Q&A Regarding Use of the Template for Title IIA Recalculation for Non-Public/Private Schools
The following information contains responses to frequently asked questions using the template for the recalculation of Title II, Part A, funds to provide equitable services to non-public/private schools.
Q: Does A1 mean I should use 2010-11 enrollment
data for all recalculations?
A: No. It means
that the most current enrollment aligned with each school year should be
used (e.g. 2007-08 enrollment for the 2007-08 FY). When you get to 2011-12
or 2012-13, the most current enrollment data right now is still 2010-11
(until the 11-12 enrollment is available).
Q: You gave us links to private school enrollment
data, but I don’t see the enrollment for our school district going back
from 2007 through 2012. Do I have to locate that myself?
A: Yes.
It should be in your BEDS data for each school year.
Q: I can only find one year of enrollment on
the link provided. Where is the rest?
A: The link
provides excel sheets. There are separate tabs at the bottom of the page
to access multiple years. There is also a small scroll bar at the bottom
right that runs right to left. You may have to scroll over to locate all
of the cells.
Q: I have five private schools in my district.
Do I only use the enrollment of one in the box for A2?
A: No.
Use the total enrollment of all of the private schools in your district
(e.g. School A=150, School B=300, School C=15, School D= 45, School E=59
for a total of 569.) In this example, you would use the total enrollment
number of 569 for A2.
Q: I don’t understand B2. What do all of these
items mean?
A: In reality, B2 asks you to total
the amount of Title II, Part A, funds that the district used for everything
EXCEPT professional development. Do not include the private school portion
here; use the district expenditures only.
Q: B3 asks me to subtract B2 from B1. Shouldn’t
the difference equal the amount that the district actually spent for professional
development in the school year that I am recalculating since it is the only
other allowable Title IIA expense that we could have considered?
A: Yes,
it should.
Q: C1 is confusing. Why are we going back to
FY 2001?
A: There were two discreet programs available
before NCLB that were rolled into NCLB from its inception. These prior
programs were Eisenhower Professional Development and Class Size Reduction.
A “hold harmless” provision was built into NCLB to make sure that non-public/private
schools would always be entitled to some amount of equitable services for
professional development. A decision was made to tie that “hold harmless”
amount to the 2001 Eisenhower and Class Size Reduction programs.
Q: If the district uses transferability to Title
I in the FY 2012-13, can we still transfer 100% of Title IIA funds as allowed
in this fiscal year?
A: Not if the district has
any non-public/private schools. At minimum, the “hold harmless” MUST be
reserved for the non-public schools before funds are transferred for the
purposes of Title I.
Q: How do I know what funds were spent for professional
development back in 2001? What do I do?
A: Check
to see if the district still has the fiscal records for 2001-02. If the
records still exist, investigate the amount of IIA money that was actually
used for professional development in BOTH the Eisenhower and the Class Size
Reduction and total that amount for C1.
Q: What if we don’t have the 2001 records?
A: Look
at the table provided below the template and use the Eisenhower amount in
its entirety for C1. Do not include the Class Size Reduction amount at
all.
Q: In D1, what if both amounts are the same?
A: Just
use one of the two amounts, either B3 or C1.
Q: Does the “hold harmless” amount in C1 change
for every fiscal year I am recalculating?
A: No.
It should be exactly the same for all of the years of recalculation because
the “hold harmless” is grounded in programs at one point in time – the 2001
fiscal year for Eisenhower Professional Development and Class Size Reduction.
Q: E1 gives me the amount that I have to share
with the non-public/private schools (e.g. $2,166.50). Does this mean that
the amount in E1 goes to EACH of the schools (e.g. School 1=$2,166.50, School
2=$2,166.50, School 3=$2,166.50, School 4=$2,166.50, School 5=$2,166.50).
A: No.
It is the total amount to be shared with ALL of the non-public/private schools.
The best way to equitably share with EACH school is to take the per pupil
amount in D1 (e.g. $3.50 per pupil) and multiply it by the enrollment number
for each school listed when you totaled the private school enrollment in
A2. For example, a per pupil amount of $3.50 x Private School A’s 150 students
equals $525 to be equitably shared with School A. Private School B’s enrollment
of 300 means the school is entitled to $1,225 in services [300 x 3.50=1,225].
Private School C (enrollment 15) would be entitled to $52.50 [15 x 3.50].
Private School D is $3.50 x 45 = $157.50, and Private School E would get
$3.50 x 59 = $206.50. The total of these five amounts should equal E1 [$525
+ $1,225 + $52.50 + $157.50 + $206.50 would be $2,166.50].
Q: What if a private school has always declined professional development
services under Title IIA? Do I still have to recalculate?
A: Yes. The private school may have declined services because the
amount of services available was too small to accept; however, the recalculation
may change the amount of services to the degree that the private school
may reconsider acceptance. The district must recalculate for all five years,
and if there are any additional amount of services available for any of
the years from 2007-08 through 2011-12, the district must notify the private
school and collaborate to reach a decision.
Q: After the five-year recalculation, the non-public school in my district
is entitled to a large increase in equitable services. The private school
has decided to transfer the balance to Title I. Is this allowable?
A: No. The equitable sharing portion to non-public schools is to
be used only for allowable professional development under Title II, Part
A. The non-public school cannot transfer funds or request that funds be
transferred. However, if the LEA chooses to transfer Title IIA funds for
the purposes of Title I, the LEA must now follow Title I rules to provide
equitable services to eligible Title I students in the private school(s).
The LEA decision to use transferability will change the Title I per pupil
amount that must be equitably shared with the private school(s).
Q: On the Field Memo, I am confused about the "Calculation of the
Hold Harmless Amount" for Line C1 in the template. What do I add together?
A: Here is a series of questions to ask that will lead you to the
amount for Line C1:
1) Does my district still have the detailed fiscal records that
my business official can access dating back to 2001-02? If yes,
move to question 2. If no, move to question 3.
2) Question 1 was "Yes." Next, can my business official
total the exact amounts within BOTH the Class Size Reduction budget
code AND the Eisenhower budget code that the DISTRICT ALONE (not
non-public schools) spent on professional development? If Yes,
THIS TOTAL BECOMES THE PREFERRED HOLD HARMLESS AMOUNT TO BE PLACED
IN C1.
3) Question 1 was "No." My district has NOT retained
the detailed fiscal records from 2001-02. I see that underneath
the template, there is a link to an excel sheet that provides the
amount of Eisenhower funds the district received back in 2001.
Do I use ONLY this total Eisenhower amount and ignore the Class
Size Reduction amount? YES, THIS EISENHOWER TOTAL NOW BECOMES THE
ALTERNATIVE HOLD HARMLESS AMOUNT TO BE PLACED IN C1.