The last few emails have focused on the Title I program. Today I’m switching gears just a bit and moving into the Title IIA program. Title IIA for professional development has many additional uses under ESSA, and perhaps significantly more funds for the benefit of your students and their teachers. (Funding for Title IIA was discussed in an earlier email in this series.)
You can find non-regulatory guidance from the U.S. Department of Education on the Title IIA program here. This guidance does not cover equitable services (funding for equitable services is covered under the equitable services guidance found here.) It does give you a really full picture of the possibilities for the use of Title IIA funds under ESSA.
The opening section for the guidance sets the stage for the focus of Title IIA. It reads:
Support for Educators
- Multiple Pathways to Teaching and Leading
- Induction and Mentorship
- Meaningful Evaluation and Support
- Strong Teacher Leadership
- Transformative School Leadership
While not exhaustive, this section highlights important opportunities to support educators, while acknowledging that Title II, Part A funds alone likely are not enough to fully address and support the entire educator career continuum.
An important element of Title IIA equitable services to keep in mind when planning Title IIA activities for students attending private schools is that the primary beneficiary of the program must be the students. Meeting their needs is the foundation of the program. This means that the primary beneficiary is not the private school and is not the private school teacher. The activities under Title IIA are allowable only insofar as they lead to higher student achievement.
Throughout the guidance, there is an explanation of each of the areas detailed above and a list of recommended strategies. In the guidance, the U.S. Department of Education acknowledges that Title IIA cannot be the sole source of funding to accomplish all objectives. This brings the issue of supplement/supplant into the forefront. This term means that federal funds must supplement but not supplant the use of state and local funds. Sometimes this is interpreted to also mean the funds from private schools. While this interpretation is a reach under the general understanding of supplement/supplant (how can the district judge whether the private school can afford to privately pay for the professional development planned?), generally speaking, federal funds should be used to add to the professional development, either in time or quality, rather than take the place of professional development.
For example, if the private school normally brings in a speaker for a day at the beginning of each school year on a topic that the school (or group of schools) will be focusing on throughout the school year, federal Title IIA funds are not a way to “save” money on this activity. Instead, federal funds can be used to extend this activity. If the speaker is only for the one day with private funds, federal funds could bring the speaker back mid-year to assess how the project has progressed and to breathe new life into it. Federal funds could add a coaching component to the project. Or, if the private funding is no longer available to the private school (such as a grant that expired after three years), the project could continue with federal funds and in the absence of private funds that are no longer available.
Similarly, if the private school schedules professional development days throughout the school year, but due to lack of funding is setting up professional learning communities around a publication that meets their professional focus, federal funds could add a coaching component, a speaker, or more resources to enhance what the school was already doing.
As you read through the Title IIA guidance prior to consultation with your public school district, examine your professional development goals outlined in the school’s strategic plan, accreditation documents, etc. and determine how Title IIA could extend and enhance your efforts to improve teaching and learning in your classrooms.