Federal Program Compliance Division
ESSASupport@tea.texas.gov
Title I, Part A Frequently Asked Questions
This document provides the answers to program-related questions received by the Division. You can also
navigate through the document using the Bookmarks in your PDF viewer. The newest questions that have been
added will be noted by “*” and in blue font. Responses that have been revised will be noted by “*” and date of
revision.
For questions or additional information, please contact us at ESSASupport@tea.texas.gov.
Questions and responses are organized by the following topic areas:
• Campus Improvement Plan (CIP)/District Improvement Plan (DIP)
• Campus Improvement Plan (CIP)/District Improvement Plan (DIP) Stakeholders
• Carryover
• Community Eligibility Provision (CEP)
• Compliance Documentation
• Compliance Report for LEAs – Title I, Part A (PR1000)
• Comprehensive Needs Assessment (CNA)
• Consolidated Administrative Costs
• District of Innovation
• Early Childhood Education
• Eligibility/Within-LEA Allocations/SC5000 Schedule
• ESSA Consolidated Federal Grant Application
• Federal Report Card Dissemination
• New Title I, Part A Campus Processes
• Paraprofessional Requirements – Title I, Part A
• Parent and Family Engagement (PFE) Requirements
• Procurement
• LEA Reservations
• Schoolwide Program
• Supplement, Not Supplant (SNS) – Title I, Part A
• Targeted Assistance Program
• Time and Effort Documentation
• Title I, Part A-Specific Training
• Use of Funds – Title I, Part A
o Contracted Services
o Equipment
o Other
o Payroll/Personnel
o Professional Development
o Supplies and Materials
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Campus Improvement Plan (CIP)/District Improvement Plan
(DIP)
Q1: Our LEA is comprised of only three campuses: high school (not served), middle school (not
served), and elementary (schoolwide). Can our CIP and DIP be one document? Are there any
parameters?
A1: It is acceptable for a small LEA or single campus LEA to have a document that consolidates the CIP
and DIP into one document, but they must identify goals/activities separately for the district and
campuses. For audit and/or random validation monitoring purposes, an LEA may be asked to
identify specific goals/activities listed in their DIP and CIP to support the activity. If the expense is
charged at the campus level, an auditor will want to see that activity identified in the CIP.
Similarly, if the expense is charged at the LEA level, an auditor will want to see the activity
identified in the DIP.
Although a Campus Improvement Plan is required for Title I, Part A campuses, state law requires
all campuses to have a CIP and all LEAs to have a DIP. TEC 11.252 lists the state requirements for
the DIP. But the LEA should also review the Title I, Part A provisions and assurances to see what
assurances and descriptions are required to be included in the plan. (Likewise, for other federal
grant programs the LEA participates in.) TEC 11.253 lists the state requirements for each CIP. If
the LEA is wanting a single document to serve for all its campuses, it should be very clear which
campus needs, goals, and activities go with which campus. The LEA should also review the Title I,
Part A provisions and assurances for schoolwide programs to be sure that all of the required
descriptions and assurances are included for the campus that is schoolwide.
Q2: Do we document 2020-2021 Title I, Part A activities funded with 2019-2020 funds in the campus
and district improvement plans for 2020-2021 or 2019-2020?
A2: If Title I, Part A funded activities are taking place in the 2020-2021 school year, they should be
based on the comprehensive needs assessment conducted for the 2020-2021 school year and
included in the 2020-2021 plans. If the activities took place in the 2019-2020 school year, they
should be based on the comprehensive needs assessment conducted for the 2019-2020 school
year and included in the 2019-2020 plans.
Q3: Is there a current timeline document or chart that shows when CIPs/DIPs are due for
campuses/LEAs and a deadline for when they should be posted to their website?
A3: For purposes of the Title I, Part A program, the improvement plans should be completed prior to
the certification and submission of the ESSA Consolidated Federal Grant Application. For purposes
of the Title I, Part A program, improvement plans are not “due” to TEA. However, in the case of an
audit or random validation monitoring, LEAs may be requested to submit their plans. For Title I,
Part A purposes, it would be a local decision as to when and whether the improvement plans
would be posted to their website. Best practice would be that the improvement plans be posted
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on the LEA/campus websites and made widely available to stakeholders at the beginning of the
school year.
Please note that there are also State requirements related to District and Campus Improvement
Plans. For information related to the plan requirements for the State Compensatory Education
program, please visit the TEA State Compensatory Education web page.
Q4: Are charter schools with only one campus required to complete a District Needs Assessment or
District Improvement Plan under ESSA?
A4: It is acceptable for a small LEA or single campus LEA to have a document that consolidates the
CNA, CIP and DIP into one document, but they must identify needs and goals/activities separately
for the district and campuses. For audit and/or random validation monitoring purposes, an LEA
may be asked to identify specific needs and/or goals/activities listed in their DIP and CIP to
support the activity. If the expense is charged at the campus level, an auditor will want to see that
activity identified in the CIP. Similarly, if the expense is charged at the LEA level, an auditor will
want to see the activity identified in the DIP.
Although a Campus Improvement Plan is required for Title I, Part A campuses, state law requires
all campuses to have a CIP and all LEAs to have a DIP. TEC 11.252 lists the state requirements for
the DIP. But the LEA should also review the Title I, Part A provisions and assurances to see what
assurances and descriptions are required to be included in the plan. (Likewise, for other federal
grant programs the LEA participates in.) TEC 11.253 lists the state requirements for each CIP. If
the LEA is wanting a single document to serve for all its campuses, it should be very clear which
campus needs, goals, and activities go with which campus. The LEA should also review the Title I,
Part A provisions and assurances for schoolwide programs to be sure that all of the required
descriptions and assurances are included for any campus that is schoolwide.
Q5: Are LEAs required to translate their CIP?
A5: LEAs are required to make their CIP available to parents and the public in an understandable and
uniform format, and to the extent practicable, provided in a language that the parents can
understand. For audit and/or random validation purposes, if the LEA is not going to provide the
document in a language that the parents can understand, the LEA would need to document why
they did not translate the document and how the parents were able to obtain the information
(i.e., oral translation).
The statutory language related to your question reads as follows.
ESSA Section 1114
(b) SCHOOLWIDE PROGRAM PLAN.—An eligible school operating a schoolwide program shall
develop a comprehensive plan (or amend a plan for such a program that was in existence on the
day before the date of the enactment of the Every Student Succeeds Act) that—
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(4) is available to the local educational agency, parents, and the public, and the information
contained in such plan shall be in an understandable and uniform format and, to the extent
practicable, provided in a language that the parents can understand;
Q6: If an LEA makes changes to its DIP or a campus makes changes to its CIP after the plan has
already been approved by the school board, do they have to take the DIP or CIP back to the
school board for approval?
A6: For the Title I, Part A program, this is a local decision that would depend on the LEA’s policies and
procedures associated with the board approval of documents.
Q7: Does the DIP need to be approved by the board of trustees?
A7: It depends. The Texas Education Code (TEC) §11.251(a) requires that the board of trustees
annually approve the district and campus performance objectives. TEA School Improvement
guidance requires districts to obtain board approval of their improvement plans if the district or
campus is designated for certain levels of federal intervention. Such requirements can be
referenced on the TEA Division of School Improvement Campus Accountability Interventions and
Guidance webpage.
Additionally, for any LEA, if the district and campus decision-making process that has been
established by the LEA’s local school board specifies that board approval of the DIP is required,
then the plan would be subject to board approval.
Response Revised 11/30/2022
Q8: Does an LEA reservation of funds need to be documented in the DIP?
A8: Yes. It is important to note in the DIP what reservation of funds the LEA has made and to ensure
that the reservation(s) correspond to an identified need as per the comprehensive needs
assessment process. Please note that some reservations are required by statute, such as for
Homeless children and youth; children in local institutions for neglected children; and if
appropriate, children in local institutions for delinquent children, and neglected or delinquent
children in community day programs. LEAs that provide equitable services to students attending
private nonprofit schools would reserve funds to cover the administrative costs of the private
school program, as well as for the equitable services. Depending on the size of the LEA
entitlement, there may also be a required reservation of funds for Parent and Family Engagement.
The LEA has the option to make additional reservations, such as for Title I, Part A preschool
programs or Title I, Part A services to students in foster care. In all of these cases, in addition to
documenting the reservations in the DIP, the LEA must indicate the amounts reserved for these
activities on the PS6101 of the Consolidated Federal Grant Application on eGrants. For additional
information, see the following sections of the Title I, Part A Program Guide: Reservation of Funds,
Parent and Family Engagement, Services to Homeless Students, Private Nonprofit Schools.
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Q9: Do LEA activities funded by Title I, Part A need to be specified in the DIP?
A9: Yes. All LEA activities funded by Title I, Part A are required to be documented in the DIP.
Additionally, it is important to ensure that such activities be carried out as a result of an identified
need as per the comprehensive needs assessment process. Please note that solely having an
activity specified in the DIP does not necessarily make it an allowable use of Title I, Part A funds.
There are several steps and requirements for using Title I, Part A. funds. Inclusion in the DIP is
only one part of the required steps. Please reference the Use of Funds section of Title I, Part A
Program Guide and the Title I, Part A Use of Funds reference document for the steps required to
determine whether an LEA can use Title I, Part A funds for a particular expense.
Q10: How often should the LEA review the DIP?
A10: The LEA, in consultation with stakeholders, should review the DIP at least quarterly to ensure that
the LEA is on track to meet the goals set through the activities noted in the plan related to
providing opportunities to meet the challenging State academic standards.
Q11: How often should the LEA revise the DIP?
A11: The LEA, in consultation with stakeholders, should revise the DIP at any time deemed necessary
based on student needs and especially when progress is not being made towards the goals and
objectives of the plan. At a minimum the DIP should be revised annually in order to address new
findings from the LEA’s Comprehensive Needs Assessment and the LEA’s evaluation of the plan’s
effectiveness in meeting its stated goals.
Q12: Does the DIP need to be translated into multiple languages?
A12: LEAs operating at least one schoolwide program must establish translation procedures related to
ensuring that campus improvement plans are, to the extent practicable, provided in a language
that parents can understand. USDE has not provided guidance or defined the term “to the extent
practicable.” However, not translating required documents is not an option. Although it is not a
statutory requirement for LEAs to translate their DIP, please note that it is a requirement that LEAs
follow their translation procedures to ensure that requirements are met as related to timely and
meaningful stakeholder consultation which may include parents who are economically
disadvantaged, are disabled, have limited English proficiency, have limited literacy, or are of any
racial or ethnic minority background.
Q13: Can a Targeted Improvement Plan used to carry out school improvement activities be attached
as an appendix to the DIP to satisfy the improvement activities requirement?
A13: Yes. A school that is identified for school improvement can add their required improvement plan
as an appendix to the DIP to satisfy the improvement activities requirement under ESSA. Please
note that there may be other requirements associated with being identified for school
improvement. LEAs are to follow all state school improvement interventions and submission
requirements as prescribed by the Division of School Improvement.
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Q14: Is the DIP subject to random validation monitoring?
A14: Yes. The DIP and the processes associated with district improvement planning are subject to
random validation monitoring. Various Title I, Part A program requirements are required to be
included in the DIP and thus, applicable pages from the DIP may be requested as documentation if
your LEA is selected for random validation monitoring.
Q15: Does including an activity in the DIP automatically allow my LEA to use Title I, Part A funds for
that activity?
A15: No. There are several steps and requirements for using Title I, Part A. funds. Solely having an
activity included in the DIP does not necessarily make it an allowable use of Title I, Part A funds.
There are several steps and requirements for using Title I, Part A. funds. Inclusion in the DIP is
only one part of the required steps. Please reference the Title I, Part A Program Guide and the
Title I, Part A Use of Funds reference document for the steps required to determine whether an
LEA can use Title I, Part A funds for a particular expense.
Q16: Is the DIP required to be made available to the public?
A16: Yes. Please note that the information contained in the plan is required to be in an understandable
and uniform format and, to the extent practicable, provided in a language that the parents can
understand.
Q17: Is there a specific format that TEA recommends for the DIP?
A17: No. The requirement in statute is that the information contained in the plan be in an
understandable and uniform format and, to the extent practicable, provided in a language that the
parents can understand. We acknowledge that there are vendors that provide DIP-related
products. TEA does not endorse any of the vendors nor require LEAs to use a vendor for this
purpose.
Q18: What elements of the comprehensive needs assessment are required to be included in the DIP?
A18: It is beneficial for the DIP to include a summary of the comprehensive needs assessment process
and identified areas of need and strengths as related to students meeting the challenging State
academic standards.
Q19: When should the CNA and District Improvement Plan/Campus Improvement Plan processes be
completed as it relates to the Title I, Part A program?
A19: The CNA, DIP and CIP processes should be completed prior to the certification and submission of
the ESSA Consolidated Federal Grant Application. Each LEA shall periodically review and, as
necessary, revise its plan per Sec. 1112(a)(5). Each schoolwide program campus shall regularly
monitor and revise their plan as necessary based on student needs to ensure that all students are
provided opportunities to meet the challenging State academic standards as per Sec. 1114(b)(3).
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Q20: One of the Statutorily Required Descriptions for the Title I, Part A LEA Program Plan has to do
with transitions for students from middle grades to high school and high school to
postsecondary education. Is the description required to be in their plan if the LEA skips or
doesn't serve any of the high school campuses with Title I, Part A funds?
A20: If an LEA applies for and receives Title I, Part A funds, they are required to meet all the statutory
requirements for the LEA plan regardless of which campuses they choose to serve with their
Title I, Part A funds.
Q21: What are the public posting requirements for District and Campus Improvement Plans?
A21: The Title I, Part A statutory requirement [Section 1114 (b)(4)] related to making the schoolwide
program plan/campus improvement plan available states the following, “An eligible school
operating a schoolwide program shall develop a comprehensive plan (or amend a plan for such a
program that was in existence on the day before the date of the enactment of the Every Student
Succeeds Act) that—is available to the local educational agency, parents, and the public, and the
information contained in such plan shall be in an understandable and uniform format and, to the
extent practicable, provided in a language that the parents can understand.” If posting the plan
on the campus website is the method your LEA has selected to make it available to the LEA,
parents, and the public, it is best practice to have it posted by the first day of school. The LEA
would follow its local translation policies and procedures in determining whether the document is
required to be translated into another language(s).
There are no Title I, Part A statutory requirements for posting the LEA Title I, Part A Program
Plan/District Improvement Plan. However, if the LEA Title I, Part A Program Plan/District
Improvement Plan includes specific information that is statutorily required to be made available to
the local educational agency, parents, and the public, and the information contained in such plan
shall be in an understandable and uniform format and, to the extent practicable, provided in a
language that the parents can understand, the LEA would need to make the document available to
said stakeholders (i.e. LEA Parent and Family Engagement Policy, Parents Right to Know, etc.). The
LEA would follow its local translation policies and procedures in determining whether the
document is required to be translated into another language(s).
Q22: Is there a specific deadline by which the campus improvement plan must be posted on the
campus website?
A22: The Title I, Part A statutory requirement [Section 1114 (b)(4)] related to making the plan available
states the following, “An eligible school operating a schoolwide program shall develop a
comprehensive plan (or amend a plan for such a program that was in existence on the day before
the date of the enactment of the Every Student Succeeds Act) that—is available to the local
educational agency, parents, and the public, and the information contained in such plan shall be in
an understandable and uniform format and, to the extent practicable, provided in a language that
the parents can understand.” If posting them on the campus website is the method your LEA has
selected to make them available to the LEA, parents, and the public, it is best practice to have it
posted by the first day of school.
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Q23: Do we still have the ten Schoolwide Program Components to include in our District
Improvement Plans, or are there only three elements?
A23: The Ten Components of a Title I, Part A Schoolwide Program were a requirement in developing "a
comprehensive reform strategy designed to upgrade the entire educational program in a Title I
campus" under No Child Left Behind. Currently under the Every Students Succeeds Act (ESSA),
these requirements are described much differently. According to the Supporting School Reform
by Leveraging Federal Funds in a Schoolwide Program, non-regulatory guidance, September 2016,
p.3, "There are three requirements of a schoolwide program that are essential to effective
implementation: 1) conducting a comprehensive needs assessment, 2) preparing a comprehensive
schoolwide plan, and 3) annually reviewing and revising, as necessary, the schoolwide plan." For a
comprehensive listing of Title I, Part A Schoolwide Program requirements, please see the Program-
Specific and ESSA Provisions and Assurances.
There are also requirements for LEAs that have applied for Title I, Part A funds. Please see the
Program-Specific and ESSA Provisions and Assurances for a comprehensive listing of what should
be included in the LEA’s Title I, Part A Program Plan that can be included in the District
Improvement Plan.
Q24: If an LEA has 2 small schoolwide program campuses, can both campuses jointly develop one
comprehensive needs assessment and one schoolwide program plan?
A24: Each schoolwide program campus must have its own schoolwide program comprehensive needs
assessment and schoolwide program plan/campus improvement plan. The needs of the students
attending each campus will need to be considered separately. It would not be acceptable for the
needs of the students on both campuses to be generalized together. The comprehensive needs
assessment process would need to take into account the needs of the students on each of the
campuses separately. The same would apply to the schoolwide program plan/campus
improvement plan for each campus.
Q25: How often does the LEA Title I, Part A Program Plan/District Improvement Plan and Schoolwide
Program Plan/Campus Improvement Plan have to be reviewed and revised?
A25: Guidance Related to the LEA Title I, Part A Program Plan (LEA)
Section 1112(a)(5) states that each LEA shall periodically review and, as necessary, revise its plan.
The LEA shall annually review and, as necessary, revise its plan. For Title I, Part A purposes, we
interpret periodic review as being reviewed at least once annually. It would be considered best
practice to review the LEA Title I, Part A Plan quarterly. It is important for the LEA to keep in mind
that the LEA Title I, Part A Program Plan should be a snapshot of the LEA’s current Title I, Part A
program. Thus, if the LEA determines that a change in the scope of its Title I, Part A program is
necessary, its LEA Title I, Part A Program Plan will need to be revised. In the case of an audit
and/or random validation monitoring, the LEA may be asked to make available its most current
plan. If the plan has not been revised to reference the most current information about the Title I,
Part A program being implemented, there could be an audit finding.
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Guidance Related to the Schoolwide Program Plan (Schoolwide Program Campuses)
Section 1114(b)(3) states that the plan and its implementation shall be regularly monitored and
revised as necessary based on student needs to ensure that all students are provided
opportunities to meet the challenging State academic standards.
There are two evaluation related requirements embedded in the Schoolwide Program Plan
statutory language: 1) regularly monitoring implementation and 2) evaluating the plan. Since the
campus is required to regularly monitor implementation of the Schoolwide Program Plan,
campuses operating a schoolwide program shall document that they reviewed implementation of
the plan at least semi-annually with quarterly review as best practice. They are required to
annually evaluate the Schoolwide Program Plan which includes the review and revision of the
plan, as necessary.
As per the USDE Non-Regulatory Guidance: Supporting School Reform by Leveraging Federal
Funds in a Schoolwide Program “There are three required components of a schoolwide program
that are essential to effective implementation: conducting a comprehensive needs assessment,
preparing a comprehensive schoolwide plan, and annually reviewing and revising, as necessary,
the schoolwide plan.
• Conducting a comprehensive needs assessment. To ensure that a school’s
comprehensive plan best serves the needs of those children who are failing, or are at-
risk of failing, to meet the challenging State academic standards, the school must
conduct a comprehensive needs assessment. (ESEA section 1114(b)(6)). Through the
needs assessment, a school must consult with a broad range of stakeholders, including
parents, school staff, and others in the community, and examine relevant academic
achievement data to understand students’ most pressing needs and their root causes.
(ESEA section 1114(b)(2); 34 C.F.R. § 200.26(a)). Where necessary, a school should
attempt to engage in interviews, focus groups, or surveys, as well as review data on
students, educators, and schools to gain a better understanding of the root causes of
the identified needs.
• Preparing a comprehensive schoolwide plan that describes how the school will improve
academic achievement throughout the school, but particularly for the lowest-achieving
students, by addressing the needs identified in the comprehensive needs assessment.
(ESEA section 1114(b)(7)). The schoolwide plan must include a description of how the
strategies the school will be implementing will provide opportunities and address the
learning needs of all students in the school, particularly the needs of the lowest-
achieving students. (ESEA section 1114(b)(7)(A)(i), (iii)). The plan must also contain
descriptions of how the methods and instructional strategies that the school intends to
use will strengthen the academic program in the school, increase the amount and
quality of learning time, and help provide an enriched and accelerated curriculum,
including programs and activities necessary to provide a well-rounded education. (ESEA
section 1114(b)(7)(A)(ii)). To ensure that the plan results in progress toward addressing
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the needs of the school, the plan should include benchmarks for the evaluation of
program results. This plan may be integrated into an existing improvement plan.
• Annually evaluating the schoolwide plan, using data from the State’s assessments,
other student performance data, and perception data to determine if the schoolwide
program has been effective in addressing the major problem areas and, in turn,
increasing student achievement, particularly for the lowest-achieving students. Schools
must annually revise the plan, as necessary, based on student needs and the results of
the evaluation to ensure continuous improvement. (ESEA section 1114(b)(3); 34 C.F.R.
§ 200.26(c)).”
It is important for the LEA to keep in mind that a Schoolwide Program Plan on a schoolwide
program campus should be a snapshot of the campus’s current Title I, Part A schoolwide program.
Thus, if the campus determines that a change in the scope of its Title I, Part A schoolwide program
is necessary and based on the identified needs of the campus, its campus Title I, Part A Schoolwide
Program Plan will need to be revised. In the case of an audit and/or random validation monitoring,
the LEA may be asked to make available the campus’s most current plan. If the plan has not been
revised to reference the most current information about the Title I, Part A schoolwide program
being implemented, there could be an audit finding.
Q26: For many years, our LEA has contracted with an outside vendor to provide us with an electronic
template for the comprehensive needs assessment process and campus improvement plans. Is
creating our own documents permissible?
A26: Yes, it is permissible for your LEA to create its own documents based on your LEA’s needs, as long
as the LEA is able to document that all the requirements for the Title I, Part A comprehensive
needs assessment process and the Title I, Part A Schoolwide Program Plan are included in the
documents.
*Q27: Does an LEA posting the LEA and all campus plans only on the LEA web site (instead of also
posting on the campus websites) meet the requirement for making the plans available to
parents and the public and do each have to be provided in an understandable and uniform
format, and to the extent practicable, in a language that parents can understand?
*A27: It is the LEA’s decision how to design its web site. The plans should be easily accessible by the
public and by parents, if required to be distributed to parents and the public. If a campus plan is
required to be distributed to parents, it would make most sense for the plan to be posted on the
campus website. If the sole method of distribution to parents is via website, the campus and LEA
would be responsible for communicating such method to all parents and maintain documentation
showing evidence of such communication. LEAs and campuses are required to ensure that the
plans are in an understandable and uniform format.
The LEA should follow its local translation policy or procedures to determine the appropriate
languages for translation.
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*Q28: ESSA Section 1114(b)(4), when referring to the Schoolwide Program Plan/Campus Improvement
Plan, it references that, "the information contained in such plan shall be in an understandable
and uniform format, and to the extent practicable, provided in a language that the parents can
understand." Does this mean that the plan has to be translated into other language(s)?
*A28: The LEA should follow its locally developed/adopted Translation Policy or Procedure when
determining whether documents are to be translated into another language.
*Q29: ESSA Section 1112(b)(3) requires that the LEA Program Plan/District Improvement Plan include a
description of how the local educational agency will carry out its responsibilities under
paragraphs (1) and (2) of section 1111(d). Does this requirement only apply to LEAs that have a
comprehensive or targeted support campus?
*A29: This requirement only applies to LEAs that have schools identified under Section 1111(d)(1) and
(2), which references campuses identified as comprehensive support and improvement campuses
and targeted support and improvement campuses.
*Q30: ESSA Section 1112(b)(4) requires that the LEA Program Plan/District Improvement Plan include a
description of the poverty criteria that will be used to select school attendance areas under
section 1113. What exactly should an LEA include in its plan to meet this requirement?
*A30: The requirement is referring to which measure(s) of poverty the LEA will use to establish Title I,
Part A campus eligibility. The options in statute are as follows.
To determine the number of public school students from low-income families, the ESSA statute
provides an LEA the option to use the number of public school children who are:
• Eligible for free or reduced-priced lunch (FRPL) under the Richard B. Russell National
School Lunch Act (including children counted through the Community Eligibility
Provision);
• In families receiving assistance under the State program funded under Title IV, Part A of
the Social Security Act (Temporary Assistance for Needy Families);
• Eligible to receive medical assistance under the Medicaid program;
• Ages 5-17 in poverty as counted in the most recent LEA-level census poverty data
approved by the Department; or
• Counted by the LEA using a composite of any of the above measures.
If an LEA chooses to use Ages 5-17 in poverty data, please be advised that because census data are
generally not available at the school level, this measure would most likely be part of a composite
with one or more of the additional measures noted here.
The LEA should also include additional information that may not be documented on the SC5000 as
part of its process for allocating Title I, Part A funds to eligible campuses (i.e., if using the flexibility
for high schools [above 50% poverty], if using grade span grouping/define grade spans, per-pupil
amounts, etc.).
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LEAs with an enrollment of fewer than 1,000 students or LEAs only operating one school are
exempt in statute from having to use the poverty measures to determine which of its schools
receive Title I funds. Such LEAs may use other criteria, such as academic performance or the grade
span of its schools to determine which of its schools receive Title I funds, or the LEA may choose to
allocate Title I funds to all its schools. Such LEAs will want to include the criteria that were used to
allocate funds to Title I, Part A campuses.
*Q31: Is it a requirement for the LEA written parent and family engagement (PFE) policy to be included
in the LEA Program Plan/District Improvement Plan as an addendum, or can the LEA state that it
will follow the parent and family engagement strategies laid out in the plan and post the plan on
the website or distribute it in the school handbook?
*A31: There are 2 statutory references related to the LEA PFE written policy. Section 1112 (b)(7)
references that the LEA Title I, Part A Program Plan shall describe, “the strategy the local
educational agency will use to implement effective parent and family engagement under section
1116.” Section 1116(a)(2) references that, “Each local educational agency that receives funds
under this part shall develop jointly with, agree on with, and distribute to, parents and family
members of participating children a written parent and family engagement policy. The policy shall
be incorporated into the local educational agency’s plan developed under section 1112.” Since
statute states that the policy shall be “incorporated into the LEA’s plan,” to meet compliance
requirements, the LEA should either include it in the LEA plan or as an addendum to the plan.
Although there is no distribution requirement in the Title I, Part A statute for the LEA Title I, Part A
program plan/DIP, there is a distribution requirement for the LEA PFE written policy. The LEA
would decide how it will distribute the policy to parents and family members of participating
children. The LEA could post the PFE policy on its website. However, the LEA would also need to
notify parents that the PFE policy will be made available on the website. The LEA can also have
copies available at Title I, Part A campuses and/or it can also publish the LEA PFE written policy in
the student handbook that is distributed to all parents.
*Q32: What are the Title I, Part A translation requirements as they relate to LEA and campus plans?
*A32: The following responses are related to the LEA Program Plan requirements that LEAs may include
in their District Improvement Plans and the Schoolwide Program Plan requirements that Title I,
Part A Schoolwide Program campuses may include in their Campus Improvement Plans.
General Translation Requirements
In instances where the Title I, Part A statute requires that information, to the extent practicable,
be provided to parents in a language that parents can understand, the LEA would need to follow
its written local translation policy/procedure to determine if the LEA would be providing the
information in multiple languages in accordance with such policy/procedure.
Title I, Part A LEA Program Plan
The ESSA Title I, Part A statute does not require that the Title I, Part A LEA Program Plan be
translated in its entirety; however, there are some requirements listed in statute that are either
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required to be in the plan or are referenced in Section 1112 where the plan is referenced that do
require such translation. All the Parents’ Right to Know requirements referenced in Section
1112(e) require that the notices and information be provided to parents in an understandable and
uniform format, and to the extent practicable, provided in a language that parents can understand
[Section 1112(e)(4)]. Additionally, Section 1112(b)(7) makes reference to a description of the
strategy the LEA will use to implement effective parent and family engagement under section
1116. Since the LEA Written Parent and Family Engagement Policy is required to be incorporated
into the plan, such policy is required to be distributed to parents in an understandable and
uniform format, and to the extent practicable, provided in a language that parents can understand
[Section 1116(a)(2)].
Title I, Part A Schoolwide Program Plan
Section 1114(b)(4) requires that the Schoolwide Program Plan is made “available to the LEA,
parents, and the public, and the information contained in such plan shall be in an understandable
and uniform format and, to the extent practicable, provided in language that the parents can
understand.”
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Campus Improvement Plan (CIP)/District Improvement Plan
(DIP) Stakeholders
Schoolwide Program Plan/Campus Improvement Plan Statutory Requirement for Stakeholders:
An eligible school operating a schoolwide program shall develop a comprehensive plan (or amend a
plan for such a program that was in existence on the day before the date of the enactment of the Every
Student Succeeds Act) that—is developed with the involvement of parents and other members of the
community to be served and individuals who will carry out such plan, including teachers, principals,
other school leaders, paraprofessionals present in the school, administrators (including administrators
of programs described in other parts of this title), the local educational agency, to the extent feasible,
tribes and tribal organizations present in the community, and, if appropriate, specialized instructional
support personnel, technical assistance providers, school staff, if the plan relates to a secondary school,
students, and other individuals determined by the school.
Q1: The ESSA Statute [Section 1114(b)(2)] references the following stakeholders that are required to
be involved in the development of the Campus Improvement Plan: parents and other members of
the community to be served and individuals who will carry out such plan, including teachers, principals,
other school leaders, paraprofessionals present in the school, administrators (including
administrators of programs described in other parts of this title), the local educational agency,
to the extent feasible, tribes and tribal organizations present in the community, and, if
appropriate, specialized instructional support personnel, technical assistance providers, school
staff, if the plan relates to a secondary school, students, and other individuals determined by
the school. When it references including students when the plan relates to a secondary school,
is secondary school defined as a high school only?
A1: A secondary school would include high school and middle school/junior high school campuses.
Q2: To what degree are students required to be involved in the development of the Campus
Improvement Plan (CIP) on a secondary school campus?
A2: Section 1114 of the ESSA statute provides a list of required stakeholders for the development of
the Schoolwide Program Plan - Campus Improvement Plan (CIP). The statute states that if the plan
relates to a secondary school, that students should be involved, if appropriate. The campus can
determine what is appropriate.
If the campus does not feel that it is appropriate for the students to sit through the very intense or
in-depth conversations, then they would not need to have students be involved for those
conversations. The requirement for stakeholder involvement could vary based on what may be
the most appropriate way to involve a particular group of stakeholders. For example, a campus
may determine that the most appropriate way to involve students in the development of the CIP
would be to seek input and feedback on the specific activities that directly affect students. This
can be documented in a variety of ways which includes, but is not limited to, having a meeting
that only includes students, conducting a student survey, or discussion of the item(s) at a Campus
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Committee meeting and then excusing the students. The key is for the campus to maintain
documentation locally that shows evidence of their involvement.
Q3: If a campus only has 1 administrator (Principal) how do they meet the requirement to include
school leaders, principals, and administrators mentioned in statute? Our LEA has one campus
with one principal and six teachers that make up their school community. If a campus does not
have paraprofessionals, are they excused from having that role represented on their campus?
A3: We understand that small LEAs may not have multiple people to meet the required stakeholder
requirements for a group of stakeholders or even at least 1 person to represent a particular group
of required stakeholders. To justify that all of the required stakeholders were not part of the
process because the roles did not exist within the LEA, it can be noted on the sign in sheet
retained as documentation locally. However, this does not mean that an LEA can exclude a group
of stakeholders because they weren’t invited to participate and were an available group of
stakeholders in the LEA. The LEA would not be required to have paraprofessionals represented on
the committees if the LEA has no paraprofessional staff. The LEA would be expected to have more
than one parent representative.
Q4: Statutory language for Title I, Part A, states “if appropriate, specialized instructional support
personnel, technical assistance providers, school staff…” Does the “if appropriate” apply to all
of the positions that follow? Or does it only apply to the specialized instructional staff?
A4: “If appropriate,” applies to all of the positions that follow.
Q5: Title I, Part A requires representation from LEA-level staff – that would mean any administrator
of the LEA?
A5: The Schoolwide Program Plan is to be developed with the involvement of the LEA. This would
include an LEA-level individual or individuals who have relevant knowledge of the campus needs
and have been involved in the campus needs assessment process.
Q6: Does an LEA need to have one master sign-in sheet for Federal Programs meetings (i.e.,
Comprehensive Needs Assessment (CNA), CIP, DIP, etc.) or should the sign-in sheets be separate
for each program (ex. Title I, Title II and Title IV)?
A6: If an LEA chose to use that option, one master sign-in-sheet would suffice for all programs
administered in the Federal Program Compliance Division. To ensure compliance can be
established in an audit or random validation, each sign in sheet should include the purpose, date,
and time of the meeting; stakeholder name; stakeholder group represented on the committee;
and the stakeholder’s signature indicating that they were present at the meeting. It is also
important to note that each program has their individual requirements for stakeholder groups
that are required to be involved for different purposes. Thus, it is also important for LEAs to retain
detailed agendas and minutes of meetings as documentation related to the specific program
requirements.
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Q7: What is considered timely and meaningful stakeholder consultation?
A7: Timely and meaningful stakeholder consultation is a critical requirement that can be found
throughout the ESSA statute. It is important for LEAs to ensure that their processes and
procedures include elements that document timely and meaningful stakeholder consultation.
LEAs should use the following guiding questions when considering whether stakeholder
consultation is timely and meaningful.
✓ Are stakeholders involved in the comprehensive needs assessment and district
improvement planning processes on an ongoing basis?
✓ Are the comprehensive needs assessment and LEA improvement planning processes
tailored to solicit meaningful input and feedback from all stakeholders?
✓ Do the engagement activities include goal setting and development of ideas and
activities rather than just one-way communication for information sharing purposes?
✓ Is stakeholder engagement sustained with stakeholders having the opportunity to
participate in discussions at the decision-making, implementation and evaluation
stages of the processes?
✓ Are all the required stakeholders involved and in attendance at every step of the
processes?
✓ Are there processes in place to solicit input from stakeholders from whom English is
not their primary language?
✓ Does the process have enough time built in for meaningful consultation?
✓ Are the comprehensive needs assessment and LEA improvement planning activities
part of a process rather than an event?
✓ Are there opportunities built into the process for stakeholders to share their feedback
in a comfortable setting?
✓ Has the LEA considered the barriers to greater participation by parents in activities,
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?
✓ Are the activities associated with the comprehensive needs assessment and district
improvement planning processes held at a variety of times to ensure maximum
stakeholder attendance and engagement?
✓ Are parents of participating children aware that if the District Improvement Plan is not
satisfactory to them, their comments shall be submitted by the LEA to the state via the
ESSA Consolidated Federal Grant Application?
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Q8: How does the LEA submit parent comments through the Consolidated Application?
A8: Inside the Consolidated Application on eGrants, there is an “Attach File” function that is accessible
from the Table of Contents page. It is located above the blue bar that is labeled “Grant
Resources.”
Q9: Can the same stakeholders who are consulted for the DIP be the same stakeholders utilized to
develop the Parent and Family Engagement Policy?
A9: There could certainly be some overlap between the two groups. However, although, parents of
children in schools served under Title I, Part A are required to be a part of the DIP stakeholder
consultation process, they are only one of the stakeholder groups that are part of that process.
The requirement for the Parent and Family Engagement (PFE) Policy is that it be jointly developed
with parents and family members of participating children. Thus, the stakeholder group
responsible for the development of the PFE Policy would likely need to include more parents so
that the group could include a sufficient number and representative group of parents and family
members served by the LEA to adequately represent the needs of the populations served for the
purposes of developing, revising, and reviewing the parent and family engagement policy.
Q10: Does “Principals” refer to the 1 Campus Principal and any Assistant Principals in the list of
stakeholders required to be involved in the development of the Schoolwide Program
Plan/Campus Improvement Plan?
A10: “Principals” can refer to Principal and any Assistant Principals. It is customary that a campus would
have only 1 Principal. Assistant Principals can be considered “other school leaders.”
Q11: Does there have to be at least 2 LEA Administrators on every campus improvement planning
team?
A11: The plan must be developed with the involvement of at least 2 LEA Administrators since the
administrator reference in statute is plural (including administrators of programs described in
other parts of this Title [Title I, Part C; Title I, Part D]).
Q12: The statutory listing of stakeholders required to be involved in the development of the
Schoolwide Program Plan/Campus Improvement Plan has “Administrators (including
administrators of programs described in other parts of this title)” and “the LEA, to the extent
feasible.” Are the “Administrators” serving in a dual capacity as LEA Administrators and LEA
Representatives?
A12: The administrators are serving as LEA representatives so the language that references that “the
LEA, to the extent feasible” is to be involved leaves it open for other LEA representatives that may
not be administrators to serve as stakeholders.
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Q13: Are students on a secondary campus required to be involved in the development of the campus
improvement plan?
A13: If a secondary campus deems student involvement appropriate in the development of the plan,
they can include students. If a secondary school does not have students as part of their
stakeholder list, that would be acceptable.
Q14: Is it allowable for a parent who is an employee of the LEA to be one of the stakeholders
representing parents to inform the comprehensive needs assessment and schoolwide
program/LEA improvement planning processes? How does this requirement apply to a
substitute who is a contractor instead of an employee?
A14: Texas Education Code §11.251 specifies that a parent who is an employee of the school district is
not considered a parent representative on the district and campus improvement plan committees.
The Title I, Part A statute does not include such a requirement. However, since state statute
includes this requirement, the LEA should follow the state statutory requirement when selecting
their parents that will be part of the comprehensive needs assessment and schoolwide
program/LEA improvement planning processes.
If a substitute is not an employee of the district, then they, technically, could be considered a
parent representative on the district and campus improvement plan committees.
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Carryover
*Q1: ESSA allows an exception to the 15% limit on carryover for LEAs receiving less than $50,000 in
Title I, Part A funds. If an LEA with less than $50,000 in Title I, Part A transfers Title II, Part A
and/or Title IV, Part A funds into Title I, Part A and therefore has a total over $50,000, does that
exception still apply?
*A1: Any funds transferred into the Title I, Part A program through Funding Transferability will be
included in the total amount used to calculate Title I, Part A carryover to determine if the LEA has
exceeded the 15% statutory limitation. If the transferred in amounts cause the LEA to go over
$49,999, then the 15% limit will be applied, and the LEA will need to use a waiver if the LEA wants
to carryover more than 15%.
REAP funds are not actually transferred, so they are not included in the carryover calculation when
used for Title I, Part A purposes. [Response revised, June 2023]
Q2: Are there waivers available for the Title I, Part A 15% carryover requirement?
A2: There are two waivers available related to Title I, Part A carryover as referenced below.
• Statutory waiver under Section 1127: Once every three years the LEA may be granted a
waiver of the 15% carryover limitation through Schedule WV4001 in the ESSA Consolidated
Federal Grant Application. Staff in the Grants Administration Division will determine
whether an LEA’s carryover amount will exceed the limit allowed and will apply the
statutory waiver, if it is available. If the LEA has used the statutory waiver in the past two
years, staff will check to see if the LEA meets the requirements for the Ed-Flex Statewide
Programmatic waiver related to the 15% carryover limitation. Any necessary documents
will be initiated by the Grants Administration Division.
• If the statutory waiver is not available to the LEA, and if the LEA experienced an increase in
Title I, Part A funding between the initial planning amount and the final allocation amount,
the LEA may be granted an Ed-Flex waiver through Schedule WV4001 in the ESSA
Consolidated Federal Grant Application. Any necessary documents will be initiated by the
Grants Administration Division.
*Q3: How is the amount for the Title I, Part A 15% carryover limit calculated for LEAs and for SSA
Fiscal Agents?
*A3: The Title I, Part A statute imposes a 15% carryover limit to the LEAs total Title I, Part A amount
received in a given year. This is typically the LEA’s Title I, Part A Final amount, and prior-year
Carryover and Reallocation also received does not count. In order to prevent lapsing of funds
though, Final/Revised Final expenditures processed during that grant closeout period will be
applied first to any remaining prior-year project funds (carryover and reallocation) and then to the
current year project. What remains in the current year project being closed out then becomes
carryover on the LEA’s new year project NOGA along with its new Final amount. This is true for
grants like Title II, Part A and Title IV, Part A too.
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When determining the total amount of Title I, Part A an LEA received, funding transfers from Title
II, Part A and/or Title IV, Part A into Title I, Part A as reported on the eGrants PS3109 must be also
taken into account. If the LEA reports that 100% of its Title II, Part A is being transferred and used
as Title I, Part A funds locally, then those funds count as additional Title I, Part A funds received
and after Final/Revised Final Title II, Part A expenditures are processed, 100% of remaining Title II,
Part A is considered as additional Title I, Part A carryover when calculating if total Title I, Part A
carryover exceeds the 15% of total Title I, Part A funding received and thus a waiver will be
required in order to keep all the carryover funds.
For a Shared Services Arrangement (SSA), we have to consider all the member LEAs, determine a
total Title I, Part A received by the Fiscal Agent, determine via the PS3109 which LEAs transferred
Title II, Part A and/or Title IV, Part A into Title I, Part A, add those amounts to the Title I, Part A
total, determine a total Title I, Part A carryover amount that includes proportionate shares of any
Title II, Part A and/or Title IV, Part A carryover due to funding transfers, and then determine if the
15% threshold has been exceeded. If so, the Fiscal Agent would need a waiver; otherwise the
SSA’s Title I, Part A carryover (and potentially Title II, Part A and /or Title IV, Part A carryover)
would have to be reduced to the calculated threshold amount.
As you can see, funding transfers add to the complexity and thus just looking at a prior-year Title I,
Part A Final amount and multiplying to get a 15% carryover limit amount does not always work for
LEAs and Fiscal Agents in particular.
Due to COVID, prior grants were extended to the full 27 months thus no carryover to process and
last year (2021-2022) USDE granted Texas a one-time only waiver to waive the Title I, Part A
requirement. This is the first year in a while that we have had to address Title I, Part A waivers and
the impact of funding transfers into Title I, Part A may have.
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Community Eligibility Provision (CEP)
Q1: Where can we find information related to PEIMS reporting for Economic-Disadvantage if we are
an LEA participating in the CEP Program?
A1: The guidance that is published in the 2020-2021 Texas Education Data Standards (TEDS) can be
found by accessing this link:
https://tealprod.tea.state.tx.us/TWEDS/85/379/0/0/DataComponents/ComplexType/List/8262.
2020-2021 Texas Education Data Standards (TEDS)
Section DR40
ECONOMIC-DISADVANTAGE-CODE (E0785) indicates the student's economic disadvantage
status.
Overview of Community Eligibility Provision (CEP)
• Review enrolled students against all direct certification lists for free or reduced-price
lunch eligibility.
• Distribute a locally developed income survey form to each student that is not on a
direct certification list at the beginning of the school year and each student that enrolls
during the school year.
Although the CEP program allows all students enrolled on a CEP campus to receive free meals,
students must be reported with the economic disadvantage code for which they actually qualify
based upon the direct certification lists and the locally developed income survey form.
Q2: Our LEA has two campuses. The elementary/junior high is served with Title I, Part A funds. The
high school is not. The district is moving to the CEP funding process for 20-21. Must the high
school now receive Title I, Part A funding?
A2: As a single attendance area, the LEA has the option to choose which of its eligible campuses to
serve.
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Compliance Documentation
Q1: What are acceptable forms of documentation for sign-in sheets?
A1: Given the increased use of virtual meeting environments during the 2019-2020 and 2020-2021
school years, participant rosters that include the meeting title, meeting date, and stakeholder
names and roles would be acceptable substitutes for the more traditional sign-in sheets. This
eliminates the need of a participant signature.
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Compliance Report for LEAs – Title I, Part A (PR1000)
Q1: My LEA has always presented the ESSA Consolidated Compliance Report submitted to TEA at the
Annual Title I, Part A Meeting. Is it required to be presented or provided to the public?
A1: It is not a statutory requirement that the ESSA Compliance Report for Title I, Part A be shared at
the Annual Title I, Part A Meeting nor provided to the public. The report is subject to the Public
Information Act and could be requested by the public through that avenue.
Please note that there may be information that is reported in the report that may be of interest
and/or require consultation. For example, LEA Reservation Amounts are reported. The
reservation of funds by an LEA will reduce the amount of funds available for distribution to
participating campuses; therefore, the LEA must determine what reservations are needed in
consultation with teachers, pupil services personnel (where appropriate), principals, parents of
children receiving services, and private school officials before any decisions are made by the LEA.
For a list of the statutory requirements associated with the Annual Title I, Part A Meeting, take a
look at the recently updated Title I, Part A Annual Meeting Toolkit.
Q2: When completing the PR1000, should expenditures reported for LEA reservations not exceed
the totals that were approved in the ESSA Consolidated Application – PS3101 Title I, Part A
Program Schedule?
A2: Some variance is acceptable, but the LEA should try to ensure that the application reflects its
actual program. If there is a significant change in the amount of funds reserved, the LEA should
amend its application within the amendment period; that is the case anytime the scope of the
program changes from what was in the approved application.
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Comprehensive Needs Assessment (CNA)
Q1: An LEA has decided to combine all their campuses (elementary, middle, and high) into one
campus with one campus ID number. Do they need to engage in the comprehensive needs
assessment (CNA) process separately, or is it acceptable for the newly formed campus to engage
in one comprehensive needs assessment process?
A1: The new consolidated campus would just need to have gone through the CNA process once taking
into consideration the needs of the new students that are being added to the campus.
Please note the following since you mention that the LEA has combined all its campuses.
It is acceptable for a small LEA or single campus LEA to have a document that consolidates the
Campus Improvement Plan (CIP) and District Improvement Plan (DIP) into one document, but they
must identify goals/activities separately for the district and campuses. For audit and/or random
validation monitoring purposes, an LEA may be asked to identify specific goals/activities listed in
their DIP and CIP to support the activity. If the expense is charged at the campus level, an auditor
will want to see that activity identified in the CIP. Similarly, if the expense is charged at the LEA
level, an auditor will want to see the activity identified in the DIP.
Although a Campus Improvement Plan is required for Title I, Part A campuses, state law requires
all campuses to have a CIP and all LEAs to have a DIP. TEC 11.252 lists the state requirements for
the DIP, but the LEA should also review the Title I, Part A provisions and assurances to see what
assurances and descriptions are required to be included in the plan. (Likewise, for other federal
grant programs the LEA participates in.) TEC 11.253 lists the state requirements for each CIP. If
the LEA is wanting a single document to serve for all its campuses, it should be very clear which
campus needs, goals, and activities go with which campus. The LEA should also review the Title I,
Part A provisions and assurances for schoolwide programs to be sure that all the required
descriptions and assurances are included for the campus that is schoolwide.
Q2: Who is required to be on the campus-level CNA committee?
A2: For Title I, Part A purposes, the ESSA Statute provides a list of required stakeholders for the
development of the Campus Improvement Plan (CIP). It would be best practice to include the
same stakeholders that are required for the CIP in the CNA process to ensure that they are
knowledgeable of the CNA results in their work to connect the CNA to the CIP. See additional
information below on the importance of engaging a variety of stakeholders in the process.
A schoolwide campus should include a description of the campus’s CNA process in the CNA or CIP.
The description should include the date(s) that the CNA was developed (if a new campus) or the
date(s) that the CNA was reviewed and revised for the current school year, list of stakeholders
involved that includes the individuals by name and roles, areas examined, and list of multiple data
sources analyzed. In the event that an LEA is selected for random validation, the LEA would need
to submit documentation to show that the stakeholders listed in the description were involved in
the CNA process.
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The Needs Assessment Guidebook, a resource that provides information as it relates to
stakeholders involved in the CNA process, includes the following “A needs assessment is a process
that should be undertaken with (or by) local stakeholders rather than completed entirely by a
small group of leaders or an outside entity. Engaging school staff, parents, a diverse assortment of
leaders and external support providers (even students, at the secondary level) during each phase
of the needs assessment—not just in the delivery of results—ensures that the planning, data
collection, identified needs, and consideration of underlying causes incorporate the input of a
broad knowledge base, including diverse local perspectives.
The benefit of a needs assessment conducted with collaboratively engaged stakeholders is seen
long after the needs assessment is complete. By developing trust in and through the process,
participating stakeholders are more likely to be invested in the outcomes and actively engaged in
the selection, development, and implementation of improvement plans and strategies that create
lasting change. In addition, active participation increases the overall capacity of the group to
sustain implementation and improvement efforts. Relational trust is a critical factor for
implementing lasting changes in education settings, and active stakeholder engagement can help
to build that trust (Bryk & Schneider, 2002; Louis, Leithwood, Wahlstrom, & Anderson, 2010;
Tschannen-Moran & Hoy, 2001).”
Q3: Are the Title I, Part A stakeholders required to be involved in the CNA process the same for the
development of the Campus Improvement Plan?
A3: ESSA Sec. 1114(b)(2) provides a list of required stakeholders for the development of the Campus
Improvement Plan (CIP). Including the same stakeholders required for the CIP in the
Comprehensive Needs Assessment (CNA) process will ensure that the same stakeholders are
knowledgeable of the CNA results as they work to connect the CNA to the CIP development
process. However, since a list of stakeholders for the CNA process are not listed in statute, the
campus can determine which stakeholders to include in the CNA process.
A schoolwide campus should include a description of the campus’s CNA process in the CNA or CIP.
The description should include a list of involved stakeholders’ names and roles. In the event that
an LEA is selected for random validation, the LEA would need to submit documentation to show
that the stakeholders listed in the description were involved in the CNA process.
Q4: Where in the ESSA Statute does it state that a Comprehensive Needs Assessment (CNA) is
required for LEAs receiving Title I, Part A funds?
A4: Although the ESSA Statute does not require a CNA for the components of the Title I, Part A LEA
Plan, state statute (TEC 11.252) requires the District Improvement Plan be based on a
comprehensive needs assessment. The ESSA Statute (Section 1114) does require a CNA for Title I,
Part A campuses operating a schoolwide program.
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Q5: If an LEA has 2 small schoolwide program campuses, can both campuses jointly develop one
comprehensive needs assessment and one schoolwide program plan?
A5: Each schoolwide program campus must have its own schoolwide program comprehensive needs
assessment and schoolwide program plan/campus improvement plan. The needs of the students
attending each campus will need to be considered separately. It would not be acceptable for the
needs of the students on both campuses to be generalized together. The comprehensive needs
assessment process would need to take into account the needs of the students on each of the
campuses separately. The same would apply to the schoolwide program plan/campus
improvement plan for each campus.
Q6: For many years, our LEA has contracted with an outside vendor to provide us with an electronic
template for the comprehensive needs assessment process and campus improvement plans. Is
creating our own documents permissible?
A6: Yes, it is permissible for your LEA to create its own documents based on your LEA’s needs as long
as the LEA is able to document that all the requirements for the Title I, Part A comprehensive
needs assessment process and the Title I, Part A Schoolwide Program Plan are included in the
documents.
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Consolidated Administrative Costs
Q1: Can you tell us more about Consolidated Administrative Costs?
A1: LEAs are allowed to consolidate federal grant funds from several federal grant programs in order
to pay for the costs associated with the administration of those programs. The federal grant
programs eligible for this consolidation are those awarded under the Every Student Succeeds Act
of 2015 (ESSA). The authorizing statute is the Elementary and Secondary Education Act of 1965
(ESEA), Title VIII, Part B, Sec. 8201and Sec.8203. Please note that LEAs must receive approval from
TEA to consolidate their administrative funds.
Consolidating administrative funds provides flexibility to LEAs by allowing them to charge
administrative costs to an administrative cost pool instead of assigning specific costs to specific
programs. As long as the cost is an allowable administrative activity under any of the programs
that have been consolidated, it may be charged to any of the consolidated administrative funds.
In addition, the consolidated funds may be treated as one cost objective, so LEAs are not required
to maintain personnel activity reports to document the time spent by employees on
administrative activities performed exclusively for the programs that contribute to the pool. For
these employees, LEAs must still maintain semi-annual certifications, or their equivalents, and
identify the administrative cost pool as the cost objective.
If the LEA consolidates administrative funds, a Consolidation of Administrative Costs form must be
completed, maintained locally, and submitted to TEA upon request.
For additional information related to Consolidated Administrative Costs, see the Budget Schedule
Instructions for the ESSA Consolidated Application.
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District of Innovation
Q1: Is a District of Innovation exempt from any Title I, Part A statutory requirements (i.e., fiscal
requirements [comparability; supplement, not supplant; and maintenance of effort]; Parents’
Right to Know; Campus Improvement Plan; time and effort; LEA Plan/District Improvement Plan
[DIP]).?
A1: LEAs that are operating as Districts of Innovation are not exempt from the Title I, Part A federal
statutory requirements referenced (fiscal requirements [comparability; supplement, not supplant;
and maintenance of effort]; Parents’ Right to Know; Campus Improvement Plan; time and effort;
LEA Plan/District Improvement Plan [DIP]). Please note that there are some parents’ right-to-
know requirements that relate to teacher and paraprofessional certification requirements that
may not apply to a District of Innovation if the district is implementing its approved District of
Innovation teacher certification policy where such requirements may be waived as per State
statute.
Q2: If a District has a District of Innovation Plan in place that allows the district to waive site-based
activities at the campus level, are these activities still required for Title I, Part A?
A2: Stakeholder involvement is required in Title I, Part A statute. Although a meeting is one method a
campus may use for stakeholder involvement, there are multiple methods for involving
stakeholders (i.e., surveys, focus groups, correspondence, etc.). The campus would need to keep
appropriate documentation for the methods the campus used.
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Early Childhood Education
Q1: Are Title I campuses required to have a Pre-K program or is this optional?
A1: There is no requirement in ESSA that requires Title I campuses to provide a pre-kindergarten
program. For questions related to state requirements associated with pre-kindergarten programs,
please reach out to the TEA Early Childhood Education Division.
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Eligibility/Within-LEA Allocations/SC5000 Schedule
Q1: Do campuses identified as “skipped” on the SC5000 need to have a CIP in place?
A1: Since “skipped” campuses will not be receiving Title I, Part A funding to implement a Title I, Part A
program, they are not obligated to meet the program requirements associated with receiving
Title I, Part A funding, such as the Campus Improvement Plan. Please note that although the
“skipped” campus is not required to have a CIP in place to meet the Title I, Part A requirements,
Texas Education Code Section 11.253(c) requires the following, “Each school year, the principal of
each school campus, with the assistance of the campus-level committee, shall develop, review,
and revise the campus improvement plan for the purpose of improving student performance for
all student populations, including students in special education programs under Subchapter A,
Chapter 29, with respect to the student achievement indicators adopted under Section 39.053 and
any other appropriate performance measures for special needs populations."
As per the Schedule SC5000 Title I, Part A Campus Selection Guidance (Page 9), the LEA confirms
by submission of its application that “skipped” campuses meet the following requirements: 1) The
skipped campus meets the comparability of services requirement; 2) The skipped campus receives
supplemental funds from other State or local sources that are expended per the requirements of a
TA or a SW campus; and 3) The funds expended from such other sources equal or exceed the
amount that would be provided on the campus under Title I, Part A. Additionally, if the LEA
chooses to “skip” a campus, the LEA must provide the eligible private school children who reside
within the boundaries of the “skipped” campus’s attendance area the opportunity to receive
Title I, Part A services.
Q2: Is the LEA’s low-income percentage in part one of schedule SC5000 based only on students ages
5 to 17 as of the snapshot date (date we are using for enrollment)?
A2: The LEA Total Low-Income % is calculated by dividing the total number of students who meet the
LEA’s selected poverty measure by the LEA’s total number of students (either residing or enrolled,
as the LEA has determined).
The LEA has several options concerning the data it uses to calculate low-income percentages.
Statute allows LEAs to select from the following measures of poverty:
• Children eligible for free and/or reduced-price lunches under the National School Lunch
Act;
• Children in families receiving assistance under Title IV, Part A of the Social Security Act
(Temporary Assistance to Needy Families, or TANF);
• Children eligible to receive medical assistance under the Medicaid program;
• Children, ages 5 through 17, inclusive, in poverty as counted in the most recent LEA-level
census poverty data approved by the US Department of Education; or
o Note: Because census data are generally not available at the school level, if an LEA
uses this measure, it would most likely be part of a composite with one or more of
the above measures
• A composite of any of the above measures.
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The LEA would be restricted to ages 5 through 17 only if they were selecting the 4
th
bulleted item
solely as their only measure of poverty. For all other data (bullets # 1, 2, 3 and 5), the low-income
percentage would be based on student enrollment numbers regardless of student ages.
Q3: Are the campus numbers (enrollment and low-income percentage) based on our LEA procedures
and may include students who are 18 years of age on the snapshot date?
A3: Whichever data option the LEA selects, the LEA must use the same measure of poverty as noted in
Q1 above—
• To identify eligible campuses;
• To determine the campus rankings; and
• To determine Title I, Part A allocations to campuses.
For campuses, the LEA would be restricted to ages 5 through 17 only if they were selecting the 4
th
bulleted item solely as their only measure of poverty as noted in Q1 above. For all other data
(bullets # 1, 2, 3 and 5), the low-income percentage would be based on student enrollment
numbers regardless of student ages if the basis of eligibility being selected for the campuses is
“enrollment.”
Q4: Based on US Department of Agriculture flexibility related to the Pandemic, students will not be
required to complete and return a National School Lunch Program (NSLP) application. Thus, our
LEA will not have data available for determining low-income percentages. Can the LEA create a
low-income survey to determine low-income percentages?
A4: In a Fact Sheet released by the US Department of Education (USDE) on January 4, 2021, related to
NSLP data, they stated that an LEA can use data from a poverty survey that replicate NSLP or other
poverty data. If the form replicates NSLP or other poverty data, then it would be acceptable for
use in reporting Title I, Part A Low-Income data. The poverty thresholds to be used would be the
same ones used to calculate Free and Reduced Priced Lunch eligibility. Community Eligibility
Provision (CEP) campuses use this method since they do not collect NSLP applications.
Additionally, if the LEA does not have the best available poverty data from 20-21 because they did
not collect a survey, they can use 19-20 data.
Q5: Based on the flexibility provided by the US Department Education (USDE) related to using school
year (SY) 2019-2020 data for determining low-income percentages, what documentation would
the LEA need to maintain if using this flexibility?
A5: The LEA would need to maintain the same documentation that was kept when the 2019-2020
poverty data were entered for the 2020-2021 SC5000. Each LEA is required to maintain auditable
documentation locally supporting the poverty numbers provided on the SC5000 in the case of an
audit and/or random validation monitoring. If the LEA uses SY 2019-2020 National School Lunch
Program (NSLP) data as the LEA selected measure of poverty, the LEA will need to maintain
auditable documentation that supports that the LEA used the same measure of poverty data for
the LEA and all campuses and that the date used to determine low-income data and enrollment
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numbers was the same for all campuses. Examples of the documentation would be NSLP student
information system generated reports and the actual NSLP applications that support the numbers
from reports generated by the NSLP student information system.
Q6: For LEAs who ordinarily use Direct Certification as their Basis of Eligibility but are providing
meals to students using Summer Seamless Option, may we still enter their Direct Certification %
on the SC5000? Or is there something else we should do?
A6: If an LEA is using direct certification as a basis of eligibility, for the low-income percentage, the LEA
would enter the % of students on the campus that are considered low-income based on direct
certification. Keep in mind that the number of students directly certified is a subset of the total
number of students eligible for free and reduced-priced meals.
Q7: May LEAs choose to use 2019-2020 enrollment and National School Lunch Program (NSLP)
numbers on the SC5000 for the 2021-2022 ESSA Consolidated Application?
A7: For enrollment, an LEA uses the most recently available data, which will be from the previous
school year in most cases. Since enrollment data should be available for 2020-2021, the LEA
would use enrollment data from 2020-2021. The as-of date is selected by the LEA. The date used
to determine enrollment numbers must be the same for all campuses.
The US Department of Education released a Fact Sheet on January 4, 2021, with the following non-
regulatory guidance related to low-income percentages for within-LEA allocations.
Due to the novel Coronavirus disease 2019 (COVID-19), the U.S. Department of Agriculture’s
(USDA’s) Food and Nutrition Service (FNS) granted nationwide waivers (USDA waivers) through
June 30, 2021, to support access to nutritious meals while minimizing potential exposure to
COVID-19. The USDA waivers relate to the National School Lunch Program (NSLP), the School
Breakfast Program (SBP), the Seamless Summer Option (SSO), and the Summer Food Service
Program (SFSP).
For LEAs that choose to participate under the USDA waivers, complete NSLP data collected
through household applications may not be available from school year (SY) 2020-2021. To the
extent that SEAs and LEAs use NSLP data to help carry out the Title I, Part A program, they
ordinarily would use NSLP data from SY 2020-2021 to implement their Title I, Part A program in SY
2021-2022 because the SY 2020-2021 data would be the best data available. The information that
follows outlines options for LEAs to successfully implement their Title I, Part A program without
complete NSLP data.
To the extent that NSLP data from SY 2020-2021 are not available, options available to an LEA for
its within-LEA allocations in SY 2021-2022 include using:
• Medicaid or Temporary Assistance to Needy Families (TANF) data or a composite of data of
these two sources from SY 2020- 2021;
• The best available NSLP data, which may be from SY 2019-2020;
• NSLP data from SY 2020-2021 that may be accessible (e.g., counts of children identified
through direct certification);
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• A composite of NSLP, Medicaid, and TANF data, which might include Medicaid or TANF
counts from SY 2020-2021 and the best available FRPL data, which may be from SY 2019-
2020; or
• Data from a poverty survey conducted by the SEA or LEA that replicate NSLP, Medicaid, or
TANF data.
Q8: For LEAs implementing the CEP program, is it acceptable for the LEA to use a socio-economic
survey to determine the LEA and campus low-income percentages utilized to determine within-
LEA allocations?
A8: An LEA can use data from a poverty survey that replicates the National School Lunch Program
(NSLP) survey or other poverty data. If the survey replicates the NSLP or other poverty data
survey, then it would be acceptable for use in reporting Title I, Part A Low-Income data for the LEA
and campuses.
Q9: An LEA has 2 Title I, Part A served campuses that are combining. They will be at a new physical
location, with a new name, but will be keeping the PEIMS number of one of the campuses. For
the application, would we average the two schools’ snapshot (that is the date we use)
free/reduced-price lunch information?
A9: The process would remain the same as with all campuses reported on the SC5000. To determine
the campus low-income % for the combined campus, the LEA would divide the number of low-
income students by the figure entered in the “Total Campus Enrollment” field and enter that
result. The LEA would use the number of low-income students, multiplied by the per-pupil
amount the LEA chooses, to determine a campus’s Title I, Part A allocation.
Please note that LEAs that have a total enrollment of less than 1,000 students can determine per-
pupil amounts without any regard to campus low-income percentages. The LEA may choose to
serve any and/or all campuses without regards to the campus low-income percentages. Such an
LEA may use other criteria, such as academic performance or the grade span of its schools to
determine which of its schools receive Title I funds, or it may choose to allocate Title I funds to all
of its schools.
Q10: For 2021-2022, I understand that LEAs may use their 2019-2020 National School Lunch Program
(NSLP) data if that is the best available information. Which enrollment numbers do they use:
2019-2020 or 2020-2021?
A10: An LEA uses the most recently available data for enrollment, which will be from the previous
school year in most cases. Since enrollment data should be available for 2020-2021, they would
use enrollment data from 2020-2021. The as-of date is selected by the LEA. The date used to
determine enrollment numbers must be the same for all campuses.
Q11: Is it allowable for an LEA to reduce the Title I, Part A allocation for a stand-alone Pre-
Kindergarten campus due to other funds being available to the campus?
A11: If the LEA wants to serve the PK campus but wants to adjust the amount of Title I, Part A funds
allocated to the campus, they can use the related exception. ESSA Section 1113(c)(2)(B) permits
an LEA to reduce the amount of Title I, Part A funds allocated to a Title I, Part A campus by the
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amount of supplemental funds from State or local sources that it spends on programs that meet
the intent and purpose of Title I, Part A. The LEA would need to maintain documentation to that
effect and ensure that the reduction of Title I, Part A funds is for State or local sources that meet
the intent and purpose of Title I, Part A.
Under 34 C.F.R. 200.79(b), a program meets the intent and purposes of Title I, Part A if the
program either—
1. Is implemented in a school in which the percentage of children from low-income families is
at least 40 percent;
2. Is designed to promote schoolwide reform and upgrade the entire educational operation
of the school to support students in their achievement toward meeting the challenging
State academic standards that all students are expected to meet;
3. Is designed to meet the educational needs of all students in the school, particularly the
needs of students who are failing, or are most at risk of failing, to meet the challenging
State academic standards; and
4. Uses the State’s assessment system to review the effectiveness of the program;
OR
1. Serves only students who are failing, or are most at risk of failing, to meet the challenging
State academic standards;
2. Provides supplementary services designed to meet the special educational needs of
participating students to support their achievement toward meeting the State’s student
academic achievement standards; and
3. Uses the State’s assessment system to review the effectiveness of the program.
It is important to note that if the LEA substitutes 100% of the Title I, Part A funds with
supplemental state or local sources, it is essentially “skipping” the campus. A “skipped” campus is
not considered a Title I, Part A campus.
Q12: I have a campus that is not Title I, Part A eligible. May I use the Ed-Flex Waiver to make it
Schoolwide Program eligible?
A12: There are two types of Ed-Flex Waivers involved here. If the LEA wishes to serve a campus is not
Title I, Part A eligible, the LEA must first apply and be approved for an Ed-Flex Individual
Programmatic Waiver. This is separate from the SW Ed-Flex Waiver that is part of the Consolidated
Application. There are two application windows for the Individual Ed-Flex Programmatic Waiver:
in May, for a July 1 start date, and in August for an October 1 start date. The specific dates are
posted on the web site (linked above), along with the application forms.
Once the LEA has received approval for the waiver to establish the campus’s Title I, Part A
eligibility, the LEA can apply for the SW Ed-Flex Waiver through the Consolidated Application.
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Q13: I have a campus that is Title I, Part A eligible but not SW eligible, how can I make it SW eligible?
A13: The LEA may be able to use a Feeder Pattern, or, if the campus was previously a schoolwide
program, the LEA may use “SW from a previous year.” If neither of these options works, the LEA
may request an Ed-Flex SW waiver through the ESSA Consolidated Federal Grant Application.
Q14: When applying the "35 percent rule," must all school attendance areas with at least 35 percent
poverty be served?
A14: No. However, the school attendance areas to be served must be selected in rank order.
Q15: May an LEA allocate a greater per-pupil amount, for example, to schoolwide program schools
than to targeted assistance schools since schoolwide programs serve all children in the school?
A15: The Title I statute requires allocations to be based on the total number of low-income children in a
school attendance area or school. Therefore, poverty is the only factor on which an LEA may
determine funding. In other words, an LEA may not allocate funds based on the instructional
model, educational need, or any other non-poverty factor. In fact, now that Title I, Part A places
the responsibility for selecting participants and designing programs on schools rather than on the
LEA, the LEA will not necessarily be in a position to know in advance the instructional model or
educational need when determining allocations.
Q16: Is there any flexibility in how an LEA may count children from low-income families in middle and
high schools?
A16: Of the four measures of poverty the statute permits an LEA to use for identifying eligible school
attendance areas and allocating funds to those areas, eligibility for free or reduced-price lunch is
by far the measure most frequently used. Yet, we know from experience that high school and
middle school students are less likely to participate in free and reduced-price lunch programs than
are elementary school students. Hence, those schools often may not be identified as eligible for
Title I services or, if eligible, may not receive as high an allocation as their actual poverty rate
would require. In order to address the situation, an LEA may use comparable data collected
through alternative means such as a survey. Also, an LEA may use the feeder pattern concept. This
concept would allow the LEA to project the number of low-income children in a middle school or
high school based on the average poverty rate of the elementary or middle school attendance
areas that feed into that school.
Q17: Can an LEA have different per-pupil amounts within a grade span?
A17: Yes, if the campuses are equal to or below 75% low-income, campuses within the same grade
span can have different amounts, provided the LEA follows the rank and serve rule within a grade
span group. All campuses above 75% must follow the Rank and Serve rule regardless of grade
span. Only single attendance areas do not have to follow these rules for per-pupil amounts.
Response Revised 06/30/2022
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Q18: If an LEA uses PEIMS snapshot data to get their enrollment numbers and they want to pull their
low-income numbers (economically disadvantaged) from there, which codes would they use?
For example: 01- eligible for free meals under the NSLP, 02- eligible for reduced-price meals
under the NSLP, and 99-other economically disadvantaged. Would they just use the number of
students coded as 01 & 02 or would they also include 99 since some use 99 for students who
qualify as economically disadvantaged but are not direct certified?
A18: If the LEA uses a composite of National School Lunch Program (NSLP), Medicaid, and Temporary
Assistance to Needy Families (TANF) data as their selected poverty measure, the LEA can choose
to use students coded with a 99, in addition to 01 and 02, for their low-income percentage. The
LEA would maintain documentation for students coded 01, 02, and 99.
Q19: What is the difference between residing and enrollment?
A19: Enrollment is the total number of students enrolled on a campus, based on the as-of date selected
by the LEA. Residing is the number of students residing in the attendance area.
Q20: For the number of targeted assistance program students served, would the LEA report previous
year students served, or an anticipated number of students to be served for 21-22; or the
number of students who qualify for services in 21-22 based on local criteria?
A20: The LEA would report the estimated number of students to be served on the Targeted Assistance
campus.
Q21: If a campus is using direct certification as the basis of eligibility, is the percentage for low
income 100% or the actual percentage?
A21: The actual percentage of low-income students should be used. Direct certification is selected only
when the LEA is solely using direct certification data as a poverty measure. Keep in mind that the
number of students directly certified is a subset of the total number of students eligible for free
and reduced-priced meals.
Q22: Do you have to amend if the actual numbers change from the estimated number of Targeted
Assistance students entered when submitting the application?
A22: The LEA may amend the SC5000 if the actual numbers change from the estimated number of
Targeted Assistance students entered when submitted the application.
Q23: If campuses are closed in AskTED, how do we remove these campuses from the SC5000
Schedule?
A23: If the campuses are listed in AskTed, even if closed, they will always show up on the SC5000. For
any closed campus, designate “0” for enrollment, “None” for the Basis of Eligibility, and “NS” for
Campus Status.
Q24: Charter Schools are not required to set aside money for private school equitable services,
correct?
A24: That is correct.
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Q25: Can Title I, Part A funds that are reserved at the LEA level for foster care student transportation
be used at non-Title I, Part A campuses?
A25: No. The only Title I, Part A LEA reserved funds that can be used for students at non-Title I, Part A
campuses are those funds reserved at the LEA level for services to homeless students.
Q26: If the campus with the highest number and percentage of low-income students is a high school,
can an LEA "skip" that campus and only serve the elementary schoolwide program-eligible
campuses?
A26: Yes. For LEAs with a total enrollment of 1,000 or more students, a campus is identified as a
skipped campus in the following situations: 1) A campus has a low-income percentage over 75%
and is not served. 2) Another campus with the same grade span and a lower low-income
percentage is served. The LEA confirms by submission of its application that skipped campus(es)
meet the following requirements: 1) The skipped campus meets the comparability of services
requirement; 2) The skipped campus receives supplemental funds from other State or local
sources that are expended per the requirements of a TA or a SW campus; and 3) The funds
expended from such other sources equal or exceed the amount that would be provided to the
campus under Title I, Part A.
Q27: If an LEA redirects funds into Title I, Part A from Title II, Part A and Title IV, Part A through the
Rural Education Achievement Program (REAP) which then makes its Title I, Part A allocation over
$500,000, does the LEA at that point need to make the required 1% parent and family
engagement reservation?
A27: Redirected funds through REAP is not indicated on the PS3101 (only funds transferred through
Funding Transferability). Thus, if the LEA redirects funds through REAP that will not affect the
Parent and Family Engagement requirement if the amount is over $500,000. However, if the LEA
transfers funds into Title I, Part A from Title II, Part A and/or Title IV, Part A through Funding
Transferability which causes the LEA Title I, Part A allocation to exceed $500,000, they will be
required to reserve at least 1% for parent and family engagement activities.
Q28: What percentage should be reserved for homeless and foster care transportation?
A28: The reservation for services to homeless students’ reservation is required by all LEAs, regardless of
the Title I status of their campuses. An amount must be reserved for this purpose (a minimum of
$100 is required). The reservation should be what the LEA deems to be reasonable and necessary,
which may be determined based on a needs assessment. The LEA should maintain documentation
to demonstrate how the LEA decided on the amount reserved. If an LEA chooses to reserve funds
for foster care transportation, the LEA is required to reserve a minimum of $100.
Q29: Please clarify what is meant by LEAs with less than 1,000 students being exempt from using
poverty measures. What might that look like and how would it be reported on the SC5000?
A29: LEAs with less than 1,000 students are still required to complete the SC5000 and are to maintain
documentation locally that shows how they chose to allocate funds to their campuses. Such an
LEA may use other criteria, such as academic performance or the grade span of its schools to
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determine which of its schools receive Title I funds, or it may choose to allocate Title I funds to all
its schools.
Q30: What are some examples of allowable expenditures with Title I, Part A funds reserved at the LEA
level for administration of Title I, Part A programs?
A30: Such costs may include payroll costs associated with the role of the person or persons that
manage and administer the Title I, Part A program.
Q31: Is an LEA required to rank and serve campuses if there is only one campus per grade span with
no overlapping grade levels?
A31: If the LEA has less than 1,000 students, the LEA is not required to rank campuses. Such an LEA
may use other criteria, such as academic performance or the grade span of its schools to
determine which of its schools receive Title I funds, or it may choose to allocate Title I funds to all
its schools. If the LEA has 1,000 or more students, the LEA is required to follow the rank and serve
process for allocating funds to their campuses.
Q32: In the ranking example, two of the campuses were Title I, Part A eligible because they had at
least a 35% low-income percentage. Would those campuses implement a targeted assistance
program since the schoolwide program eligibility threshold is 40%?
A32: Since the campuses do not meet schoolwide program eligibility, they could implement a targeted
assistance program.
Q33: On the SC5000, do we use the schoolwide status for schools who have gone through the
schoolwide transition process and will be schoolwide in 2021-22?
A33: If the campus has completed the one-year schoolwide transition planning process, they are
eligible to be served as a schoolwide campus. If they have not completed this process, the campus
must use another designation until the process is complete. The SC5000 may be amended to
change that designation to SW upon completion of the planning process.
Q34: Is foster care transportation an allowable activity to be conducted with Title I, Part A funds that
have been reserved at the LEA level?
A34: Yes, foster care transportation is listed on the PS3101 as one of the activities that can be
conducted with reserved funds.
Q35: Please describe more about Direct Certification. What is required? Multiplier?
A35: Direct Certification can be a complex process for LEAs that have CEP and non-CEP campuses. That
is when the multiplier is required. Appendix A of the following document provides additional
information about the multiplier. https://www2.ed.gov/policy/elsec/leg/essa/within-district-alloc-
guid-draft-for-public-comment-3112020.pdf Please reach out via email to
[email protected] if you have questions related to the process.
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Q36: If a district has less than 100 students, do they still have to determine per-pupil allocations?
A36: An LEA with an enrollment of fewer than 1,000 students is exempt in statute from having to use
the poverty measures to determine which of its schools receive Title I funds. Such an LEA may use
other criteria, such as academic performance or the grade span of its schools to determine which
of its schools receive Title I funds, or it may choose to allocate Title I funds to all its schools. LEAs
must maintain documentation of the per-pupil amounts used to determine Title I, Part A
allocations.
*Q37: What are the pros and cons of using grade span grouping versus straight rank and serve?
*A37: Using grade span grouping for Title I, Part A eligibility could allow campuses to be Title I, Part A
eligible that otherwise would not be eligible on their own. The same is true for schoolwide
program eligibility. For campuses with a low-income percentage equal to or below 75%, the
flexibility in grade span grouping could also allow an LEA to allocate Title I funds by grade span
within each grade span and not across grade spans. Response Revised 06/30/2022
Q38: May a served campus with 74% poverty receive the same amount per pupil as those equal to or
greater than 75% poverty? Or must the 74% campus receive an amount that is less?
A38: The LEA must ensure that it allocates Title I, Part A funds to its campuses with a poverty
percentage above 75 percent first. If the LEA has funds remaining, the LEA has the discretion to
allocate the remaining funds using a variety of methods. An LEA is not required to allocate the
same per-pupil amount to each participating school. If an LEA allocates different per-pupil
amounts to participating campuses, the LEA must allocate a per-pupil amount that is equal to or
higher to campuses with higher poverty rates than it allocates to campuses with lower poverty
rates.
Q39: Please clarify how an LEA with only one campus per grade span with no campuses above 35%
should approach allocations.
A39: If the LEA chooses to serve any campus below 35% low-income, the 125% rule comes into effect.
The 125% rule requires an LEA to allocate an amount for each low-income child in each
participating Title I school that is at least 125 percent of the LEA’s allocation per low-income child.
Q40: We have always skipped a campus based on the local/state funding allocated each year to them.
With enrollment changes and programming changes, this campus no longer qualifies based on
this year's numbers. Do we take this next year to set up a schoolwide program for them, thus
they are not receiving Title l programming/funding until 2022-2023?
A40: If the campus is engaged in the one-year schoolwide transition process, the campus can choose to
implement a targeted assistance program and thus receive Title I, Part A funding in 2021-2022.
Q41: Could you give an example of state and local funds that would meet the intent and purpose of
Title I, Part A for the purposes of skipping a campus?
A41: State compensatory education funding is an example of supplemental state funds that could meet
the intent and purpose of Title I, Part A for the purposes of skipping a campus.
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Q42: If all of our campuses are below 35%, how are we supposed to allocate 125% to all of them?
A42: If the LEA chooses to serve any campus below 35% low-income, the 125% rule comes into effect.
The 125% rule requires an LEA to allocate an amount for each low-income child in each
participating Title I school that is at least 125 percent of the LEA’s allocation per low-income child.
The LEA would need to use the rank and serve process and may not be able to serve all eligible
campuses if there are not enough funds. The intent of the 125% rule is to concentrate the Title I,
Part A funds in campuses that have higher poverty percentages; it is not necessarily the intent that
all campuses be served.
Q43: How does an LEA determine the amount of funds a campus will receive for Title I, Part A
funding?
A43: The campus allocation is determined by the number of low-income students multiplied by the per-
pupil amount. For example, if the per-pupil amount that is determined by the LEA for the campus
is $1,500 and the campus has a total of 250 students and 78% of the students come from low-
income families, the number of low-income students would be 195. The LEA would determine the
campus’s allocation by multiplying 195 times $1,500. The campus allocation would be $292,500.
Q44: Is there a specific requirement for the date used to pull low-income data for eligibility?
A44: LEAs are required to use the same date for all campuses in the LEA. TEA does not collect that date;
the LEA must maintain auditable documentation in case it is requested. For the year of data used
to determine poverty counts of public schools, an LEA uses the most recently available data, which
will be from the previous school year in most cases.
Q45: Can an LEA serve a campus that only enrolls prekindergarten students as a schoolwide campus?
A45: If the campus meets overall Title I, Part A eligibility requirements and schoolwide program
eligibility requirements, an LEA can choose to serve a campus that only enrolls prekindergarten
students. In determining overall Title I, Part A eligibility please note that the LEA must use the
same poverty measure(s) for all its campuses, both for eligibility and for determining allocations.
For example, the LEA likely wouldn’t have Census low-income data for students ages 5-17 that
would apply to a campus that only has pre-K students. Such an LEA would need to use another
poverty measure for all its campuses.
Q46: How many times can a campus use the "schoolwide previous year" provision for implementing a
schoolwide program on a campus that does not currently meet the 40% threshold?
A46: A campus can use the “Schoolwide Previous Year” provision and remain a schoolwide program
until the campus is either schoolwide eligible on its own or is no longer Title I, Part A eligible and
cannot be served.
Q47: With Title I, Part A funds, are we able to not allocate funds to a campus and instead use them at
the LEA-level to hire a campus interventionist to support the campus?
A47: The LEA reservations process occurs prior to allocation of funds to campuses. Funds reserved at
the LEA level should be used for LEA-wide Title I, Part A activities to benefit students at Title I,
Part A served campuses. The campus would still need to be allocated funds based on the rank and
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serve process. If the campus in question did not receive a Title I, Part A campus allocation, the
campus would not be considered a Title I, Part A served campus and thus, the LEA would not be
able to use LEA reserved funds to provides services to the students on that campus.
Q48: Would it be accurate to say that if you choose to use "residing" numbers, you would have to
remove students who are out-of-district transfers in order to get an accurate account of total
students in LEA/campuses? Enrollment would account for ALL students regardless of whether
they live within the LEA boundaries?
A48: That is correct.
Q49: What are the required Title I, Part A LEA reservations?
A49: An LEA that receives Title I funds must reserve a proportional share of those funds to provide
equitable services to eligible children who attend a private school.
If the Title I, Part A LEA entitlement amount (includes funds transferred via Funding
Transferability) is greater than $500,000, the LEA must reserve at least 1% of funds for Districtwide
Parent and Family Engagement Activities. The LEA must distribute at least 90% of its Districtwide
Parent and Family Engagement reservation to its Title I schools, giving priority to high-need
schools. For this purpose only, Texas defines ‘high-need schools’ as low-income schools with high
percentages of students who do not meet the challenging State academic standards.
The Services to Homeless Students reservation is required by all LEAs, regardless of the Title I
status of their campuses. An amount must be reserved for this purpose (a minimum of $100 is
required). The reservation should be what the LEA deems to be reasonable and necessary which
may be determined based on a needs assessment. The LEA should maintain documentation to
demonstrate how the LEA decided on the amount reserved.
ESSA also requires an LEA to reserve Title I, Part A funds to provide services comparable to those
provided to children in Title I, Part A campuses to children in local institutions for neglected
children.
Q50: Is staff development a required LEA reservation?
A50: Although an LEA can use Title I, Part A reserved funds for LEA-wide professional development
activities, it is not a statutory required reservation.
Q51: Is it required that a campus be a targeted assistance program campus before transitioning to a
schoolwide program campus?
A51: No. However, a campus implementing a schoolwide program must ensure that it has met all the
statutory requirements for implementing a schoolwide program during the one-year planning
process. If the LEA determines, in consultation with the school, that less time is needed to
develop and implement the schoolwide program, the LEA will need to retain documentation to
that effect. All documentation to demonstrate compliance for schoolwide planning must be
maintained locally for audit and validation/monitoring purposes. Documentation of the planning
process must include a comprehensive needs assessment, the inclusion of the required
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stakeholders in the process, incorporation of the required descriptions into the Campus
Improvement plan, documentation related to parent and family engagement (PFE) requirements
(i.e., school-parent compact and PFE policy), and the provision for an evaluation of program
effectiveness that will inform the next year’s needs assessment and planning. If the LEA
determines that ESC training/technical assistance was part of the reason that less time was
needed to develop and implement the schoolwide program, then the LEA would need to keep
such documentation in addition to the documentation noted above.
Q52: If an LEA has one prekindergarten campus serving only 3- and 4-year-old students, is the Title I,
Part A campus eligibility based on the age of the students they serve, or their within-LEA ranking
based on the percentage of low-income students on the campus?
A52: The campus’ eligibility to receive Title I, Part A funds must be based on the low-income percent for
the campus and in accordance with the statutory requirements for ranking and serving Title I,
Part A eligible campuses.
The LEA has several options concerning the data it uses to calculate low-income percentages.
Statute allows LEAs to select from the following measures of poverty:
• Children eligible for free and/or reduced-price lunches under the National School Lunch
Act;
• Children in families receiving assistance under Title IV, Part A of the Social Security Act
(Temporary Assistance to Needy Families, or TANF);
• Children eligible to receive medical assistance under the Medicaid program;
• Children, ages 5 through 17, inclusive, in poverty as counted in the most recent LEA-level
census poverty data approved by the US Department of Education; or
o Note: Because census data are generally not available at the school level, if an LEA
uses this measure, it would most likely be part of a composite with one or more of
the above measures
• A composite of any of the above measures.
The LEA would be restricted to ages 5 through 17 only if they were selecting the 4
th
bulleted item
solely as their only measure of poverty. For all other data (bullets # 1, 2, 3 and 5), the low-income
percentage would be based on student enrollment numbers regardless of student ages.
If the LEA wishes to qualify the preschool campus for Title I, Part A, the LEA will need to use a
poverty measure other than the Census low-income data, or at least use a composite that
included at least one additional measure from the list above. Otherwise, the LEA would not be
able to consider students under the age of 5 in its determinations of the campus low-income
percentages.
Q53: If the LEA only has three campuses with no grade levels that overlap, and all three campuses are
eligible to implement a Title I, Part A schoolwide program, can the LEA still allocate a higher per-
pupil amount for the elementary school if the middle school has a higher low-income percent?
A53: An LEA may determine eligibility within grade spans and choose which grade span(s) to serve. In
doing so, the LEA may use its district-wide percentage of poverty or the percentage of poverty
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data of the relevant grade span(s). If a grade-span poverty percentage is above 35 percent, the
LEA may also identify as eligible any school with a poverty percentage of at least 35 percent. If
there is only one school in a grade span, that school is eligible for Title I funds, provided that any
school above 75 percent poverty has received a Title I, Part A allocation.
Consistent with statutory requirements, the LEA must ensure that its school above 75 percent
poverty receives a per-pupil allocation that is at least as high as the per-pupil allocations of all its
other campuses. When an LEA allocates Title I funds by grade span, the rule that the LEA must
allocate a higher per-pupil amount to campuses with higher poverty rates than it allocates to
campuses with lower poverty rates would apply within each grade span and not across grade
spans for campuses grouped with a low-income percent of 75 and below.
Q54: Please explain more about preschool and Title I, Part A. We have a preschool campus where all
students meet eligibility for free or reduced lunch, but they are not considered a Title I, Part A
campus. Why?
A54: If the campus meets Title I, Part A eligibility criteria based on the poverty measure selected, it may
be served. There are flexibilities provided in statute to LEAs that include not serving a campus or
skipping a campus. Ultimately, the LEA would need to ensure that it is allocating funds to eligible
Title I, Part A campuses in accordance with the statutory requirements for ranking and serving
Title I, Part A eligible campuses.
The LEA has several options concerning the data it uses to calculate low-income percentages.
Statute allows LEAs to select from the following measures of poverty:
• Children eligible for free and/or reduced-price lunches under the National School Lunch
Act;
• Children in families receiving assistance under Title IV, Part A of the Social Security Act
(Temporary Assistance to Needy Families, or TANF);
• Children eligible to receive medical assistance under the Medicaid program;
• Children, ages 5 through 17, inclusive, in poverty as counted in the most recent LEA-level
census poverty data approved by the US Department of Education; or
o Note: Because census data are generally not available at the school level, if an LEA
uses this measure, it would most likely be part of a composite with one or more of
the above measures
• A composite of any of the above measures.
The LEA would be restricted to ages 5 through 17 only if they were selecting the 4
th
bulleted item
solely as their only measure of poverty. For all other data (bullets # 1, 2, 3 and 5), the low-income
percentage would be based on student enrollment numbers regardless of student ages.
If the LEA wishes to qualify the preschool campus for Title I, Part A, the LEA will need to use a
poverty measure other than the Census low-income data, or at least use a composite that
included at least one additional measure from the list above. Otherwise, the LEA would not be
able to consider students under the age of 5 in its determinations of the campus low-income
percentages.
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Q55: Can a campus use Schoolwide Program (SWP) Previous Year to meet SWP eligibility
requirements if the campus used feeder pattern to establish its eligibility in the previous year?
A55: Yes, a campus can use SWP Previous Year to establish SWP eligibility in a future year if they were
ever eligible to run a SWP through feeder pattern the feeder pattern option. The SWP Previous
Year option does not apply to campuses who apply for an Ed-Flex Schoolwide Program Eligibility
waiver. Response Revised 06/30/2022
Q56: If an LEA uses a locally developed income survey to gather data related to low-income students,
can students who are coded in the Public Education Information Management System (PEIMS)
with a code of 99 (other Economically Disadvantaged [ECD]) be included in the low-income
numbers for the LEA and/or a campus?
A56: If the locally developed income survey replicates National School Lunch Program, Medicaid, or
Temporary Assistance to Needy Families data, the LEA can include students coded 99 (other ECD)
in its low-income calculations for Title I, Part A purposes. This process would be something that
the LEA would document in the LEA’s Title I, Part A Program Plan in the case of an audit and/or
random validation monitoring.
Q57: If the LEA and/or campus low-income percentages have changed (based on current-year
snapshot data) since the current-year ESSA Consolidated Application was submitted, does an
LEA need to amend the SC5000?
A57: The LEA has the discretion to use the best available data at the time that the application is
submitted and is not required to amend and update the data as additional data become available.
TEA does not recommend that an LEA amend the SC5000 for this purpose. If the LEA decides to
amend the SC5000 with the most recent data, the LEA needs to be extremely cautious since it has
been operating its campus Title I, Part A programs based on the percentages originally submitted.
Submitting new data could affect campus eligibility and allocations as they relate to the rank and
serve statutory requirements.
Q58: If a campus meets overall Title I, Part A eligibility, but does not meet the 40% threshold to
operate a schoolwide program, what options does the campus have to be able to implement a
schoolwide program?
A58: If a Title I, Part A eligible campus does not meet the 40% threshold to operate a schoolwide
program, the campus has three alternative options for establishing campus schoolwide program
eligibility. Please note that the one-year schoolwide transition planning process applies to all
campuses that will be implementing a schoolwide program for the first time.
1. Schoolwide Previous Year
The Schoolwide Previous Year option can be used for a campus that was SW eligible in a
previous year and still meets the basic Title I, Part A eligibility criteria. This basis can be
used each year until the campus is either Schoolwide program eligible on its own, using
Residing, Enrollment, or Direct Certification, or is no longer Title I, Part A eligible and
cannot be served. Please note that this option cannot be used to establish basic Title I
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eligibility for a campus. The LEA is responsible for maintaining documentation locally that
shows evidence of the campus being eligible to operate a Schoolwide program in a
previous year. If the LEA does not have documentation, the LEA cannot use the Schoolwide
Previous Year option.
If the campus meets the criteria for Schoolwide Previous Year, on the SC5000 - Title I,
Part A Campus Selection, Part B. Campus Selection Data section under the “Additional
Eligibility” column, the LEA would select the “SW Previous Year” checkbox.
If the campus in question has not ever operated a schoolwide program, then the feeder
pattern option may be a viable option for establishing schoolwide program eligibility.
2. Feeder Pattern
The Feeder Pattern option can be used for a campus to establish schoolwide program
eligibility by projection, based on the number of low-income students in the elementary
school attendance area(s) that feed into that campus. The LEA must maintain the
following documentation for any campus whose eligibility is established via feeder pattern:
low-income numbers and enrollment from those campuses that comprise the feeder
pattern for the campus in question.
If the campus meets the criteria for the feeder pattern option, on the SC5000 - Title I,
Part A Campus Selection, Part B. Campus Selection Data section under the “Basis of
Eligibility” column, the LEA would select “Feeder Pattern” from the drop-down listing.
If the campus in question does not meet the criteria for the feeder pattern option, then the
Schoolwide Eligibility Ed-Flex Waiver option would be the only other viable option for
establishing schoolwide program eligibility.
3. Schoolwide Eligibility Ed-Flex Waiver
The Schoolwide Eligibility Ed-Flex waiver allows any campus otherwise eligible to receive
Title I, Part A funds to implement a Title I, Part A schoolwide program regardless of the
percentage of students from low-income families. This Statewide Programmatic Waiver of
Schoolwide Eligibility will be valid for one year. After the one-year waiver is implemented,
the campus may continue to implement a schoolwide program for as long as the campus
remains an eligible Title I, Part A attendance area. The LEA must maintain a completed
Supporting Documentation Form on file locally. The Supporting Documentation form can
be found on the TEA Ed-Flex Waivers Webpage under Statewide Programmatic Waivers.
Although there is no evaluation of this Statewide Programmatic Waiver of Schoolwide
Eligibility beyond the one-year waiver period, TEA will track and report to USDE the
performance of all campuses granted this waiver until the point the campus has a low-
income percentage of 40.00% or greater.
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If this option is selected, previously the LEA was required to complete the WV4004–Ed-Flex
Title I, Part A SW Eligibility schedule. The WV4004 schedule has been discontinued
beginning in 2022-2023. If the campus chooses to apply for the Schoolwide Program
Eligibility Statewide Programmatic Ed-Flex Waiver, on the SC5000 - Title I, Part A Campus
Selection, Part B. Campus Selection Data section under the “Additional Eligibility” column,
the LEA would select the “SW Ed-Flex Waiver” checkbox.
Note: If the campus selected “Individual Prog. Waiver” because a campus does not meet
the low-income criteria to be a Title I campus at all, the LEA would need to apply for and
receive an Ed-Flex Individual Programmatic waiver in order to qualify as a Title I campus
before requesting a SW eligibility waiver. At the time that the LEA receives approval of an
Ed-Flex Individual Programmatic waiver, an amendment to the SC5000 can be submitted
requesting a SW Ed-Flex Waiver.
Q59: For how long can the Schoolwide Previous Year option be used to establish schoolwide program
eligibility for a Title I, Part A eligible campus?
A59: If a Title I, Part A eligible campus does not meet the 40% threshold, and it was previously
schoolwide program eligible on its own, the Schoolwide Previous Year option can be used to
establish Schoolwide Program eligibility on a campus each year the campus is Title I, Part A eligible
on its own (using Residing, Enrollment, or Direct Certification).
Q60: Does the eligibility threshold of 40% low-income that is required to operate a Schoolwide
program apply to campuses within an LEA that has an enrollment of less than 1,000 students?
A60: Yes. Although LEAs with an enrollment of less than 1,000 is exempt from the rank and serve
statutory requirements that govern overall Title I, Part A eligibility, campuses within an LEA that
has an enrollment of less than 1,000 students are still required to follow the eligibility
requirements as they relate to operating a schoolwide program.
Q61: Is it allowable to allocate Title I, Part A funds to a stand-alone Pre-Kindergarten campus?
A61: If the campus is Title I, Part A eligible, they can be served regardless of the grade levels offered.
The campus would be treated like any other campus.
Q62: Is it allowable to allocate $340 per pupil at the elementary level for high-poverty schools (over
75%) and $370 per pupil to high-poverty secondary schools (over 75%) or does the LEA need to
have the same per pupil allocation for all high poverty school regardless of the grade span?
A62: ESSA requires the LEA to first allocate, in rank order of poverty, Title I funds to its schools above
75% poverty, including any middle schools or high schools. An LEA is not required to allocate the
same per-pupil amount to each participating school. However, if an LEA allocates different per-
pupil amounts to participating campuses with a poverty percent above 75%, the LEA must allocate
a per-pupil amount that is equal to or higher to campuses with higher poverty rates than it
allocates to campuses with lower poverty rate regardless of grade span. The grade-span grouping
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option can only be utilized to allocate funds to campuses with 75% poverty or below after high-
poverty schools (over 75% poverty) have been allocated funds.
If the low-income percentages for the high-poverty secondary schools are all greater than the low-
income percentages for all the high-poverty elementary schools, then it would be allowable to
allocate $340 per pupil at the elementary level for high-poverty schools (over 75%) and $370 per
pupil to high-poverty secondary schools (over 75%). However, if the low-income percentages for
any of the high-poverty elementary schools are greater than the low-income percentages for any
of the high-poverty secondary schools, then it would not be allowable to allocate $340 per pupil at
the elementary level for high-poverty schools (over 75%) and $370 per pupil to high-poverty
secondary schools (over 75%).
Q63: If a campus has a low-income percentage of 39.64%, is the campus eligible to operate a
Title I, Part A Schoolwide program since 39.64 % can round up to 40%?
A63: The threshold for schoolwide program eligibility is 40%. Unless the campus has a low-income
percentage of at least 40% (no rounding), they are not eligible on their own to implement a
schoolwide program. If the campus was ever previously at 40%, it can maintain schoolwide status
up until the campus is no longer Title I, Part A eligible. Additionally, the campus may be able to
use the feeder pattern option, if applicable, or apply for an Ed-Flex Waiver for Schoolwide
Eligibility.
*Q64: Does an LEA’s entitlement change if a campus chooses to operate a targeted assistance program
instead of a schoolwide program?
*A64: An LEA’s Title I, Part A entitlement is based on Census data updates, not on how many campuses
the LEA serves as Schoolwide or Targeted Assistance.
In other words, the size of the LEA’s funding amount does not increase with the number of
campuses or students served. If the LEA decides to serve a new eligible campus, the level of
Title I, Part A funding does not increase.
The Title I, Part A allocations an LEA makes to its eligible, served campuses are based on the
number of low-income students at each campus, not on the number of students served or the
total number of students enrolled.
Schoolwide campuses are allocated funds based on their number of low-income students, just like
targeted assistance campuses. Schoolwide campuses do not get more because they are
schoolwide.
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ESSA Consolidated Federal Grant Application
Q1: It is my understanding that LEAs need to have a public hearing for the ESSA application. Can you
tell me what information must be included or what that might look like? When does this public
hearing need to take place? Before or after the submission of the ESSA Application?
A1: As per ESEA Section 8306(a)(7) and the ESSA section of the Program-Specific Provisions and
Assurances, upon submission of the ESSA Consolidated Federal Grant Application, an LEA is to
assure that “before the application was submitted, the applicant afforded a reasonable
opportunity for public comment on the application and considered such comment.”
If an LEA chooses to meet this requirement via a public hearing, the LEA will follow their local
policies and procedures related to public hearings. Additionally, the LEA would want to ensure
that the public had time to review the ESSA Consolidated Federal Grant Application before the
public hearing so that they are able to provide comments on the content of the application. As
per statute, the opportunity for public comment on the application and consideration of such
comment would need to take place before the application is submitted. Documentation of this
requirement would be retained locally and could include the dates in which the public was
provided with the opportunity to review the application prior to the public hearing, the public
hearing notice, public hearing agenda and public hearing minutes.
Q2: When thinking about stamp-in dates for ESSA Consolidated Applications, what is the stamp-in
date tied to (other than when the application was submitted)? How does the stamp-in date
affect payroll and different positions paid from Title I, Part A and LEA positions, in particular?
A2: The funds are not effective for payroll positions until they have been entered on the application
and that application has been certified and submitted. The stamp-in date is the date the LEA
certified and submitted the application and is the date the funds are effective for a particular
position. If an LEA submits an amendment and adds a position, that position has the same stamp-
in date as when the amendment was submitted.
Q3: Can you provide clarification as to the PS3101 – Title I, Part A Program Schedule, Part 1B, Line 5:
Administration of Title I, Part A reserved funds amount?
A3: An LEA reserves funds in this category for activities related to the administration of Title I, Part A
Programs (including administration of Title I, Part A programs for students at facilities for
neglected and delinquent). Such costs may include payroll costs associated with the role of the
person or persons that manage the Title I, Part A program.
Q4: Are indirect costs included on the PS3101 – Title I, Part A Program Schedule?
A4: Since the reserved funds percentage is calculated based on the total LEA Title I, Part A funds
available, if indirect costs are to be charged for any of the activities to be conducted with reserved
funds, then they would be included in the amount noted on Part B of the PS3101. Although
indirect costs are noted on the budget schedule, the program schedule is different. If some or all
the indirect costs being noted in the budget schedule are being used at the LEA level, then the LEA
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would need to include that amount in the PS3101 – Part 1B; Line 5. The Total Funding and
Transfer Amount(s) noted on Part 1A; Line 4 includes all Title I, Part A funds (including any indirect
costs that the LEA may classify as indirect costs on the budget schedule) so to accurately reflect
funds being reserved at the LEA level, indirect costs would need to be considered when
completing the PS3101.
Q5: On the PS3101 of the ESSA Consolidated Application, how does an LEA determine the amount of
funds to set aside for Services to Eligible Private School Students and Homeless Students?
A5: For services to eligible private school students, there is a reservation calculation worksheet that
the LEA completes in the ESSA Consolidated Federal Grant Application. It is referenced as the
PS3099. For services to homeless students, an amount must be reserved for this purpose (a
minimum of $100 is required). The reservation should be what the LEA deems to be reasonable
and necessary which may be determined based on a needs assessment. The LEA should maintain
documentation to demonstrate how the LEA decided on the amount reserved.
Q6: What is the difference in lines 2 and 3 of section B of the PS3101 – Title I, Part A program
schedule in the ESSA Consolidated Application? What does it mean by Administration of Title I,
Part A Programs for Eligible Private School (PNP) Students?
A6: Line 2 references the total calculation of the private school reservation as noted on the PS3099.
Line 3 references any funds reserved at the LEA level for the administration of PNP equitable
services. Funds may be reserved at the LEA level for the costs associated with administering the
Title I, Part A program. An example is the LEA using Title I, Part A funds reserved at the LEA for the
salary of their Title I, Part A Director that administers and manages the program at the LEA level.
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Federal Report Card Dissemination
Q1: Is an LEA required to post federal report cards for all campuses regardless of whether they
receive Title I, Part A funds? If they must post for all campuses, are they required to notify
parents at all campuses?
A1: Each LEA that receives Title I, Part A funding is responsible for disseminating the state, LEA and
campus-level federal report cards for all campuses, regardless of whether they are Title I
served. The LEA does need to notify the parents of enrolled students at all campuses.
*Q2: For how long must federal report card data be posted on an LEA’s website?
*A2: An LEA shall keep at least 3 years of federal report card data on its website.
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New Title I, Part A Campus Processes
Q1: When an LEA launches a new school, how does/what is the process for that campus to receive
Title I, Part A funding?
A1: The process an LEA follows to launch a new campus that is eligible to receive Title I, Part A funding
is generally a two-step process with many other processes embedded in each of the steps. We
have provided general information for the two steps and references to resources that provide the
detailed intricacies for each of the steps. Additionally, the LEA can reach out to its regional
Education Service Center Title I, Part A contact for technical assistance and support related to the
processes. The technical assistance and support for this process are provided under the ESC ESSA
Basic Services Initiative and are free of charge to LEAs.
Step 1: Determine Title I Campus Eligibility
Campus eligibility for Title I, Part A is determined through the SC5000 schedule which the LEA
completes as part of its ESSA Consolidated Federal Grant Application in eGrants.
Detailed information related to Title I, Part A campus eligibility can be found in the following
documents: Schedule SC5000 Title I, Part A Campus Selection – ESSA Consolidated Federal Grant
Application Guidance Document and Section II. C. Campus Eligibility of the Title I, Part A –
Improving Basic Programs Program Guide.
Step 2: Determine the Title I program the school will implement
Once it is determined that a campus meets Title I eligibility requirements, the campus will need to
determine which Title I program (Targeted Assistance Program or Schoolwide Program) the school
will implement based on the eligibility requirements for each program.
Schoolwide Program
A schoolwide program permits a school to use funds from Title I, Part A and other federal
programs to upgrade the entire education program in a Title I school to improve the achievement
of the lowest achieving students. This contrasts with a Title I, Part A targeted assistance program,
in which Title I, Part A funds are used only for programs that provide services to eligible children
identified as failing or being most at risk of failing to meet the state’s challenging academic
standards.
Generally, speaking, to be eligible for a Schoolwide Program, the campus must have a low-income
percentage of at least 40%. (If the campus is eligible for Title I, Part A, but does not meet the 40%
threshold, it is possible to request a SW Eligibility waiver in the ESSA Consolidated Federal Grant
Application.)
ESSA Section 1114(b)(1)(A) states that an eligible school operating a schoolwide program shall
develop a comprehensive plan that is developed during a 1-year period, unless—the local
educational agency determines, in consultation with the school, that less time is needed to
develop and implement the schoolwide program. The Schoolwide Program section of the Title I,
Part A –Improving Basic Programs Program Guide provides the requirements for the
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comprehensive plan that is based on the comprehensive needs assessment.
If the LEA determines, in consultation with the school, that less time is needed to develop and
implement the schoolwide program, the LEA would need to retain documentation to that
effect. All documentation to demonstrate compliance for schoolwide planning must be
maintained locally for audit and validation/monitoring purposes. Documentation of the planning
process must include a comprehensive needs assessment, the inclusion of the required
stakeholders in the process, incorporation of the required descriptions into the Campus
Improvement plan, documentation related to parent and family engagement (PFE) requirements
(i.e., school-parent compact and PFE policy), and the provision for an evaluation of program
effectiveness that will inform the next year’s needs assessment and planning. If the LEA
determines that ESC training/technical assistance was part of the reason that less time was
needed to develop and implement the schoolwide program, then the LEA would need to keep
such documentation in addition to the documentation noted above.
Detailed information related to Title I, Part A Schoolwide Program Requirements can be found in
the following document: Section II. E. Schoolwide Program Requirements of the Title I, Part A –
Improving Basic Programs Program Guide.
Targeted Assistance Program
A Targeted Assistance (TA) Program provides services to eligible children identified as having the
greatest need for special assistance. Targeted assistance program campuses are either ineligible
for a schoolwide program or have chosen not to operate a schoolwide program. A campus may be
served as a Targeted Assistance campus, provided the campus is Title I, Part A eligible (at least
35% low-income, or equal to or greater than the LEA low-income percentage). TA campuses may
only serve students identified in greatest need of services. Students must be selected for services
based on multiple, educationally related, objective criteria established by the LEA. The selection
criteria may be supplemented by the campus. The criteria for determining student eligibility for
students served on TA campuses must be included in the District and the Campus improvement
plans.
Detailed information related to Title I, Part A Schoolwide Program Requirements can be found in
the following document: Section II. F. Targeted Assistance Programs of the Title I, Part A –
Improving Basic Programs Program Guide.
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Paraprofessional Requirements – Title I, Part A
Q1: When should an LEA document compliance with the requirements?
A1: For audit and/or random validation purposes, we would advise your LEA to complete the forms for
current-year instructional paraprofessionals that are funded by Title I, Part A funds.
Q2: Are LEAs required to report the number of paraprofessionals who meet the requirements?
A2: There is currently no annual ESSA report associated with the Title I, Part A Paraprofessional
requirements.
Q3: If we have a paraprofessional that completed a similar paraprofessional assessment 10 years
ago while in California, would it count and exempt her from taking another assessment to meet
the requirements?
A3: Your LEA can accept the results of the assessment if you are able to document that the employee
met a rigorous standard of quality and demonstrated through a local academic
assessment: Knowledge of and the ability to assist in instructing reading, writing, and
mathematics; or knowledge of and the ability to assist in instructing reading readiness, writing
readiness, and mathematics readiness, as appropriate. You would need official assessment
documentation that includes the name of the assessment, date of assessment, assessment score,
and passing standard.
Q4: Is the local assessment to be developed within the district, or is there a certified assessment
through the local ESC?
A4: The assessment can be developed by the LEA, as long as the LEA is able to document the
following:
• The assessment assesses knowledge of and the ability to assist in instructing reading, writing,
and mathematics; or knowledge of and the ability to assist in instructing reading readiness,
writing readiness, and mathematics readiness, as appropriate.
• The passing standard of the assessment demonstrates that the individual met a rigorous
standard of quality.
The LEA can utilize external assessment providers for an assessment, including your regional
Education Service Center.
Q5: What changed in the requirements from the transition of NCLB to ESSA?
A5: The only changes from what was expected under NCLB vs. ESSA are as follows.
1. The Elementary and Secondary Education Act (ESEA), as amended by the Every Student
Succeeds Act (ESSA), requires that LEAs ensure that paraprofessionals performing instructional
duties whose salaries are paid in full or in part from Title I, Part A funds on a Schoolwide or
Targeted Assistance campus, meet the Title I, Part A Paraprofessional requirements.
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2. Additionally, within one year of being hired, Title I, Part A paraprofessionals must have
the Educational Aide state certification. Note: Charter school personnel are exempt from the
state certification requirement unless it is required by local policies and procedures.
For more information related to the Educational Aide state certification, visit the Becoming an
Educational Aide in Texas web page.
Q6: What is the timeframe for the paraprofessionals to complete their requirements?
A6: Prior to providing services, Title I, Part A paraprofessionals must have a high school diploma or its
recognized equivalent and meet one of the following requirements:
1. Complete at least two years of study at an institution of higher education (defined as
completion of 48 semester hours or equivalent trimester hours) of college coursework or
an applicable number of semester hours as defined by the institution of higher education
attended, whichever is less;
2. Possess an associate (or higher) degree; or
3. Meet a rigorous standard of quality and can demonstrate, through a local academic
assessment—
▪ Knowledge of and the ability to assist in instructing reading, writing, and
mathematics; or
▪ Knowledge of and the ability to assist in instructing reading readiness, writing
readiness, and mathematics readiness, as appropriate.
Additionally, within one year of being hired, Title I, Part A paraprofessionals must have the
Educational Aide state certification. For more information related to the Educational Aide state
certification, visit the Becoming an Educational Aide in Texas web page.
Q7: What is a rigorous local academic assessment?
A7: The rigorous standard of quality would be determined by the assessment provider (LEA, ESC,
external vendor).
Q8: Does the Title I, Part A Paraprofessional LEA Documentation Form need to be updated yearly?
A8: If the status of the employee’s qualifications has not changed, the form would not need to be
updated yearly.
Q9: Can college remedial courses count towards the completion of 48 semester hours requirement
noted in the requirements for Title I, Part A Paraprofessionals?
A9: It is a local decision. If the LEA’s policies and procedures allow for accepting remedial courses
when hiring individuals, the LEA could accept the courses for this purpose. If the LEA does not
accept remedial courses as per the LEA’s hiring practices, then the LEA would not accept them for
this purpose.
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Q10: Should the “Determining Title I, Part A Paraprofessional Requirements” form be placed in the
personnel file, and if an Instructional Assistant were to go to another district, should the form
be accompanied with the service record?
A10: The documentation form must be maintained in the employee’s service record or personnel file. It
would be a local decision as to which method the LEA chooses to use, or the LEA can use both
methods (maintained in the personnel file and accompanied with the service record if the
employee transitions to another LEA).
Q11: We understand that within one year of taking on the role of paraprofessional, to meet the
Title I, Part A Paraprofessional Requirements, the paraprofessional must acquire state
paraprofessional certification. Is this still true if the paraprofessional already holds a Texas
teaching certification?
A11: If the paraprofessional already holds a Teaching certification, that would satisfy the state
certification requirement for Title I, Part A paraprofessionals.
Q12: Charter school paraprofessionals being paid partially or in full with Title I, Part A funds are not
required to have the state educational aid certification. However, they do need to have at least
one of the three additional requirements?
A12: That is correct. If a charter school does not have a certification requirement in its local policies
and procedures for paraprofessionals, then they are not required to obtain the state certification.
However, they are required to have a high school diploma or its recognized equivalent and meet
one of the three requirements noted below.
1. Complete at least two years of study at an institution of higher education (defined as
completion of 48 semester hours or equivalent trimester hours) of college coursework or an
applicable number of semester hours as defined by the institution of higher education
attended, whichever is less;
2. Possess an associate (or higher) degree; or
3. Meet a rigorous standard of quality and can demonstrate, through a local academic
assessment—
o Knowledge of and the ability to assist in instructing reading, writing, and mathematics;
or
o Knowledge of and the ability to assist in instructing reading readiness, writing
readiness, and mathematics readiness, as appropriate.
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Q13: When the No Child Left Behind (NCLB) Act requirements for highly qualified were implemented,
the LEA went through a process of certifying those who did not have the college hours to meet
the highly qualified requirement. Are those staff still considered highly qualified, or was there a
time limit on those certifications?
A13: If the LEA has the documentation for that certification process referenced in item #3 below, and it
meets the following requirements, then the certification process is still valid.
Prior to providing services, Title I, Part A paraprofessionals must have a high school
diploma or its recognized equivalent and meet one of the following requirements:
1. Complete at least two years of study at an institution of higher education (defined
as completion of 48 semester hours or equivalent trimester hours) of college
coursework or an applicable number of semester hours as defined by the institution
of higher education attended, whichever is less;
2. Possess an associate (or higher) degree; or
3. Meet a rigorous standard of quality and can demonstrate, through a local academic
assessment—
• Knowledge of and the ability to assist in instructing reading, writing, and
mathematics; or
• Knowledge of and the ability to assist in instructing reading readiness,
writing readiness, and mathematics readiness, as appropriate.
Additionally, within one year of being hired, Title I, Part A paraprofessionals must have the
Educational Aide state certification.
Note: Charter school personnel are exempt from the state certification requirement unless
it is required by local policies and procedures.
There are documentation form templates under the Resources section of the TEA Title I, Part A
Requirements for Paraprofessionals webpage.
Q14: Are college hours received from a college in a foreign country allowed to meet the Title I, Part A
Paraprofessional requirements?
A14: The qualification requirement for paraprofessionals refers to at least two years of study at an
institution of higher education. Foreign colleges and universities are institutions of higher
education. The LEA would need to follow its policies and procedures for obtaining a translation of
the transcript and determining whether the coursework meets the requirement.
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Parent and Family Engagement (PFE) Requirements
Q1: Is there a deadline for the School-Parent Compact for campuses each year?
A1: Although the ESSA statute does not provide specific information related to a deadline for the
school-parent compact for campuses each year, the intent of the statute as it relates to the
distribution of the school-parent compact is that it be distributed at the beginning of the school
year (within the first 4 to 6 weeks) annually. As referenced in ESSA Section 1116(d), the purpose
of the school-parent compact is to “outline how parents, the entire school staff, and students will
share the responsibility for improved student academic achievement and the means by which the
school and parents will build and develop a partnership to help children achieve the State’s high
standards.” For additional information and resources related to the requirements associated with
the school-parent compact requirement, please visit the Title I, Part A Parent and Family
Engagement Statewide Initiative School Parent Compacts web page.
Q2: Are the ESSA requirements for Parent and Family Engagement activities primarily the
responsibility of the campuses or the LEA?
A2: ESSA references parent and family engagement-related responsibilities for both LEAs and
campuses. LEAs and campuses are both required to have a written parent and family engagement
(PFE) policy. The delineated responsibilities that are referenced in the ESSA requirements that are
specific to LEAs and campuses for the written PFE policies. For additional information and
resources related to the requirements associated with the LEA and campus written parent and
family engagement policies, please visit the Title I, Part A Parent and Family Engagement
Statewide Initiative Written Parent and Family Engagement Policies web page.
Q3: If the LEA originally had activities in the Campus Improvement Plan (CIP) or District
Improvement Plan (DIP) for parent and family engagement, is the LEA out of compliance if they
choose not to do those activities or can the LEA simply change the CIP or DIP to reflect the
decision to change?
A3: In general, the CIP and DIP are living documents based on the needs identified as a result of the
comprehensive needs assessment process. We understand that such needs may change mid-year
or as a result of an extenuating circumstance (i.e. pandemic). It is important to keep the CIP and
DIP as up to date as possible in the case of an audit and/or random validation monitoring. Thus,
LEAs can amend their CIP and DIP at any time that they are able to document that needs have
changed, as long as they follow the improvement planning process requirements, which includes
the involvement of various stakeholder groups, including parents. For audit and/or random
validation monitoring, it is important for LEAs and campuses to maintain all versions of the CIP and
DIP with the dates the documents were updated being noted within the documents. The LEA
should exercise caution when making decisions related to making changes to PFE-related activities
since it is required to consult with parents and family members of participating children when
such changes are to be initiated. The LEA should also verify to see if there are any implications
related to the funds reserved at the LEA level for parent and family engagement activities. The
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activities may have also been listed in the LEA and/or campus parent and family engagement
written policies and thus, revisions to the policies would need to occur, as well, in consultation
with parents and family members of participating children. Statute states that the written policies
shall be jointly developed with, and distributed to, parents and family members of participating
children, and agreed on by such parents. Additionally, the LEA shall involve parents and family
members of children receiving Title I, Part A funds in the decisions regarding how Title I, Part A
funds reserved under Section 1116(a)(3)(A) are allotted for parental involvement activities.
[Section 1116(a)(3)(B)]
Q4: We are looking to add the following job duties to our parent liaison. Would this be allowable?
1. Work with individual and/or small groups of students in corrective or
reinforcement activities assigned by the teacher except where certain programs
may prohibit supervision of a given activity.
2. Assist the teacher in implementing special strategies for reinforcing material or
skills based on a sympathetic understanding of individual students, their needs,
interests and abilities.
3. Assist with supervision of students.
A4: Assignment of job duties is a local decision. Although the duties you are wanting to add do seem
to meet the intent and purpose of Title I, Part A, they would not be considered parent and family
engagement duties as they are tied to student instruction. You may consider revising the job title
and function in the job description document to include instructional duties. This would ensure
that your documentation maintained locally is as accurate as possible in the case of an
audit. Additionally, you would want to ensure that the instructional duties referenced are tied to
a need based on a comprehensive needs assessment and documented in the campus
improvement plan.
Adding the instructional duties might also change some of the budget coding for the position. For
example, if the LEA was using funds reserved for parental involvement activities to pay for the
parent liaison, but then added the instructional duties, the LEA would want to be sure that only an
appropriate percentage of the salary was coded to the parental involvement reservation.
Q5: When should the Parent Right to Know letters be sent out for any teacher teaching outside of
their certification area?
A5: Campuses must provide to each individual parent timely notice that the parent’s child has been
assigned or taught for four or more consecutive weeks by a teacher who does not meet state
certification or licensure requirements soon after the four weeks have passed. Sample
Notification Letters can be found on the Statewide Parent and Family Engagement Initiative Web
Site for Parents’ Right to Know. Additionally, another resource that you may find helpful is An
Administrator’s Checklist to ESSA Parent and Family Engagement. It provides a comprehensive list
of all the parental involvement requirements.
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Q6: We have a teacher (teaching a core subject on a Title I campus) that is working through an ACP
program but does not have an intern or probationary certification. After how many weeks, do
we have to provide notification to parents of their children being taught by a non-certified
teacher?
A6: ESSA Section 1112(e)(1)(B)(ii) states that schools that receive Title I, Part A funds shall provide to
each individual parent of a child who is a student in such school with respect to such student,
timely notice that the student has been assigned, or has been taught for 4 or more consecutive
weeks by, a teacher who does not meet applicable State certification or licensure requirements at
the grade level and subject area in which the teacher has been assigned.
To determine if a teacher meets State certification requirements based on the information
provided by the LEA (teacher that is working through an ACP program but does not have an intern
or probationary certification and he/she is teaching a core subject), please reach out to the
Division of Educator Certification. They are available only via helpdesk ticket. If it is determined
that the teacher in this circumstance does not meet State certification requirements, then the
notification requirement referenced above would need to be met.
Q7: Are LEAs required to send the Parents’ Right to Know notification for teachers who are currently
in an Alternative Certification Program (ACP)?
A7: ESSA requires that campuses provide to each individual parent timely notice that the parent’s
child has been assigned or taught for four or more consecutive weeks by a teacher who does not
meet state certification or licensure requirements soon after the four weeks have passed. Sample
Notification Letters can be found on the Statewide Parent and Family Engagement Initiative Web
Site for Parents’ Right to Know. Additionally, another resource that you may find helpful is An
Administrator’s Checklist to ESSA Parent and Family Engagement. It provides a comprehensive list
of all the parental involvement requirements.
The notification is required if the teacher does not meet state certification or licensure
requirements. In some cases, teachers enrolled in alternative certification programs may meet
state certification requirements. However, in other cases, teachers enrolled in alternative
certification programs may not meet state certification requirements. For specific questions
related to state certification requirements, please reach out to the Division of Educator
Certification by submitting a HelpDesk Ticket under the “Educator Certification and CPE” card on
the HelpDesk web page.
Q8: Are charter schools required to comply with the requirement related to parental notification of
teachers who are not certified and have been teaching for 4 or more weeks?
A8: ESSA Section 1112(e)(1)(B) states, “ADDITIONAL INFORMATION.—In addition to the information
that parents may request under subparagraph (A), a school that receives funds under this part
shall provide to each individual parent of a child who is a student in such school, with respect to
such student—
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(ii) timely notice that the student has been assigned, or has been taught for 4 or more consecutive
weeks by, a teacher who does not meet applicable State certification or licensure
requirements at the grade level and subject area in which the teacher has been assigned.”
Teachers employed by open enrollment charter schools in Texas are not required to be certified as
per state certification or licensure requirements except in the case of teachers assigned to teach in
special education or bilingual programs, in which case the appropriate state certification is
required. Therefore, the parents right to know requirement referenced in ESSA statute (Section
1112[e][1][B][ii]) would only apply to special education and bilingual teachers employed by an
open enrollment charter school.
Q9: Is it acceptable for campuses to host their Annual Title I Meeting in a virtual/remote setting?
A9: Yes, it is acceptable for LEAs to host their Annual Title I, Part A Meeting in a virtual/remote setting.
Documentation is key. The LEA would need to document how all the requirements associated
with the Annual Title I meeting were met (i.e., attendance, offered to all parents, translation,
information provided, opportunity for feedback, etc.). Additionally, the LEA would need to
consider alternative options to share the information from the meeting with parents that may not
be able to attend the meeting being held in a remote setting. The updated Annual Title I, Part A
Annual Meeting Toolkit has resources related to the Annual Title I, Part A Annual Meeting
requirement and a section with suggestions for hosting the meeting in a virtual setting.
Q10: Does the LEA PFE Policy need to be approved by the board of trustees?
A10: It depends. Federal statute does not require the PFE policy to be approved by the board unless
the LEA’s local policies and procedures require that all policies by approved by the board. The LEA
should note, however, that federal statute does require the LEA’s PFE policy to be incorporated
into the LEA plan. [Section 1116(a)(2)] If the LEA is required by either its district and campus
decision-making process or by state law to obtain board approval of its improvement plan, the PFE
policy would be subject to local board approval.
Q11: Can the Title I, Part A campus annual meeting be combined with other beginning
of the year events?
A11: In some cases, yes. The meeting shall be set 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 Title I, Part A, and to explain the requirements of Title I, Part A, and
the right of the parents to be involved. The Title I, Part A annual meeting can be part of a larger
event, but it can’t be reduced to a 5–10-minute summary or a handout. The LEA must give
parents more than one attendance option (different days and times) to participate in the annual
meeting.
Q12: How do LEAs document the annual evaluation of the content and effectiveness of
the PFE policy?
A12: Acceptable forms of documentation for the annual evaluation of the content and effectiveness of
the PFE Policy includes, but is not limited to, evaluation meeting agenda, minutes, sign in sheets,
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survey instruments, survey responses, focus groups, focus group responses and/or an evaluation
report.
Q13: How often does the campus written PFE policy need to be updated?
A13: The campus written PFE policy shall be evaluated at least annually to ensure that it meets the
changing needs of parents and the school. However, it should be updated as the needs change for
the parents and the school which may be more frequently than annually.
Q14: Does the campus PFE policy need to be translated into other languages?
A14: LEAs operating at least one schoolwide or targeted assistance program must establish Translation
procedures related to ensuring that the campus PFE Policy is, to the extent practicable, provided
in a language that parents can understand. USDE has not provided guidance or defined the term
to the extent practicable. However, it is a requirement that campuses follow their LEA’s
translation procedures in determining whether the policy needs to be translated into other
languages.
Q15: Can a campus use an already established committee to review, evaluate and guide the decisions
related to the PFE requirements including the creation/revision of the campus PFE policy?
A15: Yes. The campus can use an already established committee to review, evaluate and guide the
decisions related to the PFE requirements including the creation/revision of the campus PFE policy
as long as the already established committee is comprised of a sufficient number and
representative group of parents and family members served by the campus to adequately
represent the needs of the populations served for the purposes of developing, revising, and
reviewing the parent and family engagement policy.
Q16: Can the same stakeholders who are consulted for the DIP be the same stakeholders utilized to
develop the LEA Parent and Family Engagement Policy?
A16: There could certainly be some overlap between the two groups. However, although, parents of
children in schools served under Title I, Part A are required to be a part of the DIP stakeholder
consultation process, they are only one of the stakeholder groups that are part of that process.
The requirement for the Parent and Family Engagement (PFE) Policy is that it be jointly developed
with parents and family members of participating children. Thus, the stakeholder group
responsible for the development of the PFE Policy would likely need to include more parents so
that the group could include a sufficient number and representative group of parents and family
members served by the LEA to adequately represent the needs of the populations served for the
purposes of developing, revising, and reviewing the parent and family engagement policy.
Q17: Where can I find sample LEA and campus PFE policies?
A17: Sample templates that have been vetted for compliance and include all the PFE requirements can
be accessed in the Additional Resources section of the Title I, Part A Program Guide.
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Q18: Is the school-parent compact required for all Title I, Part A campuses?
A18: Yes.
Q19: Where are the school-parent compacts required to be kept?
A19: Copies of school-parent compacts should be retained by the campus or LEA in accordance with the
record retention policies and procedures of the LEA. Signatures are not required.
Q20: How does a campus make their PFE policy available to the local community?
A20: There are a variety of ways that a campus can make their PFE policy available to the local
community. Campuses can post direct links to the PFE policy on its web site, make hard copies
available to individuals in the local community upon request, make hard copies available for
viewing in public locations and/or have the policy available at the front office of the campus.
Q21: Are all Title I, Part A campuses required to host annual parent-teacher
conferences for parents of all children served under Title I, Part A?
A21: Only elementary Title I, Part A campuses are required to host annual parent-teacher conferences
for parents of all children served under Title I, Part A. At the conference, the school-parent
compact shall be discussed as the compact relates to the individual child’s achievement.
Q22: Can the LEA and campus PFE policies be included in the Student Handbook/Code of Conduct
publication provided to parents yearly to meet the requirements for distribution?
A22: It depends. The following requirements related to the distribution of the PFE policies would need
to be met for the Student Handbook/Code of Conduct (SH/COC) to be an acceptable distribution
method for the PFE policies. The LEA and campuses must ensure that the most current PFE
policies are published in the SH/COC document. If the PFE policies are revised at any time before
a new SH/COC is distributed, an addendum to the SH/COC providing the revised PFE policy must
be distributed to all parents of participating students. The SH/COC meets the translation
requirements as set out in the LEAs translation procedure. The PFE policy is noted separately in
the table of contents and easily accessible and written in an understandable and uniform format
within the SH/COC document. Parents may request a hard copy.
Q23: Can the LEA reserve more than 1 percent of its Title I, Part A entitlement to assist schools to
carry out PFE activities?
A23: Yes. If the LEA’s Title I, Part A entitlement is greater than $500,000, the LEA is required to reserve
at least 1 percent of its Title I, Part A entitlement to assist schools to carry out parent and family
engagement activities. The LEA can reserve more than 1 percent. Please note that at least 90
percent of the funds reserved shall be distributed to Title I, Part A schools, with priority given to
high-need schools. It is also required that the LEA involve parents and family members of children
in Title I, Part A served campuses in the decisions regarding how reserved Title I, Part A funds are
allotted for parent and family engagement activities.
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Q24: Is a campus required to convene the Title I, Part A annual meeting and the parent policy
development meetings at different times of the day?
A24: Yes. Parents should be offered multiple opportunities to receive the information. Each Title I,
Part A campus shall offer at least two attendance options for its annual Title I meeting (at different
times of the day and at different days of the week) to ensure maximum participation by parents
and family members of participating students. Likewise, parents must have more than one
meeting opportunity to provide input on the development, review, and evaluation of the PFE
policy.
Q25: Does the parent and family engagement policy for LEA and/or campuses require school board
approval or is it okay to include the policy in our administrative regulations and our department
handbook/plan without the board voting to approve it as a board policy?
A25: The LEA would need to follow their local policies and procedures for policy adoption.
Q26: Is there a translation policy template?
A26: We currently do not have a template. We are looking to identify exemplars of translation policies
that can be shared through the Statewide Title I, Part A Parent and Family Engagement Initiative
when they are vetted and available for sharing.
Q27: Are non-traditional campuses (head start, credit recovery, dropout recovery, DAEPs, etc.)
required to meet the parent and family engagement requirements (school-parent-student
compact, annual Title I, Part A meeting, campus written PFE policy, etc.)?
A27: Every campus served with Title I, Part A funds is required to meet all parent and family
engagement statutory requirements. Each campus is required to have its own School-Parent-
Student Compact and a campus written PFE policy that is based on the needs of the parents
served by the campus. Additionally, each campus is required to host the annual Title I, Part A
meetings.
Q28: Is the family engagement plan required under TEC 29.168 for elementary schools the same as
the campus parent and family engagement policy required under Title I, Part A?
A28: They each have separate statutory requirements. The two documents can be combined into one,
as long as the requirements of each are addressed. The Family Engagement Plan referenced in
TEC 29.168 is related to prekindergarten programs. The specific requirements for the high-quality
prekindergarten program family engagement plan can be found in the following Commissioner’s
Rules: https://tea.texas.gov/sites/default/files/ch102aa.pdf.
The Title I, Part A written PFE policy requirements are noted in the Title I, Part A Program Guide.
Q29: Do the Title I, Part A PFE statutory requirements apply to only Schoolwide Program Campuses,
or do they also apply to campuses operating a Targeted Assistance Program?
A29: The PFE requirements noted in Section 1116 apply to any Title I, Part A served campus, regardless
of the program being implemented on the campus.
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Q30: Which parents would be involved in developing the required PFE statutory requirements on a
Targeted Assistance Campus? All parents, or only the parents of students served by the
targeted assistance program?
A30: On a targeted assistance campus, the parents and family members of participating children would
be involved in developing the required PFE statutory requirements on the campus.
Q31: If a campus serves 5
th
and 6
th
grade students, does the parent-teacher conference Title I, Part A
requirement apply to 6
th
grade since that grade level is usually not considered “elementary”?
A31: It would depend on how the LEA classifies the campus. If the LEA considers the campus an
elementary school, the conferences would be required for both grade levels. If the LEA considers
the campus a secondary school, the conferences would not be required for neither grade level.
Statute specifically states the requirement is for elementary schools.
Q32: Are there specific qualifications for translators that are utilized by the LEAs to act as face-to-face
interpreters or to translate documents?
A32: There is no statutory requirement that references qualifications for interpreters or individuals
translating documents. It is a local decision. The LEA would refer to their local policies and
procedures for interpreters and translation of documents.
Q33: If an LEA chooses to reserve an amount that is more than the 1% that is statutorily required for
parent and family engagement, is the LEA required to comply with the 90% distribution to
Title I, Part A campuses requirement for the amount reserved above the 1%?
A33: The ESSA Statute, Section 1116(a)(3)(C) states, “Not less than 90 percent of the funds reserved
under subparagraph (A) [for parent and family engagement activities] shall be distributed to
schools served under this part, with priority given to high-need schools.” Since the statutory
requirement is 1%, the LEA would only need to meet the 90% distribution requirement for the
statutory requirement amount of 1%. The LEA should maintain documentation that at least 90%
of the 1% reservation was distributed to Title I, Part A campuses.
Q34: Can a campus and/or LEA coordinate their parent and family engagement activities across
multiple federal programs?
A34: Section 1116(a)(2)(C) states that “(2) Each local educational agency that receives funds under
Title I, Part A part shall develop jointly with, agree on with, and distribute to, parents and family
members of participating children a written parent and family engagement policy. The policy shall
be incorporated into the local educational agency’s plan developed under section 1112, establish
the agency’s expectations and objectives for meaningful parent and family involvement, and
describe how the agency will—(C) coordinate and integrate parent and family engagement
strategies under this part with parent and family engagement strategies, to the extent feasible and
appropriate, with other relevant Federal, State, and local laws and programs;” The keywords are
“to the extent feasible and appropriate.” Coordination could look different based on the needs of
the families being served. In a schoolwide program, for example, the Annual Title I Meeting
requirement may not meet the coordination requirements for another program if the program has
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requirements that are specific to the population being served. However, for example, if time is
scheduled during the meeting that is tailored to meet the needs of another program and for
parents/family members of students being served by the other program, it may become more
conducive to meeting the requirements for another program. The LEA would need to see how best
to coordinate to ensure they are meeting the needs and requirements of the different populations
they are serving.
Q35: Can Title I, Part A funds be used to coordinate with Title III, Part A, to provide English classes for
parents?
A35: Providing English classes/literacy training for parents would be allowable under Title I, Part A “if
the LEA has exhausted all other reasonably available resources of funding for such training”
[Section 1116 (e)(7)]. If it is determined that the LEA can document that it has exhausted all other
reasonably available resources of funding for such training, it would be allowable to use Title I,
Part A funds. The LEA would need to ensure that the steps and requirements for use of Title I,
Part A funds are met as per the Title I, Part A Use of Funds reference document. The activity would
need to have been identified through the comprehensive needs assessment process and
documented in the appropriate improvement plan (DIP and/or CIP).
From a Supplement, Not Supplant perspective, Title III, Part A funds must be supplemental to
other federal funds, but Title I, Part A funds are not required to be supplemental to other federal
funds; therefore, it would be allowable for Title I, Part A funds to replace Title III, Part A funds, but
not the reverse.
Q36: Is the Annual Title I Meeting required to be conducted by the campus or the LEA?
A36: The Annual Title I Meeting is required to be conducted by each Title I, Part A served campus.
Q37: Is it acceptable for the LEA Written Parent and Family Engagement (PFE) Policy to be distributed
along with the Campus Written PFE Policy at each campus’ Annual Title I Meeting?
A37: Yes, a campus could use the Annual Title I Meeting as an opportunity to distribute both the LEA
and Campus PFE policies since they are both required to be distributed.
Q38: Is the Parent and Family Engagement training that is required to be provided to school
personnel with the assistance of parents required to be provided annually?
A38: The statute does not reference whether this requirement is to be completed annually. Thus, each
of the stakeholders referenced in statute (teachers, specialized instructional support personnel,
principals, and other school leaders, and other staff) would need to have completed the training at
least once while working at the same campus or when parent needs may have changed as it
relates to how to reach out to, communicate with, and work with parents as equal partners on a
campus. The campus and LEA would need to maintain the documentation necessary to establish
compliance with this requirement. Best practice would be that the training take place annually.
Although this requirement is included in the LEA Title I, Part A Compliance Report Self-Check that
is submitted annually, when the LEA is reporting “In Compliance,” for this particular item, they are
affirming that all staff required to be trained have been trained.
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Q39: ESSA Section 1116(2) states that the LEA written parent and family engagement (PFE) policy
"shall be incorporated into the local educational agency's plan developed under ESSA Section
1112.” Does the LEA written PFE policy required under ESSA Section 1116 have to be adopted
and posted to the LEA website by a specific date each year?
A39: The LEA Written Parent and Family Engagement Policy is required to be included as part of the LEA
Title I, Part A Program Plan/District Improvement Plan. Such plan should be completed prior to
the certification and submission of the ESSA Consolidated Federal Grant Application. For
Title I, Part A purposes, it would be a local decision as to when and whether the Plan and Policy
would be posted to the LEA website as a means for making them available to the public. Best
practice would be that the Plan and Policy be posted on the LEA/campus websites and made
widely available to stakeholders at the beginning of the school year.
Q40: Is the Campus Written Parent and Family Engagement Policy required in ESSA Section 1116
required to be included in the Schoolwide Program Plan required under section 1114?
A40: The Campus Written Parent and Family Engagement Policy is not required to be included as part
of the Schoolwide Program Plan/Campus Improvement Plan. However, such plan should be
completed prior to the certification and submission of the ESSA Consolidated Federal Grant
Application. For Title I, Part A purposes, it would be a local decision as to when and whether the
Plan and Policy would be posted to the campus website as a means for making them available to
the public. Best practice would be that the Plan and Policy be posted on the LEA/campus websites
and made widely available to stakeholders at the beginning of the school year.
Q41: Section 1116(e)(3) requires that a training be provided to school staff on 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. Is the LEA or campus required to provide the training?
A41: Section 1116(e)(3), states “To ensure effective involvement of parents and to support a
partnership among the school involved, parents, and the community to improve student academic
achievement, each school and local educational agency assisted under this part— shall educate
teachers, specialized instructional support personnel, principals, and other school leaders, 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;” Since the
statute refers to both a school and LEA, either one can provide the training as long as all the
stakeholders referenced receive the training. For example, the LEA may provide the training to
Principals and the school may provide the training to the other stakeholders referenced. Schools
and the LEA must maintain documentation (agenda, training materials, and sign-in
sheets/participant rosters) locally showing evidence that the training occurred.
Q42: If an LEA has multiple campuses, however, only one campus is served under Title I, Part A, does
the LEA need a separate LEA and campus written Parent and Family Engagement Policy, or
would one document be sufficient in this situation?
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A42: One policy would be sufficient in this situation, as long as the PFE policy statutory requirements
for the LEA and Title I, Part A campus are both included in the one policy document. The name of
the campus would also need to be on the campus-specific portions of the policy, and the LEA and
campus must meet the policy distribution requirements.
Q43: If an LEA does not expend the Title I, Part A funds required to be reserved for Parent and Family
Engagement activities (1%) in a grant year, is the LEA required to reserve the funds in the
following year when the funds are carried over?
A43: A local educational agency (LEA) that received a Title I allocation that exceeded $500,000 and, as
required, reserved 1% of its allocation for parent and family engagement, but did not obligate all
of this amount by September 30, must use a portion of its Title I carryover funds equal to the
unobligated amount for parent and family engagement in addition to its current year’s reservation
for this purpose provided that the LEA only reserved 1% of its allocation. (If an LEA reserved more
than 1% for parent and family engagement and already obligated an amount equal to 1%, then it
need not use any of its carryover funds for this purpose.)
For example, an LEA with School Year (SY) 2021-2022 Title I allocation of $10,000,000 reserved
$100,000 to meet the requirement to reserve at least 1% of its allocation to carry out parent and
family engagement activities under ESEA section 1116. If this LEA only obligated $90,000 of the
$100,000 by September 30, 2022, in addition to reserving 1% of its SY 2022-2023 allocation for
parent and family engagement activities under ESEA section 1116, the LEA must also assign
$10,000 of its SY 2021-2022 carryover funds to this activity. In other words, the $10,000 in
carryover from SY 2021-2022 would be in addition to the required SY 2022-2023 PFE reservation.
*Q44: Does an LEA posting the LEA and all campus parent and family engagement policies only on the
LEA web site (instead of also posting on the campus websites) meet the requirement for making
the policies available to parents and the public and do each have to be provided in an
understandable and uniform format, and to the extent practicable, in a language that parents
can understand?
*A44: It is the LEA’s decision how to design its web site. The policies should be easily accessible by the
public and by parents, if required to be distributed to parents and the public. If a campus policy is
required to be distributed to parents, it would make most sense for the policy to be posted on the
campus website. If the sole method of distribution to parents is via website, the campus and LEA
would be responsible for communicating such method to all parents and maintain documentation
showing evidence of such communication. LEAs and campuses are required to ensure that the
policies are in an understandable and uniform format.
The LEA should follow its local translation policy or procedures to determine the appropriate
languages for translation.
*Q45: An ESSA Title I, Part A requirement states that an LEA must notify parents if a student has a non-
certified teacher in the classroom. With the teacher shortage, the LEA is contracting with
staffing agencies who offer teachers to the LEA. If the LEA uses the services of a staffing agency
to employ a teacher who may not have all the certifications, is the LEA still required to send
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such notice to parents, even if the teacher is not an employee of the district, but is an employee
of the staffing agency?
*A45: The Parents’ Right-to-Know requirement referenced below would apply to an individual that is
fulfilling the role of teacher regardless of whether that person is performing such duties as an
employee or a contractor.
Section 1112(e)(1)(B)(ii): A school that receives funds under Title I, Part A shall provide to each
individual parent of a child who is a student in such school, with respect to such student— timely
notice that the student has been assigned, or has been taught for 4 or more consecutive weeks by,
a teacher who does not meet applicable State certification or licensure requirements at the grade
level and subject area in which the teacher has been assigned.
*Q46: Do districts need to ensure they have a LOCAL POLICY outlining translation procedures, or can
locally communicated translation PROCEDURES be linked, communicated, or referenced in the
distribution communication such as in handbooks, online for required documents, etc.?
*A46: The LEA needs auditable documentation ensuring that it has a process for translating documents
that are required to be provided in a language that parents can understand. LEAs can achieve that
through adoption and implementation of a translation procedure, policy, or documented process.
*Q47: Is it allowable for an LEA to develop an online module (with the input of parents) that staff
could then push out to campuses to meet the requirement related to the training in the value
and utility of parents? All LEA staff would take the online module (with self-checks throughout),
and receive a certificate of completion. Is this allowable rather than a live training?
*A47: The statute does not provide a specific method in which the training is to be provided. As long as
the training includes the statutory requirements, the LEA and schools can determine the method
of the training based on their local needs. The statutory requirement related to the training
requirement is as follows:
ESSA Section 1116(e)(3): To ensure effective involvement of parents and to support a
partnership among the school involved, parents, and the community to improve student
academic achievement, each school and local educational agency assisted under this
part— shall educate teachers, specialized instructional support personnel, principals, and
other school leaders, 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.
*Q48: Is it a requirement for the LEA written parent and family engagement (PFE) policy to be included
in the LEA Program Plan/District Improvement Plan as an addendum or can the LEA state that
they will follow the parent and family engagement strategies laid out in the plan and post it on
the website or distribute it in the school handbook?
*A48: There are 2 statutory references related to the LEA PFE written policy. Section 1112 (b)(7)
references that the LEA Title I, Part A Program Plan shall describe, “the strategy the local
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educational agency will use to implement effective parent and family engagement under section
1116.” Section 1116(a)(2) references that, “Each local educational agency that receives funds
under this part shall develop jointly with, agree on with, and distribute to, parents and family
members of participating children a written parent and family engagement policy. The policy shall
be incorporated into the local educational agency’s plan developed under section 1112.” Since
statute states that the policy shall be “incorporated into the LEA’s plan,” to meet compliance
requirements, the LEA should either include it in the LEA plan or as an addendum to the plan.
Although there is no distribution requirement in the Title I, Part A statute for the LEA Title I, Part A
program plan/DIP, there is a distribution requirement for the LEA PFE written policy. The LEA
would decide how it will distribute the policy to parents and family members of participating
children. The LEA could post the PFE policy on its website. However, the LEA would also need to
notify parents that the PFE policy will be made available on the website. The LEA can also have
copies available at Title I, Part A campuses and/or the LEA can also publish the LEA PFE written
policy in the student handbook that is distributed to all parents.
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Procurement
Q1: May an LEA use federal funds to purchase items from large stores (i.e., Wal Mart, Target, H-E-B)
if the large store is unwilling to sign a procurement form?
A1: There is no required procurement form. However, if the LEA requires that a form be signed as
part of its local policy and the store is unwilling to sign the form, then the LEA cannot purchase
from those stores because it would be violating its local procurement policy.
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LEA Reservations
Q1: Is there a correlation between the 1% LEA reservation for Parent and Family Engagement (PFE)
and the reservation for services to homeless students?
A1: Regardless of whether the LEA is a Single Attendance Area or a Multiple Attendance Area, the LEA
shall reserve from the LEA’s entitlement such Title I, Part A funds as are reasonable and necessary,
prior to making allocations to eligible campuses, in order to accomplish the following purposes:
Districtwide Parent and Family Engagement Activities [Note: If the LEA’s Title I, Part A entitlement
is greater than $500,000, the LEA is required to reserve at least 1 percent of its Title I, Part A
entitlement to assist schools to carry out parent and family engagement activities. At least 90
percent of the funds reserved shall be distributed to Title I, Part A schools, with priority given to
high-need schools.]
Services to Homeless Students [Note: The Homeless reservation is required by all LEAs, regardless
of the Title I status of their campuses. Although an amount must be reserved for this purpose,
there is no specific amount or percentage required. It is what the LEA deems to be reasonable and
necessary. The LEA should maintain documentation to demonstrate how the LEA decided on the
amount reserved.]
Q2: Are the reservations for PFE and services to homeless students related in any way?
A2: The two reservations are not necessarily related in any way. LEAs would make a determination as
to which line item they would make an LEA reservation under and maintain documentation locally
to justify the determination. The LEA would need to abide by the reserved funds amounts noted
on Program Schedule 3101 – Title I, Part A of the ESSA Consolidated Federal Grant Application for
each of the activities areas to be conducted with reserved funds. If the LEA determines that the
needs of the LEA have changed, an amendment can be submitted to adjust the amounts
noted. The LEA should maintain documentation to demonstrate how the LEA decided on the
amount reserved.
Q3: Can funds reserved for PFE be used to support services to homeless students and vice versa?
A3: It depends. Funds reserved at the LEA level can be used for Districtwide PFE activities and
MV/homeless students. There are some instances where the LEA can document that funds
reserved for Districtwide PFE activities may be used to support homeless students and vice versa.
It is what the LEA deems to be reasonable and necessary. The LEA would need to abide by the
reserved amounts noted on Program Schedule 3101 – Title I, Part A of the ESSA Consolidated
Federal Grant Application for each of the activities areas to be conducted with reserved funds. If
the LEA determines that the needs of the LEA have changed, an amendment can be submitted to
adjust the amounts noted. The LEA should maintain documentation to demonstrate how the LEA
decided on the amount reserved.
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Q4: Is there a limit on the total amount reserved at the LEA level and on personnel paid out of the
LEA reservation for Title I, Part A?
A4: There is not a statutory limitation on the total amount reserved at the LEA level and on personnel
paid out of the LEA reservation for Title I, Part A other than that the total reserved funds cannot
exceed the LEA’s entitlement amount. However, if the total reservation exceeds 30% of the
entitlement, TEA will contact the LEA for a justification. The LEA would need to ensure that the
funds reserved are for the statutory authorized activities which include the 10 items noted below.
The LEA would need to ensure that the reserved funds are documented on the most current ESSA
Consolidated Federal Grant Application – PS3101 Title I, Part A Program Schedule. Please note
that there are additional requirements for some of the reservations noted below related to the
amount reserved for such activities: Districtwide Parent and Family Engagement Activities and
Services to Homeless Students.
1. Districtwide Parent and Family Engagement Activities (If the Entitlement Amount is
greater than $500,000, an LEA must reserve at least 1% of funds for Districtwide Parent
and Family Engagement Activities.)
2. Title I, Part A Services to Eligible Private School Students, Not Including Administration
3. Administration of Title I, Part A Programs for Eligible Private School Students
4. Preschool Programs
5. Administration of Title I, Part A Programs (including administration of Title I, Part A
programs for students at facilities for neglected and delinquent)
6. Districtwide Professional Development Activities
7. Services to Homeless Students (The Homeless reservation is required for all LEAs.
Though the reservation amount should reflect the LEA’s needs, a minimum of $100
should be reserved and documentation should be maintained to demonstrate how this
amount was determined.)
8. Services to Students Residing in Local Facilities for the Neglected
9. Services to Students Residing in Local Facilities for the Delinquent
10. Foster Care Transportation
Q5: Can an LEA serve skipped campuses with the parent and family engagement (PFE) LEA
reservation?
A5: LEA reservation funds for Parent and Family Engagement (PFE) can only be used to support Title I,
Part A served campuses. A skipped campus is not considered a Title I, Part A served
campus. Thus, it would be unallowable to serve skipped campuses with the PFE LEA reservation.
Q6: All campuses in an LEA are Title I, Part A served campuses. The LEA reserves Title I, Part A funds
each year for services to support homeless students and will continue to do so in the future. I
just wanted to clarify the Title I, Part A requirement. What is the requirement if all campuses
are Title I, Part A served campuses?
A6: The following reservation requirements apply to all LEAs receiving Title I, Part A funds. The
Homeless reservation is required by all LEAs, regardless of the Title I status of their campuses. An
amount must be reserved for this purpose at the LEA level (a minimum of $100 is required at the
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LEA level). The Homeless reservation should be what the LEA deems to be reasonable and
necessary which may be determined based on a needs assessment. The LEA should maintain
documentation to demonstrate how the LEA decided on the amount reserved.
Q7: If an LEA reserved the required 1% of their Title I, Part A funds for parent and family
engagement but did not expend the full 1%, does the remaining amount carryover for the same
purpose in the following year?
A7: LEAs are not required to allocate the amount remaining that is carried over for the same purpose
in the following year unless it is required by their local policies and procedures related to
carryover funds.
Q8: If an LEA has Title I, Part A served campuses and non-Title I, Part A campuses, may the LEA
reserve funds for Districtwide Professional Development activities?
A8: The LEA may reserve funds for Districtwide Professional Development activities to support Title I,
Part A served campuses only. Non-served campuses cannot benefit from LEA reserved funds for
Districtwide Professional Development activities.
Q9: If an LEA has Title I, Part A served campuses and non-Title I, Part A campuses, may the LEA
reserve funds for Districtwide Parent and Family Engagement (PFE) activities?
A9: If the LEA receives over $500,000 in Title I, Part A funds, they are required to reserve funds for PFE
activities. If the LEA receives $500,000 or less in Title I, Part A funds, the LEA may reserve funds
for Districtwide PFE activities. The PFE reserved funds can only be used to support Title I, Part A
served campuses.
Q10: As we share the April campus estimates for Title I, Part A with our campus principals, I wanted
to be sure to provide the most updated information on what is allowable with the PFE
reservation. Can you please point me in the right direction? Are there any changes based on the
CARES Act?
A10: At least 90% of the funds reserved at the LEA for Parent and Family Engagement shall be
distributed to Title I, Part A schools, with priority given to high-need schools. The LEA shall involve
parents and family members of children in Title I, Part A served campuses in the decisions
regarding how reserved Title I, Part A funds are allotted for parent and family engagement
activities. Funds reserved to carry out parent and family engagement activities shall be used to
carry out activities and strategies that are consistent with the LEA’s parent and family engagement
policy, including at least one of the following:
• Supporting schools and nonprofit organizations in providing professional development for
LEA and school personnel regarding parent and family engagement strategies, which may
be provided jointly to teachers, principals, other school leaders, specialized instructional
support personnel, paraprofessionals, early childhood educators, parents and family
members.
• Supporting programs that reach parents and family members at home, in the community,
and at school.
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• Disseminating information on best practices focused on parent and family engagement,
especially best practices for increasing the engagement of economically disadvantaged
parents and family members.
• Collaborating, or providing subgrants to schools to enable such schools to collaborate, with
community-based or other organizations or employers with a record of success in
improving and increasing parent and family engagement.
• Engaging in any other activities and strategies that the LEA determines are appropriate and
consistent with the LEA’s parent and family engagement policy.
For additional information related to the Parent and Family Engagement Requirements, you can
also refer to the Title I, Part A Program Guide.
The requirements associated with the Title I, Part A parent and family engagement reservation
were not impacted by the CARES Act. For CARES Act information, please visit the CARES Act
Funding and COVID Expense Reimbursement FAQ.
Q11: If a district is required to provide 90% of their reservation for parent engagement back to the
campuses, can the 90% be captured in time and effort for the parent liaison?
A11: If the employee is providing Campus-specific PFE responsibilities, the time the employee spends
on such responsibilities would be considered at the campus level. Additionally, the LEA would
need to ensure that it is following LEA policies and procedures related to the classification of
employees (LEA vs. campus). The LEA would need to retain detailed documentation in case of an
audit or random validation monitoring review.
Q12: Is there a maximum amount that an LEA may reserve?
A12: No. An LEA must bear in mind, however, that the goal of Part A is to enable participating children
to make adequate progress toward meeting the challenging student performance standards that
all children are expected to meet. Moreover, if the 125 Percent Special Allocation Rule applies, the
LEA must calculate 125 percent of the LEA's allocation per low-income child before it reserves any
funds.
Q13: How may an LEA reserve funds for activities such as parental involvement and professional
development?
A13: An LEA may reserve funds at the LEA level for activities such as parental involvement and
professional development or the LEA may require its Title I schools to carry out these activities
from their allocations. For example, an LEA that is required to spend at least 1 percent of its
allocation for parental involvement activities may reserve the full 1 percent from its Part A
allocation, require each school to spend a requisite amount from its Part A allocation, or use a
combination of these approaches. If the LEA does decide to reserve funds for parental
involvement, at least 90% of that reservation must be allocated to campuses.
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Q14: How may preschool children be served under Title I, Part A?
A14: There are several ways in which preschool children may be served under Part A. For example—
• A participating school may use part of its Part A funds to operate a preschool program.
• An LEA may reserve an amount from the LEA's total allocation to operate a Part A
preschool program for eligible children in the district as a whole or for a portion of the
district.
• An LEA may reserve an amount from the LEA's total allocation and distribute these funds to
schools that wish to operate a Part A preschool program.
Q15: Is it correct that an LEA may not have total LEA reservations that exceed 10% of the total Title I,
Part A allocation?
A15: Although Title I, Part A funds must be allocated to campuses as per the rank and serve statutory
requirements, there is no statutory required percent of funds to be allocated to campuses. If the
LEA total reservation exceeds 30%, TEA will contact the LEA for a justification.
Q16: Is an LEA obligated to provide services to the neglected/delinquent facilities using Title I, Part A
funds?
A16: If the LEA applies for Title I, Part A funds, the LEA is required to reserve funds for children in local
institutions for neglected children and if appropriate, children in local institutions for delinquent
children, and neglected or delinquent children in community day programs. [Section
1113(c)(3)(A)(ii) & (iii)] The reservation amounts are required to be noted on the PS3101 in the
ESSA Consolidated Grant Application. The amount would be based on the needs identified and no
less than $100.
*Q17: If an LEA has reserved Title I, Part A funds in the PS3101 for Preschool Programs, can those funds
serve any Preschool student in the program, or only those meeting the low-income criteria?
*A17: Table 1 (Page 10) of the USDE Non-Regulatory Guidance on early learning has a chart that
references mechanisms by which schools and LEAs can use Title I, Part A funds to support
preschool programs that may be useful. Specifically reference the orange section of the chart that
is referenced below. Student eligibility will depend on the type of Title I program involved. If the
child resides in the attendance area of a Schoolwide campus, the child could be served in the LEA’s
Title I preschool program; if the child resides in the attendance area of a Targeted Assistance
campus, the child would need to meet the educationally related eligibility criteria established by
the LEA/campus.
Table 1. Mechanisms by which schools and LEAs can use Title I, Part A funds to support preschool
programs
District (LEA)-Operated: An LEA may reserve a portion of funds from its Title I allocation to
operate a preschool program for eligible children in the LEA as a whole or in a portion of the LEA.
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• District (LEA) as a Whole: An LEA may serve preschool children who reside throughout the
LEA and whom the LEA identifies as eligible because they are at risk of failing to meet the
State’s academic achievement standards when they reach school age. An LEA may not use
Title I funds to implement a preschool program throughout the district to benefit all
preschool students in the LEA unless all the schools in the LEA are Title I schools operating
schoolwide programs.
• Portion of the District (LEA): An LEA may serve preschool children who reside in specific
Title I school attendance areas (e.g., its highest-poverty school attendance areas) served by
some or all of its Title I schools if, for example, an LEA does not have sufficient Title I funds
to operate a preschool program for the district as a whole.
*Q18: The LEA is required to reserve at least 1% for Parent and Family Engagement (PFE) since the
LEA’s entitlement is greater than $500,000. All funds reserved meet the 1% requirement and
are used for PFE Liaison salaries. How can the LEA ensure that it is meeting the statutory
requirement that 90% of the 1% reservation be distributed to high-need schools?
*A18: If the all of the LEA’s required PFE reservation is used to pay PFE liaisons who are assigned to the
Title I, Part A campuses and provide services on the campuses for parent and family engagement
activities, it is acceptable to count those funds (PFE Campus Liaison Salaries) as meeting the 90%
of the 1% LEA PFE reservation that is required to be distributed to Title I, Part A schools. In this
case, all of the 1% PFE reservation is distributed to the campuses.
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Schoolwide Program
Q1: The Board of Trustees approved a name change for an elementary school. They kept the same
campus number. The only thing that changed was the name. Does the campus have to go
through a schoolwide program transition process?
A1: Since the name of the campus is the only thing that changed, they would not be required to go
through a schoolwide program transition process.
Q2: We have had several LEAs that are reconfiguring their campuses to combine different grade
levels to create new campuses. There are a couple of scenarios that we have seen:
• Multiple campuses that are Schoolwide where grade levels are being reconfigured.
• Multiple campuses that are a mixture of Schoolwide and Eligible, but Not Served that are
being reorganized
o It varies, but sometimes certain grade levels go up to an Intermediate or Middle
School level from an existing elementary campus; or sometimes the LEA expands an
Elementary School to include grades from Intermediate or Middle Schools. We have
also seen where campuses are combined, and then multiple elementary schools are
created.
• What is the best way to handle these situations? Do the “new” campuses need to go
through the process to become Schoolwide?
A2: The campuses would need to go through the process to some extent because there has been a
change in the composition of the student body. However, the time that it would take for the
planning process would all depend on the extent of the reorganization/reconfiguration and how
the collective needs of the student body of the “new” school would be affected. If the LEA
determines, in consultation with the school, that less time was needed to develop and implement
the schoolwide program based on the collective needs of the “new” student body, the LEA will
need to retain documentation to that effect. All documentation to demonstrate compliance for
schoolwide planning must be maintained locally for audit and validation/monitoring purposes.
Documentation of the planning process must include a comprehensive needs assessment, the
inclusion of the required stakeholders in the process, incorporation of the required descriptions
into the Campus Improvement plan, documentation related to parent and family engagement
(PFE) requirements (i.e., school-parent compact and PFE policy), and the provision for an
evaluation of program effectiveness that will inform the next year’s needs assessment and
planning. If the LEA determines that Education Service Center (ESC) training/technical assistance
was part of the reason that less time was needed to develop and implement the schoolwide
program, then the LEA would need to keep such documentation in addition to the documentation
noted above.
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Q3: We have also had questions about how the Education Service Center (ESC) is supposed to
support those campuses who are going through the process of transitioning to
Schoolwide. What are the recommended steps, trainings, etc. that we need to do in support of
the LEA?
A3: The recommended steps and training would center around the comprehensive needs assessment,
the inclusion of the required stakeholders in the process, incorporation of the required
descriptions into the Campus Improvement plan, documentation related to parent and family
engagement (PFE) requirements (i.e., school-parent compact and PFE policy), and the provision for
an evaluation of program effectiveness that will inform the next year’s needs assessment and
planning.
Q4: What is a Title I, Part A schoolwide program?
A4: A Title I, Part A schoolwide program permits a school to use funds from Title I, Part A and other
federal education program funds and resources to upgrade the entire educational program of the
school in order to raise academic achievement for all the students. This contrasts with a Title I,
Part A targeted assistance program, in which Title I, Part A funds are used only for programs that
provide services to eligible children identified as having the greatest need for special assistance.
Q5: What happens if a school that becomes a schoolwide program drops below the initial eligibility
threshold in a subsequent year?
A5: To promote effective, long-term planning, a school can maintain its schoolwide program eligibility
even if it drops below the initial poverty threshold. There is no required redetermination of
schoolwide program status if the campus continues to operate a schoolwide program. Therefore,
a school that becomes a schoolwide campus with 41% poverty can continue its schoolwide
program even if its poverty level falls below 40% in following years, if the campus continues to
meet the general Title I eligibility requirements.
Q6: How does a school become a schoolwide program?
A6: A campus can operate a SW program using Title I, Part A funds if it meets one of the
following criteria:
• The campus has a low-income percentage of 40% or greater based on the school’s
attendance area.
• The campus had a low-income percentage greater than or equal to 40% in a previous year.
• The campus can remain SW in the subsequent year provided the campus is still Title I, Part A
eligible.
• The campus uses feeder pattern to become SW eligible.
• The campus is Title I, Part A eligible, and the LEA has requested and been approved for an
Ed-Flex Waiver through the Consolidated Application to designate the campus SW.
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• The campus was SW in a previous year but is no longer Title I, Part A eligible (This option is
available if the LEA designates the campus for a One-Year Transition. Under this option, the
campus can only be designated SW for one additional year if it does not re-establish an
eligible low-income percentage. This option can only be used once per campus.).
• The campus is not (or no longer) Title I, Part A eligible, but the LEA applies and is approved
for an Ed-Flex Individual Programmatic Waiver that covers Title I, Part A eligibility, as well as
a SW eligibility waiver. Applications for an Ed-Flex Individual Programmatic Waiver are
made outside the eGrants process. Information concerning the application form and the
timeframe for obtaining approval for the waiver are available on the Ed-Flex web site.
Q7: Does Title I have to pay for implementing the three elements in a schoolwide program?
A7: Even though a campus with a schoolwide program must include these elements in its school, it is
not obligated to use solely Title I funds to pay for implementing them. For example, Campus A
becomes a schoolwide program and decides to include most of its federal funds in the schoolwide
program. The campus may design the schoolwide program it wants without worrying about which
funding source will pay for it or even how the federal funds will be used. If the campus as a whole
includes the three elements, it can spend the vast majority of its federal resources as it chooses.
Despite the seemingly equal weight of each of the three elements, schools should not forget the
purpose of a schoolwide program. The comprehensive needs assessment process, campus
improvement planning process, and active parent and family engagement are strategies that can
help a schoolwide program meet its core purpose and should guide a campus towards the overall
purpose—identifying and implementing those instructional strategies that can increase the quality
and amount of learning time for all children to enable them to achieve the challenging State
academic standards.
Q8: May a schoolwide program implement a pull-out approach or operate specific programs that
focus on a particular grade?
A8: If the campus meets the requirements related to the three elements, it can implement any
approach it chooses to meet the needs of its students. In most cases, enabling all children to
master the challenging State academic standards will require comprehensive improvements in the
instructional program that is provided to all students at the campus. But schoolwide program
activities need not be uniform for the whole school. If the school’s comprehensive needs
assessment indicates that certain children can benefit from different types of activities or other
pull-out services for some more intensive instruction, a school certainly should conduct those
activities.
Q9: May a schoolwide program school combine funds it receives under the Individuals with
Disabilities Education Act (IDEA)?
A9: Yes. Under the 1997 reauthorization of IDEA, an LEA may use a per-child share of its IDEA, Part B
funds in a schoolwide program school in which children with disabilities are participating.
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Specifically, the amount of Part B funds that may be combined may not exceed an amount equal
to the number of children with disabilities participating in the schoolwide program multiplied by
the amount of Part B funds per child with disabilities the LEA received. Unlike other federal
education programs whose funds are combined in a schoolwide program, the reauthorized IDEA
only allows flexibility in the use of funds. All other requirements of the IDEA, such as those
concerning the rights and services afforded to individual children with disabilities, must still be
met for children in schoolwide program schools.
Example—
Step 1
Total IDEA, Part B LEA
allocation, excluding indirect
cost
Divided by Total number of
children enrolled in Special
Education in the LEA
Equals Per pupil
amount
$50,000
÷ 107
= $467
Step 2
Per pupil amount
Multiplied by Number of
children in Special Education
enrolled on the SW campus
Equals Total IDEA,
Part B contribution to
the SW campus
program
$467
X 7
= $3,269
Q10: If a schoolwide program campus combines funds from other federal education programs, how
does the campus determine if the intent and purposes of those programs are met?
A10: A schoolwide program campus must meet the intent and purposes of the programs from which
funds are combined in order to ensure that the needs of the intended beneficiaries of those
programs are addressed. Therefore, the school must be able to demonstrate that its schoolwide
program contains enough activities to reasonably address those needs and thus meet the intent
and purposes of each program. However, the campus does not need to document that it used
funds from a particular program to meet the specific intent and purposes of that program.
Consistent with 34 CFR 200.29(c)(1), a schoolwide program school seeking to consolidate its
Migrant Education Program from Title I, Part C must receive prior approval from TEA.
Q11: What happens if a Schoolwide campus chooses to combine funds from some of its federal
programs in its schoolwide program, but does not want to combine funds from other federal
programs?
A11: If the campus, in consultation with the LEA, decides not to combine a specific federal fund source
such as Migrant Education funds on its Schoolwide campus, the campus must then restrict the use
of Migrant funds to Migrant program activities. The LEA must track the program activities and
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expenditures to the Migrant program to show both program and fiscal compliance as it would on a
Targeted Assistance campus.
Q12: If a schoolwide program campus is not required to identify particular children, how can the school
determine whether it is meeting the needs of the intended beneficiaries of the federal
education programs whose funds it has combined?
A12: A schoolwide program campus is not required to identify particular children as eligible to
participate in a schoolwide program because it is not required to focus federal education funds on
particular children. All children are eligible to participate in all aspects of the schoolwide program,
as appropriate. However, in order to know how best to address the needs of all children in the
school, particularly the needs of children who are members of the target population of any
program whose funds are combined, the school by necessity needs to know which children have
special needs because they are, for example, migrant, or limited English proficient, or at risk of
failing to meet the state’s academic standards. The school also must identify children by certain
characteristics in order to disaggregate data on its final state assessment.
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Supplement Not Supplant (SNS) – Title I, Part A
Q1: If an LEA has paid for transportation for homeless and foster care students out of local funds
and now wants to reserve Title I, Part A funds at the LEA level for the same purposes, would it
be considered supplanting?
A1: For Title I, Part A purposes, if the LEA has a valid SNS Methodology or a Statement of Exemption in
place it would not be considered supplanting for the LEA to use Title I, Part A funds to pay for
transportation costs for homeless and foster care students that were previously paid out of local
or state funds.
Q2: Does an LEA apply the traditional presumptions of supplant to Title I, Part A campuses
implementing a Targeted Assistance Program?
A2: No. The Title I, Part A Supplement Not Supplant (SNS) requirements (SNS Methodology or
Statement of Exemption) apply to the Title I, Part A program in its entirety. There are not separate
SNS documentation requirements that depend on whether an LEA has campuses implementing a
Schoolwide Program or a Targeted Assistance Program. The traditional presumptions of supplant
do not exist for the Title I, Part A program.
If an LEA has an SNS Methodology or Statement of Exemption, the LEA has met its SNS
documentation requirement and can use Title I, Part A funds on a Targeted Assistance campus for
students that have been identified to receive such services. As per the ESSA Statute, Section
1115(c)(1), “eligible children are children identified by the school as failing, or most at risk of
failing, to meet the challenging State academic standards on the basis of multiple, educationally
related, objective criteria established by the LEA and supplemented by the school, except that
children from preschool through grade 2 shall be selected solely on the basis of criteria, including
objective criteria, established by the LEA and supplemented by the school.”
Q3: Does Supplement, Not Supplant (SNS) only apply to use of general funds or does it relate to
other grant funds too? For example, if the district uses ESSER funds for additional positions in
2021-2022, would it be supplanting to use Title I, Part A in 2022-2023 to continue paying that
same position?
A3: The ESSER funds are federal funds. Title I, Part A is only required to supplement state and local
funds. The LEA would only need to be concerned with supplanting ESSER funds when federal
funds are included in the SNS provision, such as with Title III, Part A and Rural and Low-Income
Schools.
Q4: How does having an Exemption for the Supplement, Not Supplant Methodology impact funds
reserved at the LEA level?
A4: There is no difference in how reserved funds are viewed. Any State and local funds that are
retained at the LEA level must be used in a Title I neutral manner; and Title I, Part A funds that are
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reserved at the LEA level must be used only for Title I, Part A purposes, as indicated in the LEA’s
approved ESSA Consolidated Federal Grant Application.
Q5: What SNS methodology is used for Title I, Part LEA reservations?
A5: The SNS Methodology for distributing state and local funds to campuses (or valid Statement of
Exemption) meets the SNS requirement for Title I, Part A. For funds that are retained at the LEA
level, the LEA makes the following assurances as part of its methodology or Statement of
Exemption:
• any State and local funds that are retained at the LEA level will be used in a Title I neutral
manner; and
• any Title I, Part A funds that are reserved at the LEA level will be used only for Title I, Part A
purposes, as indicated in the LEA’s approved ESSA Consolidated Federal Grant Application.
Q6: Is it true that the Supplement, Not Supplant rule is no longer in place for ESSA?
A6: No. The Supplement, Not Supplant requirement is still a statutory provision under many programs
included in ESSA. However, the ESSA statute provides a new method of documenting compliance
with the requirement for Title I, Part A. The SNS Methodology requirement for Title I, Part A
states that the SNS requirement is met for Title I, Part A if the LEA has a written Title I-neutral
method for distributing State and local funds to its campuses, or if the LEA has a valid Statement
of Exemption from the Methodology requirement.
Other ESSA programs, such as Title II, Part A and Title IV, Part A, which have an SNS provision in
statute, still follow the traditional way of demonstrating compliance with the SNS
requirement. According to the traditional presumptions of supplanting, the LEA would be
considered to be out of compliance under the following conditions, unless the LEA has
documentation to rebut the presumption:
• Providing Services Required Under State or Local Law;
• Providing Same Services as Those Provided in Prior School Year with State or Local Funds;
or
• Providing the Same Services in Federal and Non-Federal Programs
Q7: Are there exemplar SNS documents we can review?
A7: Section C of the Supplement, Not Supplant Handbook provides examples of SNS Methodologies
and Section F provides templates for the Statement of Exemption and an SNS Methodology. An
LEA is not required to use these templates, but the information and elements contained in the
template must be present in the LEA’s documentation.
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Q8: When we place teachers that are funded out of Title I, Part A funds in a grade level to help with
student academic success, do we need to make sure we are not supplanting? For example, do
we need to make sure that in that grade level we are meeting the 22:1 ratio before placing a
teacher funded out of Title I, Part A in that grade level?
A8: As per the Supplement, Not Supplant Handbook, “The term “supplement, not supplant” has
traditionally meant that federal funds cannot be used to perform a service that would normally be
paid for with state or local funds. The new SNS methodology requirement for Title I, Part A
represents a shift in mindset. For Title I, Part A, LEAs no longer look at whether an individual cost
meets the traditional SNS requirement. Instead, the LEA’s allocation of State and local funds to
campuses is examined as a whole to ensure that Title I, Part A funds are supplemental. The LEA
demonstrates through its SNS Methodology that its distribution of State and local funds to
campuses has been accomplished in a Title I-neutral manner. In other words, the LEA allocates
State and local funds to its campuses without regard to their Title I status. Each campus receives
all of the State and local funds it would otherwise receive if it were not receiving assistance under
Title I. Once that is accomplished, either through a Title I-neutral SNS Methodology or through a
Statement of Exemption, the supplemental requirement for Title I, Part A funds at the campus
level has been met.” In other words, the LEA does not apply the traditional presumptions of
supplanting to Title I, Part A funds and would make determinations about the use of Title I, Part A
funds based on the Comprehensive Needs Assessments and the Campus Improvement Plans.
The Title I, Part A program is a campus-based program and funds should also be distributed to
campuses as per the statutory requirements for ranking and serving Title I, Part A eligible
campuses. Schoolwide program campuses should use their funds based on the results of a
comprehensive needs assessment and what has been included in the campus improvement plan.
As with any use of Title I, Part A funds, LEAs are required to follow the steps and requirements
noted in the Title I, Part A Use of Funds document.
Q9: If a LEA has a Statement of Exemption for the Title I, Part A SNS compliance requirement, can
the LEA pay for a Reading Interventionist out of Title I, Part A Funds that was paid with local
funds in the previous year? (Assuming that it is in the LEA’s CNA, CIP, it's reasonable, necessary,
and allocable etc.)
A9: When documenting compliance with SNS for Title I, Part A, we do not look at the individual activity
level. If the LEA has a valid, written methodology for allocating its state and local funds to its
campuses, or it has a valid Statement of Exemption, the LEA has met the SNS requirement for
Title I, Part A. To determine the allowability of individual Title I, Part A activities, the LEA would
then ensure that it has met the remaining items on the Use of Funds one-pager. The traditional
SNS presumptions of supplanting do not apply to Title I, Part A.
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Targeted Assistance Program
Q1: Can you assist in helping me understand the ESSA language below (Section 1115, Targeted
Assistance campuses)? Does the highlighted language below mean that a district could use
Title I, Part A funds to implement the program described below for all students?
Each targeted assistance program SHALL use methods and instructional strategies to
strengthen the academic program of the school…
• Activities may include expanded learning time, before- and after-school programs,
summer programs and opportunities, a schoolwide tiered model to prevent and address
behavior problems, and early intervening services.
A1: The statutory language related to the bullet you referenced is as follows.
TARGETED ASSISTANCE SCHOOL PROGRAM.—To assist targeted assistance schools and local
educational agencies to meet their responsibility to provide for all their students served under this
part the opportunity to meet the challenging State academic standards, each targeted assistance
program under this section shall—
(2) serve participating students identified as eligible children under subsection (c), including by—
(B) using methods and instructional strategies to strengthen the academic program of the
school through activities, which may include—
(i) expanded learning time, before- and afterschool programs, and summer
programs and opportunities; and
(ii) a schoolwide tiered model to prevent and address behavior problems, and early
intervening services, coordinated with similar activities and services carried out
under the Individuals with Disabilities Education Act (20 U.S.C. 1400 et seq.);
The “shall” refers to serving participating students identified as eligible children with activities
which may include “a schoolwide tiered model to prevent and address behavior problems, and
early intervening services, coordinated with similar activities and services carried out under the
Individuals with Disabilities Education Act (20 U.S.C. 1400 et seq.)”
Since the recommended (“may include”) activity refers to serving participating students identified
as eligible children, it would not be allowable to use Title I, Part A funds to implement this activity
schoolwide for all students in a Targeted Assistance campus.
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Q2: There has been some flexibility granted across federal programs given our current
circumstances. Does any flexibility apply to Title I, Part A Targeted Assistance campuses in
allowing materials purchased with Title I, Part A funds to be used for entire classrooms rather
than the targeted student population that qualify based on pre-determined criteria?
A2: There has not been any flexibility applied to Title I, Part A Targeted Assistance campuses in
allowing materials purchased with Title I, Part A funds to be used for entire classrooms rather than
the targeted student population that qualify based on pre-determined criteria.
Q3: May an LEA and school use Title I, Part A funds to identify at-risk students?
A3: No. It is the responsibility of the LEA and school to identify at-risk students from State or local
sources. After eligible children are identified, Part A funds may be used to identify those most in
need or to identify their specific educational needs. Please note that the definition of “at risk” for
Title I, Part A purposes refers to students being at risk of academic failure and not necessarily to
the “at risk” of dropping out criteria as defined for State Compensatory Education purposes.
Q4: May a school provide services to particular children for less than a full school
year?
A4: A school may serve students who are in greatest need of assistance for only a particular skill for
the period of time it takes the student to master the skill. In other words, if not necessary, a
student need not be a participant for an entire school year.
Q5: May a Targeted Assistance Program choose to serve all the students in a particular grade within
a school?
A5: No. In a Targeted Assistance Program, the school must identify students who are failing or most at
risk of failing to meet the State’s academic achievement standards. This cannot be all of the
students in a grade level.
Q6: Are there any requirements for teachers that are fully funded by Title I, Part A funds on a
targeted assistance campus?
A6: The ESSA Statute Section 1115(d) provides the following requirements related to teachers that are
paid with Title I, Part A funds on a Targeted Assistance Campus, “To promote the integration of
staff supported with funds under this part into the regular school program and overall school
planning and improvement efforts, public school personnel who are paid with funds received
under this part may— (1) participate in general professional development and school planning
activities; and (2) assume limited duties that are assigned to similar personnel who are not so paid,
including duties beyond classroom instruction or that do not benefit participating children, so long
as the amount of time spent on such duties is the same proportion of total work time as prevails
with respect to similar personnel at the same school.”
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Q7: Can a Title I, Part A campus operating a targeted assistance program put on a family
engagement night and invite all campus parents and families?
A7: If the campus is using its Title I, Part A funds for hosting the family engagement night, then it
would only be acceptable for such services to be provided to the families of students identified as
eligible to be served by the Targeted Assistance Program. You would also want to ensure that you
are following your campus written Title I, Part A Parent and Family Engagement Policy.
Q8: Can a Title I, Part A campus operating a targeted assistance program provide the parent
electronic newsletter to all campus parents and families?
A8: If the campus is using its Title I, Part A funds for creating the newsletter and/or sending out the
newsletter, then it would only be acceptable for such services to be provided to the families of
students identified as eligible to be served by the Targeted Assistance Program. You would also
want to ensure that you are following your campus written Title I, Part A Parent and Family
Engagement Policy.
Q9: How specific does a Targeted Assistance Program campus need to be in its campus improvement
plan?
A9: For a targeted assistance campus, the campus will want to make sure that it includes all the parent
and family engagement requirements (campus written parent and family engagement policy) and
any information related to campus Title I, Part A expenditures in its campus improvement plan.
Q10: Does a Targeted Assistance Program campus need to address the specific services provided to
eligible students in its campus improvement plan?
A10: For a targeted assistance campus, the campus will want to include all the specific
services/activities that are funded by the Title I, Part A program.
Q11: Does a Targeted Assistance Program campus need to have Title I, Part A specifically stated in its
campus improvement plan?
A11: For a targeted assistance campus, the campus will want to include Title I, Part A as a fund source
for activities/services that are tied to the campus goals and needs that are being funded with
Title I, Part A funds. LEAs and campuses should include anything and everything that is funded by
Title I, Part A in the case of an audit. All the activities/services funded by Title I, Part A should be
the result of a comprehensive needs assessment of the students eligible to receive Title I, Part A
services.
*Q12: Who determines the criteria for determining which students are to be served in a Targeted
Assistance Program?
*A12: As per ESSA Section 1115(c)(1)(B), the LEA is required to establish the criteria for determining
student eligibility for services on a Targeted Assistance Campus. A campus can supplement the
LEA’s criteria. Eligible children are children identified by the school as failing, or most at risk of
failing, to meet the challenging State academic standards on the basis of multiple, educationally
related, objective criteria, except that children from preschool through grade 2 shall be selected
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solely on the basis of criteria, including objective criteria, established by the local educational
agency and supplemented by the school.
The LEA should include the multiple, educationally related, objective criteria that it uses to
determine eligibility in its LEA Title I, Part A Program Plan/District Improvement Plan. If the
campus supplements the criteria, the campus should include a description of the supplemental
criteria in its Campus Improvement Plan, or the LEA can include it in the LEA Title I, Part A Program
Plan/District Improvement Plan.
The LEA and campus should be able to maintain documentation locally concerning how the
students eligible for Title I, Part A services on a Targeted Assistance Campus met the LEA-
established criteria and, if applicable, any supplemental criteria established by the campus in the
case of an audit and/or random validation monitoring.
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Time and Effort Documentation
Q1: Our LEA is considering using Title I funds to pay a stipend to a principal to be the Title I
coordinator. Does time and effort have to be kept in the case of a stipend?
A1: Time and effort documentation is required for any type of compensation paid with federal funds,
including stipends. A stipend should be paid based on policies and procedures adopted by the
board or local authorities. A good example is a board approving a policy to pay a stipend in the
amount of $1000 for all teachers with graduate degrees. There is a good chance that this
position’s regular salary is paid with local funds, but the stipend will be paid out of federal funds.
The principal must maintain time and effort documentation that describes a policy/reason
adopted by the appropriate authority or the board supporting the stipend for such activities. The
document must be signed and dated by the supervisor authorizing the stipend.
If the principal was paid for extra duty pay outside of the normal working hours, the time and
effort documentation would include a time sheet of extra duties performed and a supplemental
pay agreement approved by the supervisor for provided specific services eligible under the federal
program.
Either way, the time and effort documentation is required.
Q2: If an LEA federal programs director is split-funded from all ESSA programs (i.e., 50% Title I, Part
A; 20% Title II, Part A; 10%Title III, Part A; and 20% Title IV, Part A), is a semi-annual certification
alone acceptable documentation to satisfy time and effort requirements?
A2: Yes, based on the programs listed. If they were also paid out of Title I, Part C then the answer
would be “no,” and they would need to fill out a PAR. No, a personnel activity report (PAR) is
required. Response Revised 06/30/2022
Q3: If you checked to pay for substitute teachers from Title I, Part A in the ESSA Consolidated
Application budget schedule (BS6101 – Payroll Costs), does the LEA need to maintain time and
effort documentation for substitute teachers paid with Title I, Part A funds?
A3: Selecting the checkbox on Part 3 of the BS6101 related to substitutes indicates that the LEA will
use funds to pay for substitute teachers. LEA time and effort documentation is required for any
type of compensation paid with federal funds.
Q4: Since the Title I, Part A program is part of the Ed-Flex program and any position fully funded by
an Ed-Flex program does not require time and effort, do we need to keep time and effort
documentation for the individuals that are 100% funded by the Title I, Part A program?
A4: The Ed-Flex Statewide Administrative Waiver that states the following, “This waiver eliminates the
requirement that charges for salaries and wages be supported by a semi-annual certification that
the employee worked solely on that program for the period covered by the certification. This
waiver is allowable, as long as the employee’s job description clearly states that the employee is
assigned 100 percent to the program or single cost objective.” The Ed-Flex waiver can be used
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instead of time and effort if the employee is 100% funded from the Title I, Part A. The LEA would
need to update job descriptions for its employees to state the position is 100% funded by Title I,
Part A. While not required it is also good practice to list the Financial Accountability System
Resource Guide (FASRG) coding for the employee in the job description and have the employee
review sign and date the new job description.
Q5: Our LEA has reading and math specialists that are funded by 70% State Compensatory Education
(SCE) and 30% Title I, Part A. They all work on a Title I, Part A Schoolwide campus. Although paid
out of 2 separate funds, their duties align with a single cost objective. Can these employees
complete a semi-annual certification, or do they need to complete the monthly time/effort
forms?
A5: The employees can complete a semi-annual certification, certifying under a single cost objective.
Q6: What documentation is required for a teacher that is 100% funded by Title I, Part A on a
campus?
A6: If a teacher is 100% funded by Title I, Part A, it is required that the employee have a job
description for time and effort documentation purposes. It should clearly state that the employee
is assigned 100% to the program or single cost objective. While not required, it is also good
practice to list the Financial Accountability System Resource Guide (FASRG) coding for the
employee in the job description and have the employee review sign and date the new job
description.
The Ed-Flex Statewide Administrative Waiver states the following, “This waiver eliminates the
requirement that charges for salaries and wages be supported by a semi-annual certification that
the employee worked solely on that program for the period covered by the certification. This
waiver is allowable as long as the employee’s job description clearly states that the employee is
assigned 100 percent to the program or single cost objective.” The Ed-Flex waiver can be used
instead of time and effort if the employee is 100% funded from the Title I, Part A. The LEA would
need to update job descriptions for its employees to state the position is 100% funded by Title I,
Part A. While not required, it is also good practice to list the Financial Accountability System
Resource Guide (FASRG) coding for the employee in the job description and have the employee
review sign and date the new job description.
*Q7: How should the LEA document time and effort for substitute teachers who are being paid with
Title I, Part A funds?
*A7: There are two source documents TEA auditors look for when evaluating substitute teacher pay
from a federal grant:
1. Teacher of record – usually the LEAs keep documentation on who needed a sub and when; and
2. Timesheet or comparable record for the time worked.
TEA auditors would not ask for a contract or job description for a substitute teacher.
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*Q8: If an LEA redirects funds via REAP/Funding Transferability from Title II, Part A and/or Title IV,
Part A into Title I, Part A, how should that be described on the job description for employees
paid from Title II, Part A/Title IV, Part A and performing Title I, Part A duties? The job
description is not being used as part of the Ed-Flex waiver for Time and Effort.
*A8: Specific to the job description, it does not need to list the grant the employee is being paid from.
Rather, the description should be an updated list of job duties that align with the Title I, Part A
cost objectives (the description may already provide for this).
*Q9: The LEA has several Title I, Part A Instructional Aides who are funded 80% Title I, Part A and 20%
local. What documentation is needed to satisfy the time and effort requirement?
*A9: Texas has approval from USDE to continue its Ed-Flex waiver authority through the 2023-2024
school year. One of the administrative waivers eliminates the requirement that charges for
salaries and wages be supported by periodic certification if an employee works on a covered
program or single cost objective.
The Ed-Flex covered programs are:
• Title I, Part A
• Title I, Part C
• Title I, Part D
• Title II, Part A
• Title IV, Part A
• Perkins
The employee job description must state the employee is assigned 100% to the program or single
cost objective. One way to tell if the employee is working on a single cost objective is to review
their activities and determine if they could be funded 100% by the federal grant (rather than just
80%). In this case, it does appear they could use the job description as documentation, even
though the employees are split-funded because they are working on a single cost objective.
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Title I, Part A-Specific Training
Q1: We are training our new principals remotely on the Title I, Part A program. To whom will I send
the attestation letters that they sign indicating that they have received the training? Is it an
email or an upload to TEASE/TEAL?
A1: The only “attestation” related to principals is the NCLB principal attestation that the principal was
aware of the Highly Qualified teacher status and para status of all the Title I teachers and
paras. The attestations were kept locally. However, the NCLB requirement for attestations is not
in the ESSA statute and thus is no longer a requirement for LEAs.
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Use of Funds – Title I, Part A
Contracted Services Use of Funds
When determining Title I, Part A use of funds allowability, an LEA/campus should always reference the
Title I, Part A Use of Funds reference document.
Q1: The LEA is wanting to use Title I, Part A funds to contract with the Education Service Center (ESC)
for Effective Schools Framework (ESF) support. Is this allowable if they have addressed it in their
CNA and CIP?
A1: Professional and contracted services necessary to carry out the intent and purpose of Title I, Part A
would be an allowable use of Title I, Part A funds as long as the steps and requirements noted in
the Title I, Part A Use of Funds document are met. The LEA would need to document how the
support received by the ESC for the Effective Schools Framework meets the intent and purpose of
the Title I, Part A program. Additionally, the campus/es benefitting from the services would have
to be Schoolwide Program campuses.
Q2: Is it allowable to use Title I, Part A funds to repair Chromebooks purchased with local funds?
A2: If the LEA has a valid SNS methodology or Statement of Exemption, the use of Title I, Part A funds
to pay for the repairs would be an allowable use of funds, as long as the student device repairs are
for students being served by the Title I, Part A program. As with the use of any Title I, Part A
funds, the campus would need to ensure that the LEA is able to document how the activity meets
the intent and purpose of the Title I, Part A program which is to provide all children significant
opportunity to receive a fair, equitable, and high-quality education, and to close educational
achievement gaps. The LEA will also need to ensure that the activity is identified as a need, noted
in the CIP, and that the use of funds steps and requirements are followed as per the Title I, Part A
Use of Funds document.
The campus would also need to ensure that it is following the LEA’s local policies and procedures
as they relate to the EDGAR requirements.
Q3: Is it allowable for an LEA to use Title I, Part A funds for professional oral or written translation
services?
A3: It is allowable for an LEA to use Title I, Part A funds for professional oral or written translation
services on Title I, Part A campuses if they meet the steps and requirements noted in the Title I,
Part A Use of Funds document.
Q4: Is it allowable to use Title I, Part A funds for contracted services to provide technical assistance
and support related to Title I Comparability requirements?
A4: If your LEA meets all the Title I, Part A use of funds requirements as noted on the Title I, Part A Use
of Funds document, it would be considered allowable to pay a consultant to assist in duties
associated with program administration activities (Title I Comparability) taking into consideration
the following guidance.
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For audit and/or random validation purposes, the LEA would need to keep documentation on file
that supports the funds being charged to Title I, Part A are related to time spent working directly
on Title I, Part A program administration activities and to meet the intent and purpose of the
Title I, Part A program which is to provide all children significant opportunity to receive a fair,
equitable, and high-quality education, and to close educational achievement gaps. The work
conducted by the consultant would be considered program administration activities which would
need to be conducted with funds reserved at the LEA level. The LEA would also need to ensure
that it is in compliance with the procurement threshold (2CFR 200.320) and obligation of funds
(34CFR 76.707) requirements noted in EDGAR.
Q5: Is it allowable to use Title I, Part A funds to purchase online tutoring services for students?
A5: If the campuses are schoolwide campuses, the use of funds for online tutoring is allowable, as long
as the LEA has a valid SNS Methodology or a Statement of Exemption in place. If one or more of
the campuses is Targeted Assistance, the LEA would have to ensure that only students identified
as most in need receive the Title I, Part A services. If one or more of the campuses is a non-Title I
campus, this would not be an allowable use of funds for those campuses. Please refer to the
Title I, Part A Use of Funds document as well. The LEA needs to be able to document how the
activity meets the intent and purpose of the Title I, Part A program which is to provide all children
significant opportunity to receive a fair, equitable, and high-quality education, and to close
educational achievement gaps. The need for this particular use of funds would need to have been
identified in the comprehensive needs assessment and noted in the campus improvement plan.
The LEA would also need to ensure that it is in compliance with the procurement threshold (2CFR
200.320) and obligation of funds (34CFR 76.707) requirements noted in EDGAR.
Q6: After determining that all the Title I, Part A use-of-funds steps and requirements have been met
as per the Title I, Part A Use of Funds document, can an LEA pay for a software program license
at the beginning of the year?
A6: As per the EDGAR FAQ document (Question 7.10 – Page 24), “As long as the subgrantee receives
the full benefit of the subscription (full access to the service) at the beginning of the grant year,
the contract for that grant year may be paid at the beginning of the period of availability. If the
subscription contains items that are not all available at the beginning of the service, such as
completing one level of the software before the next level is available, then you may only pay for
the service that has been invoiced and received during the period of the invoice. In this example,
you could not pay for the entire year of the subscription at the beginning of the grant year
because you have not received the full benefit (full access).”
Q7: May Title I, Part A funds be used to provide training/professional development for instructional
and pupil services personnel not paid with Title I, Part A funds?
A7: The cost of training personnel not paid with Title I, Part A funds is an allowable charge if the
training is specifically related to the Title I, Part A program and designed to meet the specific
educational needs of Title I, Part A participants and supplements, rather than supplants, state and
local training.
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Q8: How would an LEA handle a multi-year contract as it relates to obligation of funds?
A8: The LEA cannot use federal funds to pay for services that have not been rendered. Although the
LEA can obligate the funds for the current year, they cannot be expended until the services have
been received/rendered and within the current grant year dates. If allowed in the LEA’s policies
and procedures, the LEA can prepay services that have not been rendered with other funds (local
or state). When the services are completed, the LEA can then reimburse the local/state fund
accounts with the federal funds.
Q9: Is it an allowable use of Title I, Part A funds for a schoolwide campus to purchase student
electronic device monitoring software?
A9: If the LEA has a valid SNS methodology or Statement of Exemption, the use of Title I, Part A funds
to pay for electronic device monitoring software would be an allowable use of funds, as long as
the student devices are for students being served by the Title I, Part A program. As with the use of
any Title I, Part A funds, the campus would need to ensure that the LEA is able to document how
the activity meets the intent and purpose of the Title I, Part A program. The LEA will also need to
ensure that the activity is identified as a need, noted in the CIP, and that the use of funds steps
and requirements are followed as per the Title I, Part A Use of Funds document.
Q10: In an LEA that has Title I, Part A served campuses and non-Title I, Part A served campuses, is it
allowable use of Title I, Part A LEA reserved funds to purchase a district-wide curricular support
program that will be used to help close the academic achievement gaps for Title I, Part A served
campuses and use state/local resources to fund the program for non-Title I, Part A served
campuses?
A10: USDE has provided the following guidance related to the issue of state/local funds that are
retained for use at the district level:
ESEA section 1118(b)(2) requires an LEA to demonstrate compliance with the supplement, not
supplant requirement by having a methodology that ensures that its allocation of State and local
funds to schools is Title I neutral so that Title I, Part A funds used in Title I schools are
supplemental. There is no similar compliance test for State and local funds reserved for
districtwide activities. However, because the general supplement, not supplant requirement in
ESEA section 1118(b)(1) applies to all State and local funds, an LEA must conduct districtwide
activities supported by such funds in a manner that does not take into account a school’s Title I
status (e.g., by implementing a policy of conducting districtwide activities in a Title I-neutral
manner).
They do give an exception in a case where the state/local funds are used to provide a “Title I-like”
program at non-Title I campuses and Title I, Part A funds are used to provide such a program at
Title I, Part A campuses.
In short, the LEA can’t allocate Title I, Part A funds to non-Title I, Part A campuses; but it could use
Title I, Part A funds reserved at the district level to provide a supplemental curricular support
program (such as described in the question) at its Title I, Part A campuses, and supplemental
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state/local funds that were reserved at the district level to provide a similar program for its non-
Title I campuses.
As with any other Title I, Part A use of funds, the LEA would need to follow the steps and
requirements noted in the Title I, Part A Use of Funds reference document. The LEA could use LEA
reserved funds for Targeted Assistance campuses since they are considered Title I, Part A served
campuses. They would indicate on the PS3101 only the amount of Title I, Part A funds that are
reserved for the activity.
Q11: Is it allowable to use Title I, Part A funds to contract with a community-based organization to
provide academic and enrichment programming for students?
A11: The intent and purpose of the Title I, Part A program is to provide all children significant
opportunity to receive a fair, equitable, and high-quality education, and to close educational
achievement gaps. If the activities/services being provided by the community-based organization
meet the intent and purpose of the Title I, Part A program and such activities/services are based
on the needs identified in the comprehensive needs assessment and documented in the campus
improvement plan, the use of Title I, Part A funds would be allowable as long as the other steps
and requirements noted in the Title I, Part A use of funds reference document have been met.
If the LEA has a contract with the organization and/or rental agreement, it would need to adhere
to the provisions of the contract/agreement and be sure to meet documentation and obligation of
funds requirements if they are using Title I, Part A funds for those purposes.
Q12: Is it allowable to use Title I, Part A funds to contract with an entity to validate transcripts for
students new to the LEA from other countries?
A12: In order for Title I, Part A funds to be used for this activity, the LEA would need to have a valid SNS
Methodology for distributing its state and local funds (or have a valid Statement of Exemption),
and the activity would have to be identified as a need in the Comprehensive Needs Assessment,
be part of the District and/or Campus improvement plan, and meet the intent and purpose of
Title I, Part A. The LEA would also need to ensure that it is following the steps and requirements
for Title I, Part A use of funds, as per the Title I, Part A Use of Funds document.
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Equipment Use of Funds
When determining Title I, Part A use of funds allowability, an LEA/campus should always reference the
Title I, Part A Use of Funds reference document.
Q1: May equipment be purchased with Title I, Part A funds?
A1: Yes. An LEA, however, must determine that—
1) the equipment is reasonable and necessary to effectively operate its Title I, Part A
programs;
2) existing equipment it already has will not be sufficient; and
3) the costs are reasonable.
Q2: May Title I, Part A funds be used to pay the interest on lease-purchase agreements for the
purchase of, for example, computer equipment?
A2: Interest paid or incurred during the grant period for equipment is allowable subject to the
following conditions.
1. The financing is provided (from other than tax or user fee sources) by a bona fide third party
external to the LEA;
2. The assets are used in support of federal awards;
3. Earnings on debt service reserve funds or interest earned on borrowed funds pending payment
of the construction or acquisition costs are used to offset the current period’s cost or the
capitalized interest, as appropriate. Earnings subject to being reported to the Federal Internal
Revenue Service under arbitrage requirements are excludable.
4. LEAs will negotiate the amount of allowable interest whenever cash payments (interest,
depreciation, use allowance, and contributions) exceed the LEA’s cash payments and other
contributions attributable to that portion of real property used for federal awards. Interest paid
in a prior grant period cannot be charged retroactively to the current grant period.
Q3: What procedures govern disposition of equipment purchased with Title I, Part A funds?
A3: The disposition of equipment purchased with Title I, Part A funds is governed by Chapter 34 of the
Code of Federal Regulations, Section 80.32(e).
Q4: When an LEA recovers funds from the sale of equipment or real property purchased with Title I,
Part A funds, may these funds be retained by the LEA or school?
A4: A state’s procedures govern the disposition of Title I, Part A equipment and real property. Texas
applies the provision in 34 CFR 80.32(e) as its state procedures:
When equipment purchased with federal program funds can no longer be used for the originally
authorized purpose or for other activities currently or previously supported by the federal
government, disposition of the equipment will be as follows:
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• Unit cost less than $5,000—Items of equipment with a current per-unit fair market
value of less than $5,000 may be retained, sold, or otherwise disposed of with no
further obligation to TEA.
• Unit cost $5,000 or more—Items of equipment with a current per-unit fair market
value of $5,000 or more may be retained or sold. If the LEA elects to retain the
equipment, it shall purchase the equipment for its fair market value. Market value may
be determined by an independent appraiser, e.g., a vendor for the equipment. If the
LEA elects to sell the equipment, the equipment may be sold to the highest bidder
through the competitive bidding procedure normally used by the LEA to dispose of
surplus property. In either case, the proceeds from the purchase/sale may be credited
to the appropriate federal program’s sub-fund and used to expand that program at the
LEA. If the LEA does not wish to use the proceeds in that program, the proceeds will be
refunded to TEA.
Q5: What options does an LEA have to make maximum use of equipment purchased, in whole or in
part, with Title I, Part A funds.
A5: An LEA has several options to increase flexibility in using Title I, Part A equipment. When an LEA
purchases equipment with Title I, Part A funds, for example, it may share the cost with other
federal, state, or local programs that will also make use of the equipment on a proportional basis.
Likewise, an LEA that wishes to use Title I, Part A equipment in non-Title I, Part A activities may
pay a reasonable user fee to the Title I, Part A program for the portion of time the equipment is
used in non-Title I, Part A activities. Further, an LEA may use Title I, Part A equipment in non-Title I,
Part A activities without paying a user fee or sharing costs in accordance with the standards
described in Q13, below. Additionally, an LEA may take into consideration when it decides its
equipment needs under Title I, Part A whether other equipment—e.g., LEA-funded adult
education equipment used at night—would be available for Title I, Part A use during the day.
Q6: Are there circumstances under which Title I, Part A equipment may be used in non-Title I, Part A
activities without paying a user fee or sharing costs?
A6: Yes, subject to the standards described here. Any equipment purchased with Title I, Part A funds
must be reasonable and necessary to implement a properly designed program for Title I, Part A
participants. The USDE recognizes, however, that under some circumstances, equipment
purchased as part of a properly designed Title I, Part A program may, without constituting an
improper expenditure, be used on a less than full-time basis. If that equipment could be made
available for other educational uses without interfering with its use in the Title I, Part A program
or significantly shortening its useful life, the USDE would have no objection to the non-Title I,
Part A use, given the fact that the equipment would otherwise be idle.
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Other Use of Funds
When determining Title I, Part A use of funds allowability, an LEA/campus should always reference the
Title I, Part A Use of Funds reference document.
Q1: Is it allowable to use Title I, Part A funds to pay for shipping and the distribution costs of the
Texas Home Learning packets to parents of students most in need?
A1: If the campuses are schoolwide campuses, this would not be a problem, as long as the LEA has a
valid SNS Methodology or a Statement of Exemption in place. If one or more of the campuses is
Targeted Assistance, the LEA would have to ensure that only students identified as most in need
receive the Title I, Part A services. If one or more of the campuses is a non-Title I campus, this
would not be an allowable use of funds for those campuses. Please refer to the Title I, Part A Use
of Funds document as well.
Elements of this question are answered in the Federal Funding & Grants COVID 19 FAQ Document
(5/7/2020) published on the TEA website referenced below.
Eligible Uses of Grant Funds Section
2. Can LEAs use federal grant funds to provide hotspots for students without home
Internet access or other costs associated with Learning from Home programs? Updated
April 14, 2020
Many school systems around the state are working to expand wireless hotspot locations in
communities where free commercial Internet services are not otherwise available. Please
document all costs associated with these expenditures, in anticipation that additional
funding streams may become available as Congress continues to authorize financial
support for COVID-19.
In the meantime, there are many sources of funds currently available to be redeployed for
these types of purposes:
ESSA, Title I, Part A served Schoolwide campuses may use their Title I, Part A funds
to provide internet hot spots, technology resources, and other at home learning
costs as long as it is identified in the campus comprehensive needs assessment
(CNA) as a need.
Note: As long as the LEA has the required supplement, not supplant methodology
documented and implemented, there is not a supplanting issue.
ESSA, Title IV, Part A may also be a potential federal fund source. However, Title IV has the
traditional rules of supplant so it is only allowable if the LEA has not previously spent state
or local funds for the same costs this year or in the prior year.
Other state or local funds may also be used for these types of activities, but keep in mind it
may cause a supplant issue for the use of ESSA, Title IV, Part A funds as described above.
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Q2: Title I, Part A allowable use of funds allows for organizational memberships as long as the
membership is in the name of the LEA. However, there are some organizations that do not offer
organizational memberships. We have parent liaisons who want to join an organization for the
purpose of obtaining information for sharing with parents. Would this be allowable under Title I,
Part A?
A2: Costs associated with membership dues or fees for business, technical, and professional
organizations directly related to and necessary to carry out the objectives of the grant are
generally allowable under Title I, Part A as long as the LEA meets the requirements as noted on the
Title I, Part A Use of Funds document.
Q3: Our LEA would like to host SAT college entrance exam camps throughout the year. We have
local funds to host the first three camps. However, is it allowable to use Title I, Part A funds for
an additional boot camp or would this be considered supplanting?
A3: If the campuses are schoolwide campuses, this would not be a problem, as long as the LEA has a
valid Supplement, Not Supplant Methodology or a Statement of Exemption in place. If one or
more of the campuses are Targeted Assistance, the LEA would have to ensure that only students
identified as most in need receive the Title I, Part A services. If one or more of the campuses is a
non-Title I campus, this would not be an allowable use of funds for those campuses. Please refer
to the Title I, Part A Use of Funds document as well which includes the requirements of having this
activity as an identified need in the comprehensive needs assessment and documented in the
campus improvement plan.
Q4: Is it allowable to use Title I, Part A funds to pay for costs associated with the state-required
Reading Academies?
A4: If the LEA has a valid SNS methodology or Statement of Exemption, the use of Title I, Part A funds
to pay for the state required Reading Academies would be an allowable use of funds. Professional
development is an allowable use of funds under Title I, Part A as long as it is being provided for
schoolwide program/targeted assistance program teachers and the use of funds steps and
requirements are followed as per the Title I, Part A Use of Funds document.
Since the inception of ESSA, the method of determining compliance with the Supplement, Not
Supplant requirements for Title I, Part A changed. For Title I, Part A, LEAs are no longer required
to adhere to the traditional presumptions of supplant (of which one traditional presumption
included state requirements). The requirement related to Supplement, Not Supplant for Title I,
Part A is that the LEA must have a valid Supplement, Not Supplant Methodology or a Statement of
Exemption in place. For more information related to the methodology or statement of exemption,
click here to access the most current version of the Supplement, Not Supplant Handbook.
Please note that the traditional presumptions of supplant are still in place for other federal
programs (i.e., including but not limited to Title II, Part A and Title IV, Part A). For a complete list
of federal programs that still take into account the traditional presumptions of supplant, click here
to access the most current version of the Supplement, Not Supplant Handbook.
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Q5: Is it allowable to use Title I, Part A funds to purchase student meals during intersession?
A5: Title I is intended to address the academic needs of children who are not meeting, or most at-risk
of not meeting, challenging State academic standards. Generally, given this purpose, Title I funds
are used for instructional strategies that are designed to improve the academic achievement of
low-achieving students, not for meals.
Having said this, however, the statute recognizes that students may have needs, such as hunger,
that prevent them from being able to take full advantage of the educational program they are
offered. Accordingly, section 1115(e)(2) authorizes a local educational agency (LEA) to use a
portion of its Title I funds, as a last resort, to provide health, nutrition, and other social services
not otherwise available to Title I participating students if the school, if appropriate, has engaged in
a comprehensive needs assessment and established a collaborative partnership with local service
providers and funds are not reasonably available from other public or private sources to provide
such services. Thus, an LEA may use Title I funds to provide breakfast or lunch to those Title I
students that it identifies as needing the meal, provided that this service is reasonable and
necessary to the success of a school’s Title I program; the activity is consistent with the school’s
comprehensive assessment of the academic needs of the Title I children served; and funds for this
service are not otherwise available from other public or private sources for those purposes.
In these limited instances, an LEA would have to demonstrate that it has exhausted all other
sources of funding before it pays for nutrition services with Title I funds. This might include, for
example, checking whether any programs administered by the U.S. Department of Agriculture can
meet the needs of these students. If the LEA ultimately cannot identify another source of funding
for breakfast or lunch for those Title I students in need of this service, then under section
1115(e)(2) it may use some of its Title I funds to address the need.
Q6: Is it allowable to use Title I, Part A funds to pay for the actual cost of insurance for technology
equipment purchased through Operation Connectivity?
A6: The actual cost of insurance for equipment purchased through Operation Connectivity may be
charged as a direct cost to Title I, Part A so long as the insurance costs are not contained in any
other comprehensive casualty insurance that may be held by the LEA. As with any use of Title I,
Part A funds, the LEA would also need to ensure to follow the steps and requirements noted on
the Title I, Part A Use of Funds document.
Q7: Can Title I, Part A funds be used for students in a non-Title I, Part A campus?
A7: Title I, Part A funds can only be used to support Title I, Part A students at Title I, Part A served
campuses (with only 1 exception referenced below). If a campus, based on their campus low-
income percentage, does not meet Title I, Part A eligibility requirements to operate a Schoolwide
Program or Targeted Assistance Program, they are not considered a Title I, Part A campus and thus
students on the campus cannot be served by Title I, Part A funds. The LEA provides TEA with the
campuses served with Title I, Part A funds on the ESSA Consolidated Federal Grant Application –
SC5000 Title I, Part A Campus Selection. Title I, Part A funds can only be used for campuses noted
as operating a Schoolwide Program or Targeted Assistance Program.
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The only exception is related to the LEA reservation for services to homeless students. The ESSA
statute allows for Title I, Part A funds reserved by the LEA for services to homeless students to be
used to support homeless students on all campuses regardless of their Title I status.
Q8: Is it allowable to use Title I, Part A funds to pay for instructional activities for students during
intersession?
A8: If the campuses are Schoolwide campuses, the use of Title I, Part A funds for intersession
instructional activities is allowable as long as the LEA has a valid SNS Methodology or a Statement
of Exemption in place. If one or more of the campuses is Targeted Assistance, the LEA would have
to ensure that only students identified as most in need receive the Title I, Part A services. If one or
more of the campuses is a non-Title I campus, this would not be an allowable use of funds for
those campuses because Title I, Part A funds can only be used to serve Title I, Part A students.
Please refer to the Title I, Part A Use of Funds document. The need for this particular use of funds
would need to have been identified in the comprehensive needs assessment and noted in the
campus improvement plan for the campuses. The LEA would also need to be able to document
that the use of funds meets the intent and purpose of Title I, Part A, which is to provide all
children significant opportunity to receive a fair, equitable, and high-quality education, and to
close educational achievement gaps.
Q9: The LEA is changing website companies and wanted to do a one-time purchase of a component
that is an App. They would like to utilize Title I, Part A funds for this by splitting the cost
between their Title I Schoolwide campuses. It will be used to share information with
parents. Would this type of purchase be allowable if they are able to answer all of the items on
the Title I, Part A Use of Funds document?
A9: The LEA would need to ensure that they are following the steps and requirements for Title I, Part A
use of funds as per the Title I, Part A Use of Funds document. The LEA would specifically need to
be able to document how this use of funds is necessary to carry out the intent and purpose of
Title I, Part A, which is to provide all children significant opportunity to receive a fair, equitable,
and high-quality education, and to close educational achievement gaps. Additionally, the use of
funds would need to have been identified in the comprehensive needs assessment and included in
the campus improvement plan. Title I, Part A funds can only be used to support Title I, Part A
campuses.
If the funds being used for the purchase are from the LEA parent and family engagement (PFE)
reservation, the LEA would also need to ensure that they are following the requirements for PFE
reserved funds which are noted in ESSA Section 1116(a)(3)(D)(i-v) referenced below.
Funds reserved to carry out parent and family engagement activities shall be used to carry out
activities and strategies that are consistent with the LEA’s parent and family engagement policy,
including at least one of the following:
• Supporting schools and nonprofit organizations in providing professional development for LEA
and school personnel regarding parent and family engagement strategies, which may be
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provided jointly to teachers, principals, other school leaders, specialized instructional support
personnel, paraprofessionals, early childhood educators, parents, and family members.
• Supporting programs that reach parents and family members at home, in the community, and
at school.
• Disseminating information on best practices focused on parent and family engagement,
especially best practices for increasing the engagement of economically disadvantaged parents
and family members.
• Collaborating, or providing subgrants to schools to enable such schools to collaborate, with
community-based or other organizations or employers with a record of success in improving
and increasing parent and family engagement.
• Engaging in any other activities and strategies that the LEA determines are appropriate and
consistent with the LEA’s parent and family engagement policy.
Q10: Is it allowable to use Title I, Part A funds to pay for the Texas Success Initiative Assessment
(TSIA) fees for students on Title I, Part A Schoolwide campuses?
A10: The use of Title I, Part A funds for the TSIA is allowable as long as the LEA follows the steps and
requirements for Title I, Part A use of funds as per the Title I, Part A Use of Funds document. The
LEA needs to be able to document how the activity meets the intent and purpose of the Title I,
Part A program which is to provide all children significant opportunity to receive a fair, equitable,
and high-quality education, and to close educational achievement gaps. The use of funds would
need to have been identified in the comprehensive needs assessment and noted in the campus
improvement plan. Additionally, the services could only be provided for students attending
schoolwide campuses as long as the LEA has a valid SNS Methodology or a Statement of
Exemption in place. If a campus is a Targeted Assistance campus, the LEA would have to ensure
that only students identified as most in need receive the Title I, Part A services. If the students
attend non-Title I campuses, this would not be an allowable use of Title I, Part A funds for those
campuses.
Q11: Is it allowable to use Title I, Part A funds to upgrade a culinary arts room to meet industry
standards?
A11: Section 8526 of ESSA states that, no funds under this Act may be used for construction,
renovation, or repair of any school facility. If an upgrade includes construction, renovation, or
repair of any school facility, it would be an unallowable use of Title I, Part A funds.
Q12: Is it allowable to use Title I, Part A funds to upgrade and install stainless steel equipment in the
culinary arts room to meet industry standards?
A12: When determining whether Title I, Part A funds can be used it is always important to ensure that
the use of funds is reasonable and necessary to carry out the intent and purpose of the Title I,
Part A program, which is to provide all children significant opportunity to receive a fair, equitable,
and high-quality education, and to close educational achievement gaps. An LEA would need to be
able to document that the use of funds is reasonable and necessary to meet such intent and
purpose of the Title I, Part A program.
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If the LEA can document that paying for the upgrading and installation of all stainless steel
equipment for student use meets the intent and purpose of the Title I, Part A, that they have
followed the steps and requirements noted on the Title I, Part A Use of Funds document, and that
the need has been identified as a result of the Comprehensive Needs Assessment process and
listed in the Campus Improvement Plan, it would be considered an allowable use of Title I, Part A
funds. Additionally, the use of funds would only be allowed on Title I, Part A Schoolwide
campuses since Title I, Part A funds can only be used to serve Title I, Part A students. It would be
difficult to justify and document such costs on a Targeted Assistance campus.
The LEA should also review any policies and procedures referencing construction, renovation, or
repair of any school facility to ensure that their definitions of such activities do not include
upgrading and installation of equipment because if the definitions do include such activities, it
would be an unallowable use of Title I, Part A funds based on Section 8526 of ESSA.
Q13: We have Title I, Part A campuses that closed at the end of this school year, and they have funds
that they left unspent. It would not be reasonable or necessary to spend these remaining funds
to purchase items for campuses that are closing. May I redistribute these funds to purchase
items for the remaining Title I campuses without violating the Title I, Part A campus allocations
requirements?
A13: Under these circumstances, it would be acceptable to reallocate funds that were remaining from
closed campuses to the remaining campuses. The LEA would need to make sure that they remain
in compliance with the rank and serve requirements for the remaining campuses. If the LEA is not
using within grade-span groupings, the LEA must allocate a per-pupil amount that is equal to or
higher to campuses with higher poverty rates than it allocates to campuses with lower poverty
rates. If the funds are evenly distributed as noted, this should not be a problem since the per-
pupil amounts should have already met the requirements. The LEA would need to document the
reasons for their deviation from the initial campus allocations as they noted in their explanation in
the case of an audit and/or random validation monitoring.
Q14: May Title I, Part A funds be used to pay the cost of renting or leasing privately owned facilities
for instructional purposes or office space?
A14: The cost to rent or lease space in privately owned buildings is allowable if the space is necessary
for the success of the program and space in publicly owned buildings is not available to the
grantee.
Q15: Are maintenance and operation costs such as janitorial services and utility costs allowable
charges?
A15: Maintenance and operation costs are allowable charges to Title I, Part A to the extent that the
costs are not otherwise included in rent or other charges for space, are reasonable and necessary
for the success of the program and are distributed on an equitable basis.
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Q16: May Title I, Part A funds be used to construct or acquire real property?
A16: No. The Title I, Part A statute does not authorize the use of Title I, Part A funds for construction or
acquisition of real property.
Q17: Does this mean that Title I, Part A funds may not be used to buy mobile vans or portable
building or to install wiring for vans or computers?
A17: No. These are permissible uses of Title I, Part A funds. A mobile van or portable building is a piece
of equipment, not real property. Items such as wiring that, for example, make a van operational
are part of the equipment.
Q18: Can Title I, Part A funds pay for student fees associated with the submission of Career and
Technical Education (CTE) certification applications?
A18: Student fees associated with the submission of Career and Technical Education (CTE) certification
applications are allowable under Title I, Part A, as long as the LEA meets the Title I, Part A Use of
Funds requirements as noted on the Title I, Part A Use of Funds document. The use of funds
would need to have been identified in the comprehensive needs assessment and noted in the
campus improvement plan.
Q19: Can LEAs reserve Title I, Part A funds for services to homeless students for certification fees that
a student will incur at the end of a certification course/program?
A19: It is an allowable use of Title I, Part A funds reserved at the LEA level for Services to Homeless
Students to pay for certification fees a student experiencing homelessness will incur at the end of
a certification course/program. As with any use of Title I, Part A funds, the LEA would need to
follow the steps and requirements noted in the Title I, Part A Use of Funds document.
Two principles govern the use of Title I, Part A funds to provide such services to homeless
students. First, the services must be reasonable and necessary to assist homeless students to take
advantage of educational opportunities. (ESEA section 1113(c)(3)(A); 2 CFR § 200.403(a)). Second,
Title I, Part A funds must be used only as a last resort when funds or services are not available
from other public or private sources, such as the USDA’s National School Lunch Program and
Breakfast Program, public health clinics, or local discretionary funds (sometimes provided by the
PTA) used to provide similar services for economically disadvantaged students generally. (See
ESEA section 1115(e)(2)).
Q20: Our district has used a TEA Use of Funds Questionnaire in the past for purchases over $1000 as a
best practice. Is the use of this form still a requirement for Title I, Part A? I have not found it on
your website. Please advise.
A20: TEA requires that an LEA follow the steps and requirements for use of Title I, Part A funds that are
identified in the Title I, Part A Use of Funds document for all expenditures regardless of dollar
amount. There is not a specific form that is required. There are some EDGAR-related expenditure
forms that can be found on the TEA Forms for Prior Approval, Disclosure, and Justification
webpage.
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Q21: Where can we find the form that TEA uses to determine if an expenditure/activity is allowable
(i.e., for Field Trips)?
A21: TEA requires that an LEA follow the steps and requirements for use of Title I, Part A funds that are
identified in the Title I, Part A Use of Funds document for all expenditures. There are some
EDGAR-related expenditure forms that can be found on the TEA Forms for Prior Approval,
Disclosure, and Justification webpage.
Q22: What guidance is available related to providing “light meals” using Title I, Part A Parent and
Family Engagement (PFE) funds reserved at the LEA level or on a campus?
A22: As per the most current Budgeting Costs Guidance Handbook, “The following costs are allowable:
• Food necessary to conduct nutrition education programs for parents
• Parent involvement activities in which refreshments are necessary to encourage participation
or attendance by parents, such as in low-income areas, and thus meet program objectives.
Full meals for parents or students are unallowable for these purposes under any circumstances.
Expenditures must be reasonable in cost, necessary to accomplish program objectives, and an
integral part of the instructional program.”
Q23: What is the definition of “nutritional” when it comes to providing snacks with Title I, Part A
funds?
A23: There is no specific guidance on the definition of “nutritional.” However, the LEA can use the
Smart Snack standards that have been established by the US Department of Agriculture. The
following website provides information about smart snacks: https://www.fns.usda.gov/cn/tools-
schools-focusing-smart-snacks.
Q24: Is it allowable to use Title I, Part A funds to assist schools in identifying and serving gifted and
talented students which includes the following activities: a testing program to identify students,
GT curriculum, pay a teacher working with GT students, extension program during the school
day, and general supplies for GT students?
A24: All the items listed would be an allowable use of Title I, Part A funds on a schoolwide program
campus as long as the LEA/campus ensures that it is following the steps and requirements for
Title I, Part A use of funds as per the Title I, Part A Use of Funds reference document. Specifically,
the use of funds would need to have been identified in the comprehensive needs assessment and
noted in the campus improvement plan. The LEA/campus would also need to be able to document
how this use of funds meets the intent and purpose of Title I, Part A, which is to provide all
children significant opportunity to receive a fair, equitable, and high-quality education, and to
close educational achievement gaps.
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Q25: For an LEA that is running a summer school program as an intervention for students to pass their
STAAR assessments, can they use Title I, Part A funds to pay for students who are out-of-district
students? Examples of students would include students visiting for the summer or students who
attend charter schools.
A25: In the scenario described above, you would have to limit the non-district or non-Title I students to
less than 5-10% of the total participants and ensure the non-district or non-Title I students are not
taking time in instruction, Q&A, or discussions away from the Title I students.
Program Income:
Any tuition paid is generating program income from the Title I, Part A funds. The LEA would have
to reduce its Title I, Part A allocation by the amount of program income generated unless the LEA
files a form with TEA for program income.
The LEA must have prior approval from TEA to add this program income back to its Title I, Part A
program (creates a larger Title I, Part A program). Any Title I, Part A student in the district could
attend the summer school program without tuition. Tuition paid by non-district students or non-
Title I students is considered program income.
The non-district students should be charged the full cost of their seat in the summer school.
Teacher’s students (teacher kids) should be charged the same way if they are not Title I students
in the LEA.
Teacher’s student and out-of-district student registration should only be opened after all in-
district Title I students have had the opportunity to register, followed by in-district non-Title I
students; otherwise, the LEA is planning for program income which becomes profit. Profit is
strictly prohibited by federal regulations.
Q26: Is it allowable to use Title I, Part A funds to purchase additional lunches and breakfasts for
Title I, Part A students?
A26: Title I, Part A is intended to address the academic needs of children who are not meeting, or most
at-risk of not meeting, challenging State academic standards. Generally, given this purpose, Title I,
Part A funds are used for instructional strategies that are designed to improve the academic
achievement of low-achieving students, not for meals.
Having said this, however, the statute recognizes that students may have needs, such as hunger,
that prevent them from being able to take full advantage of the educational program they are
offered. Accordingly, section 1115(e)(2) authorizes a local educational agency (LEA) to use a
portion of its Title I funds, as a last resort, to provide health, nutrition, and other social services
not otherwise available to Title I participating students if the school, if appropriate, has engaged in
a comprehensive needs assessment and established a collaborative partnership with local service
providers and funds are not reasonably available from other public or private sources to provide
such services. Thus, an LEA may use Title I funds to provide an extra breakfast or lunch to those
Title I students that it identifies as needing the additional meal provided that this service is
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reasonable and necessary to the success of a school’s Title I program; the activity is consistent
with the school’s comprehensive assessment of the academic needs of the Title I children served;
and funds for this service are not otherwise available from other public or private sources for
those purposes.
In these limited instances, an LEA would have to demonstrate that it has exhausted all other
sources of funding before it pays for nutrition services with Title I funds. This might include, for
example, checking whether any programs administered by the U.S. Department of Agriculture can
meet the needs of these students. If the LEA ultimately cannot identify another source of funding
for the second breakfast or lunch for those Title I students in need of this service, then under
section 1115(e)(2) it may use some of its Title I funds to address the need.
Q27: An LEA is considering budgeting a large amount of Title I, Part A funds for out-of-state travel.
How does the LEA determine if the amount is reasonable and necessary?
A27: As per the Program Guidelines 2022-2023 ESSA Consolidated Federal Grant Application, out-of-
state travel costs are allowable Title I, Part A expenditures; however, they should be minimal,
reasonable and necessary to meet the intent and purpose of the Title I, Part A program, which is
to provide all children significant opportunity to receive a fair, equitable, and high-quality
education, and to close educational achievement gaps. Grantees must retain documentation that
participation of an individual in a conference is necessary for the project. Travel costs are
allowable, as long as the expenses for transportation, lodging, subsistence, and related items are
only incurred by employees on official business of the grantee and follow the grantee’s regular
business operations and written travel policy. The LEA should retain travel documentation locally
as noted in the Budgeting Costs Guidance Handbook, so that such documentation may be
provided to the LEA’s independent auditor or to TEA monitors if the LEA is selected for a review.
The LEA should take the following into consideration when deciding to use Title I, Part A funds for
out-of-state travel:
• As with any use of Title I, Part A funds, the LEA would need to follow the steps and
requirements noted in the Title I, Part A Use of Funds document.
• As per the Budgeting Costs Guidance Handbook, grant funds may not be used for out-of-
state training when the same type and quality of training is available in state.
• The LEA is aware that “minimal” is subject to interpretation by the LEA’s independent
auditor or TEA monitor, and the LEA should be prepared to justify that the expenditure is
considered to be “minimal” as per its local policies and procedures.
• As per the Program Guidelines 2022-2023 ESSA Consolidated Federal Grant Application,
travel costs for officials, such as the executive director, superintendent, or board members,
may not be funded under Title I, Part A until further guidance is available from USDE.
If the LEA plans on using grant funds for out-of-state travel, they are required to complete the
appropriate TEA justification form(s) and retain the documentation at the local level. The LEA must
keep and maintain the form(s) so that it may be provided to the LEA’s independent auditor or to
TEA monitors if the LEA is selected for a review.
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Q28: Can Title I, Part A funds be used to purchase a marquee or similar signage for a campus?
A28: The intent and purpose of the Title I, Part A program is to provide all children significant
opportunity to receive a fair, equitable, and high-quality education, and to close educational
achievement gaps. It would be difficult to justify and document that this type of use of Title I,
Part A funds is reasonable and necessary to meet the intent and purpose of Title I, Part A.
Q29: Is it allowable use of Title I, Part A funds to pay mileage for LEA/campus Title I, Part A staff
attending one-day workshops that meet the intent and purpose of the Title I, Part A program?
A29: As with any use of the Title I, Part A funds, the campus would need to ensure that they are
following the steps and requirements for use of Title I, Part A funds that are referenced in the
Title I, Part A Use of Funds reference document. Although using Title I, Part A funds to pay for
travel costs associated with Title I, Part A related travel would be allowable if the steps and
requirements for use of funds are met, the LEA would need to follow its local policies and
procedures to determine if it is permissible to reimburse an employee for mileage for a one-day
workshop.
Q30: Is it allowable for an LEA to use Title I, Part A funds to pay for the costs associated with travel
(registration, airfare, lodging, meals, etc.) for 12 LEA-level administrators to attend an out-of-
state national conference?
A30: Since the positions you reference are LEA-level positions, the funds used would have to be Title I,
Part A LEA-reserved funds. It would be difficult to connect that activity with an authorized use of
Title I, Part A LEA-reserved funds noted below. The newly released US Department of Education
guidance on Within-LEA Allocations references the following authorized use of Title I, Part A LEA-
reserved funds.
In addition to the required Title I, Part A reservations, an LEA, at its discretion, may reserve funds
for:
• Children in local institutions for delinquent children and neglected or delinquent
children in community-day programs (ESEA section 1113I(3)(A)(iii); 34 C.F.R. §
200.77(a)(3));
• Financial incentives and rewards to teachers who serve students in Title I schools
identified for comprehensive support and improvement or implementing targeted
support and improvement plans under section 1111(d) of the ESEA for the purpose
of attracting and retaining qualified and effective teachers, in an amount that does
not exceed five percent of the LEA’s total Title I allocation (ESEA section 1113(c)(4);
34 C.F.R. § 200.77(b));
• Administration of Title I programs for public school children, including the option of
paying for variations in personnel costs, such as seniority pay differentials or fringe
benefit differentials, as LEA-wide administrative costs, rather than as part of the
funds allocated to schools (34 C.F.R. § 200.77(e)); and
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• Other authorized activities, such as early childhood education, school
improvement, and coordinated services. (ESEA section 1113(c)(5); 34 C.F.R. §
200.77(f)).
Additionally, Title I, Part A LEA-reserved funds must be used to support Title I, Part A served
campuses. If the positions provide support and leadership across the LEA and the LEA has non-
Title I, Part A served campuses, it would be difficult to justify this use of funds as reasonable and
necessary to carry out the intent and purpose of the Title I, Part A program.
Please refer to the information from the following documents related to Out-of-State Travel.
Program Guidelines – 2022-2023 ESSA Consolidated Federal Grant Application – Title I, Part A
Out-of-state travel costs are allowable; however, they should be minimal, reasonable, and
necessary to meet the intent and purpose of the Title I, Part A program. LEAs must retain
documentation that participation of an individual in a conference is necessary for the project.
Travel costs are allowable, as long as the expenses for transportation, lodging, subsistence, and
related items are only incurred by employees on official business of the grantee and follow the
grantee’s regular business operations and written travel policy. If you plan on using Title I, Part A
funds for out-of-state travel, you will be required to complete the appropriate TEA justification
form(s) and retain the documentation at the local level. You must keep and maintain this form so
that it may be provided to your independent auditor or to TEA monitors if your LEA is selected for
a review.
TEA Budgeting Costs Guidance Handbook
Unallowable Other Operating Costs (6400)
Grant funds may not be used for the following:
• Out-of-state training when the same type and quality of training is available in state
Q31: If an LEA transfers 100% of its Title II, Part A or Title IV, Part A funds through funding
transferability into the Title I, Part A program, can those funds be used for Title I, Part A served
and non-Title I, Part A served campuses in an LEA?
A31: The funds become Title I, Part A funds, so they can only be used for Title I, Part A served
campuses, unless they are to be used to provide services to Homeless Children & Youth and/or
Children in Local Institutions for Neglected Children.
Q32: Is it allowable use of Title I, Part A funds to pay for costs associated with a Title I, Part A field trip
that was canceled?
A32: It would be unallowable to use Title I, Part A funds to pay for costs associated with a Title I, Part A
field trip that was canceled because such use does not provide benefit to the program and doesn’t
meet the intent and purpose of the Title I, Part A program, which is to provide all children
significant opportunity to receive a fair, equitable, and high-quality education, and to close
educational achievement gaps.
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*Q33: Is it allowable use of Title I, Part A funds to purchase a program that sends out age-appropriate
books to students up to 3 years old who are in the LEA? The books come with questioning
stems for parents to assist them in learning how to read with their child and what types of
questions to ask. The LEA would be doing this to try and increase students' exposure to literacy
prior to enrolling in their preschool program.
*A33: Table 1 (Page 10) of the USDE Non-Regulatory Guidance on early learning has a chart that that
describes several ways in which Title I, Part A funds may be used to support preschool programs.
The LEA would need to be sure that the preschool students served are residing in the attendance
area of a schoolwide campus, or if the students reside in the attendance area of a targeted
assistance campus that they are identified according to the LEA’s criteria as at risk of failing to
meet the State’s academic achievement standards when they reach school age.
The students served in such preschool programs should be reported at the end of the year on the
PR1000 as students (ages 0-2) or students (ages 3-5, not reported in PEIMS).
As with any Title I, Part A activity, the LEA must ensure that it addresses a need that has been
identified in the Comprehensive Needs Assessment, is included in the District and/or Campus
Improvement Plan, and meets the other items listed in the Title I, Part A Use of Funds document.
*Q34: How does an LEA determine whether a use of Title I, Part A funds is considered reasonable and
necessary?
*A34: Page 19 of the TEA General and Fiscal Guidelines provides an explanation of “Reasonable and
Necessary” that an LEA would use to determine allowability. It would be up to the LEA to maintain
documentation to demonstrate that such costs were reasonable and necessary in the case of an
audit. In the event of an audit, TEA or audit staff would make the final determination concerning
whether the documentation is sufficient to demonstrate compliance.
*Q35: Is it an allowable use of Title I, Part A funds to purchase virtual reality equipment that will allow
students to explore and be exposed to instructional activities through virtual reality?
*A35: If the campuses using the devices are Schoolwide campuses, the use of Title I, Part A funds for
purchasing virtual reality devices is allowable, as long as the LEA has a valid SNS Methodology or a
Statement of Exemption in place. If one or more of the campuses is Targeted Assistance, the LEA
would have to ensure that only students identified as most in need of services were benefiting
from the equipment. If one or more of the campuses is a non-Title I campus, this would not be an
allowable use of funds for those campuses because Title I, Part A funds can only be used to serve
Title I, Part A students.
The use of funds would need to be in accordance with the Title I, Part A Use of Funds Reference
Document. The need for this particular use of funds would need to have been identified in the
comprehensive needs assessment and noted in the campus improvement plan for the campuses.
The LEA would also need to be able to document that the use of funds meets the intent and
purpose of Title I, Part A, which is to provide all children significant opportunity to receive a fair,
equitable, and high-quality education, and to close educational achievement gaps. Additionally,
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the cost of the devices would need to be considered reasonable and necessary to meet the intent
and purpose of the Title I, Part A program.
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Payroll/Personnel Use of Funds
When determining Title I, Part A use of funds allowability, an LEA/campus should always reference the
Title I, Part A Use of Funds reference document.
Q1: If our LEA has determined through the needs assessment process that additional focus is needed
on early literacy and parental involvement strategies, is it possible to fund a Director or Program
Coordinator for early literacy or parental involvement from Title I, Part A funds?
A1: Based on the job duties and responsibilities associated with the position of Director or Program
Coordinator, the position could be considered a direct program cost or a direct administrative
cost. Additional information about such costs can be found in the ESSA Consolidated Application
Instructions (BS6001 Section). Such costs are generally allowable under Title I, Part A as long as
the LEA meets the Title I, Part A Use of Funds requirements as noted on the Title I, Part A Use of
Funds document. Additionally, if the position is an LEA-level position, it would need to be
budgeted as funds reserved at the LEA level.
Q2: If we are going to be running a district-wide summer school for students that are failing, do all
students have to be from Title I campuses in order to pay the teachers with Title I, Part A funds?
A2: The basic way in which an LEA should determine whether certain activities are allowable uses of
Title I, Part A funds has not changed. Title I-funded summer school needs to be for Title I eligible
students. Which would mean that the program for failing students from non-Title I campuses
would be paid with SCE funds. The LEA would need to ensure that they retain documentation
showing this in the case of an audit or random validation monitoring review. The LEA should refer
to the items listed in the Title I, Part A Use of Funds document and ascertain whether the LEA is in
compliance.
Per the “COVID-19 AND FEDERAL GRANT FUNDS: FREQUENTLY ASKED QUESTIONS,” Use of Funds
Section, Question 6:
“LEAs will receive all flexibilities available to TEA in the use of their federal grant funds.
Information on stimulus funding for education is expected in the next 30 days to address
COVID-19 needs; therefore, we do not anticipate significant changes to how you expend
your current federal grant funds unless the needs of your students and school communities
change. After you update your comprehensive needs assessment, you may consider
changes to the planned uses of your federal grant funds. Refer to the When to Amend
guidance document and submit amendments (by email or eGrants only) when necessary.
District’s planning process for the next school year may also need to be altered. TEA will be
flexible in compliance reviews if you document your circumstances and try to meet the
intent of the law as best as you can at the time.”
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Q3: Our LEA has a Parent Engagement Specialist that is 50% funded from the district reservation for
parent engagement. The specialist, while not specifically assigned to any one campus, facilitates
the compacts, policies, and parent engagement activities at each of the campuses. Can the
funding for the specialist remain at the LEA level, or should the specialist be split-funded across
each of the campuses?
A3: If the employee is providing LEA-specific PFE responsibilities, the time the employee spends on
such responsibilities would be considered district reservation time. If the employee is providing
Campus-specific PFE responsibilities, the time the employee spends on such responsibilities would
be considered at the campus level. Additionally, the LEA would need to ensure that it is following
LEA policies and procedures related to the classification of employees (LEA vs. campus). The LEA
would need to retain detailed documentation in case of an audit or random validation monitoring
review.
Q4: Can we pay a current employee for contracted services (6200) out of Federal Funds (Title I) for
leading professional development outside of her normal contract days or would this be an Extra-
Duty Pay Agreement and be paid out of 6100 Salaries?
A4: Professional development is an allowable use of funds under Title I, Part A as long as it is being
provided for Title I, Part A teachers and the use of funds steps and requirements are followed as
per the Title I, Part A Use of Funds document. The LEA would also need to ensure it is compliant
with the SNS requirements associated with Title I, Part A. For Title I, Part A, the LEA would meet
the SNS requirement by having a valid SNS methodology or Statement of Exemption.
As far as the method used to pay for the services, the LEA would need to follow its local policies
and procedures related to employee compensation in determining how to compensate the
employee for providing professional development services.
Q5: Is it allowable to provide incentive pay out of Title I, Part A to non-STAAR teachers (K-6),
Instructional Coach, Interventionist and an Assistant Principal?
A5: The LEA would need to ensure that it is following the steps and requirements for Title I, Part A use
of funds as per the Title I, Part A Use of Funds document. The LEA would specifically need to be
able to document that this use of funds meets the intent and purpose of Title I, Part A, which is to
provide all children significant opportunity to receive a fair, equitable, and high-quality education,
and to close educational achievement gaps. Providing incentive pay to the individuals listed might
not meet the intent and purpose of the law. It would be advisable that the LEA pay for its STAAR
teachers out of Title I, Part A funds because that would be more in line with the intent and
purpose and use local funds to pay for their non-STAAR teachers and the other administrators
noted. Additionally, the use of funds would need to have been identified in the comprehensive
needs assessment.
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Q6: The district has selected to use a majority of its Title I, Part A funds to pay for a district-wide
Curriculum director. The responsibilities include managing the ESSA program and provide
curriculum support K-12. The district does qualify for an SNS exemption. They can answer yes
questions outlined on the “Use of Funds” page. Would this be allowable with Title I, Part A
funds?
A6: If the LEA meets all the Title I, Part A use of funds requirements, it would be considered allowable
to pay the salary of a district-wide Curriculum Director taking into consideration the following
guidance. For audit and/or random validation purposes, the LEA would need to keep
documentation on file that demonstrates that the time and effort requirements are met and
documentation that supports the funds being charged to Title I, Part A are related to time spent
working directly on Title I, Part A activities. It would also be advisable to note the Title I, Part A
duties in the job descriptions for audit and/or random validation purposes. Additionally, if the LEA
has any non-schoolwide campuses, this is a difficult thing to justify. The curriculum is to the
benefit of all the LEA’s students.
The LEA should also consider that the time spent on program administration activities would be
considered activities to be conducted with reserved funds. If the employee is providing LEA-
specific Title I, Part A responsibilities, the time the employee spends on such responsibilities would
be considered district reservation time. If the employee is providing campus-specific Title I, Part A
responsibilities, the time the employee spends on such responsibilities would be considered at the
campus level. Additionally, the LEA would need to ensure that it is following LEA policies and
procedures related to the classification of employees (LEA vs. campus). The LEA would need to
maintain detailed documentation in case of an audit or random validation monitoring review.
Q7: We are working on an idea to help parents get their students registered for Pre-Kindergarten
remotely. Online registration can be challenging for some parents, and we typically have a large
group come into our early childhood education centers to get help filling out documents. The
assistant typically sits with parents and does the online registration with the parents. In
preparing for the possibility that we may not be able to do this in person, we want to set up a
helpline for parents to call in and get assistance with registration. Can the funds from the Title I
Pre-K district reservation be used to pay teacher assistants extra-duty pay to assist parents with
this process?
A7: Costs associated with providing parents with support for navigating school systems and processes
are allowable under Title I, Part A as long as the LEA meets the requirements noted on the Title I,
Part A Use of Funds document. The use of funds would need to have been identified in the
comprehensive needs assessment and noted in the campus improvement plan.
If all the students will be attending Title I, Part A schoolwide campuses, it shouldn’t be an
issue. On a targeted assistance campus, services should only be provided to students identified as
most in need to receive the Title I, Part A services. The only potential issue is providing parent
support for non-Title I campuses as it would be an unallowable use of funds for those campuses.
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Q8/Q9/Q10 Scenario: We have 2 district Home/School Liaisons who are paid on a 187-day contract out
of our ESSA fund allocation. Throughout the school year, they are also reimbursed for mileage when
using their personal vehicles to address student/family needs. Recently, they submitted mileage
reimbursement forms for days that they were not officially on contract indicating that they were still
working to address student needs throughout the summer.
Q8: Can they be reimbursed for activities when they were not officially on contract from
federal funds?
A8: If the employees were not authorized to be paid extra-duty pay outside of the contract, the
district is not obligated to pay for extra-duty pay and/or mileage. However, if the district
determines that services were allowable and allocable to the grant and wants to pay for
mileage, the reimbursements must be supported by documentation that at a minimum
should include an actual mileage log for each trip contemporaneously maintained by the
claimant, list of services provided during the trip, dates of services, locations where
services were provided and the list of participants who received services on each trip and
in accordance with the district’s policies and procedures regarding mileage
reimbursement. Generally, such mileage reimbursement is considered reasonable and
necessary when the employee is performing their duties that meet the intent and purpose
of the Title I, Part A program considering that all the steps and requirements for use of
Title I, Part A funds are met (including that it is based on an identified needs in the
comprehensive needs assessment; and documented in the campus improvement plan).
Q9: In order to justify that expense, should we also request timesheets and pay them
extra-duty to pay for the services performed using their personal vehicle?
A9: If the employees were not authorized to be paid extra-duty pay outside of the contract, the
district is not obligated to pay for extra-duty pay and/or mileage. However, if the district
determines that services were allowable and allocable to the grant and wants to pay
extra-duty pay, it must be supported by documentation and in accordance with the
district’s policies and procedures regarding extra-duty pay. Generally, such extra-duty pay
is considered reasonable and necessary when the employee is performing their duties that
meet the intent and purpose of the Title I, Part A program considering that all the steps
and requirements for use of Title I, Part A funds are met (including that it is based on an
identified needs in the comprehensive needs assessment; and documented in the campus
improvement plan).
Q10: What documentation would/should be required to comply with regulations.
A10: The LEA would need to maintain the following documentation locally: payroll, extra-duty
pay, an actual mileage log for each trip contemporaneously maintained by the claimant,
list of services provided during the trip, dates of services, locations where services were
provided and the list of participants who received services on each trip in accordance with
the district’s policies and procedures regarding mileage reimbursement and Title I, Part A
Use of Funds (including that it meets the intent and purpose of Title I, Part A; is based on
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an identified needs in the comprehensive needs assessment; and documented in the
campus improvement plan) documentation.
Q11: Is it allowable to leverage Title I, Part A funds to pay for District Coordinator for School
Improvement (DCSI) support services provided by an Education Service Center (ESC) for
campuses with an “F” rating identified in need of intervention by the state? Since the services
provided are state required, would this use of funds be considered a supplant?
A11: Professional and contracted services necessary to carry out the intent and purpose of Title I, Part A
would be an allowable use of Title I, Part A funds as long as the steps and requirements noted in
the Title I, Part A Use of Funds document are met. The LEA would need to document how the
support received by the ESC for the DCSI services meets the intent and purpose of the Title I,
Part A program. Additionally, the campus/es benefitting from the services would have to be
Title I, Part A Schoolwide Program campus/es.
Since the inception of ESSA, the Supplement, Not Supplant requirements for Title I, Part A
changed. For Title I, Part A, LEAs are no longer required to adhere to the traditional presumptions
of supplant (of which one traditional presumption included state requirements). The requirement
related to Supplement, Not Supplant for Title I, Part A is that the LEA must have a valid
Supplement, Not Supplant Methodology or a Statement of Exemption in place. For more
information related to the methodology or statement of exemption, click here to access the most
current version of the Supplement, Not Supplant Handbook.
Please note that the traditional presumptions of supplant are still in place for other federal
programs (i.e., including, but not limited to Title II, Part A and Title IV, Part A). For a complete list
of federal programs that still take into account the traditional presumptions of supplant, click here
to access the most current version of the Supplement, Not Supplant Handbook.
Q12: Is it allowable to use Title I, Part A funds to pay for the salary (100%) of the District Coordinator
for School Improvement (DCSI)?
A12: If the LEA meets all the Title I, Part A use of funds requirements (including documenting an
identified need as a result of a comprehensive needs assessment and documenting the activity in
the campus improvement plan), it would be considered allowable to pay the salary of the DCSI,
taking into consideration the following guidance. For audit and/or random validation purposes,
the LEA would need to keep documentation on file that demonstrates that the time and effort
requirements are met and documentation that supports the funds being charged to Title I, Part A
are related to time spent working directly on activities that meet the intent and purpose of the
Title I, Part A program. It would also be advisable to note the Title I, Part A duties in the job
description for audit and/or random validation purposes. However, if the LEA has any non-
schoolwide campuses, this is a difficult thing to justify because school improvement is to the
benefit of all the LEA’s students.
The LEA should also consider that the time spent on program administration activities would be
considered activities to be conducted with LEA reserved funds. If the employee is providing LEA-
specific Title I, Part A responsibilities, the time the employee spends on such responsibilities would
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be considered district reservation time. If the employee is providing campus-specific Title I, Part A
responsibilities, the time the employee spends on such responsibilities would be considered at the
campus level. Additionally, the LEA would need to ensure that it is following LEA policies and
procedures related to the classification of employees (LEA vs. campus). The LEA would need to
maintain detailed documentation in case of an audit or random validation monitoring review.
Q13: Is it allowable to use Title I, Part A funds to pay for the salary of an aide to assist a school nurse
with assessing student illness to prevent students from having to lose instructional time from
waiting on the nurse?
A13: It would be difficult to justify and maintain documentation demonstrating how this use of funds is
necessary to carry out the intent and purpose of Title I, Part A, which is to provide all children
significant opportunity to receive a fair, equitable, and high-quality education, and to close
educational achievement gaps.
Q14: Is it allowable to use Title I, Part A funds to pay a receptionist to transfer phone calls to teachers
after regular school hours?
A14: It would be difficult to justify and maintain documentation demonstrating how this use of funds is
necessary to carry out the intent and purpose of Title I, Part A, which is to provide all children
significant opportunity to receive a fair, equitable, and high-quality education, and to close
educational achievement gaps.
Q15: Would it be an allowable expense to pay for the educational aid certificate for the parent
liaison?
A15: Paying for the costs associated with a paraprofessional meeting highly qualified requirements is
allowable under Title I, Part A as long as the LEA meets the Title I, Part A Use of Funds
requirements as noted on the Title I, Part A Use of Funds document.
Q16: Is it allowable to use Title I, Part A funds to pay an ESL teacher who works with students on
language building skills?
A16: The LEA would need to ensure that it is following the steps and requirements for Title I, Part A use
of funds as per the Title I, Part A Use of Funds document. The LEA needs to be able to document
how the activity meets the intent and purpose of the Title I, Part A program which is to provide all
children significant opportunity to receive a fair, equitable, and high-quality education, and to
close educational achievement gaps. The use of funds would need to have been identified in the
comprehensive needs assessment and noted in the campus improvement plan. Additionally, the
services could only be provided for students attending schoolwide campuses as long as the LEA
has a valid SNS Methodology or a Statement of Exemption in place. If a campus is a Targeted
Assistance campus, the LEA would have to ensure that only students identified as most in need
receive the Title I, Part A services. If the students attend non-Title I campuses, this would not be
an allowable use of Title I, Part A funds for those campuses.
For audit and/or random validation purposes, the LEA would need to keep documentation on file
that demonstrates that the time and effort requirements are met and documentation that
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supports the funds being charged to Title I, Part A are related to time spent working directly on
Title I, Part A activities. It would also be advisable to note the Title I, Part A duties in the job
description for audit and/or random validation purposes.
Q17: Is it allowable to use Title I, Part A funds for extra-duty pay for instructional coaches training
teachers on non-duty days?
A17: Professional development is an allowable use of funds under Title I, Part A, as long as it is being
provided for Title I, Part A teachers on a Title I, Part A Schoolwide program campus or teachers
providing services to Title I, Part A students on a Targeted Assistance program campus and the use
of funds steps and requirements are followed as per the Title I, Part A Use of Funds
document. The LEA needs to be able to document how the activity meets the intent and purpose
of the Title I, Part A program which is to provide all children significant opportunity to receive a
fair, equitable, and high-quality education, and to close educational achievement gaps. The LEA
would also need to ensure it is compliant with the Supplement, Not Supplant (SNS) requirements
associated with Title I, Part A. For Title I, Part A, the LEA would meet the SNS requirement by
having a valid SNS methodology or Statement of Exemption.
As far as the method used to pay for the services, the LEA would need to follow its local policies
and procedures related to employee compensation in determining how to compensate the
employee for providing professional development services outside of their normal contract duty
days. Extra-duty pay must be supported by documentation and in accordance with the LEA’s
policies and procedures regarding extra-duty pay.
Q18: Is it allowable to use Title I, Part A funds to pay the salary for a Communities in Schools (CIS)
position?
A18: The LEA would need to ensure that it is following the steps and requirements for Title I, Part A use
of funds as per the Title I, Part A Use of Funds document. The LEA would specifically need to be
able to document that this use of funds meets the intent and purpose of Title I, Part A, which is to
provide all children significant opportunity to receive a fair, equitable, and high-quality education,
and to close educational achievement gaps. The use of funds would need to have been identified
in the comprehensive needs assessment and noted in the campus improvement plan.
Additionally, the CIS services could only be provided for students attending schoolwide campuses
as long as the LEA has a valid SNS Methodology or a Statement of Exemption in place. If a campus
is a Targeted Assistance campus, the LEA would have to ensure that only students identified as
most in need receive the Title I, Part A services. If the students attend non-Title I campuses, this
would not be an allowable use of Title I, Part A funds for those campuses.
Q19: Is it allowable to use Title I, Part A funds to pay a stipend or extra-duty pay to a counselor to
mentor other counselors?
A19: If the LEA meets all the steps and requirements noted in the Title I, Part A Use of Funds document
(including documenting an identified need as a result of a comprehensive needs assessment and
documenting the activity in the campus improvement plan), it would be considered allowable to
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pay stipends/extra-duty pay, taking into consideration the following guidance and ensuring that
the LEA is able to document how the activity meets the intent and purpose of the Title I, Part A
program which is to provide all children significant opportunity to receive a fair, equitable, and
high-quality education, and to close educational achievement gaps.
If the stipend/extra-duty pay would benefit campuses identified as schoolwide program campuses,
this would not be a problem, as long as the LEA has a valid SNS Methodology or a Statement of
Exemption in place. It would be difficult to document this use of funds for a Targeted Assistance
campus and it would not be allowable for anyone providing services to a non-Title I, Part A
campus.
For audit and/or random validation purposes, the LEA would need to keep documentation on file
that demonstrates that the time and effort requirements are met and documentation that
supports the funds being charged to Title I, Part A are related to time spent working directly on
activities that meet the intent and purpose of the Title I, Part A program.
Time and effort documentation is required for any type of compensation paid with federal funds,
including stipends. A stipend should be paid based on policies and procedures adopted by the
board or local authorities. A good example is a board approving a policy to pay a stipend in the
amount of $1000 for all teachers with graduate degrees. There is a good chance that this
position’s regular salary is paid with local funds, but the stipend will be paid out of federal funds.
The LEA must maintain time and effort documentation that describes a policy/reason adopted by
the appropriate authority or the board supporting the stipend for such activities. The document
must be signed and dated by the supervisor authorizing the stipend. If the employee was paid for
extra-duty pay outside of the normal working hours, the time and effort documentation would
include a time sheet of extra duties performed and a supplemental pay agreement approved by
the supervisor for specific services provided that are eligible under the federal program.
Q20: Is it allowable to use Title I, Part A funds to fund a summer instructional program for students
who will start Pre-Kindergarten for the first time in the Fall?
A20: Strategies for assisting preschool children in the transition from early childhood education
programs to local elementary school programs (including providing early instruction through a
summer program for students who will be enrolling in a PK program) is an allowable use of funds
under Title I, Part A as long as the steps and requirements noted on the Title I, Part A Use of Funds
document are followed. The LEA needs to be able to document how the activity meets the intent
and purpose of the Title I, Part A program which is to provide all children significant opportunity to
receive a fair, equitable, and high-quality education, and to close educational achievement gaps.
The use of funds would need to have been identified as a need in the comprehensive needs
assessment and noted in the campus improvement plan. If all the students will be attending Title I,
Part A schoolwide campuses, it shouldn’t be an issue. On a targeted assistance campus, services
should only be provided to students identified as most in need to receive the Title I, Part A
services.
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Q21: If an employee is retiring and they were paid out of Title I, Part A funds and the LEA has a policy
to pay out any unused sick leave, can the LEA use Title I, Part A funds to pay the balance of
unused sick days?
A21: The Title I, Part A use of funds referenced is to be treated like other fringe benefits under 200.431
of EDGAR, but, generally, the LEA must follow their local policy and treat federal funds the same as
state and local funds in this instance. So, if the LEA’s local policy pays for unused sick leave by
their funding pattern, then Title I, Part A can pay its share by the funding pattern; however, if their
policy is to pay all unused sick leave from local funds, then Title I, Part A can't be charged.
Q22: Is it allowable to use Title I, Part A funds to pay for professional development/training for non-
core content area teachers?
A22: If the LEA has a valid SNS methodology or Statement of Exemption, the use of Title I, Part A funds
to pay for professional development for teachers would be an allowable use of Title I, Part A funds
as long as it is being provided for schoolwide program/targeted assistance program teachers and
the use of funds steps and requirements are followed as per the Title I, Part A Use of Funds
document. The use of funds would need to have been identified in the comprehensive needs
assessment and noted in the campus improvement plan. To pay for professional development for
non-core content area teachers using Title I, Part A funds, the LEA would specifically need to be
able to document that the use of funds for non-core-content instruction teachers meets the intent
and purpose of Title I, Part A, which is to provide all children significant opportunity to receive a
fair, equitable, and high-quality education, and to close educational achievement gaps.
Q23: Is it allowable for Title I, Part A funds to be used to pay teachers extra-duty pay for a planning
session to develop a tutoring program, or can they only be paid extra-duty pay when they are
serving students and student attendance is reported?
A23: Title I, Part A funds can be used to pay teachers extra-duty pay for planning to develop the
tutoring program as long as the LEA is following the steps and requirements for Title I, Part A use
of funds as per the Title I, Part A Use of Funds document. The LEA would need to be able to
document how this use of funds is necessary to carry out the intent and purpose of Title I, Part A,
which is to provide all children significant opportunity to receive a fair, equitable, and high-quality
education, and to close educational achievement gaps. Additionally, the use of funds would need
to have been identified in the comprehensive needs assessment and included in the campus
improvement plan. Extra-duty pay must be supported by documentation and in accordance with
the LEA’s policies and procedures regarding extra-duty pay.
Q24: Is it allowable for Title I, Part A funds to be used to pay a tutoring coordinator who will manage
the scheduling, paperwork, and identifying which students will be served?
A24: Title I, Part A funds can be used to pay a tutoring coordinator as long as the LEA is following the
steps and requirements for Title I, Part A use of funds as per the Title I, Part A Use of Funds
document. The LEA would need to be able to document how this use of funds is necessary to
carry out the intent and purpose of Title I, Part A, which is to provide all children significant
opportunity to receive a fair, equitable, and high-quality education, and to close educational
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achievement gaps. Additionally, the use of funds would need to have been identified in the
comprehensive needs assessment and included in the campus improvement plan. For audit
and/or random validation purposes, the LEA would need to keep documentation on file that
demonstrates that the time and effort requirements are met and documentation that supports
the funds being charged to Title I, Part A are related to time spent working directly on activities
that meet the intent and purpose of the Title I, Part A program.
Q25: Is it allowable to use Title I, Part A funds to pay the salary of the Title I Coordinator if their job
duties include writing the ESSA grant application?
A25: LEA positions that are 100% paid with federal funds cannot write grant applications. They would
need a small percentage of state and/or local funds in their time and effort to cover writing and
submitting grant applications/amendments. The work preparing the responses for the application
is part of the planning and budget process from evaluating the prior year’s program
effectiveness. Writing the grant application is defined as completing the application forms and
submitting the application to TEA, but the LEA can define it more broadly.
Q26: Is it allowable to use Title I, Part A funds to pay the salary of a 504 facilitator?
A26: It would be difficult to justify and maintain documentation demonstrating how this use of funds is
necessary to carry out the intent and purpose of Title I, Part A, which is to provide all children
significant opportunity to receive a fair, equitable, and high-quality education, and to close
educational achievement gaps. However, if the LEA can document that paying the salary of a 504
facilitator meets the intent and purpose of the Title I, Part A program because it is related to
student academic achievement, they would need to ensure that they have followed the steps and
requirements noted on the Title I, Part A Use of Funds document and that the need has been
identified as a result of the Comprehensive Needs Assessment process and listed in the Campus
Improvement Plan. Additionally, the services could only be provided for students attending
schoolwide campuses as long as the LEA has a valid SNS Methodology or a Statement of
Exemption in place. If a campus is a Targeted Assistance campus, the LEA would have to ensure
that only students identified as most in need receive the Title I, Part A services. If the students
attend non-Title I campuses, this would not be an allowable use of Title I, Part A funds for those
campuses.
For audit and/or random validation purposes, the LEA would need to keep documentation on file
that demonstrates that the time and effort requirements are met and documentation that
supports the funds being charged to Title I, Part A are related to time spent working directly on
Title I, Part A activities. It would also be advisable to note the Title I, Part A duties in the job
description for audit and/or random validation purposes.
Q27: Is it allowable to use Title I, Part A funds to pay the salary of a Dyslexia teacher?
A27: The LEA would need to ensure that it is following the steps and requirements for Title I, Part A use
of funds as per the Title I, Part A Use of Funds document. Although utilizing Title I, Part A funds to
pay a Dyslexia Teacher’s salary is allowable based on the general duties of a teacher and the
connection to student academic achievement, the use of funds would need to have been
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identified in the comprehensive needs assessment and noted in the campus improvement
plan. Additionally, the services could only be provided for students attending schoolwide
campuses as long as the LEA has a valid SNS Methodology or a Statement of Exemption in place. If
a campus is a Targeted Assistance campus, the LEA would have to ensure that only students
identified as most in need receive the Title I, Part A services. If the students attend non-Title I
campuses, this would not be an allowable use of Title I, Part A funds for those campuses.
For audit and/or random validation purposes, the LEA would need to keep documentation on file
that demonstrates that the time and effort requirements are met and documentation that
supports the funds being charged to Title I, Part A are related to time spent working directly on
Title I, Part A activities. It would also be advisable to note the Title I, Part A duties in the job
description for audit and/or random validation purposes.
Q28: Is it allowable to use Title I, Part A funds to pay for stipends?
A28: First, the LEA would need to determine and maintain documentation if the reason for the stipend
meets the intent and purpose of the Title I, Part A program which is to provide all children
significant opportunity to receive a fair, equitable, and high-quality education, and to close
educational achievement gaps. If the LEA meets all the steps and requirements noted in the
Title I, Part A Use of Funds document (including documenting an identified need as a result of a
comprehensive needs assessment and documenting the activity in the campus improvement
plan), it would be considered allowable to pay stipends, taking into consideration the following
guidance. As noted in the Title I, Part A Use of Funds document, the stipend amount should also
be reasonable and necessary to carry out the intent and purpose of the Title I, Part A program.
If the stipend would benefit campuses identified as schoolwide program campuses, this would not
be a problem, as long as the LEA has a valid SNS Methodology or a Statement of Exemption in
place. It would be difficult to document this use of funds for a Targeted Assistance campus and it
would not be allowable for anyone providing services to a non-Title I, Part A campus.
For audit and/or random validation purposes, the LEA would need to keep documentation on file
that demonstrates that the time and effort requirements are met and documentation that
supports the funds being charged to Title I, Part A are related to time spent working directly on
activities that meet the intent and purpose of the Title I, Part A program.
Time and effort documentation is required for any type of compensation paid with federal funds,
including stipends. A stipend should be paid based on policies and procedures adopted by the
board or local authorities. A good example is a board approving a policy to pay a stipend in the
amount of $1000 for all teachers with graduate degrees. There is a good chance that this
position’s regular salary is paid with local funds, but the stipend will be paid out of federal funds.
The LEA must maintain time and effort documentation that describes a policy/reason adopted by
the appropriate authority or the board supporting the stipend for such activities. The document
must be signed and dated by the supervisor authorizing the stipend.
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Q29: Is it allowable to use Title I, Part A funds to pay for the salary of an interventionist?
A29: The LEA would need to ensure that it is following the steps and requirements for Title I, Part A use
of funds as per the Title I, Part A Use of Funds document. Although utilizing Title I, Part A funds to
pay an Interventionist’s salary is generally allowable based on the general duties of an
interventionist and the connection to student academic achievement, the use of funds would
need to have been identified in the comprehensive needs assessment and noted in the campus
improvement plan. The LEA would need to ensure that all the duties the position would be
performing meet the intent and purpose of Title I, Part A, which is to provide all children
significant opportunity to receive a fair, equitable, and high-quality education, and to close
educational achievement gaps.
Additionally, the services could only be provided for students attending schoolwide campuses as
long as the LEA has a valid SNS Methodology or a Statement of Exemption in place. If a campus is
a Targeted Assistance campus, the LEA would have to ensure that only students identified as most
in need receive the Title I, Part A services. If the students attend non-Title I campuses, this would
not be an allowable use of Title I, Part A funds for those campuses.
For audit and/or random validation purposes, the LEA would need to keep documentation on file
that demonstrates that the time and effort requirements are met and documentation that
supports the funds being charged to Title I, Part A are related to time spent working directly on
Title I, Part A activities. It would also be advisable to note the Title I, Part A duties in the job
description for audit and/or random validation purposes.
Q30: Is it allowable to use Title I, Part A funds to pay the salary of career and technical education
(CTE) teacher?
A30: The LEA would need to ensure that it is following the steps and requirements for Title I, Part A use
of funds as per the Title I, Part A Use of Funds document. Although utilizing Title I, Part A funds to
pay a teacher’s salary is generally allowable based on the general duties of a teacher and the
connection to student academic achievement, the use of funds would need to have been
identified in the comprehensive needs assessment and noted in the campus improvement
plan. The LEA would need to ensure that all the duties the position would be performing meet the
intent and purpose of Title I, Part A, which is to provide all children significant opportunity to
receive a fair, equitable, and high-quality education, and to close educational achievement gaps.
Additionally, the services could only be provided for students attending schoolwide campuses as
long as the LEA has a valid SNS Methodology or a Statement of Exemption in place. If a campus is
a Targeted Assistance campus, the LEA would have to ensure that only students identified as most
in need receive the Title I, Part A services. If the students attend non-Title I campuses, this would
not be an allowable use of Title I, Part A funds for those campuses.
For audit and/or random validation purposes, the LEA would need to keep documentation on file
that demonstrates that the time and effort requirements are met and documentation that
supports the funds being charged to Title I, Part A are related to time spent working directly on
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Title I, Part A activities. It would also be advisable to note the Title I, Part A duties in the job
description for audit and/or random validation purposes.
Q31: Is it allowable to use Title I, Part A funds to pay the salary of school counselor?
A31: The LEA would need to ensure that it is following the steps and requirements for Title I, Part A use
of funds as per the Title I, Part A Use of Funds document. Although utilizing Title I, Part A funds to
pay a portion of a Counselor’s salary is allowable based on the general duties of a counselor and
the connection to student academic achievement, the use of funds would need to have been
identified in the comprehensive needs assessment and noted in the campus improvement
plan. Additionally, the services could only be provided for students attending schoolwide
campuses as long as the LEA has a valid SNS Methodology or a Statement of Exemption in place. If
a campus is a Targeted Assistance campus, the LEA would have to ensure that only students
identified as most in need receive the Title I, Part A services. If the students attend non-Title I
campuses, this would not be an allowable use of Title I, Part A funds for those campuses.
For audit and/or random validation purposes, the LEA would need to keep documentation on file
that demonstrates that the time and effort requirements are met and documentation that
supports the funds being charged to Title I, Part A are related to time spent working directly on
Title I, Part A activities. It would also be advisable to note the Title I, Part A duties in the job
description for audit and/or random validation purposes.
Q32: Is it allowable to use Title I, Part A funds to pay the salary of a computer technician that
provides technology support for student devices at Title I, Part A campuses?
A32: The LEA would need to ensure that it is following the steps and requirements for Title I, Part A use
of funds as per the Title I, Part A Use of Funds document. The LEA would specifically need to
maintain documentation demonstrating how this use of funds is necessary to carry out the intent
and purpose of Title I, Part A, which is to provide all children significant opportunity to receive a
fair, equitable, and high-quality education, and to close educational achievement gaps. Although
utilizing Title I, Part A funds to pay a Computer Technician’s salary may be allowable, the use of
funds would need to have been identified in the comprehensive needs assessment and noted in
the campus improvement plan. Additionally, the services could only be provided for students
attending schoolwide campuses as long as the LEA has a valid SNS Methodology or a Statement of
Exemption in place. If a campus is a Targeted Assistance campus, the LEA would have to ensure
that only students identified as most in need receive the Title I, Part A services. If the students
attend non-Title I campuses, this would not be an allowable use of Title I, Part A funds for those
campuses.
For audit and/or random validation purposes, the LEA would need to keep documentation on file
that demonstrates that the time and effort requirements are met and documentation that
supports the funds being charged to Title I, Part A are related to time spent working directly on
Title I, Part A activities. It would also be advisable to note the Title I, Part A duties in the job
description for audit and/or random validation purposes.
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Q33: Is it allowable to use Title I, Part A funds to pay board-approved retention stipends to
employees that are paid out of Title I, Part A?
A33: If the LEA meets all the steps and requirements noted in the Title I, Part A Use of Funds document
(including documenting an identified need as a result of a comprehensive needs assessment and
documenting the activity in the campus improvement plan), it would be considered allowable to
use Title I, Part A funds to pay retention stipends to employees that are paid out of Title I, Part A,
taking into consideration the following guidance and ensuring that the LEA is able to document
how the activity meets the intent and purpose of the Title I, Part A program which is to provide all
children significant opportunity to receive a fair, equitable, and high-quality education, and to
close educational achievement gaps. As noted in the Title I, Part A Use of Funds document, the
stipend amount should also be reasonable and necessary to carry out the intent and purpose of
the Title I, Part A program.
If the stipend would benefit campuses identified as schoolwide program campuses, this would not
be a problem, as long as the LEA has a valid SNS Methodology or a Statement of Exemption in
place. It would be difficult to document this use of funds for a Targeted Assistance campus and it
would not be allowable for anyone providing services to a non-Title I, Part A campus.
For audit and/or random validation purposes, the LEA would need to keep documentation on file
that demonstrates that the time and effort requirements are met. Time and effort documentation
is required for any type of compensation paid with federal funds, including stipends. An employee
paid 100% from grant funds will be covered under the periodic certifications.
A stipend should be paid based on policies and procedures adopted by the board or local
authorities. A good example is a board approving a policy to pay a stipend in the amount of $1000
for all teachers with graduate degrees. The LEA must maintain time and effort documentation
that describes a policy/reason adopted by the appropriate authority or the board supporting the
stipend for such activities. The document must be signed and dated by the supervisor authorizing
the stipend.
Q34: Is it allowable to use Title I, Part A funds to pay the salary of summer school staff (principals,
assistant principals, school nurses, PEIMS clerks, registrars, and attendance clerks)?
A34: When determining whether Title I, Part A funds can be used for payroll it is important to ensure
that the use of funds is reasonable and necessary to carry out the intent and purpose of the Title I,
Part A program which is to provide all children significant opportunity to receive a fair, equitable,
and high-quality education, and to close educational achievement gaps. An LEA would need to be
able to document that the use of funds would meet such intent and purpose of the Title I, Part A
program.
It would be difficult to justify and maintain documentation demonstrating how the use of funds
for the positions referenced (principals, assistant principals, school nurses, PEIMS clerks,
registrars, and attendance clerks) is necessary to carry out the intent and purpose of Title I, Part A,
which is to provide all children significant opportunity to receive a fair, equitable, and high-quality
education, and to close educational achievement gaps. However, if the LEA can document that
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paying the salary for any of those positions meets the intent and purpose of the Title I, Part A,
they would need to ensure that they have followed the steps and requirements noted on the
Title I, Part A Use of Funds document and that the need has been identified as a result of the
Comprehensive Needs Assessment process and listed in the Campus Improvement
Plan. Additionally, the use of funds would only be allowed on Title I, Part A Schoolwide campuses
since Title I, Part A funds can only be used to serve Title I, Part A students. It would be difficult to
justify and document such payroll costs on a Targeted Assistance campus.
For audit and/or random validation purposes, the LEA would need to keep documentation on file
that demonstrates that the time and effort requirements are met and documentation that
supports the funds being charged to Title I, Part A are related to time spent working directly on
Title I, Part A activities. It would also be advisable to note the Title I, Part A duties in the job
description for audit and/or random validation purposes.
Q35: As part of the HB3 Reading Academies requirement, our LEA has decided to utilize existing LEA
staff to serve as the blended facilitators for this program. To date, the salaries for these staff
members are federally funded under Title I, Part A. It has been recommended by our LEA
leadership that a one-time stipend be added on top of the annual salary for these duties. Is this
allowable under Title I, Part A since the HB3 Reading Academies are a state requirement? If it is
unallowable, would it be allowable to fund the stipend out of another fund source for the
employees that are paid with Title I, Part A funds?
A35: If the LEA has a valid SNS methodology or Statement of Exemption, the use of Title I, Part A funds
to pay for costs associated with the state-required Reading Academies would be an allowable use
of Title I, Part A funds. Once that is accomplished, either through a Title I-neutral SNS
Methodology or by through a Statement of Exemption, the supplemental requirement for Title I,
Part A funds at the campus level has been met. For district-level funds, the LEA must ensure that
it is using State and local funds that are retained at the LEA level in a Title I neutral manner. Then
any Title I, Part A funds that are reserved at the LEA level are also considered to be supplemental
in nature. Professional development is an allowable use of funds under Title I, Part A as long as it is
being provided for schoolwide program/targeted assistance program teachers and the use-of-
funds steps and requirements are followed as per the Title I, Part A Use of Funds document.
Since the inception of ESSA, the method of determining compliance with the Supplement, Not
Supplant requirements for Title I, Part A changed. For Title I, Part A, LEAs are no longer required
to adhere to the traditional presumptions of supplant (of which one traditional presumption
included state requirements). The requirement related to Supplement, Not Supplant for Title I,
Part A is that the LEA must have a valid Supplement, Not Supplant Methodology or a Statement of
Exemption in place. For more information related to the methodology or statement of exemption,
click here to access the most current version of the Supplement, Not Supplant Handbook.
Please note that the traditional presumptions of supplant are still in place for other federal
programs (i.e., including but not limited to Title II, Part A and Title IV, Part A). For a complete list
of federal programs that still take into account the traditional presumptions of supplant, click here
to access the most current version of the Supplement, Not Supplant Handbook.
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To utilize Title I, Part A funds to pay for a stipend, the LEA would first need to determine and
maintain documentation if the reason for the stipend meets the intent and purpose of the Title I,
Part A program, which is to provide all children significant opportunity to receive a fair, equitable,
and high-quality education, and to close educational achievement gaps. If the LEA meets all the
steps and requirements noted in the Title I, Part A Use of Funds document (including documenting
an identified need as a result of a comprehensive needs assessment and documenting the activity
in the campus improvement plan), it would be considered allowable to pay stipends, taking into
consideration the following guidance. As noted in the Title I, Part A Use of Funds document, the
stipend amount should also be reasonable and necessary to carry out the intent and purpose of
the Title I, Part A program.
If the stipend would benefit campuses identified as schoolwide program campuses, this would not
be a problem, as long as the LEA has a valid SNS Methodology or a Statement of Exemption in
place. It would be difficult to document this use of funds for a Targeted Assistance campus, and it
would not be allowable for anyone providing services to a non-Title I, Part A campus.
For audit and/or random validation purposes, the LEA would need to keep documentation on file
that demonstrates that the time and effort requirements are met and documentation that
supports the funds being charged to Title I, Part A are related to time spent working directly on
activities that meet the intent and purpose of the Title I, Part A program.
Time and effort documentation is required for any type of compensation paid with federal funds,
including stipends. A stipend should be paid based on policies and procedures adopted by the
board or local authorities. A good example is a board approving a policy to pay a stipend in the
amount of $1000 for all teachers with graduate degrees. There is a good chance that this
position’s regular salary is paid with local funds, but the stipend will be paid out of federal funds or
vice versa. The LEA must maintain time and effort documentation that describes a policy/reason
adopted by the appropriate authority or the board supporting the stipend for such activities. The
document must be signed and dated by the supervisor authorizing the stipend.
It is allowable for an employee whose salary is paid out of Title I, Part A to be paid a stipend from
another fund source as long as it meets the use of funds requirements for that fund source.
Q36: May Title I, Part A funds be used to pay for employee benefits such as pension plans,
unemployment insurance coverage, health insurance, severance pay, and life insurance?
A36: Yes. Employers’ contributions for employee benefits such as these are an allowable use of Title I,
Part A funds provided the benefits are granted under approved plans and the costs are distributed
equitably to the Title I, Part A grant and to other activities.
Q37: May Title I, Part A funds be used to pay the salary costs for employees during periods of
authorized absences such as annual leave, sick leave, and sabbatical leave?
A37: Yes. Employee benefits in the form of compensation paid during reasonable authorized absences
from the job are an allowable use of Title I, Part A funds if the benefits are provided under an
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established leave system and the costs are equitably allocated to all related activities, including
the Title I, Part A program.
Q38: Can Title I, Part A funds be used to pay, in-full or in-part, the salaries of music, art, or physical
education teachers?
A38: The LEA would need to ensure that it is following the steps and requirements for Title I, Part A use
of funds as per the Title I, Part A Use of Funds document. Although utilizing Title I, Part A funds to
pay a teacher’s salary is generally allowable based on the general duties of a teacher and the
connection to student academic achievement, the use of funds would need to have been
identified in the comprehensive needs assessment and noted in the campus improvement
plan. The LEA would need to ensure that all the duties the position would be performing meet the
intent and purpose of Title I, Part A, which is to provide all children significant opportunity to
receive a fair, equitable, and high-quality education, and to close educational achievement gaps.
Additionally, the services could only be provided for students attending schoolwide campuses as
long as the LEA has a valid SNS Methodology or a Statement of Exemption in place. If a campus is
a Targeted Assistance campus, the LEA would have to ensure that only students identified as most
in need receive the Title I, Part A services. If the students attend non-Title I campuses, this would
not be an allowable use of Title I, Part A funds for those campuses.
For audit and/or random validation purposes, the LEA would need to keep documentation on file
that demonstrates that the time and effort requirements are met and documentation that
supports the funds being charged to Title I, Part A are related to time spent working directly on
Title I, Part A activities. It would also be advisable to note the Title I, Part A duties in the job
description for audit and/or random validation purposes.
Q39: Can Title I, Part A funds be used to pay for the salary of the social and emotional learning (SEL)
executive director at the LEA level? The position supports all campuses in the LEA and all
campuses in the LEA are Title I, Part A served campuses that implement a schoolwide program.
A39: If the LEA meets all the Title I, Part A use of funds requirements, it would be considered allowable
to pay the salary of a district-wide Executive Director with tasks associated with social and
emotional learning taking into consideration the following guidance. For audit and/or random
validation purposes, the LEA would need to keep documentation on file that demonstrates that
the time and effort requirements are met and documentation that supports the funds being
charged to Title I, Part A are related to time spent working directly on Title I, Part A activities. It
would also be advisable to note the Title I, Part A duties in the job descriptions for audit and/or
random validation purposes.
The LEA should also consider that the time spent on program administration activities would be
considered activities to be conducted with reserved funds. If the employee is providing LEA-
specific Title I, Part A responsibilities, the time the employee spends on such responsibilities would
be considered district reservation time. If the employee is providing campus-specific Title I, Part A
responsibilities, the time the employee spends on such responsibilities would be considered at the
campus level. Additionally, the LEA would need to ensure that it is following LEA policies and
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procedures related to the classification of employees (LEA vs. campus). The LEA would need to
maintain detailed documentation in case of an audit or random validation monitoring review.
Q40: Is there a sample or form for Supplemental Pay Agreement?
A40: A sample Supplemental Pay Agreement is not available.
Q41: For Extra-Duty Pay, what is the "Supplemental Pay Agreement"? Is that as simple as a
description of the function or purpose of the extra duty?
A41: The supplemental pay agreement for extra duty is like a contract for the work that will be
completed outside of the normal workday. It will list the terms and agreement for both parties
(dollars per hour, the type of work to be completed, the total allowable amount of pay, etc.). Both
parties will sign prior to the work being completed.
Q42: Does the district Personnel Action Form (district personnel documentation form) support the
Supplemental Pay Agreement for extra-duty pay?
A42: The PAR is used for duties during the regular school day. A separate time and effort form needs to
be kept for extra-duty pay (e.g., a record for a after school tutor would show who was tutored, on
what day, and for how long).
Q43: What type of documentation would need to be kept for substitute teacher costs paid with
Title I, Part A funds?
A43: Documentation would include the teacher of record, payroll authorizations, and a board-approved
document showing the daily rates for subs.
Q44: Can a one-time retention stipend be paid out of Title I, Part A funds if the employee is funded
out of Title I, Part A and all employees are getting a retention stipend?
A44: If the LEA meets all the steps and requirements noted in the Title I, Part A Use of Funds document
(including documenting an identified need as a result of a comprehensive needs assessment and
documenting the activity in the campus improvement plan), it would be considered allowable to
use Title I, Part A funds to pay retention stipends to employees that are paid out of Title I, Part A,
taking into consideration the following guidance and ensuring that the LEA is able to document
how the activity meets the intent and purpose of the Title I, Part A program which is to provide all
children significant opportunity to receive a fair, equitable, and high-quality education, and to
close educational achievement gaps. As noted in the Title I, Part A Use of Funds document, the
stipend amount should also be reasonable and necessary to carry out the intent and purpose of
the Title I, Part A program.
If the stipend would benefit campuses identified as schoolwide program campuses, this would not
be a problem, as long as the LEA has a valid SNS Methodology or a Statement of Exemption in
place. It would be difficult to document this use of funds for a Targeted Assistance campus and it
would not be allowable for anyone providing services to a non-Title I, Part A campus.
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For audit and/or random validation purposes, the LEA would need to keep documentation on file
that demonstrates that the time and effort requirements are met. Time and effort documentation
is required for any type of compensation paid with federal funds, including stipends. An employee
paid 100% from grant funds will be covered under the periodic certifications.
A stipend should be paid based on policies and procedures adopted by the board or local
authorities. A good example is a board approving a policy to pay a stipend in the amount of $1000
for all teachers with graduate degrees. The LEA must maintain time and effort documentation
that describes a policy/reason adopted by the appropriate authority or the board supporting the
stipend for such activities. The document must be signed and dated by the supervisor authorizing
the stipend.
Q45: Can core subject campus department heads be paid from Title I, Part A funds?
A45: The LEA would need to ensure that it is following the steps and requirements for Title I, Part A use
of funds as per the Title I, Part A Use of Funds document. Although utilizing Title I, Part A funds to
pay a teacher’s salary is generally allowable based on the general duties of a teacher and the
connection to student academic achievement, the use of funds would need to have been
identified in the comprehensive needs assessment and noted in the campus improvement
plan. The LEA would need to ensure that all the duties the position would be performing meet the
intent and purpose of Title I, Part A, which is to provide all children significant opportunity to
receive a fair, equitable, and high-quality education, and to close educational achievement gaps.
Additionally, the services could only be provided for students attending schoolwide campuses as
long as the LEA has a valid SNS Methodology or a Statement of Exemption in place. It would be
difficult to document this use of funds for a Targeted Assistance campus and it would not be
allowable for anyone providing services to a non-Title I, Part A campus.
For audit and/or random validation purposes, the LEA would need to keep documentation on file
that demonstrates that the time and effort requirements are met and documentation that
supports the funds being charged to Title I, Part A are related to time spent working directly on
Title I, Part A activities. It would also be advisable to note the Title I, Part A duties in the job
description for audit and/or random validation purposes.
Q46: Can an employee funded by the Title I, Part A program perform non-instructional duties such as
supervising hallways, student arrival/dismissal duties, and cafeteria monitoring duties?
A46: Title I, Part A funded staff can perform such duties, as long as other staff in similar positions are
also performing such duties. As per the Every Student Succeeds Act (ESSA), Section 1115 (d)(2),
“School personnel who are paid with Title I, Part A funds may assume limited duties that are
assigned to similar personnel who are not so paid, including duties beyond classroom instruction
or that do not benefit participating children, so long as the amount of time spent on such duties is
the same proportion of total work time as prevails with respect to similar personnel at the same
school.”
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Q47: A campus has an interventionist that is funded by Title I, Part A funds. The interventionist
resigned, so there is no one in the position currently. While they have the position posted, can
they pay for a "long term substitute" with Title I, Part A funds for the position?
A47: The LEA can pay for an individual to perform the duties of the interventionist that was previously
paid with Title I, Part A funds as long as the use of funds meets the steps and requirements noted
in the Title I, Part A Use of Funds reference document. The LEA would need to follow their local
policies and procedures in determining how to classify the employee performing the duties.
Technically, the person would not be performing in a traditional substitute role because there is
no one currently in the position. For documentation purposes and to maintain a clean audit trail, it
would be advised that the employee performing the interventionist duties not be classified as a
“substitute.” The LEA would need to follow their local policies and procedures in determining how
to classify the employee performing the interventionist duties.
*Q47.1: What time and effort documentation would need to be maintained locally for the
employee?
*A47.1: Staff Member Paid 100% with Federal Funds: Time and effort must be documented
appropriately for any employee compensation that is paid, in full or in part, with federal
funds. The new EDGAR does not list specific types of documentation for time and effort,
rather it lists seven characteristics of documentation that must be met (See EDGAR FAQ
8.1).
Substitute: Time and effort must be documented appropriately for any employee
compensation that is paid, in full or in part, with federal funds. The subgrantee generally
will either have a policy or procedure that all substitute pay is paid from state and/or
local, not federal or state grant, funds or the substitute pay follows the same pay as the
staff members for whom the substitute is working. If the substitute pay follows the
employees funding distribution, the LEA’s after-the-fact documentation must identify the
teacher or staff for whom the substitute is working. Either a statement signed by the
substitute or other system documentation would be sufficient. (Source: EDGAR FAQ 8.3)
Q48: When teachers are funded out of Title I, Part A funds, can they be placed in a grade level based
on the results of a comprehensive needs assessment or do they need to be placed in a certain
grade level?
A48: There is no statutory requirement that references that Title I, Part A-funded teachers are to be
placed in a particular grade level. As with any use of Title I, Part A funds, LEAs are required to
follow the steps and requirements noted in the Title I, Part A Use of Funds document. The Title I,
Part A program is a campus-based program, and funds should also be distributed to campuses as
per the statutory requirements for ranking and serving Title I, Part A eligible campuses.
Schoolwide program campuses should use their funds based on the results of a comprehensive
needs assessment and what has been included in the campus improvement plan.
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Q49: Is it allowable for an LEA to use Title I, Part A funds for extra-duty pay to meet with parents to
discuss student progress and the parent-school compact?
A49: If the LEA meets all the steps and requirements noted in the Title I, Part A Use of Funds document
(including documenting an identified need as a result of a comprehensive needs assessment and
documenting the activity in the campus improvement plan), it would be considered allowable to
pay extra-duty pay for duties performed outside of the normal working hours of the employee,
taking into consideration the following guidance and ensuring that the LEA is able to document
how the activity meets the intent and purpose of the Title I, Part A program which is to provide all
children significant opportunity to receive a fair, equitable, and high-quality education, and to
close educational achievement gaps.
For audit and/or random validation purposes, the LEA would need to keep documentation on file
that demonstrates that the time and effort requirements are met and documentation that
supports the funds being charged to Title I, Part A are related to time spent working directly on
activities that meet the intent and purpose of the Title I, Part A program.
If the employee was paid for extra-duty pay outside of the normal working hours, the time and
effort documentation would include a time sheet of extra duties performed and a supplemental
pay agreement approved by the supervisor for specific services provided that are eligible under
the federal program.
*Q49.1: How would HB 4545 requirements affect this requirement if both are happening
simultaneously?
*A49.1: If the LEA has a valid Supplement, Not Supplant Methodology or Statement of
Exemption, use of Title I, Part A funds for this activity would not be considered a
supplant.
Q50: Is it allowable to use Title I, Part A funds to pay a stipend to an experienced teacher to mentor a
non-core subject area new teacher?
A50: It would be an allowable use of Title I, Part A funds to pay a stipend to a veteran teacher to
mentor a new teacher even if the new teacher does not teach one of the core subject areas, as
long as the following requirements related to stipends are met.
First, the LEA would need to determine and maintain documentation if the reason for the stipend
meets the intent and purpose of the Title I, Part A program, which is to provide all children
significant opportunity to receive a fair, equitable, and high-quality education, and to close
educational achievement gaps. If the LEA meets all the steps and requirements noted in the Title I,
Part A Use of Funds document (including documenting an identified need as a result of a
comprehensive needs assessment and documenting the activity in the campus improvement
plan), it would be considered allowable to pay stipends, taking into consideration the following
guidance.
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As noted in the Title I, Part A Use of Funds document, the stipend amount should also be
reasonable and necessary to carry out the intent and purpose of the Title I, Part A program.
If the stipend would benefit campuses identified as schoolwide program campuses, this would not
be a problem, as long as the LEA has a valid SNS Methodology or a Statement of Exemption in
place. It would be difficult to document this use of funds on a Targeted Assistance campus for a
teacher that is not serving Title I, Part A students, and it would not be allowable for anyone
providing services to a non-Title I, Part A campus.
For audit and/or random validation purposes, the LEA would need to keep documentation on file
that demonstrates that the time and effort requirements are met and documentation that
supports the funds being charged to Title I, Part A are related to time spent working directly on
activities that meet the intent and purpose of the Title I, Part A program.
Time and effort documentation is required for any type of compensation paid with federal funds,
including stipends. A stipend should be paid based on policies and procedures adopted by the
board or local authorities. A good example is a board approving a policy to pay a stipend in the
amount of $1000 for all teachers with graduate degrees. There is a good chance that this
position’s regular salary is paid with local funds, but the stipend will be paid out of federal funds.
The LEA must maintain time and effort documentation that describes a policy/reason adopted by
the appropriate authority or the board supporting the stipend for such activities. The document
must be signed and dated by the supervisor authorizing the stipend.
Q51: Can Title I, Part A funds be used to pay for substitutes for teachers who are absent expending
their local sick/leave days or state leave days? These substitute costs were previously paid out
of local district funds and not from their campus allocation.
A51: Yes, it is technically allowable. However, TEA recommends only paying for substitutes for actual
campus staff whose salary is paid from Title I, Part A funds, even on a schoolwide campus.
In this instance, as long as the LEA has an appropriately implemented supplement, not supplant
methodology, it is not a supplant to pay for these substitute costs from Title I, Part A. However,
several things need to be considered and well documented before doing so. If using other federal
grant funds to pay substitutes, the LEA must consider the presumptions of supplanting that are in
effect for that fund source.
If the LEA decides to pay for all substitute costs on a campus, this could potentially result in an
audit finding or impact for the LEA’s compliance with maintenance of effort (MOE) requirements
due to the shifting of state and local expenditures in the previous year to federal funds in the
current year.
When paying substitute costs with any federal grant funds, the LEA must consider and document
whether the cost is reasonable, necessary, and allocable to determine if it is programmatically an
allowable cost.
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In addition to consideration regarding reasonable, necessary, and allocable, for Title I, Part A funds
to be used, the LEA must document:
• What need to pay all substitute costs was identified in the comprehensive needs
assessment?
• How is this activity identified in the CIP?
• How will this activity be evaluated and show the substitutes were effective in improving
student academic achievement?
Q52: Is it allowable to use Title I, Part A funds to pay a portion of the salary of a district-wide Special
Programs Director for the position’s Title I, Part A-related duties? If yes, what is the
documentation needed to be maintained locally for compliance?
A52: If the LEA meets all the Title I, Part A use of funds requirements as per the Title I, Part A use of
funds reference document, it would be considered allowable to use Title I, Part A funds to pay a
portion of a district-wide Special Programs Director’s salary taking into consideration the following
guidance.
▪ The LEA must have a valid Supplement, Not Supplant methodology for allocating State and
local funds to campuses, or Statement of Exemption. In both situations, the LEA must also
ensure that State and local funds that are reserved at the LEA level are used to support
activities that do not take the Title I status of campuses into account.
▪ As with the use of any Title I, Part A funds, the LEA would need to ensure that it is able to
document how the activity meets the intent and purpose of the Title I, Part A program, which
is to provide all children significant opportunity to receive a fair, equitable, and high-quality
education, and to close educational achievement gaps.
▪ For audit and/or random validation purposes, the LEA would need to keep documentation on
file that demonstrates that the time and effort requirements are met (personnel activity
report) and documentation that supports the funds being charged to Title I, Part A are related
to time spent working directly on Title I, Part A activities. It would also be advisable to note the
Title I, Part A duties in the job descriptions for audit and/or random validation purposes.
▪ The LEA should also consider that the time spent on program administration activities would
be considered activities to be conducted with reserved funds. If the employee is providing LEA-
specific Title I, Part A responsibilities, the time the employee spends on such responsibilities
would be considered district reservation time. If the employee is providing campus-specific
Title I, Part A responsibilities, the time the employee spends on such responsibilities would be
considered at the campus level. Additionally, the LEA would need to ensure that it is following
LEA policies and procedures related to the classification of employees (LEA vs. campus). The
LEA would need to maintain detailed documentation in case of an audit or random validation
monitoring review.
▪ As per the TEA Budgeting Costs Guidance Handbook, Title I, Part A funds may not be used for
grant writing or obtaining grant funds, which includes the ESSA Consolidated Federal Grant
Application.
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Q53: Does a teacher have to be off official contract hours before being paid for extra-duty activities
such as tutorials?
A53: Although extra-duty pay for teachers to provide instructional support to students during
afterschool tutorials is an allowable use of Title I, Part A funds on a schoolwide program campus
and for students meeting the criteria on a targeted assistance campus, extra-duty pay for tutorials
would be considered allowable, reasonable, and necessary only when such duties are performed
outside of the scheduled working hours for the teachers. If the teacher’s normal schedule is
Monday – Friday from 7:30 am – 4:00 pm, the teacher could only be compensated with extra-duty
pay for tutorials that take place on Saturday, Sunday, and/or before/after the teacher’s normal
scheduled working hours. As with any use of Title I, Part A funds, the LEA would need to follow the
steps and requirements noted in the Title I, Part A Use of Funds document. The LEA would also
need to ensure that it is following its local procedures for extra-duty pay compensation and that it
is able to maintain the appropriate time and effort documentation.
Q54: Is it allowable use of Title I, Part A funds for class-size reduction?
A54: As with any use of the Title I, Part A funds, the campus would need to ensure that it is following
the steps and requirements for use of Title I, Part A funds that are referenced in the Title I, Part A
Use of Funds reference document. If the LEA has a valid Supplement, Not Supplant (SNS)
methodology or statement of exemption, they have met the SNS requirement for this specific use
of Title I, Part A funds. Although Title I, Part A statute does not specifically reference class-size
reduction, use of Title I, Part A funds must be used in accordance with the intent and purpose of
the program, which is to provide all children significant opportunity to receive a fair, equitable,
and high-quality education, and to close educational achievement gaps. This would include
ensuring that such activities are evidence-based as referenced in the USDE Non-Regulatory
Guidance: Using Evidence to Strengthen Education Investments that applies to Title I, Part A.
Q55: Can the salary of a Migrant Education Program Specialist be paid with Title I, Part A funds? This
person only works on the Migrant Program and nothing else.
A55: If the steps and requirements for use of Title I, Part A funds noted in the Title I, Part A Use of
Funds reference document are met, it is allowable to use Title I, Part A funds to pay for the salary
of the Migrant Education Program Specialist on a Title I, Part A Schoolwide Program campus
taking into consideration the following guidance. As with the use of any Title I, Part A funds, the
campus would need to ensure that the LEA is able to document how the activity meets the intent
and purpose of the Title I, Part A program, which is to provide all children significant opportunity
to receive a fair, equitable, and high-quality education, and to close educational achievement
gaps.
On a Title I, Part A Targeted Assistance campus, Title I, Part A funds may not be used to provide
services that are otherwise required by law to be made available to Migrant children but may be
used to coordinate or supplement such services.
For audit and/or random validation purposes, the LEA would need to keep documentation on file
that demonstrates that the time and effort requirements are met and documentation that
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supports the funds being charged to Title I, Part A are related to time spent working directly on
Title I, Part A activities. It would also be advisable to note the Title I, Part A duties in the job
descriptions for audit and/or random validation purposes.
The LEA should also consider that the time spent on program administration activities would be
considered activities to be conducted with reserved funds. If the employee is providing LEA-
specific Title I, Part A responsibilities, the time the employee spends on such responsibilities would
be considered district reservation time. If the employee is providing campus-specific Title I, Part A
responsibilities, the time the employee spends on such responsibilities would be considered at the
campus level. Additionally, the LEA would need to ensure that it is following LEA policies and
procedures related to the classification of employees (LEA vs. campus). The LEA would need to
maintain detailed documentation in case of an audit or random validation monitoring review.
Response Revised 11/30/2022
Q56: Is it allowable for a Title I, Part A campus to use Title I, Part A funds to hire a full-time
administrative position to manage the climate and culture on the campus?
A56: The LEA would need to ensure that it is following the steps and requirements for Title I, Part A use
of funds as per the Title I, Part A Use of Funds document. The LEA would specifically need to be
able to document that this use of funds meets the intent and purpose of Title I, Part A, which is to
provide all children significant opportunity to receive a fair, equitable, and high-quality education,
and to close educational achievement gaps. The use of funds would need to have been identified
in the comprehensive needs assessment and noted in the campus improvement plan.
Additionally, this position would need to be on a Schoolwide program campus.
Q57: Is it allowable use of Title I, Part A funds to support paraprofessionals in obtaining their
alternative certification?
A57: Paying for the costs associated with a paraprofessional obtaining certification as a teacher through
an Alternative Certification Program is allowable under Title I, Part A, as long as the LEA meets the
Title I, Part A Use of Funds requirements as noted on the Title I, Part A Use of Funds document.
*Q58: To justify payroll expenditures for extra-duty pay for tutoring, is it required to maintain the
following documentation locally: student sign-in sheets, tutoring agreement, and tutor
timesheet?
*A58: If the LEA were to have an audit, all three documents would be needed. It is appropriate to
document the procedures related to this process in the local Administrative Procedures Manual to
demonstrate adequate internal controls. The documents themselves are required to demonstrate
compliance with allowability. Requirements for internal controls are found in 2 CFR 200.302 and
allowability requirements are referenced in 2 CFR 200.403.
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Professional Development Use of Funds
When determining Title I, Part A use of funds allowability, an LEA/campus should always reference the
Title I, Part A Use of Funds reference document.
Q1: Can Title I, Part A funds be used to send a teacher to a workshop?
A1: It depends. The campus/LEA must be able to show that the workshop is an integral part of the
teacher’s development plan to improve in one or more of the areas described on the previous two
pages. Additionally, the campus/LEA must refer to the Title I, Part A Use of Funds reference
document to ensure that all use of funds criteria are met.
Q2: What is considered evidence-based?
A2: Section 8101(21)(A) of the ESEA defines evidence-based as “…the term ‘evidence-based,’ when
used with respect to an LEA, or school activity, means an activity, strategy, or intervention that –
(i) demonstrates a statistically significant effect on improving student outcomes or other relevant
outcomes based on –
(I) strong evidence from at least one well-designed and well-implemented experimental
study;
(II) moderate evidence from at least one well-designed and well-implemented quasi-
experimental study; or
(III) promising evidence from at least one well-designed and well-implemented
correlational study with statistical controls for selection bias; or
(ii) demonstrates a rationale based on high-quality research findings or positive evaluation that
such activity, strategy, or intervention is likely to improve student outcomes or other relevant
outcomes; and
(iii) includes ongoing efforts to examine the effects of such activity, strategy, or intervention.”
For detailed information and guidance on the definition of “Evidence-Based,” see USDE Non-
Regulatory Guidance: Using Evidence to Strengthen Education Investments.
Q3: Can Title I, Part A funds be used to provide teachers with stipends to attend professional
development outside of their work schedule (for example, after hours, during the summer or on
weekends)?
A3: It depends. The campus/LEA must be able to show that the workshop is an integral part of the
teacher’s development plan to improve in one or more of the areas described on the previous two
pages. Additionally, the campus/LEA must refer to the Title I, Part A Use of Funds reference
document to ensure that all use of funds criteria are met.
Q4: Can Title I, Part A funds be used to provide new teachers with stipends to attend new teacher
orientation which is considered outside of their contracted workdays?
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A4: It depends. The campus/LEA must be able to show that the workshop is an integral part of the
teacher’s development plan to improve in one or more of the areas described on the previous two
pages. New teacher orientations are known for providing general information about campus/LEA
policies and procedures and in part do not focus on improving student academic achievement
related to the State’s challenging academic standards. Additionally, such orientations may not
meet standard for professional development activities that are sustained (not stand-alone, 1-day,
or short-term workshops), intensive, collaborative, job-embedded, data-driven, and classroom-
focused. If a campus/LEA determines that it meets the professional development requirements
noted in the ESSA definition for professional development, they will also need to refer to the Title
I, Part A Use of Funds reference document to ensure that all use of funds criteria are met.
Q5: Can Title I, Part A funds be used to pay for professional development for music and physical
education teachers?
A5: Professional development is an allowable use of funds under Title I, Part A, as long as it is being
provided for Title I, Part A teachers on a Title I, Part A Schoolwide program campus or teachers
providing services to Title I, Part A students on a Targeted Assistance program campus, and the
use of funds steps and requirements are followed as per the Title I, Part A Use of Funds
document. The LEA needs to be able to document how the activity meets the intent and purpose
of the Title I, Part A program, which is to provide all children significant opportunity to receive a
fair, equitable, and high-quality education, and to close educational achievement gaps. The LEA
would also need to ensure it is compliant with the Supplement, Not Supplant (SNS) requirements
associated with Title I, Part A. For Title I, Part A, the LEA would meet the SNS requirement by
having a valid SNS methodology or Statement of Exemption.
Q6: If a Title I, Part A campus is operating a targeted assistance program and all the teachers on the
campus have at least 1 Title I, Part A student in their classroom, can Title I, Part A funds be used
for campus-wide Professional Development for all of them?
A6: Professional development is an allowable use of funds under Title I, Part A, as long as it is being
provided for Title I, Part A teachers on a Title I, Part A Schoolwide program campus or teachers
providing services to Title I, Part A students on a Targeted Assistance program campus and the use
of funds steps and requirements are followed as per the Title I, Part A Use of Funds
document. The LEA needs to be able to document how the activity meets the intent and purpose
of the Title I, Part A program which is to provide all children significant opportunity to receive a
fair, equitable, and high-quality education, and to close educational achievement gaps. The LEA
would also need to ensure it is compliant with the Supplement, Not Supplant (SNS) requirements
associated with Title I, Part A. For Title I, Part A, the LEA would meet the SNS requirement by
having a valid SNS methodology or Statement of Exemption.
*Q7: Is it allowable to use Title I, Part A funds for professional development activities for a school
nurse?
*A7: It would be difficult to justify how the use of campus Title I, Part A funds for professional
development for a school nurse meets the intent and purpose of the Title I, Part A program, which
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is to provide all children significant opportunity to receive a fair, equitable, and high-quality
education, and to close educational achievement gaps. However, if the LEA is able to document
how the activity meets the intent and purpose of the Title I, Part A program, the LEA may choose
to use Title I, Part A funds for such purpose. Professional development is an allowable use of
funds under Title I, Part A, as long as it is being provided for staff on a Title I, Part A Schoolwide
program campus or staff providing services to Title I, Part A students on a Targeted Assistance
program campus, and the use of funds steps and requirements are followed as per the Title I, Part
A Use of Funds document.
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Supplies and Materials Use of Funds
When determining Title I, Part A use of funds allowability, an LEA/campus should always reference the
Title I, Part A Use of Funds reference document.
Q1: Our LEA wants to purchase a print instructional resource to send home to parents who do not
have technology available. We want to use Title I, Part A funds to pay for this for the eligible
campuses and will use other funds for the non-Title I funds. While this has become a district
initiative due to COVID-19, it is mostly an equity issue for students and families who are unable
to afford multiple devices, or any, to complete schoolwork. We are hoping to also purchase
summer school materials to send home to lessen the summer slide for all students. Is this an
allowable Title I, Part A use of funds?
A1: Elements of this question are answered in the Federal Funding & Grants COVID 19 FAQ Document
(5/7/2020) published on the TEA website referenced below:
Eligible Uses of Grant Funds Section
2. Can LEAs use federal grant funds to provide hotspots for students without home
Internet access or other costs associated with Learning from Home programs? Updated
April 14, 2020
Many school systems around the state are working to expand wireless hotspot locations in
communities where free commercial Internet services are not otherwise available. Please
document all costs associated with these expenditures, in anticipation that additional
funding streams may become available as Congress continues to authorize financial
support for COVID-19.
In the meantime, there are many sources of funds currently available to be redeployed for
these types of purposes:
ESSA, Title I, Part A served Schoolwide campuses may use their Title I, Part A funds
to provide internet hot spots, technology resources, and other at home learning
costs as long as it is identified in the campus comprehensive needs assessment
(CNA) as a need.
Note: As long as the LEA has the required supplement, not supplant methodology
documented and implemented, there is not a supplanting issue.
ESSA, Title IV, Part A may also be a potential federal fund source. However, Title IV has the
traditional rules of supplant so it is only allowable if the LEA has not previously spent state
or local funds for the same costs this year or in the prior year.
Other state or local funds may also be used for these types of activities, but keep in mind it
may cause a supplant issue for the use of ESSA, Title IV, Part A funds as described above.
Please refer to the Title I, Part A Use of Funds document as well.
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Q2: Our Homeless Department has requested to purchase face coverings for teachers and students
that are tutoring and/or being tutored at local homeless shelters. Would this be allowable with
Title I, Part A funds?
A2: Costs associated with the purchasing of face coverings directly related to and necessary to carry
out the objectives of the grant are allowable under Title I, Part A as long as the LEA meets the
requirements as noted on the Title I, Part A Use of Funds document.
Q3: Can cap and gowns be purchased with Title I Part A funds?
A3: Costs associated with the purchasing of caps and gowns for students are allowable under Title I,
Part A as long as the LEA meets the Title I, Part A Use of Funds requirements as noted on the Title
I, Part A Use of Funds document. The use of funds would need to have been identified in the
comprehensive needs assessment and noted in the campus improvement plan. The LEA should
consider purchasing the caps and gowns and retaining them for future use.
Additionally, the caps and gowns could only be purchased for students attending schoolwide
campuses as long as the LEA has a valid SNS Methodology or a Statement of Exemption in place. If
a campus is a Targeted Assistance campus, the LEA would have to ensure that only students
identified as most in need receive the Title I, Part A services. If the students attend non-Title I
campuses, this would not be an allowable use of funds for those campuses.
Q4: Scenario: Schools A, B, C & D were Title I, Part A Schoolwide Campuses in 2019-2020; Schools A
& B fell out of Title I eligibility in 2020-2021; Schools C & D remain Title I, Part A Schoolwide
Campuses in 2020-2021
Question: If electronic devices were purchased with Title I, Part A funds for students in Schools
A, B C & D in 2019-2020 and were issued to students, does the LEA have to take the devices from
students in Schools A & B for 2020-2021 and transfer the devices for use in Schools C & D in
2020-2021?
A4: There are 2 options your LEA has to ensure compliance with EDGAR.
Option 1: The LEA would determine if there is a need for the devices at any Title I, Part A
campuses. If yes, the devices would need to be transferred to the Title I, Part A campuses
where there is a need. If no, the LEA would need to document that such a need doesn’t
exist, why a need doesn’t exist and how the LEA made that determination, and then
proceed to determine if there is a need for the devices in any other Federal Program. If
yes, the devices would need to be transferred to the other Federal Program where there is
a need. If no, the LEA would need to document that such a need doesn’t exist, why a need
doesn’t exist and how the LEA made that determination.
If the LEA determines and documents that a need doesn’t exist for the devices in any
Title I, Part A campus nor in any other Federal Program, then the devices can remain on the
non-Title I, Part A campuses. Maintain documentation locally in the case of an audit.
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Option 2: The LEA can purchase them at the depreciated rate with local/state funds and
the funds from the purchase would go back into the Title I, Part A Program. This would
need to be documented locally in the case of an audit.
Q5: I have a question regarding the possibility of leasing computers with Title I, Part A funds. Could
you tell me where I might find guidance on this and if it is an allowable use of funds?
A5: Costs associated with the purchasing or leasing of computers are allowable under Title I, Part A as
long as the LEA meets the requirements noted on the Title I, Part A Use of Funds document.
As per the Budgeting Costs Guidance Handbook, rentals and leases for equipment, including the
rental or lease of computers are considered Professional and Contracted Services (6200) costs that
do not require specific approval.
Q6: I received a request to purchase an instructional software program for special education
students only that are at a Title I, Part A campus. Is this allowable?
A6: Costs associated with software programs used to support students are allowable under Title I,
Part A as long as the LEA meets the requirements noted in the Title I, Part A Use of Funds
document. The use of funds would need to have been identified in the comprehensive needs
assessment and noted in the campus improvement plan.
If all the students will be attending Title I, Part A schoolwide campuses, it shouldn’t be an
issue. On a targeted assistance campus, services should only be provided to students identified as
most in need to receive the Title I, Part A services.
Q7: A Title I, Part A schoolwide campus would like to install a Smart TV to enhance the music and art
program. Is this allowable if they include it in the CIP?
A7: The LEA would need to ensure that they are following the steps and requirements for Title I, Part A
use of funds as per the Title I, Part A Use of Funds document. The LEA would specifically need to
be able to document how this use of funds is necessary to carry out the intent and purpose of
Title I, Part A, which is to provide all children significant opportunity to receive a fair, equitable,
and high-quality education, and to close educational achievement gaps. Additionally, the use of
funds would need to have been identified in the comprehensive needs assessment and included in
the campus improvement plan.
Q8: Is it allowable under Title I, Part A to purchase face coverings, gloves, hand sanitizer, zip-lock
bags, and other health and safety-related items for students to use?
A8: Costs associated with the purchasing of face coverings, gloves, hand sanitizer, zip-lock bags, and
other health and safety-related items directly related to and necessary to carry out the objectives
of the grant are allowable under Title I, Part A, as long as the LEA meets the requirements noted
on the Title I, Part A Use of Funds document.
Although these items could possibly be an allowable expense, as described above, there might be
better options: such as using Title IV, Part A funds or school safety funds.
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Q9: Can we purchase face coverings for homeless students? Is there an exception to use the Title I,
Part A set-aside funds for the homeless?
A9: The LEA can use the Title I, Part A funds reserved at the LEA level for services to Homeless
students to purchase face coverings for homeless students as long as the need is identified in the
comprehensive needs assessment and all other steps and requirements are followed as per the
Title I, Part A Use of Funds document.
Q10: Is it allowable to spend 2019-2020 Title 1 funds on computer software/programs/licenses to be
used for this upcoming school year (2020-2021)?
A10: Since the end date of the 2019-2020 ESSA Federal Consolidated Grant was extended to September
30, 2021, costs associated with software programs/licenses used to support students in 2020-2021
from 2019-2020 Title I, Part A funds are allowable under Title I, Part A as long as the LEA meets the
requirements noted on the Title I, Part A Use of Funds document. The use of funds would need to
have been identified as a need in the 2020-2021 comprehensive needs assessment and noted in
the 2020-2021 campus improvement plan.
If all the students will be attending Title I, Part A schoolwide campuses, it shouldn’t be an
issue. On a targeted assistance campus, services should only be provided to students identified as
most in need to receive the Title I, Part A services.
Additional information related to the extension of the 2019-2020 ESSA Federal Consolidated Grant
can be found in the News Bulletin sent out on June 26, 2020.
Q11: Is it allowable to use Title I, Part A funds to purchase laptops that will be utilized to provide
tutoring and instructional services for homeless students?
A11: It is an allowable use of Title I, Part A funds reserved at the LEA level for Services to Homeless
Students to purchase laptops that will be utilized to provide tutoring and instructional services for
homeless students. As with any use of Title I, Part A funds, the LEA would need to follow the steps
and requirements noted in the Title I, Part A Use of Funds document.
Q12: Is it allowable to use Title I, Part A funds to purchase teacher desktop computers?
A12: Desktop computers for teacher use (instruction) at a schoolwide campus is an allowable use of
Title I, Part A funds, as long as the LEA follows the steps and requirements as per the Title I, Part A
Use of Funds document. The LEA needs to be able to document how the activity meets the intent
and purpose of the Title I, Part A program, which is to provide all children significant opportunity
to receive a fair, equitable, and high-quality education, and to close educational achievement
gaps. The use of funds would need to have been identified in the comprehensive needs
assessment and noted in the campus improvement plan.
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Q13: A campus would like to purchase mounted projectors for the family engagement spaces used on
the campus. The campus would provide monthly parent and family engagement (PFE) events
and provide weekly before and after school events. Can the campus use the Title I, Part A LEA
PFE reserved funds to purchase the projectors?
A13: The LEA would need to ensure that they are following the steps and requirements for Title I, Part A
use of funds as per the Title I, Part A Use of Funds document. The LEA would specifically need to
be able to document how this use of funds is necessary to carry out the intent and purpose of
Title I, Part A, which is to provide all children significant opportunity to receive a fair, equitable,
and high-quality education, and to close educational achievement gaps. Additionally, the use of
funds would need to have been identified in the comprehensive needs assessment and included in
the campus improvement plan.
The LEA would also need to ensure that they are following the requirements for PFE reserved
funds which are noted in ESSA Section 1116(a)(3)(D)(i-v) referenced below.
Funds reserved to carry out parent and family engagement activities shall be used to carry out
activities and strategies that are consistent with the LEA’s parent and family engagement policy,
including at least one of the following:
• Supporting schools and nonprofit organizations in providing professional development for LEA
and school personnel regarding parent and family engagement strategies, which may be
provided jointly to teachers, principals, other school leaders, specialized instructional support
personnel, paraprofessionals, early childhood educators, parents, and family members.
• Supporting programs that reach parents and family members at home, in the community, and
at school.
• Disseminating information on best practices focused on parent and family engagement,
especially best practices for increasing the engagement of economically disadvantaged parents
and family members.
• Collaborating, or providing subgrants to schools to enable such schools to collaborate, with
community-based or other organizations or employers with a record of success in improving
and increasing parent and family engagement.
• Engaging in any other activities and strategies that the LEA determines are appropriate and
consistent with the LEA’s parent and family engagement policy.
Q14: Is it allowable to use Title I, Part A funds to purchase CPR mannequins to train students?
A14: The LEA would need to ensure that they are following the steps and requirements for Title I, Part A
use of funds as per the Title I, Part A Use of Funds document. The LEA would specifically need to
be able to document how this use of funds is necessary to carry out the intent and purpose of
Title I, Part A, which is to provide all children significant opportunity to receive a fair, equitable,
and high-quality education, and to close educational achievement gaps. Additionally, the use of
funds would need to have been identified in the comprehensive needs assessment and included in
the campus improvement plan.
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Q15: Is it allowable to use Title I, Part A funds to purchase security cameras for Title I, Part A
Schoolwide campuses?
A15: It would be difficult to justify/document that purchasing security cameras would meet the intent
and purpose of Title I, Part A, which is to provide all children significant opportunity to receive a
fair, equitable, and high-quality education, and to close educational achievement gaps. However,
if the LEA can justify and document such an expense, they would need to follow the steps and
requirements for Title I, Part A use of funds as per the Title I, Part A Use of Funds
document. Additionally, the use of funds would need to have been identified in the
comprehensive needs assessment and included in the campus improvement plan.
Q16: One of our Title I, Part A Schoolwide campuses is planning a parent engagement event whose
purpose is to provide parents with community resources and communicate next school year’s
district and school initiatives. The parent coordinator at the school would like to be able to
provide parents with a canvas tote bag with the campus logo and fill it with pamphlets from
local community resources, snacks, and a water bottle with the campus logo. Are these costs
allowable use of Title I, Part A funds?
A16: The guidance noted in the most recent version of the TEA Budgeting Costs Guidance Handbook
states the following as it relates to the items referenced.
Page 15 “Supplies and Materials (6300)”
Grant funds may not be used for the following:
• Supplies and materials, including electronic devices, for personal use. Must be used only
for grant-related activities.
• Costs associated with awards banquets, ceremonies, celebrations, and social events
• Cell phones for personal use
• Gifts or items that could be construed as a gift
• Souvenirs, memorabilia, or promotional items (such as T-shirts, caps, tote bags, key chains,
or imprinted pens)
NOTE: Refer to the “Other Specific Items of Cost” section of this handbook for information on
incentives to participate and awards for recognition.
Thus, it would be an unallowable use of Title I, Part A funds to purchase the promotional items
referenced.
Q17: Is it allowable to use Title I, Part A funds to purchase school supplies for students identified as
socioeconomically disadvantaged?
A17: Costs associated with the purchasing of school supplies used to support students attending Title I,
Part A schoolwide campuses are allowable under Title I, Part A as long as the LEA meets the Title I,
Part A Use of Funds requirements as noted on the Title I, Part A Use of Funds document. On a
targeted assistance campus, services should only be provided to students identified as most in
need to receive the Title I, Part A services. The use of funds would need to have been identified as
a need in the comprehensive needs assessment and noted in the campus improvement plan.
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Q18: Is it allowable to use Title I, Part A funds to purchase clothing items such as school uniforms,
shoes, socks, and basic hygiene items for students experiencing homeless?
A18: Costs associated with the purchasing of clothing items such as school uniforms, shoes, socks, and
basic hygiene items for students experiencing homelessness are allowable under Title I, Part A
regardless of whether a campus is Title I, Part A served. The LEA can utilize the funds reserved at
the LEA level for services to homeless students. The homeless set-aside may be used to provide
services to homeless students in Title I schools that are not ordinarily provided to other Title I
students. The USDE Education for Homeless Children and Youths Program Non-Regulatory
Guidance states the following (Pages 40-41 Question M-4):
“Title I, Part A funds may be used to provide a wide variety of services to homeless students. In
addition to providing services to assist homeless students in meeting the State’s challenging
academic standards, Title I, Part A funds may be used to provide services to homeless children and
youths, including those in Title I schools, that may not ordinarily be provided to other Title I
students. (ESEA section 1113(c)(3)(C)(ii)). For example, to help homeless students effectively take
advantage of educational opportunities, an LEA may use Title I, Part A funds to provide, where
appropriate, items or services including, but not limited to—
• Items of clothing, particularly if necessary to meet a school’s dress or uniform
requirement;
• Clothing and shoes necessary to participate in physical education classes;
• Student fees that are necessary to participate in the general education program;
• Personal school supplies such as backpacks and notebooks;
• Birth certificates necessary to enroll in school;
• Immunizations;
• Food;
• Medical and dental services;
• Eyeglasses and hearing aids;
• Counseling services to address anxiety related to homelessness that is impeding learning;
• Outreach services to students living in shelters, motels, and other temporary residences;
• Extended learning time (before and after school, Saturday classes, summer school) to
compensate for lack of quiet time for homework in shelters or other overcrowded living
conditions;
• Tutoring services, especially in shelters or other locations where homeless students live;
• Parental involvement specifically oriented to reaching out to parents of homeless students;
• Fees for AP and IB testing;
• Fees for college entrance exams such as SAT or ACT; and
• GED testing for school-age students.
Two principles govern the use of Title I, Part A funds to provide such services to homeless
students. First, the services must be reasonable and necessary to assist homeless students to take
advantage of educational opportunities. (ESEA section 1113(c)(3)(A); 2 CFR § 200.403(a)). Second,
Title I, Part A funds must be used only as a last resort when funds or services are not available
from other public or private sources, such as the USDA’s National School Lunch Program and
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Breakfast Program, public health clinics, or local discretionary funds (sometimes provided by the
PTA) used to provide similar services for economically disadvantaged students generally. (See
ESEA section 1115(e)(2)).”
Q19: May Title I, Part A funds be used to purchase band instruments with approximately half of the
LEA’s Title I, Part A allocation?
A19: The LEA would need to ensure that they are following the steps and requirements for Title I, Part A
use of funds as per the Title I, Part A Use of Funds document. The LEA would specifically need to
be able to document how this use of funds is necessary to carry out the intent and purpose of
Title I, Part A, which is to provide all children significant opportunity to receive a fair, equitable,
and high-quality education, and to close educational achievement gaps. As noted in the Title I,
Part A Use of Funds document, the amount should also be reasonable. It could be difficult to
justify that using half of the LEA’s Title I, Part A allocation for band instruments is reasonable and
necessary to carry out the intent and purpose of the Title I, Part A program. The LEA would also
need to consider the rank and serve requirements related to campus allocations to ensure that
the funds used to purchase the instruments are from a campus allocation. However, if the LEA
can document and provide a rationale that justifies the use of funds, it may use Title I, Part A
funds. In the case of an audit, the LEA would need to have auditable documentation justifying the
use of funds. Additionally, the use of funds would need to have been identified in the
comprehensive needs assessment and included in the campus improvement plan.
Q20: May Title I, Part A funds be used to purchase furniture (i.e., shelves for a library, locked cabinets
for chemical storage in a science lab)?
A20: The LEA would need to ensure that they are following the steps and requirements for Title I, Part A
use of funds as per the Title I, Part A Use of Funds document. The LEA would specifically need to
be able to document how this use of funds is necessary to carry out the intent and purpose of
Title I, Part A, which is to provide all children significant opportunity to receive a fair, equitable,
and high-quality education, and to close educational achievement gaps. Additionally, the use of
funds would need to have been identified in the comprehensive needs assessment and included in
the campus improvement plan (CIP).
When a campus writes a CIP, they usually tie their activities to strategies and goals. If they can tie
the purchase of furniture to an activity, strategy, and goal, then they could evaluate the
effectiveness of how the use of funds was in meeting the goal identified. They could also use this
rationale as part of their documentation related to how the use of funds is necessary to carry out
the intent and purpose of the Title I, Part A program.
On another note, when it comes to furniture, the Budgeting Costs Guidance Handbook does
mention that it is possible that furniture could be capitalized depending on the cost of the
furniture and local policies/procedures for capital outlay. In that case, “all capital outlay requires
specific approval from TEA.”
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Q21: Is it allowable use of Title I, Part A funds for a schoolwide campus to purchase two-way
communication radios?
A21: It would be difficult to justify/document that purchasing two-way communication radios would
meet the intent and purpose of Title I, Part A, which is to provide all children significant
opportunity to receive a fair, equitable, and high-quality education, and to close educational
achievement gaps. However, if the LEA can justify and document such an expense, they would
need to follow the steps and requirements for Title I, Part A use of funds as per the Title I, Part A
Use of Funds reference document. Additionally, the use of funds would need to have been
identified in the comprehensive needs assessment and included in the campus improvement plan.
Q22: Is it allowable use of Title I, Part A funds for a schoolwide campus to purchase furniture?
A22: The LEA would need to ensure that they are following the steps and requirements for Title I, Part A
use of funds as per the Title I, Part A Use of Funds reference document. The LEA would specifically
need to be able to document how this use of funds is necessary to carry out the intent and
purpose of Title I, Part A, which is to provide all children significant opportunity to receive a fair,
equitable, and high-quality education, and to close educational achievement gaps. Additionally,
the use of funds would need to have been identified in the comprehensive needs assessment and
included in the campus improvement plan (CIP).
When a campus writes a CIP, it usually ties its activities to strategies and goals. If the campus can
tie the purchase of furniture to an activity, strategy, and goal, then it could evaluate the
effectiveness of how the use of funds contributed to meeting the goal identified. The campus
could also use this rationale as part of its documentation related to how the use of funds is
necessary to carry out the intent and purpose of the Title I, Part A program.
On another note, when it comes to furniture, the Budgeting Costs Guidance Handbook does
mention that it is possible that furniture could be capitalized depending on the cost of the
furniture and local policies/procedures for capital outlay. In that case, “all capital outlay requires
specific approval from TEA.”
Q23: Is it allowable use of Title I, Part A funds for a schoolwide campus to purchase furniture and/or
supplies for an Art class?
A23: The LEA would need to ensure that it is following the steps and requirements for Title I, Part A use
of funds as per the Title I, Part A Use of Funds reference document. The LEA would specifically
need to be able to document how this use of funds is necessary to carry out the intent and
purpose of Title I, Part A, which is to provide all children significant opportunity to receive a fair,
equitable, and high-quality education, and to close educational achievement gaps. Additionally,
the use of funds would need to have been identified in the comprehensive needs assessment and
included in the campus improvement plan (CIP).
When a campus writes a CIP, it usually ties its activities to strategies and goals. If the campus can
tie the purchase of furniture to an activity, strategy, and goal, then it could evaluate the
effectiveness of how the use of funds contributed to meeting the goal identified. The campus
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could also use this rationale as part of its documentation related to how the use of funds is
necessary to carry out the intent and purpose of the Title I, Part A program.
On another note, when it comes to furniture, the Budgeting Costs Guidance Handbook does
mention that it is possible that furniture could be capitalized depending on the cost of the
furniture and local policies/procedures for capital outlay. In that case, “all capital outlay requires
specific approval from TEA.”
Keep in mind that on a schoolwide program campus, the LEA may use funds to upgrade the entire
educational program of a school that meets Title I, Part A eligibility criteria. Thus, there is no
distinction to be made as it relates to using funds for elective and/or core content courses.
Q24: Is it allowable use of Title I, Part A funds for a schoolwide campus to purchase drawstring bags
for a campus parent and family engagement activity?
A24: The LEA should be cautious with the use of funds being requested under the Title I, Part A
program because it may be considered to be a promotional item and as per the guidance below,
promotional items are an unallowable use of funds.
The guidance noted in the most recent version of the TEA Budgeting Costs Guidance Handbook
states the following as it relates to the items referenced.
Page 15 “Supplies and Materials (6300)”
Grant funds may not be used for the following:
•Supplies and materials, including electronic devices, for personal use. Must be used only
for grant-related activities.
•Costs associated with awards banquets, ceremonies, celebrations, and social events
•Cell phones for personal use
•Gifts or items that could be construed as a gift
•Souvenirs, memorabilia, or promotional items (such as T-shirts, caps, tote bags, key
chains, or imprinted pens)
NOTE: Refer to the “Other Specific Items of Cost” section of the TEA Budgeting Costs Guidance
Handbook for information on incentives to participate and awards for recognition.
However, if the LEA can document and maintain such documentation locally justifying that the
purchase is not a promotional item and that it would meet the intent and purpose of the Title I,
Part A program, then the LEA can proceed with using Title I, Part A funds for the drawstring bags.
Such documentation would need to be readily available and provided to an auditor for
consideration in the case of an audit. The need for this particular use of funds would need to have
been identified in the comprehensive needs assessment and noted in the campus improvement
plan. As with any other Title I, Part A use of funds, the LEA would need to follow the steps and
requirements noted in the Title I, Part A Use of Funds document.
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Q25: Is it allowable use of Title I, Part A funds to purchase hygiene items for students who are not
experiencing homelessness?
A25: It would be difficult for an LEA/campus to justify and document that the purchase of hygiene items
for students who are not experiencing homelessness with Title I, Part A funds would be a
reasonable and necessary expense to meet the intent and purpose of the Title I, Part A program.
The LEA/campus could reach out to other public or private sources in the community used to
provide such items for economically disadvantaged students.
If the LEA/campus is able to justify such a purchase with Title I, Part A funds as being reasonable
and necessary to meet the intent and purpose of the Title I, Part A program, it would need to
maintain documentation locally to that effect in the case of an audit. Such documentation would
also need to include documentation that other public or private sources in the community were
not available to provide such items.
Q26: Can Title I, Part A funds be used to purchase flexible seating options for students?
A26: The intent and purpose of the Title I, Part A program is to provide all children significant
opportunity to receive a fair, equitable, and high-quality education, and to close educational
achievement gaps. If the LEA can justify and document that the use of funds on a schoolwide
campus meets the intent and purpose of the Title I, Part A program and such use is based on the
needs identified in the most current comprehensive needs assessment and documented in the
most current campus improvement plan, the use of Title I, Part A funds for the purchase of flexible
seating options for students would be allowable as long as the other steps and requirements
noted in the Title I, Part A use of funds reference document have been met.
Q27: Is it allowable to use Title I, Part A funds to pay for medication needed to meet the academic
needs of a student experiencing homelessness?
A27: Use of Title I, Part A LEA-reserved funds for homeless children and youth could be justified for
medical and dental services for homeless students if the following two principles are met in
addition to the items listed on the Title I, Part A Use of Funds Reference Document. As per the
USDE Education for Homeless Children and Youth Program Non-Regulatory Guidance, two
principles govern the use of Title I, Part A funds to provide such services to homeless students.
First, the services must be reasonable and necessary to assist homeless students to take
advantage of educational opportunities. (ESEA section 1113(c)(3)(A); 2 CFR § 200.403(a)). Second,
Title I, Part A funds must be used only as a last resort when funds or services are not available
from other public or private sources, such as the USDA’s National School Lunch Program and
Breakfast Program, public health clinics, or local discretionary funds (sometimes provided by the
PTA) used to provide similar services for economically disadvantaged students generally. Best
practice is to maintain documentation locally for reaching out to at least 3 entities for services.
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Q28: Is it allowable to use Title I, Part A funds to purchase clear backpacks for all students on Title I,
Part A campuses in an LEA?
A28: It would be difficult to justify that this type of expense for all students on Title I, Part A campuses
in your LEA would be reasonable and necessary to meet the intent and purpose of the Title I,
Part A program, which is to provide all children significant opportunity to receive a fair, equitable,
and high-quality education, and to close educational achievement gaps. However, if the LEA feels
that it can justify that this type of expense meets the intent and purpose and is reasonable and
necessary, the LEA should follow the steps and requirements noted in the Title I, Part A Use of
Funds Reference Document and keep the documentation to that effect. In the case of an audit,
the auditor would make the final determination of allowability.
Use of Title I, Part A LEA-reserved funds for homeless children and youth could be justified for
purchasing the clear backpacks for homeless students if the following two principles are met in
addition to the items listed on the Title I, Part A Use of Funds Reference Document. As per the
USDE Education for Homeless Children and Youth Program Non-Regulatory Guidance, two
principles govern the use of Title I, Part A funds to provide such services to homeless students.
First, the services must be reasonable and necessary to assist homeless students to take
advantage of educational opportunities. (ESEA section 1113(c)(3)(A); 2 CFR § 200.403(a)). Second,
Title I, Part A funds must be used only as a last resort when funds or services are not available
from other public or private sources, such as the USDA’s National School Lunch Program and
Breakfast Program, public health clinics, or local discretionary funds (sometimes provided by the
PTA) used to provide similar services for economically disadvantaged students generally.
*Q29: Is it allowable to use Title I, Part A funds to purchase t-shirts that the “watchdog” volunteers can
wear while they are on campus?
*A29: It would be difficult to justify how the use of campus Title I, Part A funds to pay for t-shirts that the
“watchdog” volunteers can wear while they are on campus meets the intent and purpose of the
Title I, Part A program, which is to provide all children significant opportunity to receive a fair,
equitable, and high-quality education, and to close educational achievement gaps. If the LEA
chooses to use Title I, Part A funds for that purpose, it would be up to the LEA to document how
the activity meets the intent and purpose of the Title I, Part A program, and ensure that the use of
funds steps and requirements are followed as per the Title I, Part A Use of Funds document. In the
case of an audit, the auditor would make the determination of allowability.
*Q30: Is it allowable to use Title I, Part A funds to purchase flexible learning seating/tables?
*A30: The LEA would need to ensure that it is following the steps and requirements for Title I, Part A use
of funds according to the Title I, Part A Use of Funds reference document. The LEA would
specifically need to be able to document how this use of funds is necessary to carry out the intent
and purpose of Title I, Part A, which is to provide all children significant opportunity to receive a
fair, equitable, and high-quality education, and to close educational achievement gaps.
Additionally, the use of funds would need to have been identified in the comprehensive needs
assessment and included in the campus improvement plan (CIP).
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When a campus writes a CIP, it usually ties its activities to strategies and goals. If the campus can
tie the purchase of furniture to an activity, strategy, and goal, then it could evaluate how effective
the use of funds was in meeting the goal identified. The campus could also use this rationale as
part of its documentation for how the use of funds is necessary to carry out the intent and
purpose of the Title I, Part A program.
On another note, when it comes to furniture, the Budgeting Costs Guidance Handbook does
mention that it is possible that furniture could be capitalized depending on the cost of the
furniture and local policies/procedures for capital outlay. In that case, “all capital outlay requires
specific approval from TEA.
*Q31: Is it allowable to use Title I, Part A funds to provide clothing to migrant students who attend
Title I, Part A schoolwide program campuses?
*A31: As described in more detail below, except under very limited circumstances, an LEA may not use
Title I, Part A funds to purchase clothing for migrant students.
Section 1113(c)(3)(C)(ii) of the Elementary and Secondary Education Act of 1965 (ESEA) authorizes
an LEA to use Title I, Part A funds to provide services, such as purchasing clothing, for homeless
children and youth that are not ordinarily provided to other Title I, Part A students. This authority
only applies to homeless children and youth and, therefore, does not apply to other groups of
Title I, Part A students, such as migrant students served by Title I, Part A.
Under very limited circumstances, an LEA may use Title I, Part A funds to purchase clothing for
Title I students on an individual student basis. More specifically, under ESEA section 1115(e)(2)(B),
an LEA may use Title I, Part A to provide comprehensive services for a Title I student “as a last
resort” if “funds are not reasonably available from other public or private sources.” Such services
might include the purchase of clothing if such clothing is necessary to enable the student to
participate in school. Please note that an LEA would have to evaluate such need on a case-by-case
basis irrespective of a student being part of a particular subgroup (e.g., migrant students). In other
words, a student may not be provided clothing just by virtue of being a member of the migrant
student subgroup; there must be a student-specific need. Moreover, the cost of the clothing must
be reasonable for its purpose, and the LEA must have exhausted other sources of funds or
services, such as community clothing banks. We note that, while this authority is specific to
targeted assistance programs, the same principles would also apply similarly to a schoolwide
program if otherwise consistent with the school’s needs assessment and comprehensive
schoolwide plan.
We note that documentation of the LEA’s efforts to investigate other available resources is
important for ensuring compliance with the statute. It also serves as evidence of compliance in
case of State or Federal monitoring or audit.
