States Silent on Chapter 1, 2 Guidelines

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Washington--State and local education officials apparently have been slow to respond to the Education Department's long-awaited nonregulatory guidelines for administration of the Chapter 1 program for disadvantaged students and the Chapter 2 education block grants, federal education officials said last week.

The department mailed the documents, which have been circulating in draft form for more than a year, to chief state school officers across the country in late July.

"We really haven't received any feedback since they were distributed," said Allen J. King, deputy director of the department's division of education support, which oversees Chapter 2. "I'd say the lack of response indicates their favorable reception."

"So far there haven't been any comments," added Thomas Fagan, director of the Chapter 1 office's division of grants, policy, and administration. "I think they have been well accepted because they are very consistent with the draft guidelines."

Last November, the department published sparsely-worded regulations for Chapters 1 and 2 in keeping with its intention to reduce regulatory burdens and paperwork on states, while increasing their flexibility in administering the laws.

According to department officials, the guidelines offer suggestions to state officials in order to help them administer the programs in ways that will meet with the approval of federal auditors.

The documents, which are binding on the Education Department but not on states, address a number of topics that have been of major concern to many state and local pro-gram administrators.

For example, school districts that received funds under the old Title I program were required to establish parent-advisory councils. But under Chapter 1, that rule was dropped and replaced by another requiring districts to "consult" with parents as they designed and implemented their projects.

According to the Chapter 1 guidelines, districts can meet the new requirement by holding regularly scheduled open meetings on the projects "to explain, discuss, and consult with parents." Another alternative, the document continues, is that the districts hire full- or part-time "parent coordinators" whose primary responsibility is to work with parents.

Chapter 2 contained a similar parental-consultation requirement. The guidelines for that program suggested that local officials conduct "an ongoing process that is open to all interested persons and is calculated to provide advice within a timeframe that can affect the ultimate decision."

It also suggested that the officials provide parents with proposed and final project applications, needs-assessment documents, project plans, budgetary information, and evaluation data.

Another topic that concerned state and local officials was the reduction of record-keeping requirements brought on by the switch from Title I to Chapter 1 and by the consolidation of 28 categorical-grant programs into the single Chapter 2 block grant.

The guidelines for both programs contain similar advice for the officials. The Chapter 1 document, for example, notes that "agencies are free to keep those records that they determine are necessary for fiscal audit and program evaluation as long as they comply with the requirements of the [program's] regulations."

But the document goes on to suggest that agencies consider keeping records that show: the amount of funds that they received; how the funds were used; the total cost of the project; any costs provided from other sources; compliance with program requirements; significant project experiences and results; and evaluation data that they have collected.

A third topic of concern involves the participation of private-school students in the programs.

The Chapter 1 guidelines note, for example, that local officials should consult with their counterparts in private schools before making decisions that could affect the participation of private-school students.

It also directs local officials to take private-school students into account when they conduct their annual needs assessment. If the needs of private-school students differ from those of public-school students, the local officials must consider those needs when they design their Chapter 1 project.

The Chapter 2 guidelines also direct local officials to consult with private-school officials when designing programs funded under the block grant.

They also note, as does the Chapter 1 document, that if a private institution is considered a private nonprofit school under state law, local officials may not refuse to serve children in that school regardless of whether the school complies with other state laws.

Both Mr. King and Mr. Fagan noted that the guidelines will be updated periodically to respond to changes in the laws and to questions raised by state and local officials in the future.

Vol. 03, Issue 02

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