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Title IV-A Program Overview
NH Title IV-A Student Support and Academic Enrichment Grant Program
This section of the toolkit will provide you with a general overview of the NH Title IV-A Student Support and Academic Enrichment program. The main areas of importance for developing a good districtwide Title IV-A program for your schools will be reviewed to help districts gain a general understanding of the components of a project fundable under Title IV-A.
The Every Student Succeeds Act (ESSA) is the most recent reauthorization of the Elementary and Secondary Education Act of 1965 (ESEA). ESSA continues the civil rights foundation of ESEA, reflecting our nation’s longstanding commitment to equity of opportunity for all students. The new law has a clear goal of ensuring our education system prepares every child to graduate from high school ready to thrive in college and careers. The 2015 reauthorization includes a number of provisions that promote equitable access to educational opportunity, including holding all students to high academic standards, ensuring meaningful action is taken to improve the lowest-performing schools and schools with underperforming student groups, and providing more children with access to high-quality pre-school learning opportunities. As we work to improve education outcomes for students the ultimate goal is to provide all students with a high-quality education.
Title IV, Part A, (also known as the Student Support and Academic Enrichment Grants or SSAE) in the 2015 reauthorized Elementary and Secondary Education Act supports our nation’s commitment to equity of opportunity for all students. The Title IV, Part A the Student Support and Academic Enrichment (SSAE) program is intended to ensure all children graduate from high school ready to thrive in college and careers by increasing the capacity of State education agencies (SEAs), local education agencies (LEAs), schools, and local communities to:
Among the key values set forth in the New Hampshire ESSA Consolidated State Plan is improving our education system through personalization and competency-based teaching and learning. The New Hampshire Title IV, part A program is designed to support this vision within a framework of preparing students for the future.
- provide all students with access to a well-rounded education,
- improve school conditions for student learning, and
- improve the use of technology in order to improve the academic achievement and digital literacy of all students.
Essential Elements of the Student Support and Academic Enrichment Grant program:
The Title IV-A Program at the NH Department of Education is supporting New Hampshire School Districts in their efforts to improve personalized learning and competency-based education through the development of programs and initiatives that ensure learning experiences are integrated with digital tools and resources literacy that enhance learning. Engaging students and school communities in activities that integrate digital tools and resources is a powerful way for schools and districts to move students towards future readiness. Title IV-A funds are intended to be used by districts to supplement an identified need in the district. The New Hampshire Title IV-A Program uses the Future Ready Framework, an evidence based framework for developing systemic personalized learning through visioning, planning, and implementation of school improvement activities, as a guide for districts seeking to determine program needs. The Future Ready District Leadership Survey is a tool that districts can use to determine where the needs are in their districts around 7 areas of the framework. The NH Title IV-A program modifies that framework slightly in order to focus the needs assessment on the three main areas supported by Title IV-A: well rounded education, safe and healthy schools, and effective use of technology. Districts can use the modified Future Ready District survey tool to find areas of need in their programs and focus their Title IV-A funding around activities that address those needs.
- Timeline: Applications submitted on a rolling basis through online Grants Management System.
- Period of Availability: 2018-19 Title IV, Part A funds will remain available for obligation by LEAs until September 30, 2020, per the “Tydings Amendment.”
- Program Assurances: Program assurances must be reviewed by the Superintendent/Charter School Administrator and must be provided to and reviewed with the LEA school board/board of trustees. The Superintendent/Charter School Administrator must then sign each of the program assurances the LEA plans to participate in and attach the assurances document to the district page of the Grants Management System. Download the Federal Assurances document.
Please note that Program Assurances are different than the General Assurances, which are aligned to the Uniform Grant Guidance.
- Needs Assessment: An LEA that receives at least $30,000 in SSAE program funds must conduct a comprehensive needs assessment that includes, at a minimum, a focus on the three content areas listed above. (ESEA section 4106(d)). The NH DOE is encouraging LEA’s to implement the Future-Ready Framework* needs assessment survey to yield results for designing their plan.
- Supplement not Supplant Requirement: These funds cannot be used in place of State or local funds that would have otherwise been used for such activities.
- Equitable Services: LEAs receiving Title IV, Part A funds must comply with sections 8501-8504 of the Every Student Succeeds Act regarding equitable participation of private school students.
- Allowable Activities and Additional Resources: For more information regarding allowable uses of Title IV, Part A funds, please refer to the non-regulatory guidance provided by the US Department of Education.
For more information regarding allowable uses of Title IV-A funds, please refer to the Non-Regulatory Guidance provided by the US Department of Education.
You might consider reading Blending Teaching and Technology: Simple Strategies for Improved Student Learning, a release from Future Ready Schools. You can download a pdf of the report from the web.
For more resources for planning and implementing effective programs please refer to NH Department of Education Title IV A web page.
Future Ready Framework
The Future Ready Framework can be used to assess the characteristics of your district that need the most attention in order to focus on personalization and student centered learning. The research-based Framework emphasizes collaborative leadership and creating an innovative school culture. All content focuses on seven key areas (called gears), plus leadership, each of which are addressed during the comprehensive planning process. This framework keeps student learning at the heart of all decision-making.Improvement and planning efforts focus on seven key areas, or gears which are synchronized and nurtured through collaborative leadership.
The key areas of the Future Ready Framework are:
Districts with Grant Allocations of $30,000 or More
An LEA that receives at least $30,000 in SSAE program funds must conduct a comprehensive needs assessment that includes, at a minimum, a focus on the three content areas identified as Title IV-A Focus areas. (ESEA section 4106(d))
Districts are strongly encouraged to take and use the Future Ready District Assessment Survey to determine your district needs. The Future Ready Framework addresses the target areas necessary for student-centered, personalized learning. A copy of this survey tool is available for download and use in the Title IV-A Resources Folder. Districts who use this survey as their needs assessment will be providing The Title IV-A program with valuable information which the program can use to improve the program and get useful data on where the needs are in our state. Before completing the survey online, download a copy of the questions, review the questions with your team, and analyze the results in terms of the three main focus areas of Title IV-A funding. Use your results to develop a Title IV-A program of activities that address your needs. Then, report your results using the online survey which is available in the New Hampshire Future Ready Dashboard. The link to this tool will be available soon. Using the Assessment survey tool on the New Hampshire Dashboard will provide your team with a report that your team can use to develop your Title IV-A program. The results of your needs discussions will be used to justify need in the Online Grants Management System.
At the state level, this needs assessment data will be used to identify the critical areas of need among New Hampshire districts. To use the Future Ready survey, set up a person responsible for entering the data using the form on the NH Future Ready Dashboard. That person will enter the data into the Future Ready District Needs Assessment, allowing the NH Department of Education to access that data. District Future Ready Assessment Data will be used in aggregate form, for state level information, only.
Districts choosing not to use the Future Ready Needs Assessment Survey will be asked to upload their needs assessment results and analysis in the Online Grants Management System in order to demonstrate the connection of activities to determined need, as required by the Title IV-A federal grant program.
Districts receiving $30,000 or more are required to:
Districts with Grant Allocations of Less than $30,000
- Perform a comprehensive needs assessment in order to justify their activities as a determined need.
- Spend at least 20% of their funds on well-rounded academic programs.
- Spend at least 20% on safety and healthy students programs.
- Spend at least some of the remaining available on effective use of technology.
- Spend no more than 15% of their effective use of technology funds on infrastructure technology.
Districts with allocations under the $30,000 threshold may choose, but do not have to conduct, a needs assessment. However, those districts still must base their Title IV-A activities on demonstrated need and upload accompanying documentation in the GMS. For example, logic models or strategic plans are acceptable ways to show the relationship between an existing need and programs or activities.
Check the list of allocations to see what your Title IV-A funding level will be. This document is also available for download in the Tutorial Resources Folder.
Note: 2019-2020 Title IV-A Program funds have been approved at the same or slightly greater levels than the current allocations.
Period of Availability
The “Tydings Amendment” applies to Federal FY18 (2018-19 school year) Title IV-A funds, and therefore, will remain available for obligation by school districts through September 30, 2020. All funds must be spent within 45 days of the September 30, 2020 closing, which puts the final date at November 14, 2020.
Note: The closing date currently in the Grants Management System is September 30, 2019. This is in process of being updated to reflect application of the Tydings Amendment.
Requirement to Supplement not Supplant
In considering how to use Title IV-A program funds, LEAs must be mindful that federal funds may be used only to supplement, and not supplant, non-Federal funds that would otherwise be available for activities authorized under the Title IV-A. (ESEA section 4110). This means that, in general, LEAs may not use Title IV-A program funds if the cost of those activities would have otherwise been paid with State or local funds in the absence of the Title IV-A program funds. Title IV-A funds cannot supplant State or local funds.
SEC. 4110. SUPPLEMENT, NOT SUPPLANT.
Funds made available under this subpart shall be used to supplement, and not supplant, non-Federal funds that would otherwise be used for activities authorized under this subpart.
Supplement means to build upon or add to.
Supplant means to replace or take the place of.
Federal law prohibits recipients of federal funds from replacing state, local, or agency funds with federal funds.
Existing funds for a project and its activities may not be displaced by federal funds and reallocated for other organizational expenses. If state or local law, or district policy, requires the program, equipment, or service, it cannot be purchased using federal funds. This is illegal.
On the other hand, federal agencies encourage supplementing—that is, adding federal funds to what is available in state, local, or agency funds.
Download the Equitable Services document.
LEAs must comply with Sections 8501 through 8504 of the Every Student Succeeds Act regarding equitable participation of private school students. In general, consistent with the number of eligible children in areas served by the LEA receiving a Title IV-A grant who are enrolled in private elementary or secondary schools in areas served by the LEA, after timely and meaningful consultation with the appropriate private school officials, provide to those children and their teachers or other educational personnel, on an equitable basis, educational services or other benefits that address their needs under the grant award.
To avoid any questions about this provision, it is recommended that you list the appropriate schools in your project description and report that they have been contacted, and on whether or not those schools will participate in your activities.
New Requirement: Obligation of Funds
Funds allocated to an LEA for educational services and other benefits to eligible private school children, teachers and other educational personnel, and families must be obligated in the fiscal year for which the funds are received by the LEA.
(ESEA sections 1117(a)(4)(B) and 8501(a)(4)(B).)
New Requirement: Ombudsman
To help ensure equitable services and other benefits for eligible private school children, teachers and other educational personnel, and families, an SEA must designate an ombudsman to monitor and enforce ESEA equitable services requirements under both Title I and Title VIII.
(ESEA sections 1117(a)(3)(B) and 8501(a)(3)(B).)
Changes to Existing Requirement: Consultation
The topics subject to consultation have been expanded to include the following:
(ESEA section 1117(b)(1).)
- How the proportion of funds allocated for equitable services is determined.
- Whether the LEA will provide services directly or through a separate government agency, consortium, entity or third-party contractor.
- Whether to provide equitable services to eligible private school children by pooling funds or on a school-by-school basis.
- When, including the approximate time of day, services will be provided.
- Whether to consolidate and use funds available for Title I equitable services in coordination with eligible funds available for equitable services under programs covered under section 8501(b) to provide services to eligible private school children in participating programs.
- The written affirmation that consultation has occurred must provide the option for private school officials to indicate such officials’ belief that timely and meaningful consultation has not occurred or that the program design is not equitable with respect to eligible private school children.
Change to Existing Requirement: Updates to Programs Covered Under Title VIII
ESSA updated the covered programs to include the following:
(ESEA section 8501(b).)
- Title I, Part C − Education of migratory children
- Title II, Part A − Supporting effective instruction state grants
- Title III, Part A − English language acquisition, language enhancement, and academic achievement
- Title IV, Part A − Student support and academic enrichment grants
- Title IV, Part B − 21st Century Community Learning Centers
How to provide equitable services under Title IV, Part A:
SEAs and LEAs are required to provide equitable services for private school students and teachers under Title IV, Part A. Title VIII, Part F (sections 8501-8504) of the ESEA, as amended by the ESSA, governs equitable services for SSAE.
Although the new Title IV, Part A non-regulatory guidance does not specifically address how to calculate funding for equitable services, page 13 of the guidance does include a cross-reference to ED’s 2009 non-regulatory guidance governing equitable services under Title IX of the ESEA, as amended by the No Child Left Behind Act (NCLB) (http://www2.ed.gov/policy/elsec/guid/equitableserguidance.doc ).
With some exceptions, this guidance continues to apply because many of the requirements under Title VIII of the ESEA, as amended by the ESSA, including those governing expenditures for equitable services, remain unchanged from requirements under Title IX of the ESEA, as amended by NCLB.
USED Issues Equitable Services Guidance on Religiously-Affiliated Contractors
The U.S. Department of Education announced it will now allow religiously-affiliated organizations to contract to provide equitable services to students under the Elementary and Secondary Education Act (ESEA). Under ESEA, districts have to offer qualifying students who attend private schools the same services as their public-school peers. However, statutory language in ESEA prohibits money from going directly to private schools, instead requiring districts to provide services themselves or use contractors (this prohibition does not apply to contractors working with a public-school district).
A recent U.S. Supreme Court decision in Trinity Lutheran Church of Columbia, Inc. vs. Comer, however, found that such restrictions were unconstitutional. In that case, the Court found that a Missouri State program which denied a church the ability to apply for a playground resurfacing grant was unconstitutional because the prohibition was based solely on the religious character of the organization.
The announcement was made in draft updated guidance the equitable services requirements of ESEA. The guidance is based on an earlier version but has been updated to reflect the change in policy based on the Trinity Lutheran case. Ultimately under this updated guidance, districts will still be able to decide which contractors are used, and the services required would have to be completely secular and non-ideological. In an effort to avoid concerns about self-dealing, the contractor may not be affiliated with the private school where the services are being offered. The guidance also emphasizes that these districts must continue to follow all other fiscal and equitable services requirements of the law.
Some advocates have criticized this decision, saying it is interpreting a very narrow decision too broadly – and that access to State grants should not be equated with the provision of educational services.
The DRAFT: Providing Equitable Services to Eligible Private School Children, Teachers and Families – Updated Non-Regulatory Guidance (2019) is available.
Equipment Purchases Using Title IV-A Funds
All equipment with valued at $250 or greater, purchased using federal Title IV-A funds, must be inventoried and tracked by the LEA. Equipment over $5000 must also be tagged with a "purchased through Title IV-A funds" tag. The Title IV-A Program at the NH Department of Education will have tags available for districts who need to tag equipment over $5000 purchased as part of their Tilte IV-A program activities. The Department will record the tag numbers each district has. However, it is the district's responsibility to report the number of tags it needs to the Title IV-A Program, tag the purchased equipment, inventory it, and then track all equipment purchased using Title IV-A funds. Equipment tags and tracking documentation will be examined during site visits and expected in the final Title IV-A Program report.
Resource and Reading Links
New Hampshire ESSA Consolidated State Plan https://www.education.nh.gov/essa/documents/nh_state_plan_final_011918.pdf
Title IV-A Program at the NH Department of Education https://www.education.nh.gov/instruction/integrated/title_iv_a.htm
Updates from the US Education Department https://www2.ed.gov/policy/elsec/leg/essa/essaguidance160477.pdf
Title IX, Part E Uniform Provisions Subpart 1 — Private Schools Equitable Participation Guidance (still applicable unless otherwise noted in the “Updates” above) http://www2.ed.gov/policy/elsec/guid/equitableserguidance.doc
Non-Public Schools Listed by Name https://my.doe.nh.gov/Profiles/PublicReports/PublicReports.aspx?ReportName=SchoolsNonPublic
Non-Public Schools Listed by Town https://my.doe.nh.gov/Profiles/PublicReports/PublicReports.aspx?ReportName=SchoolsNonPublicByTown
Equitable Services for Eligible Private School Students, Teachers, and other Educational Personnel Comparison Chart https://innovation.ed.gov/files/2016/07/NCLB-ESSA-Equitable-Services-Comparison-Chart-FINAL.pdf
Future Ready Framework https://dashboard.futurereadyschools.org/framework
Student Support and Academic Enrichment Grants Non-Regulatory Guidance https://www2.ed.gov/policy/elsec/leg/essa/essassaegrantguid10212016.pdf
Blending Teaching and Technology: Simple Strategies https://futureready.org/about-the-effort/blendedlearning/
Future Ready District Self Assessment https://dashboard.futurereadyschools.org/uploads/media/default/0001/01/9c280b79595b2cf58d0142af126c9485a9911c28.pdf
DRAFT- Updated Non-Regulatory Guidance (2019) https://www2.ed.gov/policy/elsec/leg/essa/drafteseatitleiequitableservices.pdf