Dear Colleagues,

Previously, I wrote about the new Title VIII guidance.  On July 17, 2023, the U.S. Department of Education issued the long-anticipated Title VIII non-regulatory guidance for ESSA.  This guidance explains Equitable Services for Eligible Private School Children, Teachers, and Other Educational Personnel.  You can find the guidance at Today, I want to provide a summary and analysis of the Title IIA section that is included under “Program Specific Requirements”, questions H-1 to H-15.

LEA’s Responsibility

As specified in the guidance, an LEA must consider the following in making a decision regarding whether the requested PD is allowable:

  • Does the PD meet the definition of professional development?
  • Is the PD evidence-based?
  • Is the PD reasonable and necessary in order to provide Title IIA equitable services?
  • Does the PD supplement and not supplant PD that would have otherwise been provided to private school teachers, principals and other school leaders?

As a result, the structure of the PD request must strive to answer “yes” to each of these questions.

What is “Professional Development?”

The definition of professional development is two-fold:

  1. The PD activity must be part of the strategies for providing educators with the knowledge and skills necessary to enable children to succeed in a well-rounded education.
  2. The PD must be sustained (not stand-alone, 1-day, or short term workshops), intensive, collaborative, job-embedded, data driven, and classroom-focused.

How to Present an Effective PD Plan

If you want to have your teachers attend a conference or want to offer a one-day workshop, it’s content must be part of an overall focus that your school undertaking.  There should be a theme for the school’s PD throughout the year.  Coupling a one-day workshop with coaching that focuses on the same element of teaching and learning would help ensure that the PD request meets the definition of professional development.  Combining multiple one-day workshops would also help ensure it meets the definition.  Be sure you’re not presenting a “little of this, little of that” plan of action.  Ensure there is a comprehensive theme that meets students needs and has specific achievable objectives.

If you are working with a vendor or looking at an on-line opportunity, be sure to gather any evidence of effectiveness and make this part of your PD plan presentation.

“Reasonable and necessary” is a standard that always applies to federal education programs.  The best ways to demonstrate this is by tying the activity to meeting the needs of students to ensure they succeed in a well-rounded education.

“Supplement, not supplant” also applies to federal education programs.  Simply using Title IIA funds to fill in the required PD days that are in your teachers’ contract probably does not meet the requirement of supplementing what you would already be doing for PD on those required days.  Instead, Title IIA PD on those required teacher days should focus on extending and enhancing the PD the school would already provide.  For example, if the PD you planned was to purchase materials to establish a PLC, Title IIA could pay for a professional facilitator to kick off and conclude the activity, and an instructional coach that would help with the implementation of the PLC content.  You would continue the PLC discussions as planned throughout the school year; Title IIA would enhance and extend the planned activities and therefore supplement the private school’s program.  This applies whether a school is working on its own or pooling funds and working as a group.


Be sure that as the private school official in consultation, you are prepared with a comprehensive PD plan for Title IIA that the LEA can approve by answering “yes” to each of the questions specified in the guidance.

All the best,


Michelle L. Doyle

Michelle Doyle Educational Consulting