“Title I can pay for that.” These words sound like nails on a chalkboard to every Federal Programs Director across the nation. Teaching colleagues and administrators that Title I funds have specific allowable uses can be challenging. It is especially difficult to make our non-federal friends understand the Supplement, Not Supplant methodology we follow. How can we help our leaders and coworkers understand that we use Title I funds on activities that supplement the education each child is receiving through local obligation of funds? We take them back to high school chemistry: a LITMUS test.
L- Logical, reasonable and allowable
When I was a federal programs director, I relied heavily on instinct as my first tier of decision-making. When someone asked me if I could write an activity or an expense into a grant, I always started by asking myself three questions: Is this a logical request? Is this a necessary request? Is this an allowable request? Some requests really do depend on context. Consider this example. Can we use Title I funds to purchase paper plates, coffee filters, food coloring and sugar? Your first instinct might be to say no. However, in this example there is a logical reason for this request for kitchen supplies. The teacher requesting these items is the lead teacher in a STEAM lab (Science Technology, Engineering, Arts, and Math lab). The STEAM lab is funded by Title I as a supplement to the core curriculum in an at-risk neighborhood where children have minimal exposure to hands-on, explorative learning. This additional information provides logic, necessity and allowability to make this purchase. Bravo! Write it in the grant, obtain approval by your state department of education, and submit the purchase order. (Pro Tip: The Code of Federal Regulations (2 CFR) uses the terminology “Reasonable, necessary, and allocable.” This is another way to quiz yourself on any requests you receive.)
I- Improves basic programs
It’s written in the title of the grant! Title I, Part A: Improving Basic Programs Operated by Local Education Agencies is a grant that is designed to enhance existing programing. How do we ensure that funds are being used to improve upon what we already have in place? Always start with a comprehensive needs assessment (CNA). Lesli Laughter, author of Continuous Improvement without Continuous Stress: Strategies for School Leaders, refers to the CNA as, “The King of Everything.” When someone asks if Title I can pay for an expense, go back to your CNA. Is the data supporting the spending request? To experience meaningful improvement of our basic programs, we must remain focused on our goals. Piecing together a Title I grant with disconnected requests, none of which collectively address our goals, will only lead to an ineffective use of resources. If your district is not engaging in a meaningful CNA process with stakeholder involvement, you are missing the opportunity to use Title I funds in the manner they are intended. The only people who truly suffer in an ineffective grant strategy are the students. (Pro Tip: It is never too late to reevaluate your processes and to refocus on your core values.)
T- Targets identified needs
The CNA identifies needs, and all expense requests should target those needs. Whether it is requests for professional learning services, summer learning opportunities for students, materials or supplies, technology, personnel, or even transportation, it must target an identified need. When someone asks you to cover an expense with Title I funds, ask them to identify how this request targets district needs. (Pro Tip: It is helpful if all stakeholders know the identified needs and goals so that their requests can remain aligned to system growth.)
M- Measurable outcomes
The results of our Title I efforts should be measurable, but this is not as difficult as it sounds. Considering the example of the teacher above who needs kitchen supplies for her STEAM lab activities, she may not have a final summative assessment to report. How can you measure that activity? Perhaps the measurement is more subjective, such as the percentage of students engaged in the activity. There are many ways to measure the effectiveness of your Title I plan. (Pro Tip: Don’t restrict your school system to quantitative data when you are considering Title I activities.)
U- Uniform Guidance
All federal grants must follow Uniform Guidance provided by the Office of Management and Budget. This guidance provides us with allowable costs and the rules we must follow when expending Title I funds. If you do not currently have a copy of a handbook on EDGAR (Education Department General Administrative Regulations) in your office, order one now! (Pro Tip: Title I can pay for that.) If a purchase request makes you feel a little unsettled, just look it up in your handbook. If you surmise that the answer is no, then you can use the handbook as evidence to support your decision. If your school system has a legal advisor, he or she can help you to understand some of the technical legal language in your EDGAR handbook, and can also be a great resource to help you make the best decisions.
S- Supplement, not supplant
This litmus test breaks down the Supplement, not Supplant requirements of Title I, Part A in an easy-to-remember format. The purpose of this evaluation process is to verify that Title I funds are being used to enhance existing services, rather than replacing local funding obligations. You can find the official guidance from the U.S. Department of Education here, but a web search of “Supplement, not Supplant” also brings you to a page with policies from state departments of education across our great country. These individual state policies are easier to read and, in some cases, substantially more informational.
When it comes to the age-old statement, “Title I can pay for that,” it depends on allowability, necessity, and local obligations. It is hard to say no, especially when we all want what is best for our students. It is also difficult to find a one-size-fits-all formula for what is or is not allowable. Using a strategy such as the LITMUS test can empower you to make the right decisions for your students, while also ensuring funding compliance for your district. If you want or need a little extra help with compliance, your educational partners at 806 Technologies have a team of ESSA experts ready to help. (Pro Tip: Our team of ESSA experts wrote this blog just for you. We hope you enjoyed reading it as much as we enjoyed writing it!)
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