ED Publishes New Rules for Title I Schoolwide Programs

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Starting this fall, schools operating schoolwide programs under Title I can combine their compensatory-education aid with funds from most other federal programs.

Such schools will be exempt from federal regulations governing the programs so long as the schools meet "the intents and purposes" of those programs.

The change is part of an effort by the Clinton Administration and Congress to give districts and schools more flexibility in using funds they receive under Title I and other programs included in the recently reauthorized Elementary and Secondary Education Act.

Under another provision of last year's ESEA law, schools with a poverty rate of 60 percent are eligible to operate schoolwide programs, in which Title I funds are used to improve an entire school rather than for services specifically focused on students eligible for Title I. That threshold, which had been set at 70 percent, will drop to 50 percent next year.

The Education Department published a notice in the Sept. 21 Federal Register detailing the changes related to schoolwide projects. Final Title I regulations were issued in July. (See Education Week, July 12, 1995.)


Under the new rules, a schoolwide program can combine funds from almost all federal education programs with its Title I money. But the school would still be required to meet the "intents and purposes" of the original program.

For example, if a school chooses to use federal bilingual-education funds as part of a schoolwide program, the program must benefit the limited-English-proficient students that would have been served under the categorical program.

Programs whose funds cannot be combined in this way include:

  • The Individuals with Disabilities Education Act;
  • The Schools Facilities Infrastructure Improvement Act;
  • Title I programs for neglected and delinquent children;
  • Adult-education programs, unless adult-literacy services are "integrated within a schoolwide program";
  • Higher-education programs, unless they are intended to support elementary and secondary schools; and
  • Most school programs that are not run by the Education Department, such as Head Start and school-meals programs. However, schoolwide-project schools can include in their flexible-funding plans grants under the School-to-Work Opportunities Act, which is jointly funded by the Departments of Education and Labor.

Schools will not be required to account for every expenditure, said Mary Jean LeTendre, the Education Department's director of compensatory-education programs. But she said districts, and ultimately states, must ensure that schools are using the money to assist the intended beneficiaries.

The Education Department will monitor state compliance, she said, adding that federal officials will assign a high priority to assessing schoolwide programs.

Ms. LeTendre acknowledged that without specific compliance regulations, determining whether a school operating a schoolwide project is using its federal funding correctly is a more subjective matter than it is under a more traditional regulatory scheme.

'Judgment Call'

"It will still be, obviously, a judgment call as to what is sufficient for [determining whether] the intents and purposes are being met," she said.

The Federal Register notice lists several examples of how districts could use categorical programs within a Title I schoolwide program. The department intends to make examples from the field available as soon as possible.

Ms. LeTendre said additional Title I guidance is expected to be issued by the end of the month.

Janet F. Carroll, the director of compensatory-education programs in Rhode Island and the president of the National Association of State Coordinators of Compensatory Education, said the notice should clarify what funds can be combined in a schoolwide program.

But she fears that it may lead school officials to believe that they have been relieved of statutory accountability requirements under Title I and other programs.

"All of these buzzwords may have translated to less concern, less detail, less attention," Ms. Carroll said.

However, Ms. LeTendre predicted that, despite the advantages of being able to combine funding streams, it is likely that schools' long experience in operating distinct categorical programs will be a built-in barrier to change.

"The entire grasp of flexibility simply doesn't hit home in the district or the school," she said.

Vol. 15, Issue 05

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