Program Checkup – Title II, Part A
This is the second in a series of program checkups. Click here for the first article on Title I, Part A.
New Year’s is a time to get healthy, so why not take a look at the health of your LEA’s federal programs? CSS continues its series of program checkups regarding federal program requirements with today’s article focusing on the Title II, Part A – Supporting Effective Instruction program. Unlike the Title I program that is campus-focused, the Title II requirements are concentrated at the District level. Please take a minute to examine how you can make sure your Title II documentation is in top shape.
What are the requirements for Title II, Part A?
TEA has chosen to focus its compliance audits on one particular area for Title II, and that is meaningful consultation. Please see the Title II, Part A Checklist. Planning, and who is involved in it, takes center stage. There are two aspects of meaningful consultation that are evaluated:
- A LEA shall meaningfully consult with teachers, principals, other school leaders*, paraprofessionals (including organizations representing such individuals), specialized instructional support personnel**, parents, community partners, and other organizations or partners with relevant and demonstrated expertise in programs and activities designed to meet the purpose of Title II, Part A (see page 38).
- Each LEA should describe how the LEA will use data and ongoing consultation to continually update and improve activities supported under Title II, Part A.
*Note: The term ”other school leader” means a principal, assistant principal, or other individual who is an employee or officer of an elementary school or secondary school, local educational agency, or other entity operating an elementary school or secondary school; AND responsible for the daily instructional leadership and managerial operations in the elementary school or secondary school building. **The term “specialized instructional support personnel” includes: counselors, social workers, psychologists, nurses, speech therapists, librarians, or other qualified professional personnel involved in providing assessment, diagnosis, counseling, educational, therapeutic, and other necessary services (including related services) as part of a comprehensive program to meet student needs.
What type of documentation is required?
It is certain and non-negotiable that TEA will expect to see pages from the District Improvement Plan (DIP) showing meaningful and ongoing consultation. This might be narrative sections where the LEA has described its planning and evaluation processes, or specific activities that are indicated the plan.
Meaningful Consultation – The following items will be needed in addition to the DIP pages:
- Stakeholder meeting agendas and minutes (showing seeking advice for improvement of Title II program)
- Sign in sheets with meeting date and the role of each member clearly labeled (see above stakeholder list)
- Materials used during consultation events
- Surveys and their results (related to teacher and leader effectiveness, qualifications, and professional development needs)
- Current and future dates to show ongoing consultation. A minimum would be consultation for the beginning of the school year, one meeting or survey to ascertain program status or progress mid-year, and one meeting at the end of the year to evaluate the effectiveness of the Title II, Part A activities that were conducted.
The annual compliance report that is completed at the end of the school year also asks a few more programmatic compliance questions. See The Guide to Program Implementation Questions (page 16). While the focus is still on meaningful consultation, it is important to coordinate Title II with other State and Federal programs. This is typically documented in the District Improvement Plan by showing how representatives from other programs were involved in planning, and the various funding sources are listed in the plan to support the same goals and objectives. In addition, the LEA must show that Title II funds are given priority at Title I schools with the highest poverty. This can be documented by budget code distribution, or, if funding is reserved at the district level, by a schedule of services showing more time or program offerings at the high poverty Title I campuses.
CSS works with our clients to understand compliance requirements and verify preparedness for validations or audits.
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