Consultation must include a discussion of the funding available and how this determination of the proportional share was made. One way to help ensure transparency in funding discussions during consultation is to use worksheets that are completed together or sent in advance to the LEA so that they can have the data ready for discussion and examination at the consultation meeting. In this way, the LEA can complete some of the information or at least bring the necessary information into the consultation meeting for discussion. The following is an example of funding projection worksheets by programs that comprises Tool #7 in ESSA Toolkit: A Guide for Equitable Services for Private School Students, Fall 2021.
ESSA Title I: Improving the Academic Achievement of the Disadvantaged
Title IIA: Preparing, Training, and Recruiting High Quality Teachers, Principals, or Other School Leaders
Title IVA: Student Support and Academic Enrichment Grants
Funding is determined by calculating the proportion of private school students attending private schools located in the public school district in comparison to all public and private school students in the district.
Title III: Language Instruction for English Learners and Immigrant Students
There are two funding calculations for Title III. Funding is determined by calculating the proportion of private school students who are English learners and attending private schools located in the public school district in comparison to all English learners attending public and private school students in the district. Funding is also determined by calculating the proportion of private school students who are immigrant students and attending private schools located in the public school district in comparison to all immigrant students attending public and private school students in the district.
This worksheet should be completed for English learners and again for immigrant students, unless the LEA combines the funding together.
Not only is calculation of funds an important part of the consultation process between public and private school officials, but the State Education Agency (SEA) has the obligation to provide the funding amount for each program to each private school official in a timely manner that can ensure it can be used as part of the consultation process.
Two other aspects of funding are the obligation of funds and the time frame in which the funds must be spent. Funds must be fully obligated within 27 months of their availability. Funds made available July 1, 2022 (for example) must be fully obligated by September 30, 2024. Obligation of funds takes place at different times depending on how the funds will be spent. If the funds are being used to purchase property (such as tablets) the obligation is made when the LEA makes a binding written commitment to purchase the property. If the obligation is for personal services (such as direct instruction through Title I), the obligation is made when the public employees deliver the services OR when the third party is contracted to deliver the services, even if the services will actually be delivered at a later date. Obligation of funds for travel occurs when the travel occurs.
The law requires that the proportional share of funds to serve eligible private school students be obligated in the year in which they are available. If the obligation is not made at that time, the funds should be carried over for private school students to benefit from the following year (unless equitable services were received). In any case, all obligated funds must be spent within the 27 months period described above.
Being knowledgeable about the proportional share of funding, how it should be determined, and when and how it must be obligated and spent will help ensure equitable services for your students through the consultation process.