ASPD's Division of Non-Public Supports is available to support both public school district ESSA program administrators and non-public school administrators in implementing the new ESSA requirements affecting students attending non-public, private schools.  

ASPD can support Public School Districts with ...

• Conducting "Child Find" activities for locating and counting the nonpublic students - even when these students attend private schools OUTSIDE of the District boundaries
• Consulting with the nonpublic school officials to meet ESSA "timely and meaningful collaboration" requirements
• Providing Title I services for eligible nonpublic students
  • Locating staff and vendors to deliver programs and services to eligible students, attending private, non-public schools, their teachers, administrators, and parents
  • Implementing, monitoring, and evaluating "Title" programs offered for private non-public school students - especially those in schools located outside of the Public School District boundaries

ASPD can support private schools with assuring that the BILLIONS of federal Title I, Title II, Title III, and Title IV dollars available to support students attending private schools, their teachers, principals, and parents -- including students in religiously affiliated schools -- get allocated and used and are not "lost" by ...

• Correctly identifying and reporting enrollments to all Public School Districts from which students come
• Helping navigate the challenges of "timely and meaningful collaboration" with ESSA program administrators from the multiple districts in which the private school students reside  (some private schools in IL have students from as many as 15 different Public School Districts)
• Using data effectively to defend program and service requests to Public School Districts (we speak "their" language)
• Navigating multiple public bureaucracies on behalf of the students in private, non-public schools throughout the program
• Creating meaningful, valuable service models that meet the requirements of the ESSA laws and can work effectively in private, non-public schools

What are "equitable services" for students in private, non-public schools?

Key Principles Regarding Programs and Services for Non-Public Students

PUBLIC SCHOOL DISTRICT ALERT!

"Title" dollars now follow the student -- even if the student attends a private, non-public school located outside of the Public School District boundaries.

Thus, the Public School ESSA administrator must engage in timely and meaningful collaborative planning with each private school administrator at which a District's students attend, regardless of where that school is located -- even in another state.

PRIVATE SCHOOL ALERT!

Each private school administrator must provide written documentation to each Public School District  where the private school's students live to indicate whether a private school will participate in all programs (Title I, II, III, IV), some, or none available from that District.   Unlike the past, these conversations will occur with EVERY School District from which a private school draws students,  NOT just the Public School District in which a Private School is physically located.   A decision to decline participating robs private school students of programs and services that Congress provided them in ESSA.  A decision to "opt-out" should never be made for expediency or convenience.

A Private School with students from multiple schools may opt to participate in programs offered through one District and decline those from another, however, ONLY students who reside the boundaries of the District from which "Title" programs are accepted may be served by programs from that District because the dollars are specifically for the individual child.  (States have a form for this.)

1. Private schools may not operate their own program.  NO FUNDS MAY BE PAID DIRECTLY TO THE NON-PUBLIC SCHOOL.
2. ALL services and materials for non-public students must be secular, neutral, and nonideological.
3. Programs operated on non-public sites are essentially "off-site" public school programs, not private school programs.
4. Staff and third-party providers operate SOLELY under the control and direction of the PUBLIC SCHOOL DISTRICT, not the non-public school.  (Goals are established during the pre-program planning that meets ESSA's Timely and Meaningful Collaboration requirements.)
5. Program related equipment and materials used at the private school are limited to use only by students selected for participation.  These may not used by others, or for any other purpose.
6. ​Concerns of non-public administrators should first be directed to representatives of the Public School District. 
7. ​After attempts to resolve issues informally, Private School administrators may report concerns about the Public School District to the ESSA Equitable Participation Ombudsperson at the State Department of Education.
8. The Public School District may remove a program from a non-public site when objective data show it is ineffective, or when compliance issues persist.

How Non-Public Students are Selected to Participate in "Title" Programs

Students who meet "poverty" criteria generate funding.  Only students who demonstrate educational need may actually receive services.

1. The chart below, and the explanation, shows how students are selected.
2. Only students who meet the criteria at one level proceed to the next "test".   
3. A student selected to receive services will have met ALL criteria, without exception.

1. AT REGISTRATION TIME (IDEALLY), COLLECT INFORMATION about the School District and the specific public school the child would attend if NOT in the private school.
2. DETERMINE students who live in the attendance area of a local public school eligible for Title I funding - not just a Distict. (These lists are available from the local public school district or the ESSA office at the State Department of Education.)  
3. IDENTIFY students who are failing or at risk of failing - based on MULTIPLE objective criteria (i.e., standardized test scores, report card grades).  Teacher or parent recommendation IS NOT a factor for identifying potential participants.
4. PRIORITY RANK eligible students from most at-risk to least (based on data above).
5. OBTAIN a report from the LEA/SEA showing funds available for Title I, II, III, and IV.
6. SELECT a provider (based on collaborative decisions made during Timely and Meaningful Collaboration).
7. SERVE the maximum number allowed based on dollars available and the vendor's per-pupil cost.

Two ways to serve non-public students

School-by-School
Provide equitable services to eligible students with the funds allocated for that school

Pooling
Participating schools pool their allocations and serve eligible students by prioritized list of need

Requirements for Timely and Meaningful Consultation with Non-Public Schools - NEW IN ESSA (Defined in Title VIII)

"Timely and Meaningful" Consultation Defined

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Topics for Collaboration (Annually and Periodically for Benchmarking)

​Allocations and how they are determined by the State

Current and new year services including Title I parent engagement

How, when, where and by whom services will be provided

Progress monitoring for Title I services

Needs Assessment

End of year evaluation for all ESSA services

​Pooling of funds across schools for students in a SINGLE district (ESSA DOES NOT PERMIT FUND POOLING ACROSS DISTRICTS)

Entrance & exit criteria for Title I services

Cost of administering services and ways to increase ROI and serve the maximum numbers of students and their families

 If the LEA will transfer funds across Titles and if that transfer will impact equitable participation

How and when decisions about the delivery of services will be made by the LEA

LEA concerns regarding program quality or compliance issues

Resources and References

US Department of Education

ESSA  Changes from NCLB
US DoE Office of Non-Public Education (ONPE)

US DoE 2006 (NCLB) Equitable Services Toolkit


 

 ISBE

FY19 Non-Public Enrollment Data for Planning
​FY19 ESSA Projected Allocations to LEAs
​Non Public Participation Webpage
ISBE Consultation Planning Form
Non-Public Participation Presentation: (Apr 2017 - Non Public Conference)

WISCONSIN

Private School Equitable Share Amounts
Presentation:  Title I/II Private School Equitable Participation (Feb 2015)​
Best Practices for Equitable Participation of Private Schools (See p. 9)

​INDIANA

Video Overview:  Equitable Participation
TITLE I Memorandum (Overview/Explanation)
ESSA Allocations for Non-Public Schools

​Contact: Nathan Williamson Director of Title Grants and Support
317-232-6671
nwilliamson@doe.in.gov

GEORGIA

GA Non-Public Participation Site
Sample Timeline: Coordination
​GA Title II Resources/Guidance Page
Form DE-1111:  Report of Students attending Private Schools