The Department of Education has sent a letter to chief state school officers clarifying their use of Title I money for schools and districts identified as needing improvement under the No Child Left Behind Act.
The Oct. 12 letter from Jacquelyn C. Jackson, the department’s director of student achievement and school accountability programs, addresses several concerns raised by states. One of the primary questions is whether states can allocate school improvement funds under the law to a district identified as needing improvement if no individual schools in the district are in that category.
The issue has come up because as test scores are aggregated up to the district level, subgroups of students—such as those with disabilities—that were too small to count for determining adequate yearly progress for individual schools may count for the school system as a whole.
States must reserve 4 percent of their federal Title I aid for school improvement activities and allocate not less than 95 percent of that amount directly to districts.
Based on the department’s interpretation of the law, Ms. Jackson wrote, states should not initially allocate school improvement money to districts that do not have schools deemed in need of improvement. But if excess money remains after such schools have been served, the money could be given to districts based on need. “Certainly a state could determine that [districts] identified for improvement have a bona fide need,” she wrote.
The department provided more flexibility in how districts may use Title I funds set aside for professional development. Districts must set aside 10 percent of their Title I dollars for that purpose. Ms. Jackson said that money can be spent for teachers throughout the district, not just at schools in need of improvement.
She also said that states can set their own guidelines for applying the law’s rewards and sanctions to schools that do not consistently receive Title I aid from one year to the next. States are required to apply the strict consequences spelled out in the law only to schools receiving Title I funds.
