Principal Question
Question:
I was told today that our public school district uses Title 1 funds only for reading support up to grade 5. This would not be a preferred model for our private school. We prefer the Coronavirus Elementary and Secondary School Emergency Relief (ESSER) funds be used for all students.
We have voucher (WPCP) families and financial assistance families. Many of our families over the poverty level need a variety of support – extra devices in large families, WIFI hot spots, mental health support, food challenges now that they are not in school, etc.
Why can’t we use the ESSER funds to solve these problems?
Answer:
Actually, you can. Here are key things to remember in ESSER vs Title I and other federal programs.
1) ESSER funds can be used for ALL the students at your private school. ESSER funds are NOT Title I funds. Their use does not have to follow the Title I program rules. The link between the two programs is that the ESSER funds are calculated using the Title I formula. Title I does not go away. It is not replaced by ESSER. These new ESSER funds can be used for 12 allowable purposes in the ESSER law. Private schools do NOT have to use their ESSER funds for the same purposes that the public schools do. It doesn’t matter what the public district is doing.
2) Alongside ESSER funds, the normal Title I program will continue. The school district can use its Title I funds how it chooses. The private school can use its Title I funds differently, if it wishes and if the uses are allowable under the Title I law. The allowable uses are primarily for direct instruction. Title I programs can only serve Title I eligible students (the student has to be designated as educationally needy and reside in a Title I attendance area).
3) School choice program participation has NOTHING to do with eligibility for ESSER funds or for Title I funds. All three programs are separate.
4) Both ESSER & Title programs I through IV all require “timely and meaningful consultation” with the private school by the public school district. The public district will NOT get federal funds from any of these programs unless the private school “signs off” and affirms that timely and meaningful consultation occurred. The public district has to deal with the private school’s needs in a satisfactory way before the private school signs off. Do NOT sign off on the DPI Affirmation forms if you do not think consultation has been timely or meaningful. Work with the district until they answer your students’ needs.
5) One caveat: The district can not give any federal program money directly to the private school. But, they can purchase, and order, and pay for things and staff your students need, as long as the uses are allowable under the federal law governing ESSER or, if it’s a different program, the federal law governing those programs (usually Titles I through IV but there are other programs). Remember, the allowable use of the funds are determined based on federal law, not based on the whims or desires of the public school district officials or its internal policies.
