Vermont Monitoring Report, September 21-24, 2009, …€¦ · Web viewA school in became eligible for Title I for the 2008-2009 school year. Since this school had not been eligible

Vermont Department of Education

September 21-24, 2009

Scope of Review: A team from the U.S. Department of Education’s (ED) Student Achievement and School Accountability Programs (SASA) office monitored the Vermont Department of Education (VDE) the week of September 21-24, 2009. This was a comprehensive review of the VDE’s administration of the following programs authorized by the Elementary and Secondary Education Act of 1965 (ESEA), as amended: Title I, Part A, Subpart 3; and Title I, Part D. Also reviewed was Title VII, Subtitle B of the McKinney-Vento Homeless Assistance Act (Education for Homeless Children and Youth) as amended by ESEA.

In conducting this comprehensive review, the ED team carried out a number of major activities. In reviewing the Title I, Part A program, the ED team conducted an analysis of State assessments and State Accountability System Plans, reviewed the effectiveness of the instructional improvement and instructional support measures established by the State to benefit local educational agencies (LEAs) and schools, and reviewed compliance with fiscal and administrative oversight requirements required of the State educational agency (SEA). During the onsite week, the ED team visited Burlington Public Schools (BPS) and St. Albans City (SAC), interviewed administrative staff, and conducted parent meetings. The ED team then interviewed the VDE personnel to confirm the accuracy of data collected in each of the three monitoring indicator areas.

In its review of the Title I, Part D program, the ED team examined the State’s application for funding, procedures and guidance for State Agency (SA) applications under Subpart 1 applications, technical assistance provided to the SA, the State’s oversight and monitoring plan and activities, SA subgrant plans and evaluations for Neglected and Delinquent programs in Winooski Public Schools (WPS) and BPS. The ED team also interviewed the VDE Title I, Part D State coordinator to confirm information obtained at the SA site and to discuss administration of the program. In its review of the Title VII, Subtitle B of the McKinney-Vento Homeless Assistance Act (Education for Homeless Children and Youth) as amended by ESEA, the ED team examined the State’s procedures and guidance for the identification, enrollment and retention of homeless students, technical assistance provided to LEAs with and without subgrants, the State’s McKinney-Vento application, and LEA applications for subgrants and local evaluations for projects in Burlington, Winooski, Chittenden East and Colchester. The ED team visited sites and interviewed administrative and program staff. The ED team also interviewed the VDE McKinney-Vento State coordinator to confirm information obtained at the local site and discuss administration of the program. The ED team also interviewed the McKinney-Vento State coordinator to confirm the accuracy of information obtained at the local site and discuss administration of the program.

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Previous Audit Findings: None.

Previous Monitoring Findings: ED last reviewed Title I programs in Vermont on November 28-December 2, 2005. ED identified compliance findings in the areas of alternate assessments, out of level assessment option, accountability workbook components, SEA and LEA annual report cards, statewide system of support, parental involvement, program improvement requirements, schoolwide components, state allocations, audits, complaint procedures, and Committee of Practitioners.

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Improper Payments Act

During the week of September 21-24, 2009, the ED team also conducted a pilot review of the Improper Payments Act. Some of the fiscal topics discussed during the interview were time and effort; personnel; written policies and procedures; training; equipment; and allowable costs. The VDE’s method of monitoring fiscal expenditures and controls was also discussed during the interviews. The following observations/recommendations were noted during the interviews:

The BPS has established internal fiscal controls and procedures that meet requirements for expending Title I funds, accounting for their use, and maintaining necessary records as provided in Title I, Part A of the Elementary and Secondary Education Act, section 443(a) of the General Education Provisions Act (GEPA), Part 80, Subpart C of the Education Department General Administrative Regulations (EDGAR), the Improper Payments Information Act, and any other relevant standards, circulars or legislative mandates to safeguard Federal funds and assets and protect against waste, fraud and abuse. However, the VDE should work with BPS to address numerous A-133 findings.

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Overarching Requirement – SEA Monitoring

A State’s ability to fully and effectively implement the requirements of ESEA is directly related to the extent to which it is able to regularly monitor its LEAs and provide quality technical assistance based on identified needs. This principle applies across all Federal programs under ESEA.

Federal law does not specify the particular method or frequency with which States must monitor their grantees, and States have a great deal of flexibility in designing their monitoring systems. Whatever process is used, States must have mechanisms in place sufficient to ensure that they are able to collect and review critical implementation data with the frequency and intensity required to ensure effective (and fully compliant) programs under ESEA. Such a process should promote quality instruction and lead to achievement of the proficient or advanced level on State standards by all students.

Status: Met Requirements

Recommendation: ED recommends that the VDE formalize its process for identifying high-risk grantees.

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Title I, Part A Summary of Monitoring Indicators

Monitoring Area 1, Title I, Part A: AccountabilityIndicator Number

Description Status Page

1.1 The SEA has an approved system of academic content standards, academic achievement standards and assessments (including alternate assessments) for all required subjects and grades, or has an approved timeline for developing them.

FindingRecommendation

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1.2 The SEA has implemented all required components as identified in its accountability workbook.

Recommendation 6

1.3 The SEA has published an annual report card as required and an Annual Report to the Secretary.

Finding 6

1.4 The SEA has ensured that LEAs have published annual report cards as required.

Finding 7

1.5 The SEA indicates how funds received under Grants for State Assessments and related activities (Section 6111) will be or have been used to meet the 2005-06 and 2007-08 assessment requirements of the No Child Left Behind Act (NCLB).

Met Requirements N/A

1.6 The SEA ensures that LEAs meet all requirements for identifying and assessing the academic achievement of limited English proficient students.


Monitoring Area 1: Accountability

Indicator 1.1: The SEA has approved system of academic content standards, academic achievement standards and assessments (including alternate assessments) for all required subjects and grades, or has an approved timeline for developing them.

Finding (1): The VDE does not have a clear definition for limited English proficiency (LEP), except for a cut score on the English language proficiency assessment, which may be locally overridden. Definitions of limited English Proficient (LEP) students and criteria for student exit from the LEP subgroup may vary across LEAs in the State due to the flexibility the State allows for LEAs in defining criteria for student exit from the LEP subgroup.

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Citation: Section 1111(b)(2)(v)(I)(dd) of the ESEA requires adequate yearly progress (AYP) determinations for LEP students. Section 1111(b)(2)(C)(ii) of the ESEA requires that AYP progress shall be defined by the State in a manner that is statistically valid and reliable.

Further action required: The VDE must implement policies that provide for consistent definitions of LEP students and criteria for student exit from the LEP subgroup across the State. The VDE must clearly document these policies for LEAs and schools and provide ED with documentation of these policies as well as evidence that the VDE has provided this documentation to LEAs and schools.

Recommendation: ED recommends that the VDE make available a broader range of linguistic accommodations to LEP students, e.g., permitting that assessment directions be translated.

Indicator 1.2: The SEA has implemented all required components as identified in its accountability workbook.

Recommendation: ED recommends that the VDE update its accountability workbook to reflect current State policy and address all required components.

Indicator 1.3: The SEA has published an annual report card as required and an Annual Report to the Secretary.

Finding: The VDE has not ensured that it has included all required components in its State report card. Many elements for the VDE annual report card can be found at various locations on its website. However, not all required elements can be located on the website. The VDE staff indicated that some pages of the report are still under construction. Elements are difficult to locate on the website and it is unlikely that the general public can easily access the annual report card because it is not one document.

Citation: Section 1111 (h)(1)(C) of the ESEA requires that the State Annual Report Card include:

Information in the aggregate on student achievement at each proficiency level on the State academic assessments disaggregated by race, ethnicity, gender, disability status, and migrant status, English proficiency and status as economically disadvantaged (where the minimum “n” has been met);

Comparison of the actual achievement levels of each group of students previously described in the State’s annual measurable objectives for each required assessment;

The percentage of students not tested, disaggregated by the same categories noted above by subject;

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The most recent two-year trend in student achievement in each subject at each grade-level for grades in which assessment is required;

Aggregate information on any other indicator used by the State to determine AYP;

Graduation rates that are consistent with ED-approved State definitions; Information on LEAs regarding whether they made AYP, including the number

and names of schools identified for school improvement; and The professional qualifications of teachers in the State, including percentage of

such teachers teaching with emergency or provisional credentials, and the percentage of classes not taught by highly qualified teachers in the aggregate and disaggregated by high-poverty compared to low-poverty schools.

Further action required: For the next test year, 2009-2010, the VDE must include all required elements in its State report card and provide ED with the revised report, or a web link to it.

Indicator 1.4: The SEA has ensured that LEAs have published annual report cards as required.

Finding : The VDE has not ensured that each LEA’s published annual report card contains all of the required information.

Citation: Section 1111(h)(2)(B) of the ESEA requires that the SEA shall ensure that each local educational agency collects appropriate data and includes in the local educational agency’s annual report the information described in paragraph (1)(C) as applied to the local educational agency and each school served by the local educational agency. This includes:

Information, in the aggregate and disaggregated by required subgroups, on student achievement at each proficiency level on the State academic assessments;

Information that provides a comparison between the actual achievement levels of each group of students and the State’s annual measurable objectives on each of the academic assessments required under this part;

Information on how students served by the LEA achieved on the statewide academic achievement assessment compared to students in the State as a whole;

The percentage of students not tested for all required groups; The most recent two-year trend in student achievement in each subject area,

and for each grade level, for which assessments under this section are required;

Aggregate information on any other indicators used by the State to determine AYP, and aggregate information on any additional indicators used by the LEA to determine AYP;

Graduation rates that are consistent with ED approved State definitions;

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Information on the performance of the LEA regarding whether it made AYP and whether it has been identified for improvement, including the number and percent of schools identified for school improvement by name and how long the schools have been so identified; and

The professional qualifications of teachers in the LEA, including the percentage of such teachers teaching with emergency or provisional credentials, and the percentage of classes in the State not taught by highly qualified teachers, in the aggregate and disaggregated by high-poverty compared to low-poverty schools.

Further action required: For 2009-2010, the VDE must provide ED with (1) templates or web links to LEA report cards that include the required elements, and (2) a plan for how the VDE will monitor and ensure that LEA report cards contain all required elements.

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Monitoring Area 2, Title I, Part A: Program Improvement, Parental Involvement, and OptionsIndicatorNumber


2.1 The SEA has developed procedures to ensure the hiring and retention of qualified paraprofessionals.

Finding 9

2.2 The SEA has established a statewide system of support that provides, or provides for, technical assistance to LEAs and schools as required.


2.3 The SEA ensures that LEAs and schools meet parental involvement requirements.

FindingsRecommendation

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2.4 The SEA ensures that LEAs and schools identified for improvement, corrective action, or restructuring have met the requirements of being so identified.


2.5 The SEA ensures that requirements for public school choice are met.


2.6 The SEA ensures that requirements for the provision of supplemental educational services (SES) are met.


2.7 The SEA ensures that LEAs and schools develop schoolwide programs that use the flexibility provided to them by the statute to improve the academic achievement of all students in the school.


2.8 The SEA ensures that LEA targeted assistance programs meet all requirements.


Monitoring Area 2: Program Improvement, Parental Involvement and Options

Indicator 2.1: The SEA has developed procedures to ensure the hiring and retention of qualified paraprofessionals.

Finding: The VDE has not ensured that all instructional paraprofessionals hired in Title I schools are highly qualified. Staff interviewed in SAC indicated that there were paraprofessionals currently working in Title I schools in the 2009-2010 school year that did not meet the hiring requirements as specified in section 1119 of ESEA.

Citation: Section 1119(c)(1) of the ESEA requires that new paraprofessionals hired after the date of enactment of NCLB and working in a program supported with Title I funds shall have: a) completed at least 2 years of study at an institution of higher education; b) obtained an associate’s (or higher) degree; c) met a rigorous standard of quality and can demonstrate, through a formal State or local academic assessment, knowledge of, and the ability to assist in instructing, reading, writing and mathematics; or d) knowledge of and the ability to assist in instructing, reading readiness, writing readiness, and mathematics

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readiness as appropriate. Section 1119(d) of the ESEA requires that all paraprofessionals hired before the date of enactment of the reauthorized ESEA and working in a program supported with Title I funds shall, not later than four years after the date of enactment, satisfy the requirements of subsection (c) listed above. Through a policy announcement from the Deputy Secretary, ED informed States that they would have until the last day of the 2005-2006 school year to comply with these requirements.

Further action required: The VDE must ensure that SAC are complying with the requirement to employ only instructional paraprofessionals in Title l schools who meet the hiring requirements in section 1119(c) of ESEA. The VDE must provide ED with documentation of the steps that SAC has taken to immediately reassign paraprofessionals not meeting Title I hiring requirements.

Indicator 2.3: The SEA ensures that LEAs and schools meet parental involvement requirements.

Finding (1) : The VDE has not ensured that its LEAs have fully implemented the parental involvement requirements. The VDE has not ensured that all Title I schools hold annual Title I meetings that explain the requirements of the law and the right of parents to be involved. In BPS and SAC, it was not clear that the annual Title I parent meeting was being held.

Citation: Section 1118 (c) (1) of the ESEA requires that “[E]ach school served under this part shall convene an annual meeting, at a convenient time, to which all parents of participating children shall be invited and encouraged to attend, to inform parents of their school's participation under this part and to explain the requirements of this part, and the right of the parents to be involved.”

Finding (2): The VDE has not ensured that LEAs inform Title I school parents of the one percent reservation for parental involvement and allow them to be involved in the decisions regarding how these funds are allotted for parental involvement activities. BPS and SAC principals indicated that the parental involvement reservation funds were not discussed with parents.

Citation: Section 1118 (3)(B) of the ESEA requires that parents of children receiving services under this part be involved in the decisions regarding how funds reserved under subparagraph (A) are allotted for parental involvement activities. Further action required for Findings 1 and 2: The VDE must provide ED with documentation that it has informed BPS and SAC that Title I meetings must be convened for all Title I schools before the end of the 2009-2010 school year at a time convenient to parents. These Title I annual meetings must be used to inform parents of their schools’ participation in Title I and explain the right of the parents to be involved. The meetings must explain the purpose of the one percent funds for parental involvement and the

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parents’ right to be involved in how the reservation is allotted for parental involvement activities. The VDE must provide ED with documentation that the meetings were held.

Finding (3): The VDE has not ensured that each of its LEAs conducts an annual evaluation of the content and effectiveness of its parental involvement policy, revising, if necessary, the LEA’s parental involvement policies with parents. In interviews with staff from BPS and SAC, there was no evidence that parents of Title I schools were involved in the annual evaluation of the parental involvement policy.

Citation: Section 1118(a)(2)(E) of the ESEA requires the LEA to conduct, with the involvement of parents, an annual evaluation of the content and effectiveness of the parental involvement policy in improving the academic quality of the schools, including identifying barriers to greater participation by parents in activities authorized by Title I with particular attention to parents who are economically disadvantaged, are disabled, have limited English proficiency, have limited literacy, or are of any racial or ethnic minority background, and to use the findings of the evaluation to design strategies for more effective parental involvement, and to revise, if necessary, the parental involvement policies.

Further action required: The VDE must provide ED with documentation that it has provided written guidance to BPS and SAC regarding the implementation and evaluation of the annual evaluation of parental involvement policies with the involvement of parents. The VDE must ensure that BPS and SAC conduct an annual evaluation of the parental involvement policy during the 2009–2010 school year and provide ED with appropriate documentation. Finding (4): The VDE has not ensured that parents have been informed of their right to request information on the professional qualifications of their child’s teachers. Parent notification letters were not available for the SAC.

Citation: Section 1111(h)(6)(A) of the ESEA requires LEAs, at the beginning of each school year, to notify parents of children attending Title I schools that they may request, and the LEA will provide in a timely manner, information regarding the professional qualifications of the students’ classroom teachers:

Whether the teacher has met State qualifications and licensing criteria for the grade levels and subject areas in which the teacher provides instruction;

Whether the teacher is teaching under emergency or other provisional status through which the State qualification or licensing criteria have been waived;

The baccalaureate degree major of the teacher and any other graduate certification or degree held by the teacher, and the field of discipline of the certification or degree; and

Whether the child is provided services by paraprofessionals, and if so, their qualifications.

Further action required: The VDE must provide ED with documentation that it has notified SAC that it must notify parents using the VDE template of their right to know

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their child’s teachers’ qualifications and right of notification when their child is taught for four or more consecutive weeks by a teacher who is not highly qualified for the 2009-2010 school year.

Recommendation: ED recommends that the VDE work with the Vermont State Parent Information and Resource Center (PIRC) to develop and provide professional development activities for educating teachers, pupil services personnel, principals, and other staff, with the assistance of parents, in the value and utility of contributions of parents, and in how to reach out to, communicate with, and work with parents as equal partners, implement and coordinate parent programs, and build ties between parents and the school.

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Monitoring Area 3, Title I, Part A: Fiduciary ResponsibilitiesIndicator Number


3.1 SEA complies with— The procedures for adjusting ED-determined allocations

outlined in sections 200.70 – 200.75 of the regulations. The procedures for reserving funds for school improvement,

State administration, and (where applicable) the State Academic Achievement Awards program.

The reallocation and carryover provisions in sections 1126(c) and 1127 of the Title I statute.


3.2 SEA ensures that its LEAs comply with the provision for submitting an annual application to the SEA and revising LEA plans as necessary to reflect substantial changes in the direction of the program.


3.3 SEA ensures that all its LEAs comply with the requirements in section 1113 of the Title I statute and sections 200.77 and 200.78 of the regulations with regard to (1) Reserving funds for the various set-asides either required or allowed under the statute, and (2) Allocating funds to eligible school attendance areas or schools in rank order of poverty based on the number of children from low-income families who reside in an eligible attendance area.

Findings 14

3.4 SEA complies with the maintenance of effort (MOE) provisions of Title I.

SEA ensures that its LEAs comply with the comparability provisions of Title I.

SEA ensures that Title I funds are used only to supplement or increase non-Federal sources used for the education of participating children and do not supplant funds from non-Federal sources.

Finding 15

3.5 SEA ensures that its LEAs comply with all the auditee responsibilities specified in Subpart C, section 300(a) through (f) of OMB Circular A-133.


3.6 SEA ensures that its LEAs comply with requirements regarding services to eligible private school children, their teachers and families.


3.7 SEA complies with the requirement for implementing a system for ensuring prompt resolution of complaints.


3.8 SEA complies with the requirement to establish a Committee of Practitioners and involves the committee in decision-making as required.


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Monitoring Area 3: Fiduciary Responsibilities

Indicator 3.3: Within District Allocation Procedures. The LEA complies with the requirements in sections 1113, 1116, & 1118 of the Title I Statute and sections 200.77 and 200.78 of the regulations with regard to: (1) Reserving funds for the various set-asides either required or allowed under the statute, and (2) Allocating funds to eligible school attendance areas or schools in rank order of poverty based on the number of children from low-income families who reside in an eligible attendance area.

Finding (1): The VDE does not have procedures in place to ensure that schools with lower percentages of poverty do not receive a higher per pupil amount than schools with a higher percentage of poverty. A school in became eligible for Title I for the 2008-2009 school year. Since this school had not been eligible prior to this time, BPS did not initially allocate Title I funds to it. After the VDE reviewed the BPS Title I application, the VDE did require that BPS provide Title I funding to the school. However, by the time that BPS was notified of this, it did not have sufficient Title I funds to allocate to it in order to meet Title I requirements. Consequently, BPS allocated a higher per pupil amount to schools that had lower poverty levels.

Citation: Section 1113(a)(3) of ESEA requires that a local educational agency (LEA) serve its eligible school attendance areas or schools in rank order of poverty. After serving all its schools with a poverty rate above 75 percent in rank order, an LEA may then rank the remaining eligible schools by grade span and serve those schools in rank order, making sure that no lower ranked school is allocated more per pupil than a higher ranked school.

Further action required: The VDE must provide ED with a detailed description of how it will annually ensure the correct implementation of this requirement in a timely manner. In addition, the VDE must provide ED with evidence that, for the 2009–2010 school year, BPS has complied with this requirement.

Finding (2): The VDE does not have procedures in place to ensure that its LEAs calculate equitable services on parental involvement and applicable districtwide reservations. BPS had not calculated equitable services on parental involvement and applicable districtwide reservations.

Citation: Section 1118(a)(3)(A) of the ESEA requires that LEAs with a Title I, Part A allocation of greater than $500,000 to reserve not less than one percent of their Title I, Part A allocation to carry out parental involvement activities. Section 200.65 of the Title I regulations requires LEAs to calculate from these funds the amount of funds available for parental involvement activities for families of private school students based on the proportion of private school students from low-income families residing in Title I attendance areas. The LEA then must distribute to its public schools at least 95 percent of the remainder, leaving the balance of the reserved funds for parental involvement activities at the LEA level. Any funds related to this requirement that the LEA does not

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use that year must be carried over into the next fiscal year and used for parental involvement activities. If an LEA reserves more than the required one percent of its Title I, Part A funds for parental involvement activities, the requirement to allocate an equitable amount for the involvement of private school parents applies to the entire amount reserved for this purpose.

If an LEA reserves funds under Section 1119 of the ESEA for carrying out professional development activities, the LEA must provide equitable services to teachers of private school participants from this set-aside. Sections 200.65(a)(1) and (2) of the Title I regulations require an LEA to calculate the amount of funds available for professional development activities from the reserved funds based on the proportion of private school children from low-income families residing in participating public school attendance areas. Activities for the teachers of private school participants must be planned and implemented with meaningful consultation with private school officials and teachers.

Section 200.64(a)(2)(i)(A) of the Title I regulations requires that, if an LEA reserves funds for instructional activities for public elementary or secondary students at the LEA level, the LEA must also provide from these funds, as applicable, equitable services to eligible private school children. The amount of funds available to provide equitable services from the applicable reserved funds must be proportional to the number of private school children from low-income families residing in participating public school attendance areas.

Further action required: The VDE must ensure annually that its LEAs correctly calculate equitable services for services to the teachers and families of participating private school students annually. The VDE must provide ED with a detailed description of how and when it informed its LEAs of these requirements. This documentation must include letters to LEAs or agendas for technical assistance meetings. The VDE must also provide ED with a description of how it will annually ensure the correct implementation of these requirements. The VDE must submit to ED evidence that, for the 2009–2010 school year, BPS has correctly calculated the amount of Title I funds, including any applicable carryover funds that must be reserved for services for the teachers and families of private school students.

Indicator 3.4: Maintenance of Effort, Comparability, and Supplement not Supplant

Finding: Although the VDE requires its LEAs to indicate in their applications how they have met comparability requirements, it has not developed guidelines regarding when comparability must be calculated and a date by which all LEAs must meet comparability requirements. The VDE does not require that its LEAs develop written procedures for complying with comparability requirements including timelines, and how the LEA will make adjustments to Title I schools that are not comparable. The VDE does not review documents at least once every two years. Neither BPS nor SAC was able to provide written documentation that comparability requirements were met.

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Citation: Section 1120(A)(c) of the ESEA states that an LEA may receive Title I, Part A funds only if State and local funds are used in participating Title I schools to provide services that, taken as a whole, are at least comparable to services in non-Title I schools. LEAs or SEAs must keep records to document that policies were actually implemented annually and that they resulted in equivalence among schools in staffing.

Further action required: The VDE must provide ED with a detailed description that it has developed and provided guidance on comparability requirements to its LEAs. The VDE must also provide ED with a description of the procedures that it will use to annually demonstrate that its LEAs have met comparability requirements. These procedures must include a description of how it will review comparability information in a timely manner as well as how necessary staff adjustments are made for schools found to be non-comparable will be documented.

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Title I, Part DSummary of Monitoring Indicators

Neglected, Delinquent or At-Risk of Dropping-Out ProgramIndicatorNumber


1.1 The SEA has implemented all required components as identified in its Title I, Part D (N/D) plan.

Met requirements N/A

1.2 The SEA ensures that State agency (SA) plans for services to eligible N/D students meet all requirements.


1.3 The SEA ensures that local educational agency (LEA) plans for services to eligible N/D students meet all requirements.


2.1 The SEA ensures that institution-wide programs developed by the SA under Subpart 1 use the flexibility provided to them by law to improve the academic achievement of all students in the school.


3.1 The SEA ensures each SA has reserved not less than 15 percent and not more than 30 percent of the amount it receives under Subpart 1 for transition services.


3.2 The SEA conducts monitoring of its subgrantees sufficient to ensure compliance with Title I, Part D program requirements.


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McKinney-Vento Homeless Education ProgramSummary of Monitoring Indicators

McKinney-Vento Homeless Education ProgramIndicator Number


1.1 The SEA collects and reports to ED assessment data from LEAs on the educational needs of homeless children and youth.


2.1 The SEA implements procedures to address the identification, enrollment and retention of homeless students.


2.2 The SEA provides, or provides for, technical assistance for LEAs to ensure appropriate implementation of the statute.


3.1 The SEA ensures that LEA subgrant plans for services to eligible homeless students meet all requirements.


3.2 The SEA ensures that the LEA complies with providing comparable Title I, Part A services to homeless students attending non-Title I schools.


3.3 The SEA has a system for ensuring the prompt resolution of disputes.


3.4 The SEA conducts monitoring of LEAs with and without subgrants, sufficient to ensure compliance with McKinney-Vento program requirements.


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Documents

Vermont Monitoring Report, September 21-24, 2009, …€¦ · Web viewA school in became eligible for Title I for the 2008-2009 school year. Since this school had not been eligible