Welcome!

The webinar will begin at 3:30 p.m.

Title III Program MonitoringTier I, Tier II, & Tier III

and BAAS Documentation

February 6, 2014

North Carolina Department of Public Instruction

K-12 Programs

Title III/ESL Office

Monitoring Focus

• Programmatic Success

• Compliance

Areas Assessed

• ELD Standards

• Assessment & Accountability

• Instructional Support

• Fiscal Compliance

Tiered Monitoring

Build Capacity

Tier I

Tier II

Tier III

Tiered Monitoring

Build Capacity

Tier IFeb. 1 – Mar. 31,

2014

Tier II

Tier IIIhttps://www.surveymonkey.com/s/TitleIII_Tier1_Survey

Title III Self-Evaluation Survey

Tiered Monitoring

Build Capacity

Tier I

Tier IIOngoing

Tier III

Needs Based Monitoring Onsite One or Two day Monitoring

Tiered Monitoring

Build Capacity

Tier I

Tier II

Tier III

Feb. 1 2014 –

May 31. 2014

On-Site MonitoringTwo(2) Day

Exploring Monitoring Documents

http://eldnces.ncdpi.wikispaces.net/LEP+Coordinators

Title III Monitoring Plan 13-14

http://eldnces.ncdpi.wikispaces.net/LEP+Coordinators

Title III Monitoring Plan 13-14

Monitoring Schedule Considerations 13-14

http://eldnces.ncdpi.wikispaces.net/LEP+Coordinators

Monitoring Schedule Considerations 13-14

Monitoring FAQ

http://eldnces.ncdpi.wikispaces.net/LEP+Coordinators

Monitoring FAQ

Classroom Observations Form

http://eldnces.ncdpi.wikispaces.net/LEP+Coordinators

Classroom Observations Form

Guidelines for Observations

http://eldnces.ncdpi.wikispaces.net/LEP+Coordinators

Guidelines for Observations

Fiscal Documents

http://eldnces.ncdpi.wikispaces.net/LEP+Coordinators

Fiscal Documents

Title III Monitoring

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Title III Monitoring: Accountability SBE Policy GCS-A-012Subgrantees receiving Title III funds (LEAs, public charter schools, & consortia) must meet a series of Annual Measurable Achievement Objectives (AMAOs)

AMAO 1 – Progress

AMAO 2 – Proficiency

AMAO 3 – AMOs for the LEP Subgroup

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Title III, Sec. 3122(b)(2) and State Board Policy reference

(4) ACCOUNTABILITY- If a State educational agency determines that an eligible entity has failed to meet the annual measurable achievement objectives described in subsection (a) for 4 consecutive years, the agency shall —

(A) require such entity to modify the entity's curriculum, program, and method of instruction;

Policy Identification

Priority: Globally Competitive StudentsCategory: TestingPolicy ID Number: GCS-A-012

Sanctions for AMAOs Not Met

If the Title III subgrantee has failed to meet the AMAOs for four (4) consecutive years, the State Board of Education shall require the Title III subgrantee to modify its curriculum, program, or method of instruction.

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Risk Factors

Risk factors include but are not limited to: • size of subgrantee grant award,• percentage of LEP students,• program performance based on meeting

AMAOs 1 and 2,• student subgroup academic performance

based on AMOs for LEP students,• change in program or leadership, and• the length of time since previous onsite

monitoring.

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Timeline

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• AMAO 3 Calculations

• Risk Factor Analysis

• Monitoring Schedule

Tying It All Together

• Application• Improvement Plan• Monitoring • Implementation

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Budgets

Basic Supplement, Not Supplant

22USDE, Student Achievement and School Accountability (SASA)

Title I, Part A & Title III, Part A

Title I

Funds must supplement, and not supplant State and local funds

(Section 1120A of ESEA)

Title III

Funds must supplement, and not supplant other Federal, State, and local funds.

(Section 3115 of ESEA)

23USDE, Student Achievement and School Accountability (SASA)

Title III “A Supplemental Program to Serve English Learners”

• Cake – state and local funds used to provide the Core EL program

• Icing/Frosting – Other federal funds

• Sprinkles – Title III funds – High Quality Language Instruction

Educational Program (LIEP) – High Quality Professional Development

24USDE, Student Achievement and School Accountability (SASA)

Developing My LEA’s Supplemental Title III Program

Do all of the items on my local plan and budget narrative meet the following criteria?

Are they allowable? Are they allocable?Are they reasonable and necessary to

carry out grant function?Determine whether they should be

included in the 2% limit as administrative costs?

25USDE, Student Achievement and School Accountability (SASA)

Supplement, Not Supplant Requirement – General

The First Test of Supplanting:

Required by Law

The Department assumes supplanting exists if – An LEA uses Title III funds to provide services that the LEA is required to make available under State or local laws, or other Federal laws.

26USDE, Student Achievement and School Accountability (SASA)

Supplement, Not Supplant Requirement – General

The Second Test of Supplanting:

Prior Year

The Department assumes supplanting exists if – An LEA uses Title III funds to provide services that the LEA provided in the prior year with State, local or other federal funds.

This assumption can be rebutted. 27

USDE, Student Achievement and School Accountability (SASA)

To refute the “prior year” test of supplanting, the LEA would need to have contemporaneous records to confirm….

Budget cuts were made in a number of areas, not just for LEP students; and

There was in fact a reduced amount of State or local funds to pay for this activity/position; and

The LEA made the decisions to eliminate the position/activity without taking into consideration of Federal funds.

28USDE, Student Achievement and School Accountability (SASA)

Questions to Ask When Considering Whether Title III Funds Can be Used Without Violating the Supplement, not Supplant Requirement

1. What is the instructional program/service provided to all students?

2. What does the LEA do to meet Lau requirements?

3. What service is the LEA required by other Federal, State, and local laws or regulations to provide?

4. Was the program/service previously provided with State, local, and Federal funds?

29USDE, Student Achievement and School Accountability (SASA)

Supplement, Not SupplantFAQ Document

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Resources

• Office of Planning, Evaluation and Policy Development, Policy and Program Studies Service

• Office of Management & Budget (OMB) Circular a-87: http://www.whitehouse.gov/omb/circulars_a087_2004/

• EDGAR – (See parts 76 and 80 in particular) http://www2.ed.gov/policy/fund/reg/edgarReg/edgar.pdf

• Office for Civil Rights, ELL Resources http://www.ed.gov/about/offices/list/ocr/ellresources.html

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All in one place!

– System notification of budget/amendment submission

– Changed Justification feature allows you to note reason for changes

– Response from NCDPI within the system

BAAS Documentation

Why is using the changed

justification feature important?

No additional email is needed unless there is a change to the application which requires additional documentation i.e. new staff position and additional technology purchases.

Changed Justification: Not Acceptable

Changed Justification: Acceptable

Changed Justification: Acceptable

Our Responses: Status

Our Responses: DPI Comments

More Documentation Needed

Technology purchases – requires approval of supplement not supplant rationale

New staff positions – require approval of job description

Subscribe!

NC DPI ESL Consultants

Regions 1, 2, 3, 4

Charlotte “Nadja” Trez

ESL/Title III Consultant

NC DPI

919-807-3866

nadja.trez@dpi.nc.gov

Regions 5, 6, 7, 8

Ivanna (Mann Thrower) Anderson

ESL/Title III Consultant

NC DPI

919-807-3860

ivanna.thrower@dpi.nc.gov

Lindsey Fults

ESL/Title III Consultant

NC DPI

919-807-3944

lindsey.fults@dpi.nc.gov