. (i.e., Free and Reduced-price lunch, 185% or lower.)	Using comparable poverty data from the results of a private school parent survey (extrapolated, if complete, actual data is not available). The private school and/or the LEA can create and administer the survey.	Comparable poverty data from a different source. (i.e., a private school has a tuition assistance program and the income threshold for the program is generally the same as the threshold used to count public school students.)	Proportionality. An LEA applies the low-income percentage of each participating Title I public school attendance area to the number of private school students who reside in that attendance area.	Equated measure. An LEA uses what data they have available for private schools (e.g., TANF data) and correlates sources of data to determine a proportional relationship.

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Enrollment and Poverty Date

LEAs must collect this information for all private school students attending a Title I participating private school:

Student Addresses

Grade Level

Household Income-level Data

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Why do we need to capture all of this data?

Title I has multiple dependencies based on where a student resides:

A private school student generates funds if they reside in a public school attendance area served in the previous year and are low-income.
A student is only potentially eligible if they reside in a served public school attendance area.
Remember, a student doesn’t need to be low-income to receive services.
An LEA is responsible for ensuring it’s resident students receive Title I services and communicating to another neighboring LEAs if their students are in attending the private school.

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LEA and Private School Responsibilities

LEA Responsibilities	Private School Responsibilities
Share resources and communicate information with the private school regarding enrollment data.	Review any shared resources and information to better understand enrollment and poverty data requests.
If applicable. Identify the available poverty measure that will be used to collect poverty data for the students at the private school.	If applicable. Be prepared to discuss the types of poverty data that may be available and, if not readily available, work with the LEA on how to collect.
Inform the private school of the count date used for the public school students. The date must be the same.	Conduct student counts from the same (or a reasonably close) count date.
Determine how enrollment data will be collected from the private school (i.e., template, spreadsheet).	Provide requested enrollment and poverty data to the LEA in the requested format by the requested date.
Identify the numbers of students with low-income status per the poverty data provided by the private school.
Enter enrollment data into WISEgrants and communicate funding to private school.

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Title I-A Private School Enrollment

When entering private school enrollment, private school students must be assigned to the public school they would attend if enrolled in the LEA. To ensure students are assigned correctly:

Section 1117(a)(4)(A)

Make note of each student’s address and grade.
Identify any ‘Grade Span’ differences between the private school and public school attendance areas to ensure all grades within the private school are accounted for.

This may require the LEA to assign multiple public school attendance areas simply to account for all of the private school’s grades.

For WISEgrants to generate a proportional share for each participating private school, the LEA must enter enrollment for its participating private schools in the Title I Application. When entering private school enrollment into the application, LEAs must:

Enter enrollment for all private schools participating in the LEA’s Title I-A services. The private enrollment data entered for each private school must include all private school students that reside within the public school’s attendance area and would otherwise attend that public school. WISEgrants will not allow an LEA to move forward with the application until enrollment counts are entered for all participating private schools.
Enter low-income enrollment for all participating private schools - this includes identifying if the private school has zero low-income students (please note this is specific to low-income enrollment, WISEgrants will not accept zero for total enrollment from LEAs)
Use the same date used for public school enrollment, or a date relatively close.
Use the same or comparable measure of poverty for both private and public school children (when available).
Be consistent with 4K and PK counts. If 4K and PK students are included in the public school enrollment, they must also be included in the private school enrollment. If 4K and PK enrollment counts are included, the LEA must be able to include low-income enrollment data.

The most common concern we see here is that not all grade spans are covered or the LEA is trying to enter in zeros for enrollment.

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Title I-A Private School Enrollment

Reminder: Private school students should be assigned to the public school they would attend if enrolled in the district, taking into consideration their address and grade.

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Funding

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Private School Share

LEAs use student enrollment data entered in WISEgrants to determine the amount of available funding for services under each Title.
Factors that may affect the total amount of funding available under the private share:

Reservations

Direct and indirect administrative costs
Family Engagement – Title I only

Carryover
Transferability of ESEA Funds

ESEA section 1117(b)(1) and 1117(a)(4)(A)(ii) ESEA section 8501(a)(5)(c-d)

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Share for Title I - A

Calculation uses the number of low income students from Title I Public School Attendance Areas in the previous year.
Private school must share addresses and student grades so LEAs can determine:

The number of low-income students who reside in Title I-served attendance areas
If there are students who reside outside of the district, and
What students are eligible for services

Reservations are set-aside after the proportional shares are calculated.

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TI Proportional Share

WISEgrants uses the public and private enrollment data to calculate the amount of available funding for services under each subbudget (Public and Private):

Section 1117(a)(4)(A)

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Private School-level Allocations

*There are no “Unserved Attendance Areas” as the LEA allocated Title I funds to all public schools in the fiscal year.

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Shares for Titles II-A or IV-A

The proportional share calculation relies on total enrollment for the public schools and each of the participating private schools.

Uses enrollment data from the ESEA Centralized Enrollment screen.

This is only for those private schools located in the LEA’s boundaries.
Reservations are set-aside from the allocation before the proportional shares are calculated.

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TII / TIV-A Proportional Share

WISEgrants uses the total public and private enrollment data to calculate the amount of available funding for services under each subbudget (Public and Private):

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Private School-level Allocations

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Title III-A Share

2024-25 State’s Allocation

$6,997,902

Number of Students Administered the ACCESS Test in 2023-24

59,716

Share

for the School

Number of Students Administered the ACCESS Test in 2023-24

in the School

2024-25

Per Pupil Amount

$117.19

2024-25

Per Pupil Amount

$117.19

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Needs Assessment and

Planning for Services

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Needs Assessment

Required part of the consultation process for all Titles in which a private school is participating
Determines the educational needs of private school students, their teachers, and families
Results are used to identify the services that will provide the most benefit to the private school students

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Collecting Assessment Data

Private schools may not have the same data available as the LEA. Focus on the types of data available, which may include:

Scores on standardized tests (e.g., Forward Exam, IOWA, STAR, PALS, etc.)
Classroom assessments, including formative and summative (e.g., iReady, MAPS, etc.)

Data from private schools can and may be different from the data collected and used in the assessment process for the LEA’s public schools.

Portfolio of student work
Writing samples
Teacher recommendations
Input from families
Report card grades

The LEA and private school should discuss beforehand what type of data will be used for the needs assessment, taking into consideration the type of data the private school has available. Private schools may not have the same data as the LEA; and an LEA with multiple private schools may find variances in the types of data available amongst the private schools. The focus should be on the types of data that are available and how they can be used to support the needs assessment process. This slide includes examples of some varying types of data sources that should be considered.

It’s important to note that a private school can and may collect assessment data for all students attending their school to determine which students may have educational needs. This is also helpful in instances where the private school is participating in Title II and/or Title IV and a comprehensive of the private school students needs is necessary..

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Assessing Needs for Title IV-A Services

The private school collects available data for all students to prioritize areas of need for the students at the school.

The LEA and private school review the available data together.

What is the data showing us about areas of greatest need for all students at the school? What services would best meet these needs ?

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Title IV Services

Supplemental services that address one or more priorities of Title IV-A within the private school. These supported priorities include:

Well-Rounded Educational Opportunities
Safe and Healthy Students
Effective Use of Technology

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Title IV-A Services

Allowed costs include:

Staff and professional development to support the greatest academic needs
Mental health counselors
Supplies and instructional materials to support the greatest academic needs

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Assessing Needs for Title II Services

The private school collects available data for all students to prioritize areas of greatest need for the students at the school.

The LEA and private school review the available data together.

What is the data showing us about areas of greatest need for all students at the private school? What professional development would support the teachers in meeting these needs?

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Title II Services

Support the greatest needs of all students in core subjects as well as other areas that impede students’ academic achievement through high quality professional development provided to teachers and private school staff (including paraprofessionals, principals, and other school leaders).

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Title II Services

Professional Development Must:

Improve content knowledge or classroom practice or
Address student behavior in the classroom and identify early interventions to help students with special needs

Allowable costs for professional developments include:

Conference registration, transportation and lodging
Stipends to Private School Staff in excess of staffs’ contracted time
Supplies, books, or instructional resources

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Assessing Needs for Title III Services

The private school collects available data for identified EL students to prioritize areas of greatest need for the students at the school.

The LEA and private school review the available data together, including ACCESS test results.

What is the data showing us about EL student needs? What services for students and/or their families would best meet these needs? What professional development would support the teachers in meeting these needs?

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Title III Services

Support English Learners (ELs), including immigrant children and youth in attaining English language proficiency and developing high levels of academic achievement through one or more of the following:

Direct Instruction
Professional Development
Family Engagement

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Title III Services

Allowable costs include:

Teachers and paraprofessionals supporting the EL students
Supplies and instructional materials for EL students
Professional Development for Teachers of ELs
Family engagement activities for EL students

Supplemental instruction for eligible students should always be considered first.

Title III Services

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Assessing Needs for Title I Services

The private school collects available data for eligible students at risk or most at risk of failing to meet rigorous academic standards in their school setting.

The LEA and private school review the available data together.

Identify the students who qualify for services by ranking eligible students in order of greatest need.

What is the data showing us about the greatest areas of need for eligible students’? What services for students and/or their families would best meet these needs? What professional development would support the teachers in meeting these needs?

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Determining Eligibility for Title I Services

Private school student resides in a Title I served public school attendance area

�

Private school student is most at risk of failing to meet academic standards

Private school student is eligible for Title I services

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Determining Eligible Title I Students

The LEA and private school select the criteria to determine what educational need looks like in the school.
Using the criteria, the LEA and private school identify students most at risk of failing to meet academic standards.
Next, eligible students are rank ordered in the areas of greatest need and prioritized for services with those students most-in-need served first.

Private school students and their needs should not be compared to the students in the public schools, but rather to their private school peers, in the same private school setting.

ESEA sections 1115(a), 1115(c)(1)(B), and 1117(a)(3)(A)

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Title I Services

Direct services that support eligible students in core subjects, as well as other areas that impede a student’s academic achievement such as:

Reading, math, science, social studies, behavioral health, socio-emotional health, etc.

Other services may include:

Professional development to support Title I students’ needs, family engagement activities for families of Title I students, and any necessary materials, supplies, or equipment to support the services.

Simply providing materials and supplies is not considered viable Title services and not sufficient to meet equitable participation requirements.

Title I funds can be used to support academic need across core subjects and other areas that impede a student’s academic achievement such as behavioral or socio-emotional health. While the most prevalent, Reading and Math are not the only options for a TI program. Simply purchasing materials and supplies is not considered a viable Title I program.

Service delivery methods for TI support can include mentoring, counseling, small group instruction, blended instruction, expanded learning time (before and after school), summer school, family literacy programs, computer assisted instruction, and individual tutoring. Direct instructional services should always be considered first.

NOTE To Remember: You cannot purchase other services WITHOUT direct services.

All Private Schools must have a viable T1 program and they should work with their Title 1 administrator at your LEA to figure out what that looks like for your school?
Direct instructional services should always be considered first.

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Title I Services

Allowable costs include:

Teachers and paraprofessionals supporting the eligible students with the greatest academic needs
Before or after school programming for Title I students
Supplies and instructional materials for Title I services
Family engagement activities for students receiving Title I services

Direct services for eligible students should always be considered first.

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Brainstorm! Use chat or volunteer to share �(raise your hand✋)

Your LEA and participating private school review needs assessment data, and discover that it would be helpful for the private school to participate in professional development activities surrounding math. Additionally, several students could benefit from reading services. What are your suggestions?

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Title I Services Across LEAs

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TI Equitable Services Across LEAs

Under Title I, the LEA in which the private school students reside (Student Resident LEA) is responsible for ensuring that eligible students receive services and benefits. What does the term “ensure” all encapsulate?

1

Identification of Students

Identifying and/or being informed that they have resident students at a private school located outside of the LEA.

2

Enrollment Data

LEA must include enrollment data for these students in its Title I-A application. If not all enrollment data is available, the LEA is responsible for contacting the private school to collect any missing information.

3

Funding

Based on provided poverty data and the public school attendance areas for private school students, WISEgrants will determine if any funds is available for the private school.

4

Determining TI Eligibility

Does the private school student reside in a TI served public school? If yes, they are potentially eligible. A needs assessment is required to identify area(s) where support may be needed.

5

TI Services

Planning for and implementing Title I services. Services could be provided by the LEA or through a contract with another organization including a different LEA, a private school staff, or a private company.

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Identifying Students from Outside LEAs

The LEA where a private school resides will be aware of another district’s resident students first due to the consultation process.

Through consultation, the LEA where a private school resides must collect enrollment data for all students attending a private school. And, if Title I participating, the LEA must also collect the addresses and grades of students.

This allows for the identification of students from who reside in an outside LEA.
In this case, the LEA is required to contact any Student Resident LEAs to provide them with enrollment data.

Student Resident LEAs may also be aware of their students attending a private school outside of their boundaries due to bussing agreements or because students have historically attended a school.

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GIS Map to Identify the Student Resident LEA

DPI’s WI School District GIS Map

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If a private school is participating in Title I and has students that reside outside of the LEA’s boundaries, the LEA consulting with the private school must contact the Student Resident LEA.

A new tool now available in WISEgrants:

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Providing Title I Services

If an LEA has resident students in a Title I participating private school outside the LEA, how will the students’ needs be met?

Start with considering what conversations have already transpired with the LEA where the private school is located and/or the private school.
What are the area(s) of need for the students?
What type of services does the LEA where the private school is located provide? Is there opportunity to coordinate with their services?
Is there opportunity to contract with private school staff to provide before or after school supports?
Has there been discussions on “pooling funds across LEAs” within the private school?

Determining how services will be provided when students reside in one LEA but attend a private school in another is essential for ensuring the obligation of funds requirement is met. The student resident LEA is responsible for generating an allocation and ensuring services are provided. Services can be provided in a variety of ways and both LEAs and the private school should consider the following when deciding how to meet this requirement: Can the student resident LEA provide services? Can the LEA where the private school is located provide services? Can a third-party vendor or contractor provide services? Does the private school have a preference?

Once a decision has been made for how services will be provided it is essential to document the decisions that were made and ensure all parties have access to the plan for services. The student resident LEA is still responsible for ensuring services are provided to their resident students regardless of whether or not they are the entity providing the services.

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Options for Providing Title I Services

Student Resident LEA

Provides services to its own resident students, or contracts with a service provider (beside another LEA) to provide Title I services to its resident students

Coordination between LEAs

Agreement for contracted services between two LEAs
Funds available for services are based on a district’s private school share to support their resident students
*Often, the LEA where the private school is located provides the services, but services may be provided by other service providers (see below)

Pooling across LEAs within a Private School

Still results in agreement / contracted services between at least two LEAs
Funds available for services are based on the total pool of funds across; funds are used to support students with the greatest, regardless of where they reside
*Often, the LEA where the private school is located provides the services, but services may be provided by other service providers (see below)

Other Service Providers:

Private School Staff

Under contract w/ LEA
Must hold appropriate licensure
Outside of standard private school work responsibilities / day

Third-party Vendor

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Pooling Funds Across LEAs

Title I equitable services for eligible private school students are provided through combined funding generated from the the LEAs within the pool. In collaboration with relevant private school officials, the LEAs must develop criteria to determine how student needs will be assessed and how services will be provided among eligible private school children. The services provided to eligible children are not based on the funds generated by the student(s) specific LEA. Instead, the services are based on the needs assessment process and ranking of students.

The LEAs in the pool may arrange for one LEA, another public entity, or a third-party contractor to deliver services to eligible private school children and educators across the participating schools.

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Developing a

Services Plan

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Planning for Services

Factors to Consider:

Needs assessment data
The amount of available funding
The number of identified eligible private school students
Services and benefits to be provided
Location of private school compared to LEA’s public schools
When, how, by whom, and where the services will be provided
Preferences of private school participants
How services provided can be evaluated for effectiveness
An evaluation of the prior year’s services (what worked, what didn’t)

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Service Provision

How and when will services take place?
Where will services be provided?
Who will provide the services?

ESEA section 1117(b)(3) and 8501(c)(1)

Developing a plan for equitable services is a required component of consultation. An equitable services plan must include certain crucial elements, including, but not limited to how and when services will take place, where the services will be provided, and who will provide the services.

Helpful questions to consider for how and when services will take place include: What services can the LEA provide? How do these services work for the private school? Will services be provided before or after school? In a pull-out model? On weekends? In the summer? Are there certain days of the week that work best? How will the LEA ensure the students aren’t repeatedly being pulled out of the same classes?

Helpful questions to consider for where services will be provided include: Where is the private school located in relation to the LEA’s public schools? Will distance be a barrier for who can provide services or how often?

Helpful questions to consider for who will provide the services include: What is the LEA’s staff capacity? Will the LEA contract with a third-party provider? Will the LEA contract with a teacher at the private school?

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Developing a Plan for Services

LEAs must document the plan for services during the consultation process. LEA will be required to submit such documentation to DPI for monitoring purposes.

Document discussions when planning for services
Document the final decisions
Make the documentation accessible for both the public and private school officials

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Developing a Plan for Services

Incorporate ongoing consultation and deadlines into the plan for services:

Schedule dates for the LEA and private school staff to connect
LEAs have the authority to establish deadlines for a private school to meet equitable participation requirements:

Discuss deadlines during initial consultation(s) and include them in the plan for services
Deadlines can help ensure requested data is provided or follow-up occurs in a timely manner, so as not to impede the application process and services

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(Item B-31, USDE, Providing Equitable Services to Eligible Private School Children, Teachers, and Families Non-Regulatory Guidance, October 7, 2019)

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Cohesion in Title Services

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Evaluating Services

How will the services be evaluated for effectiveness throughout the school year?
What can be learned from any prior year services?
What process is in place to modify services?

ESEA section 1117(b)(3) and 8501(c)(1)

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Ensuring Services Are Provided

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Delivery of Services

An LEA is responsible for ensuring the agreed upon services are provided and that funds are obligated in the fiscal year in which they are received

Active participation by the private school is necessary
An LEA can help foster the active participation through:

Ongoing consultation
Utilization of deadlines
Referencing written evidence of the services plan

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ESEA section 1117(a)(4)(B) and 8501(a)(4)(A))

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Obligation of Funds

LEA maintains all control of ESEA funds
LEAs are responsible for obligating funds

Private schools cannot enter into contracts for services
Invoices cannot be in the private school’s name

LEAs cannot reimburse private schools for purchases

ESEA section 1117(a)(4)(B) and (d)(1))

The ESEA requires an LEA to maintain control of Title funds, materials, equipment, and property. This means that the LEA alone has the authority to obligate Title funds. Private schools may not obligate or receive Title funds. No Title funds may be paid to a private school, even as a reimbursement. For example, private schools cannot enter into contracts for services nor provide invoices in the private school’s name to be paid by the LEA. A common phrase we hear when an LEA has unobligated funds is, “the private school didn’t spend any of their funding.” While we understand that the private school must be active participants in the process to help the district meet the obligation of funds requirement, the LEA is ultimately responsible for the obligation of funds requirement. Simply put it’s not possible for the private school to spend the funds.

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Deadlines

An LEA may and should impose deadlines to ensure equitable services are provided as agreed upon through consultation and support meeting the obligation of funds requirement.

Non-regulatory guidance grants LEAs the right to use deadlines to ensure private schools remain active and engaged throughout consultation, implementation, and evaluation of services.

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Setting a Deadline

Identify the requested action
Set a clear and reasonable deadline by which action must be completed
Support the private school’s understanding of the “why” / “purpose” behind the action.

Example: As we discussed during our initial consultation meeting, the attached student enrollment form needs to be completed and returned by May 20 to help determine the amount of funding available.

Verbally communicated deadlines should be followed up in writing.

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Enforcing a Deadline

If a private school misses a deadline, it is at the discretion of the LEA on how to proceed.
A missed deadline can be viewed as a private school failing to be an active participant.
If an LEA has concerns about a missed deadline, and a private school’s continued lack of active participation, the LEA needs to reach out to DPI for support.

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ESSA Ombudsman

Monitors and enforces equitable participation of private schools in federal education programs covered by ESEA
Provides technical assistance to LEAs and private schools in consultation for the goal of reaching agreement; and
Engages with public and private stakeholders to determine how best to support their relationships.
essaombudsman @dpi.wi.gov

(Item E-1, USDE, Providing Equitable Services to Eligible Private School Children, Teachers, and Families Non-Regulatory Guidance, October 7, 2019)

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What is something you learned in this webinar that you are going to use moving forward, whether this year still or next year?��

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Questions? �

Please use the chat or raise your hand✋
Questions will be addressed as remaining time allows
Questions are being documented so that an FAQ from both sessions can be shared out with the slide deck later this month.