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AEP Online |
Blaschke on Federal FundingNew Guidance on Title V Gives LEAs More Say in Allocating Fundsby Charles Blaschke Shortly after the FY 2002 budget was passed last December, Congress realized that it had failed to appropriate any funds earmarked for state education agencies to support school improvement under Title I. In reality, the total amount of money dedicated to school improvement under No Child Left Behind in the FY 2002 budget is $20 million less than in the 2001-02 school year. But the some of the new legislative guidance does, at least, grant more control at the local level. The new U.S. Education Department guidance for state and local education agencies to implement Title V (formerly Title VI Innovative Program Strategies) clearly lets LEAs decide how to allocate local Title V-A funds among the 27 innovative assistance areas (see below). School personnel, meanwhile, have primary responsibilty for designing and implementing programs. Of the 15 percent that SEAs may set aside for administration and other purposes, half can be transferred into programs such as Title I. Or, an SEA can use most of its 15 percent set-aside for school improvements and supplemental services, by allocating those funds directly to LEAs with Title I schools targeted for improvement. LEAs must use the 85 percent allocated to them for promoting challenging academic achievement standards, improving student academic achievement, and implementing an overall education reform strategy. LEAs have sole discretion as to how funds are allocated among the 27 allowable uses. Under Education Reform and School Improvement, new allowable uses and/or innovative assistance areas include:
Under the category of Parental Options, new allowable uses and activities include:
For Special Needs populations new allowable uses include:
Literacy and adult education programs that teach principles of economics and financial literacy are now allowable, as are community-based service learning activities. School-based mental health services, as well as CPR training, are now allowable uses. And, as under the old Title VI program, purchase and use of technology--including professional development and teacher training--continue to be allowable uses. The new guidance also requires districts to conduct needs assessments, developing baseline data that will be used to direct Title V funding in proportion to level of need. And districts must annually evaluate progress toward meeting the specific needs identified. But using Title VI, and now Title V, funds to contract for services from for-profit organizations continues to be an “up in the air” issue. While the new guidance clearly allows non-profit groups such as libraries and museums to carry out "programmatic" activities that fit within the 27 categories, the guidance states, “An SEA or LEA may not use Title V-A funds to contract with a for-profit agency, organization, or institution to operate programs or conduct programmatic activities. However, this does not preclude an SEA or LEA from contracting with an individual or a for-profit corporation or other organization to purchase specific goods or services (e.g., equipment and materials, computer hardware and software, audit services, evaluation services, professional development services) to assist the SEA or LEA in carrying out a program.” As noted above, an SEA could allocate some of its Title V-A funds to districts to purchase some supplemental services in schools targeted for improvement for two consecutive years--and an LEA could do the same. The question then becomes: Can these funds can be used to contract with a state-approved for-profit supplemental service provider to conduct programmatic activities such as tutoring, online instruction, etc? One of the issues discussed with Federal officials and key Congressional committee chairmen involved in drafting NCLB was the concern that, under the 50 percent transferability provision, funds could be repeatedly reallocated--from other Titles to Title V, then to one or more of the 27 categories whose state or local funding had decreased. This, in the past, would have been considered “supplanting.” While the guidance says supplanting isn't allowed under Title IV-A, it does state that in certain instances an SEA or LEA may overcome the presumption that supplanting will result if Title V funds are used for a state-mandated program or activity whose state or local funds have been reduced. In those instances, the LEA would have to demonstrate through written documentation that it does not have the funds necessary to implement the program or activity. Later on, the new guidance states, “In no event, however, may an SEA or LEA decrease state or local funds for a particular activity because Title V-A funds are available.” Given state and local revenue shortfalls, it is very possible that Title V-A funds will be used to make up for budget reductions in state-mandated programs that are allowable under Title V, such as school improvement. And last, while an SEA continues to fall under a “maintenance of effort clause” (i.e., it must spend at least 90 percent of what it spent last year on specific activities that continue to be implemented), an LEA is not required to maintain such fiscal effort. Even though the new Title V introduces some accountability by requiring annual evaluation of progress toward goals in the 27 programmatic areas, most district officials will continue to view Title V (like its predecessor Title VI), as the most flexible ESEA funding source--a source they can use in just about any way they choose. Based upon USED studies four years ago, such funds likely will continue to be used for some software purchases, and professional development related to the implementation of state assessments and standards. However, one can anticipate LEAs transferring some of their Title V-A funds to Title I schoolwide programs, as clearly allowed in the new guidance; Title I schoolwide programs are not required to report on how funds are spent.
Questions, ideas, or in need of information? Please contact Dave Gladney at 856-241-7772 or dgladney@AEPweb.org. |
For a copy of the guidance, click here. |
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2008 The Association of Educational
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