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 V, 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.
* 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.
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
Specific Requirments:
Purpose
Title V, Part A, Innovative Programs supports education reform and innovative school improvement programs to improve school, student, and teacher performance.
Title V, Part A:
Provides support in 27 different activities such as library materials/media and professional development, not all of which are available to private schools.
Generally the amount of services and materials is limited, but it is the most flexible of all the Title programs.
Most private schools use these funds to support their libraries.
Title V, Part A services to private/nonpublic schools are governed by Title V, Part A statute and guidance.
Administrative Requirements
The public district retains control over and title to all materials purchased with Title V, Part A funds
The public district inventories and labels all materials placed in a private schools
The public district ensures that any equipment or materials placed in a private school are used only for the proper purposes
The public district ensures that materials are
Secular
Neutral
Non-ideological
Supplementary
Cannot supplant (replace) private school funds
The public district ensures that materials
Benefit specific needs of private school students
Do not benefit the general needs of private school students
Do not benefit the private schools
The public district assigns one employee to work with participating private schools
The public district ensures that materials
Benefit specific needs of private school students
Do not benefit the general needs of private school students
Do not benefit the private schools themselves
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 V, 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.
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