General Requirements:
Why Serve Private Schools
The federal programs are supported from tax dollars; therefore all children and teachers are eligible to access these programs. NCLB requires equitable services be provided to private school students, teachers, and other educational personnel.
Equitable Participation
Services should be equitable and should begin at the same time as the public school services. E-Grants calculates the equitable share to be used for services to private schools.
The key word is services. No public funds are distributed to private schools, only professional development services.
Participation Requirements
Public school districts must notify all private schools within the district boundaries of the professional development services available through Title II, Part A.
Private schools must submit the Intent to Participate forms by the spring deadline in order to qualify for services the following school year.
Public school districts must:
- Review Intent to Participate forms and determine which districts wish to participate.
- Contact private schools that indicate an intent to participate and begin consultation process (April-June). Consultation must start prior to submitting the federal grant application and continue throughout the school year.
Consultation Requirements
Consultation between the public school and private schools during the design, development, and implementation of the programs:
- Must be timely and meaningful and must happen prior to district decisions being made to ensure the needs of the private school are considered when professional development.
- Must take place on an annual basis, and be documented by the district. Public school district should complete a written affirmation form (required for Title I) indicating the date the consultation took place between the public and private school. The affirmation of consultation should be signed by both the public and private school officials.
- Must continue throughout the year, to ensure the needs of private school teachers are being met. Consultation is an ongoing process and can occur in many ways. It can be phone calls, e-mails, or a site visit.
- Consultation must cover issues such as:
* How the private school needs will be identified
* What services will be offered
* How and where the services will be provided
* How the services will be assessed and how the results of the assessment will be used to improve those services
* Service delivery mechanisms used to provide equitable services
* Who will provide the services
* The amount of funds available to serve private school students
Public schools must discuss with the private school the amount of services available to them in each of the federal programs.
This will allow the private schools to better plan appropriately and make careful decisions with the public school district to serve their students. |
* The size and scope of the services to be provided
Each public and private school should have a written plan of services to be provided.
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* Consideration of the views of the private school officials regarding the use of third-party providers
* How to resolve disagreements about provision of services:
When the LEA disagrees with the views of the private school officials on the provision of services, the LEA must provide a written explanation of the reasons why the LEA has chosen not to use a contractor.
If the private school officials are dissatisfied, they may file a complaint.
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Complaint Process
If private school officials believe that timely and meaningful consultation has not occurred or that the district did not give due consideration to their views, they should first contact the federal programs representative or superintendent at the school district to discuss their concerns.
In the event the concern is not resolved, the private school has the right to file a formal written complaint with the Office of Public Instruction (OPI). Section 200-3 of the OPI State and Federal Grants Handbook is the guideline for the complaint process.
The formal written complaint should include:
A statement that the district, other educational agency, or in some cases the OPI, has violated a requirement of a federal statue or regulation that applies to a program requiring equitable participation
- The specific requirement alleged to have been violated
- The facts on which the complaint is based
- The name and address of the complainant
- The expected resolution of the alleged violation
- The signature of the complainant
- A complaint should be sent directly to:
Patricia Johnson
Title II, Part A Coordinator
Office of Public Instruction
P. O. Box 202501, Helena, MT 59620-2501
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Specific Requirements:
Purpose
To provide an opportunity for private school teachers to participate in professional development to raise student achievement. (Under Title II, Part A private schools can only participate in professional development). Title II, Part A services to private/nonpublic schools are governed by the Uniform Provisions in ESEA Title IX, Part E.
Ways Services can be Provided
- Participation in scheduled professional development at the school district,
- Provision of services to private school staff by qualified school district staff
- Third-party services (registration to conference, or a contracted trainer).
Determining the Amount of Funds Required for Equitable ServicesThe public district must
- Calculate a per-pupil share of the amount of funds the district plans to use for professional development.
- Compare this amount to the “hold-harmless” amount in E-Grants
- Provide services equal to the larger of the two amounts as the equitable share
Public District Must Operate a Professional Development Program for the Participating Private School Regardless of Public District Needs
Sometimes a public district wants to use Title II, Part A funds to reduce class size or for the purpose of another program. Before making this decision:
- The public district must hold back equitable share for professional development of private school teachers before using the funds in any other way.
- The district must discuss any transfers with the private school before the application is submitted.
Professional Development Programs for Private School Teachers can be Different from that for Public School Teachers
- If the professional development needs of the private school teachers are different from those of the public school teachers, the district and the private school representative should develop a separate program.
- Consultation and coordination are essential to ensuring high quality, sustained, intensive, and classroom-focused professional development activities
Stipends may be paid to Private School Teachers for Professional Development Activities
- The use of the funds for stipends must be reasonable and necessary. For example, if the professional development activity is conducted during after-school hours or in the summer, stipends may be needed to compensate educators for their participation outside their regular employment hours.
- Funds must be paid directly to the private school teacher, not to their school.
Substitutes may not be hired for Private School Teachers to Attend Professional Development Activities
- Funds may be not used to pay for substitutes for private school educators.
- To provide a substitute, funds would have to be given directly to the private school and this is prohibited.
Supplement, Not Supplant
As with all federal funds, Title II, Part A funds must supplement public and private district funds. It is the duty of the public district to ensure that funds used for private school services do not supplant private school funds.
Guidance
Two federal documents govern providing Title II, Part A services to private schools:
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