Office of Accountability

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.

Last Updated: April 4, 2017