School Improvement Grants: Requirements and Monitoring Tiffany Winters, Esq. twinters@bruman

School Improvement School Improvement Grants: Requirements and Grants: Requirements and MonitoringMonitoring

Tiffany Winters, Esq.twinters@bruman.com Steven Spillan, Esq.sspillan@bruman.com Brustein & Manasevit, PLLCFall Forum 2012

Topic ListSIG ResourcesBackground on the SIG ProgramMonitoring the SIG Program

◦ Application Process◦ Implementation◦ Fiscal◦ Technical Assistance◦ Monitoring◦ Data Collection

SIG, What’s Next? Bru

School Improvement Grant 1003(g) (SIG) Resources

Latest updates: http://www2.ed.gov/programs/sif/legislation.html#guidance “Final requirements for School Improvement Grants authorized

under section 1003(g) of Title I of the ESEA,” 75 Fed. Reg. 66363 (Oct. 28, 2010).

Guidance on fiscal year 2010 School Improvement Grants under 1003(g) of the Elementary and Secondary Education Act of 1965 (U.S. Department of Education, Office of Elementary and Secondary Education: March 1, 2012).

SIG FundingFY 2009 ARRA: $3 billion

FY 2010: $546 million

FY13: Level Funding vs. Sequestration Bru

SIG Awards

Priority to the LEAs with the lowest-achieving schools that demonstrate —

(A) greatest need; and

(B) strongest commitment

Continuation Awards

Ongoing ActivitiesAn SEA may award SIG funds to an LEA for a Tier I or Tier II

school that has implemented, in whole or in part, one of the models within the last two years so that the LEA and school can continue or complete the intervention being implemented.

SIG Updates?

SIG funds authorized for use in “priority schools” through ESEA Waiver Package

Guidance addendum in March 2012

Congressional Plans?

SASA Monitoring of SIG

Areas Reviewed by SASAApplication ProcessImplementationFiscalTechnical AssistanceMonitoringData Collection

2012-2013 Monitoring Schedule

Current Published Schedule is Obsolete

No Monitoring Scheduled Past September

Behind Schedule

SASA On-Site General Schedule

Day 1: School #1 Site Visit School Leadership Team InterviewTeacher/Parent InterviewGuided Classroom Observations/Conversations with students

Day 2: LEA #1 Interview Day 3: School #2 Site Visit

Same as Day 1 Day 4: LEA #2 Interview Day 5: SEA Interview

ApplicationSEA’s application process compliant with both the State

application, requirements.

SEA RFP must ensure funds serve persistently lowest achieving schools

Serving schools identified in the Tier System.

“Persistently lowest-achieving schools” (PLAS)Lowest-achieving 5% (or lowest 5 schools, which

ever is greater) of Title I schools in improvement, corrective action, or restructuring; or

High school that has had a graduation rate less than 60%; and

Any secondary school that is eligible for, but does not receive, Title I funds that meets the same requirements as above. B

PLAS: Identification

To identify the PLAS, SEA must take into account both: (a) Academic achievement of the

“all students” group in a school in terms of proficiency on the State’s assessments in reading/language

arts and mathematics combined; and (b) The school’s “lack of progress” on those

assessments over a number of years in the “all students” group

PLAS: Listing results

PLAS: Tier III - Catchall

Tier III would include every Title I school in improvement, corrective action, or restructuring that is not a Tier I or Tier II school.

Consolidated Appropriations Act, 2010Expands the group of schools that an SEA “may” identify as

Tier I, Tier II, or Tier III schools.Does not affect the schools an SEA must identify as Tier I, Tier

II, and Tier III schools.Raised the maximum amount from $500,000 to $2,000,000.

PLAS: Newly Eligible Tier I Schools Elementary school that is eligible for Title I, Part A funds and:

Has not made AYP for at least 2 consecutive years; or Is in the State’s lowest quintile [20%] in reading/language arts

and mathematics combined; and

Is no higher achieving than the highest-achieving Tier I school

Newly Eligible Tier II Schools Secondary school that is eligible for Title I, Part A funds and:

Has not made AYP for at least 2 consecutive years; or Is in the State’s lowest quintile [20%] in reading/language arts

and mathematics combined; and

Is no higher achieving than the highest-achieving Tier I school; orA secondary school that has had a graduation rate less than 60%

over a number of years.

Newly Eligible Tier III Schools A school that is eligible for Title I, Part A funds:

Has not made AYP for at least two years; or Is in the State’s lowest quintile [20%] of performance in

reading/language arts and mathematics combined; and

Does not meet the requirements to be a Tier I or Tier II school.

Annual Lists?

ImplementationSASA monitoring will look at how each LEA is implementing its

SIG grant, focusing on each of the 4 turnaround models.

Focus is on LEAs, but SEAs will bear the burden of noncompliance.

SIG 4 Models:

RestartClosureTransformationTurnaround

SIG Models: Restart

School converts or closes and reopens under a CMO or EMO

Considerable flexibilityMust enroll any former student who wishes to

attend the school May require agreements covering behavior,

attendance, or other commitments related to academic performance

May not require students to meet academic standards prior to enrolling

SIG Models: ClosureLEA closes a school and enrolls students

in “higher achieving” schools in the LEA.

Guidance: Critical to engage families and community early, selecting the appropriate improvement model to assure a smooth transition for students and their families at the receiving schools.

Guidance – Unauthorized Closure

If an LEA closes a Tier I or II school after implementing any model other than Closure?SEA has the discretion to terminate and rescind. If SEA accepts new applications, LEA must meet all

Closure model requirements.ED allows for this circumstance, but notes that such an event

should be VERY rare.

SIG Models: Transformation

IMPORTANT:An LEA with 9 or more Tier I and Tier II

schools may NOT implement the transformation model in more than 50% of those schools.

Guidance: If an LEA is already exceeding the cap, it may not implement the transformation model in any additional schools.

SIG Models: Transformation

5 Required Activities1. Replace the principal2. Teacher/Principal evaluations3. Identify and reward school leaders, teachers, and other staff4. Professional Development5. Implement strategies to recruit, place, and retain staff

Guidance - Transformation Model

LEAs implementing a transformation model must:Provide sufficient operational flexibility. Ensure ongoing, intensive technical assistance and related

support.

2011 Transformation Waiver: Teacher Evaluations

August 12, 2011 – ED letter to Chiefs Invites those LEAs implementing a transformation model “extra

time to develop and implement teacher evaluation systems.” Proposed waiver would allow LEAs to:

Develop the evaluation systems in the 2011-2012 school year, Pilot them next year (2012-2013), and Have them up and running by the 2013-2014 school year.

Asked for application by August 26th, but expecting later submissions. B

Transformation: Replace PrincipalsCEP Report:

15 out of 45 States using the transformation model saw removing the principals as a key element of the turnaround.

16 States said that the results varied from school to school. One State said it didn't make a difference, while three others

thought it was too soon to say.

SIG Models: Turnaround9 required elements:

1. Replace the principal2. Use locally adopted competencies to measure the

turnaround staff effectiveness (50% rule)3. Implement strategies designed to recruit, place, and

retain the appropriate staff4. Provide ongoing, high-quality job-embedded

professional development5. Adopt new governance structure B

SIG Models: Turnaround

6. Use data to identify and implement an instructional program

7. Promote the continuous use of student data8. Establish schedules and implement strategies that provide

increased learning time9. Provide appropriate social-emotional and community-

oriented services and supports for students

Turnaround: Replace TeachersCEP Report

Highly unpopular with unions

8 of the 46 States implementing the turnaround model said the process helped pinpoint and enlist effective teachers.

Increased Learning TimeReports show that LEAs are struggling with this requirement.

No uniformity among districts in implementing increased learning time.

What counts as increased learning time?

Increased Learning TimeCEP Report:

Maryland schools were spending the extra time primarily on the students who are struggling the most academically.

Michigan schools were pushing to extend the school day for all students, with mixed results.

Idaho State and local officials did not see it as an essential piece of their school improvement formula.

Increased Learning Time Definition: increasing the length of the school day, week, or

year to significantly increase the total number of school hours so as to include additional time for: Instruction in core academic subjects; Instruction in other subjects and provision of enrichment

activities; and Teachers to collaborate, plan, and engage in professional

development within and across grades and subjects.

Increased Learning TimeMarch 2012 Guidance:

LEA must use a longer school day, week, or year to provide additional time for all three types of activities.

Focus should be on instruction of core academic subjects, and time for teacher collaboration & planning.

Increased Learning Time Can include before- or after- school activities. Activities must be available to all students.

March 2012 Guidance:All students must have the opportunity to participate.School must have the capacity to serve any and all students.

SIG Models: CriticismsModels do not address school climate and culture.

Ignores non-academic challenges, such as attendance and behavior.

Any focus on non-academic concerns often get in the way of SIG compliance.

FiscalFinal Requirements

Guidance

OMB Circular A-87

EDGAR Section 76.710

SIG Fiscal SEAs:

Ensuring proper LEA use of funds?Only taking 5% for State admin?Ensuring adequate funds for three year grants?

LEAs:How are you spending funds?Ensuring funds are supporting SIG activities?

SIG Cross Cutting Issues If not every Tier I school in a State was served with FY 2009

SIG funds in the 2010–2011 school year, an SEA must carry over 25% of those funds, combine them with FY 2010 SIG funds, and award those funds to LEAs in the same manner as FY 2009 SIG funds are awarded.

If a State does not serve every Tier I school, but needs more than 75% to fund all LEAs that it committed to serve – contact ED prior to issuing grants.

SIG “District-wide” Activities An LEA may use SIG funds to pay for district-level activities:

Support implementation of one of the four school intervention models in each Tier I and Tier II school it commits to serve, and

Support other school improvement strategies in the Tier III schools it commits to serve.

An LEA may not use SIG funds to support district-level activities for schools that are not receiving SIG funds.

SIG Guidance - SupplantingSIG funds must supplement, and not

supplant, non-Federal funds a school would otherwise receiveSNS applied to increased learning time Costs must:

Be directly attributable to the implementation of the model,

Be reasonable and necessary, and Exceed the cost the district would have

incurred in the absence of its implementation model.

This all requires documentation.

SIG Guidance - ComparabilityLEA is obligated to ensure that all of its Title

I schools are comparable to its non-Title I schools.

Guidance – Improvement Timeline

Receiving a SIG award restarts improvement timeline.

Regardless of where a school is in the improvement timeline, the clock restarts.

A 2012-2013 grantee could enter the first year of improvement (ESEA 1116(b)) --would be 2014-2015.

Guidance – Pre-Implementation

LEA may use carryover/current funds prior to full implementation.

Enables an LEA to prepare for full implementation of a school intervention model at the start of the next school year.

May not use the funds to pay for needs assessment.

SIG Guidance – Pre-ImplementationSEA Evaluation Criteria:

Directly related to the selected model?Reasonable and necessary?Designed to address a specific need?Represent meaningful change to improve student achievement?Research-based? Represent a significant reform that goes beyond the basic

educational program?

Pre-Implementation Allowable Activities

Family and Community EngagementRigorous Review of External ProvidersStaffing Instructional ProgramsProfessional Development and SupportPreparation for Accountability Measures

Technical AssistanceSASA monitors will look at what types of TA the SEA is

providing, particularly with respect to: Conducting the needs-assessment Preparing and amending LEA applicationsPreparing and amending budgetsSelecting the intervention model for each school

Also how the SEA is determining what types of TA to provide and to whom?

How frequently is the SEA providing technical assistance?

Technical Assistance at LEA Level

Has SEA been providing adequate TA?

How has the LEA supported, how does it currently support, and how does it plan to support schools in implementing the SIG program?

LEA Monitoring An LEA must establish SEA approved annual goals for student

achievement on the State’s assessments in both reading/language arts and mathematics that it will use. to monitor each Tier I and Tier II school that receives SIG funds.

The determination of whether a school meets the student achievement goals established by the LEA is in addition to the determination of whether the school makes AYP as required by section 1111(b)(2) of the ESEA.

LEA Monitoring• The following metrics constitute key indicators for the SIG

program, collected by SEA:

(1) Number of minutes within the school year;(2) Student participation rate on State assessments in reading/language arts and in mathematics, by student subgroup; (3) Dropout rate;(4) Student attendance rate;(5) Number and percentage of students completing advanced coursework (e.g., AP/IB), early-college high schools, or dual enrollment classes;

(6) Discipline incidents;(7) Truants;(8) Distribution of teachers by performance level on an LEA’s teacher evaluation system; and(9) Teacher attendance rate.

SEA Renewal If a Tier I or Tier II school does not meet the annual student

achievement goals established by the LEA, may an SEA renew the LEA’s SIG grant with respect to that school?

An SEA has discretion to examine factors, such asSchool’s progress on the leading indicators in section III of the

final requirements, or Fidelity with which it is implementing the modelSee section II.C(a)(ii) of the final requirements (I-16)

Renewal based on ALL factors

Guidance – Failure to Implement

LEA Unable to Implement ModelLEA must notify SEA IMMEDIATELY.

LEA must cease obligating SIG funds in that school.

If the LEA does NOT want to try a different model, SEA rescinds remaining funds and combines with carryover.

If the LEA does want to try another model, SEA has discretion to end the award, or ask LEA to reapply.

Data CollectionWhat process is the SEA/LEA using to collect data on the

leading indicators? How is the SEA/LEA keeping track of or managing this data? Is the SEA/LEA collecting any additional data beyond that

required by the SIG program?Any plans for using data aside from reporting requirements?Have LEAs begun collecting any benchmark or interim data on

the leading indicators? If so, what does the data show thus far?

Data CollectionSEA may add additional “leading indicators”

SEA may not deny LEA renewal request based on failure to make progress on SEA-added indicator, providing LEA has made progress federally-mandated indicators

SIG: What’s Next?FY 2013 Funding Fight

SIG remains top Administration priority House GOP wants to eliminate funding Skeptical of the turnaround models

Senate Democrats willing to keep funding, but offering more models

SIG: What’s Next ESEA Waiver Package

Flexibility to Support School Improvement: An SEA would have flexibility to allocate ESEA section 1003(a) funds to an LEA in order to serve any priority or focus school, if the SEA determines such schools are most in need of additional support.

Flexibility to Use SIG Funds to Support Priority Schools: An SEA would have flexibility to award SIG funds available under ESEA section 1003(g) to an LEA to implement one of the four SIG models in any priority school.

SIG: What’s NextESEA Waiver Package: Priority School

Among the lowest 5% of Title I schools in the State; A Title I-participating or Title I-eligible high school with a

graduation rate less than 60% over a number of years; or A Tier I or Tier II school under the SIG program that is using SIG

funds to implement a school intervention model.

SIG: What’s Next Senate ESEA Reauthorization Two Additional Turnaround Models

Strategic Staffing Strategy – LEA must: (I) replace the principal if he/she has served more than 2 years; (II) allow the principal to staff the school with a turnaround team of

his/her choosing; (III) provide teacher and principal incentives.

Whole School Reform Strategy - must include a partnership with a strategy developer offering a school reform program Based on at least a moderate level of evidence that the program will have

a statistically significant effect on student outcomes

QUESTIONS?

DisclaimerThis presentation is intended solely to

provide general information and does not constitute legal advice. Attendance at the

presentation or later review of these printed materials does not create an attorney-client

relationship with Brustein & Manasevit, PLLC. You should not take any action based

upon any information in this presentation without first consulting legal counsel familiar

with your particular circumstances. Bru

School Improvement Grants: Requirements and Monitoring Tiffany Winters, Esq. twinters@bruman

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