State Coordinators’ Handbook · Web viewThe law also addresses data collection in the context of...

State Coordinators’ Handbook

National Center for Homeless Education

Diana Bowman, NCHE, Senior Program Specialist

Patricia A. Popp, Virginia’s Project HOPE, State Coordinator

December 2010Revised 2019

Produced byThe SERVE Center at the University of North Carolina at Greensboro


Funded by the U.S. Department of Education, the National Center for Homeless Education (NCHE) at the SERVE Center at the University of North Carolina at Greensboro provides critical information to those who seek to remove barriers to education and to improve educational opportunities and outcomes for children and youth experiencing homelessness.

National Center for Homeless Education (NCHE)5900 Summit Ave #201

Browns Summit, NC 27214

NCHE Helpline800-308-2145

[email protected]

NCHE Websitehttp://www. [email protected]

The content of this publication does not necessarily reflect the views or policies of the U.S. Department of Education; nor does mention of trade names, commercial products, or organizations imply endorsement by the U.S. Government. This document was produced with funding from the U.S. Department of Education under contract no. ED-04-CO-0056/0001.

Permission granted to reproduce this document.

http://www.serve.org/nche

mailto:[email protected]

Table of Contents

Section A: Introduction A-1

Section B: Charting the Course: How do State Coordinators Plan and Fulfill Their Responsibilities? B-1

Section C: Connections to Collaboration C-1

Section D: Data Collection and Reporting for EDFacts D-1

Section E: Using Data for Decision Making E-1

Section F: Technical Assistance for Local Education Agencies F-1

Section G: Dispute Resolution G-1

Section H: State Monitoring of Local Educational Agency McKinney-Vento Programs H-1

Section I: The McKinney-Vento Subgrant Process I-1

Section J: Management and Fiscal Oversight of Education for

Homeless Children and Youth Program Grants J-1

Section K: Preparing for Federal Monitoring of the State

Education for Homeless Children and Youth Program K-1

Section L: Building Capacity to Support Native American Children

and Youth Experiencing Homelessness L-1

Section M: When Disaster Strikes: What State Coordinators Need to

Know and Do M-1

Appendix A-1-1

Section A. Introduction

This handbook for State Coordinators who administer the Education for Homeless

Children and Youth (EHCY) Program is intended to be used as a primer for new

coordinators to identify critical first steps and as a resource for more seasoned

coordinators as they look for ways to enhance their programs. The handbook includes the

basics necessary to ensure compliance with legislative requirements and additional

strategies that go beyond compliance, which State Coordinators have used to strengthen

supports for students experiencing homelessness in their states. The 2016 revision of the

handbook addresses new provisions of the McKinney-Vento Act1 in the Every Student

Succeeds Act (ESSA) and includes U.S. Department of Education (ED) guidance and good

practices from the 2016 Education for Homeless Children and Youths Program Non-

Regulatory Guidance.

A.1 Purpose of the State Coordinators’ Handbook

For over 20 years, a variety of tools have been developed to assist State

Coordinators in fulfilling their role. Furthermore, with the reauthorization of the

McKinney-Vento Act in 2015 by Title IX, Part A of the Every Student Succeeds Act, there are

additional requirements for State Coordinators to support local educational agencies

(LEAs) in implementing the law and strengthening collaborations across programs and

agencies. State Coordinators must be poised to learn from the past and prepare for the new

developments of the future. This handbook pulls together existing resources to provide

both new and seasoned State Coordinators a tool that provides a wide variety of resources

at their fingertips. The State Coordinators’ Handbook provides a strong foundation for

1 All resources and references mentioned are found in the Resources at the end of this section, with their links, if available.

A-1 State Coordinators’ Handbook: Section A. Introduction

understanding your program and implementing processes and procedures to carry out

your role as State Coordinator efficiently and effectively.

Additional resources and publications for State Coordinators are located on the

State Coordinators’ Web Page on the NCHE website. NCHE develops and posts resources on

an ongoing basis as the EHCY program evolves.

Section A in the handbook serves two purposes. It provides an outline for the

content that follows and offers a pre-assessment in Appendix A-1 to assist State

Coordinators in identifying the sections that would be most helpful. For each question, the

handbook directs you to the sections that will help you answer the question. We encourage

you to test yourself before diving into the details that follow and return to these questions

now and then for a refresher. State Coordinators may read the entire handbook or may

choose sections that address particular topics.

A.2 Overview

The State Coordinators’ Handbook is comprised of 11 sections addressing key topics

with which State Coordinators should be familiar. The sections provide an overview of

provisions in the McKinney-Vento Act and other relevant legislation and strategies for

program implementation that are based on good practice shared by State Coordinators.

Resources at the end of each section point to a wealth of information to expand upon topics

discussed in the section. The sections include appendices that provide tools for managing

your program and that provide templates that may be customized to fit the needs of your

State.

The 2016 revision of the handbook was reviewed by Federal EHCY program to

ensure alignment with the reauthorized law in the Every Student Succeeds Act and Federal

priorities.

Following is a preview of the State Coordinators’ Handbook.

Section A. Introduction

Purpose of the State Coordinators’ Handbook

Overview

Acknowledgements


Pre-assessment with links to sections for quick reference

Section B. Charting the Course: How do State Coordinators Plan and Fulfill Their

Responsibilities?

What you need to know about your State’s Education for Homeless Children and

Youth program

Functions of the State Coordinator outlined in the McKinney-Vento Act

State laws, policies, and procedures to review

Reviewing and revising your annual plan

Working smart

Section C. Connections to Collaborations

McKinney-Vento Act requirements for State-level collaboration

Strategies to improve your connections and collaborations

Fostering collaboration at the LEA level

Section D. Data Collection and Reporting for EDFacts

State Coordinators’ responsibilities for collecting data required for submission to

EDFacts for the Consolidated State Performance Report

Ensuring data quality

Section E. Using Data

Data sources to help inform practice

Good questions about your program that data can inform

Use of data to identify risk for compliance at the State education agency (SEA) or

LEA level

Section F. Technical Assistance for Local Educational Agencies

McKinney-Vento Act requirements for professional development for LEAs

Orienting new local homeless liaisons and supporting them in their work

Strategies and resources for professional development

Section G. Dispute Resolution

McKinney-Vento Act requirements for dispute resolution

Considerations for an effective dispute resolution policy

Common disputes


Strategies to enact before, during, and after a dispute

Section H. State Monitoring of Local Educational Agency McKinney-Vento Programs

McKinney-Vento Act requirements for LEA monitoring

Suggestions for monitoring schedules and protocols,

LEA risk assessment for monitoring

Strategies for making monitoring efficient and productive

Section I. The McKinney-Vento Subgrant Process

McKinney-Vento Act requirements for conducting the subgrant process and

managing awards

Considerations for the number and funding range for awards

Considerations for the request for proposals

Strategies for overseeing subgrantees

Section J. Management and Fiscal Oversight of Education for Homeless Children and Youth

Program Grants

State fiscal responsibilities outlined in the McKinney-Vento Act

Program planning and budgeting, record keeping, use of funds for state-level

activities

Fiscal oversight of LEAs

Use of funds for McKinney-Vento subgrants

Section K. Preparing for Federal Program Monitoring of the State Educational Agency

Education for Homeless Children and Youth Program

Managing the State program for ongoing compliance

Uniform Guidance provisions

Oversight of LEA EHCY programs

A.3 Acknowledgements

The National Center for Homeless Education would like to acknowledge and thank

the many State Coordinators whose efforts have informed our practice and provided the

road map for implementing Federal legislation and creating real programs that serve

homeless children and youth. Input from State Coordinators at national meetings,


responses to surveys conducted by the NCHE, and formal and informal conversations over

the years contributed greatly to the practical information in the handbook.

Resources

National Center for Homeless Education. State Coordinators’ Web Page at https://nche.ed.gov/sc/sc.php

Title VII-B of the McKinney-Vento Homeless Assistance Act as amended by the Every Student Succeeds Act, 42 U.S.C. § 11431 et seq., 2015. Retrieved from http://uscode.house.gov

U.S. Department of Education. (2016). Education for Homeless Children and Youths Program Non-Regulatory Guidance. Retrieved from http://www2.ed.gov/policy/elsec/leg/essa/160240ehcyguidance072716.pdf


http://www2.ed.gov/policy/elsec/leg/essa/160240ehcyguidance072716.pdf

http://uscode.house.gov/

https://nche.ed.gov/sc/sc.php

Section B. Charting the Course: How do State Coordinators Plan

and Fulfill Their Responsibilities?

State Coordinators are responsible for a variety of activities as they administer the

Education for Homeless Children and Youth (EHCY) program for their States. This section

of the State Coordinators’ Handbook provides a bird’s eye view of those responsibilities to

help new coordinators get the big picture. Charting the Course reviews the key functions of

the Office of the Coordinator for EHCY (including legislative references) and a variety of

resources that have been developed to support coordinators in their work. In addition to

the national view, this section provides direction to assist State Coordinators in

understanding what is in place within their own States. Tips for planning and making the

work more manageable are also included.

Inquiring Minds Want to Know:

What are the top five actions a new State Coordinator should pursue?

1. Get to know the relevant legislation.2. Get to know your McKinney-Vento support network.

a. National Center for Homeless Education (NCHE)b. National Association for the Education of Homeless Children and Youth

(NAEHCY)c. Fellow State Coordinators

3. Get to know your State colleagues.a. State educational agency (SEA)b. Other State agencies

4. Collect and review required State documents. Use the available data to identify your State’s strengths and challenges.

5. Create an annual action plan that aligns with your State Plan for the EHCY program, continues successful activities, and addresses current challenges. Create effective messaging to share the plan and to garner support for its implementation.

B-1 State Coordinators’ Handbook: Section B. Charting the Course

B.1.1. What are the responsibilities of the State Coordinator?

What drives your decisions and actions as a State Coordinator? The Office

Coordinator for EHCY is mandated by Federal legislation and is usually fulfilled by a single

State Coordinator, although sharing the duties of the coordinator among multiple staff is

allowed by the U.S. Department of Education (ED). Legislation informs much of the work

that must occur. In addition to Federal mandates, practice is informed by ED policy and

guidance, State legislation, the needs and priorities of your State, and, hopefully, best

practice. This section of the handbook will help you identify the background information

you need to understand the role of State Coordinator, develop a plan to ensure compliance

with mandates, and identify additional steps that can be taken to further strengthen an

existing program.

To get you started, Appendix B-1 identifies the functions of the State Coordinator

found in the McKinney-Vento Act. Jot down what you know about the current activities in

your State in the second column. The bulleted items in the first column link to sections of

this handbook and related resources that can be used to complete the “next steps” as you

grow in your role and understanding of the responsibilities of the State Coordinator.

B.1.2. What Federal legislation impacts your responsibilities as a State Coordinator

for the EHCY program?

Much of the work State Coordinators do is shaped by Federal legislation. The

Federal laws that most frequently come into play are found in Appendix B-2. After a brief

description of the connection to homeless education, there are links to the actual code,

related ED guidance documents or regulations, and resources from the National Center for

Homeless Education (NCHE) or other Federal agencies.

B.1.3. How can you become more familiar with Federal expectations and stay

abreast of legislative changes?

In addition to the links in Appendix B-2, there are a number of supports that State

Coordinators can access. For example, NCHE offers on-line trainings that are advertised to

State Coordinators and others by email and on the NCHE listerv. (NCHE automatically

subscribes new State Coordinators to the NCHE listserv and State Coordinators’ email


distribution list when notified of their appointments.) Also, NCHE facilitates State

Coordinator meetings annually in Washington D.C. and in a preconference during the

annual conference of the National Association for the Education of Homeless Children and

Youth (NAEHCY). For information on these resources, contact NCHE at 800-308-2145 or at

[email protected].

NAEHCY works closely with NCHE on a number of initiatives. Both provide training

and technical assistance in implementing legislation related to children and youth

experiencing homelessness. While NCHE is funded as the technical assistance center for ED,

NAEHCY is a membership organization that can conduct advocacy initiatives beyond work

conducted as part of Federal funding. NAEHCY sends legislative alerts when important

Federal legislation is being discussed. The NAEHCY website posts updates as legislation is

considered and after it is passed.

Organizations that may be helpful in keeping you up-to-date on Federal legislation

related to homeless children and youth include

Bassuk Center on Homeless and Vulnerable Youth

National Association for the Education of Homeless Children and Youth


National Center on Family Homelessness

National Network for Youth

United States Interagency Council on Homelessness (USICH)

B.2. What does the McKinney-Vento EHCY program look like in your State?

There are some basic documents that provide State Coordinators with the answers

for the most frequently asked questions about your State’s program. Consider having all

these documents within easy reach, whether you use hard copies in binders or electronic

files on your desktop. Ask if your State has this information available through its data

management system, which would allow for access off site. If not, and you find that you

need this information while out of your office, consider keeping the data in an electronic

form that travels easily. The following items should be easily accessible. Locating these

documents is a critical early step in learning about your State’s ECHY program.

State Plan and updates (See Section B.4.)



Annual funding allocation data, including State and local budgets and expenditures

and current balances (See Section J. Fiscal Management.)

Budget information related to the use of the State reservation for State activities.

State Coordinators should be able to determine what funds have been expended and

what remains for the State and each subgrantee to ensure that all funds are

expended in a timely fashion. (ED sends email reminders to spend down

unexpended funds to all State Coordinators, which include the status for each State.)

EDFacts and the Consolidated State Performance Report (CSPR) data. Annual data is

reported by each State to the U.S. Department of Education, which populates the

CSPR. In addition to being available through the State Department of Education and

EDFacts, NCHE makes annual summaries of the EDFacts local educational agency

(LEA) data available in Excel data workbooks for each State. Contact NCHE for your

State’s unique web link to its data workbook. Consider creating longitudinal charts

that track identification and achievement for several years.

Technical assistance logs and dispute records

Previous Federal program monitoring reports for your State

LEA monitoring reports and current protocol

Subgrant process, request for proposals, current awards, and end-of-year reports

from subgrantees

Title I homeless set aside amounts for LEAs

State dispute resolution process

B.3. What is the State Coordinator’s responsibility in ensuring the revision of State

laws and policies?

The McKinney-Vento Act states:

In any State where compulsory residency requirements or other requirements, in laws, regulations, practices, or policies, may act as a barrier to the identification of, or the enrollment, attendance, or success in school of, homeless children and youths, the State educational agency and local educational agencies in the State will review and undertake steps to revise such laws, regulations, practices, or policies, to ensure that homeless children and


youths are afforded the same free, appropriate public education as provided to other children and youths. [42 U.S.C. § 11431(2)]2

While this responsibility is placed upon the SEA rather than specifically with the

State Coordinator, the State Coordinator is in the best position to identify potential barriers

and initiate steps that will lead to needed revisions.

B.3.1. State Code

The following list provides suggestions for initial review of State code to identify the

most common barriers or inconsistencies with the McKinney-Vento Act. This list is not

exhaustive, and a review of technical assistance and barrier tracking data (records or logs

of phone and email conversations from LEAs or complaints from homeless parents,

guardians, or youth) is needed to identify specific State and local issues that arise. Common

barriers or inconsistencies with the law include areas such as:

compulsory education;

enrollment requirements, including health and immunization records;

residency requirements;

guardianship requirements;

attendance requirements;

pupil transportation requirements;

pupil record transfer;

emancipation;

runaway reporting;

consent for medical treatment; and

specific references in any State code to homeless children and youth or the

McKinney-Vento Act, including how homelessness is defined.

The 2016 Non-regulatory Guidance recommends a “review of school discipline

policies that disproportionately impact homeless students, including those who are also

children and youths of color; those who identify as lesbian, gay, bisexual, transgender, and

queer or questioning; English learners; and students with disabilities.” (ED, 6).



B.3.2. State Policy

The same topics listed for State code should be reviewed among State policies

adopted by the State Board of Education. In addition, look for the following topics:

State special education regulations. In particular, sections to review most closely are

those related to evaluation, eligibility, and provision of a free appropriate public

education (FAPE); following a special education Individualized Education Program

(IEP); when a student moves; and the appointment of a temporary surrogate for

unaccompanied homeless youth when there is no one who can act as “parent,” as

defined in the Individuals with Disabilities Educational Improvement Act (IDEA)

and in your State regulations.

The State’s dispute resolution process for McKinney-Vento. (This process may be

found in policy or addressed through procedures and guidance.)

School nutrition eligibility for free meals.

If your State policies include reference to participation in extracurricular activities,

including sports, be sure to familiarize yourself with the requirements and identify any

potential barriers or conflicts that may arise within the context of McKinney-Vento. You

should also review policies of State athletic associations to see if they pose barriers to the

participation of homeless students on sports teams due to their high mobility or other

circumstances that are directly related to their homelessness. See the NCHE brief: Ensuring

Full Participation in Extra-Curricular Activities for Students Experiencing Homelessness.

Tables B-1 and B-2 offer examples of State codes, policies, and procedures that State

Coordinators commonly identify as having either a positive or negative impact on their

work. (These codes, policies, and procedures may or may not exist in your particular State.)

Table B-1. State Codes, Policies, and Procedures Changes that May Positively Affect a

State Coordinator’s Work


Category Sample Code, Policy, or Procedure

Potential Impact

Transportation law Making transportation of students on “yellow” buses no longer a requirement.

Makes it easier for LEAS to explore other options for transporting students.

Creating a statewide process for the reimbursement of parents for mileage if transporting to school of origin.

Removes variation among LEAs and creates a uniform procedure for response to this situation.

Policies and procedures for enrolling unaccompanied youth

Requiring schools to enroll homeless students who are not supervised by a parent or guardian.

Removes the need to make a homeless determination on gray area unaccompanied youth cases.

Policies and procedures for enrollment without address

Providing alternative ways (other than requiring an address) to capture where the student is living.

Helps schools comply with immediate enrollment.


Table B-2. State Codes, Policies, and Procedures Changes that May Negatively Affect a

State Coordinator’s Work

Category Sample Code, Policy, or Procedure

Example Impact

Truancy lawNot making allowances for absentees directly caused by a student’s homelessness.

Leads to schools’ reluctance to enroll students with patterns of high absenteeism.

Policies and procedures for enrollment

Requiring a parent or legal guardian to be present.

Impacts immediate enrollment of unaccompanied homeless youth.

Policies for enrolling runaway students

Identifying running away as a status offense.

Leads to reluctance from schools to enroll students whose actions are status offenses.

B.3.3. State Guidance Documents

States may use a variety of vehicles to provide guidance on practices to localities.

Policy memos, State superintendent memoranda and email alerts, and resource manuals

may exist. Again, in addition to the topics listed above, look for resources that reference the

following topics:

Your State’s homeless education website. (If you are looking for ways to improve

your website, visit NCHE’s web page for links to State profiles that include

individual State homeless education websites.)

State homeless education forms if your State has developed statewide identification,

enrollment, or referral forms (You may review samples of these forms on the NCHE

website’s Resources by Topic webpage under “Enrollment;” however, keep in mind

that States with local control can recommend use of State-developed forms but not

require them.)

Identification and data collection for homeless status and primary nighttime

residence.


McKinney-Vento subgrant process and fiscal procedures for budgets, amendments,

and reimbursements.

Clarification on sharing the cost and responsibility for transporting homeless

students to and from their school of origin across school district lines.

Title I, Part A homeless reservation guidance or Q&A documents.

Truancy prevention and graduation rates and initiatives.

Clarification on which LEA is responsible for special education services when a

student remains in his/her school of origin but the family has moved to another

school district.

B.3.4. What do you do when a discrepancy is identified?

Article VI of the U.S. Constitution, known as the Supremacy Clause, states that

Federal law supersedes State and local law and policy. The Supremacy Clause can be of

assistance while working to amend local and State policies and procedures that are in

conflict with the McKinney-Vento Act. When McKinney-Vento and State or local processes

are in conflict, McKinney-Vento should be followed. Despite this clause, the most effective

way to remove the potential of barriers caused by such conflicts is ensuring the State and

local policies are amended to avoid confusion.

Conflicts or barriers created by State laws, regulations, policies, and practices may

be identified through

State Coordinator review of extant laws and policies,

legal challenges such as letters from advocacy law groups or lawsuits identifying

barriers,

review of technical assistance and barrier logs,

questions and comments from the field in trainings or other meetings,

task forces or other collaborations,

o For example:

The Kentucky State Coordinator collaborated with Kentucky Housing

on the Ten-Year Plan to End Homelessness.


Virginia convened an ad hoc group to explore issues related to

unaccompanied homeless youth.

A number of States have reviewed attendance policies, which can

provide a vehicle for exploring this common barrier to success. ED

launched a chronic absence initiative, Every Student Every Day, and

has provided a variety of resources to States and localities. Knowing

that students experiencing homelessness are at greater risk of high

absenteeism, State Coordinators should be at the table as this

initiative is rolled out in States.

Appendix B-3. Steps for Revising State Code, Policies, or Procedures outlines the

steps that should be followed to make needed revisions and suggests the partners who

need to be involved.

B.4. How do you make the State Plan a useful tool?

The McKinney-Vento Act states “the State educational agency shall submit… a plan

to provide for the education of homeless children and youths within the State.” [42 U.S.C.

§ 11432(g)]. The process is required once during an authorization cycle and may be

submitted as part of a State’s consolidated plan for Federal programs under the Elementary


Coordinator-to-Coordinator: Tips for Revising Policies Be on the lookout for topics that overlap with homelessness. It may be easier to highlight homelessness within another initiative than to push forward a stand-alone initiative.

Involve key stakeholders in drafting and advocating for the policy change.

Work with outside agencies or groups to carry out your agenda.

Start small and impact the areas that are easiest to impact first; then, move to the more difficult areas. I started by introducing an LEA policy through training for a couple years and had others on our team talk to districts about it. Then I informed the districts that all LEAs would need to adopt a policy within the next year. This year, any district that does not have a policy will receive a finding during consolidated monitoring.

Don't be afraid to "steal" from someone else. As our former general counsel used to tell me, “There's no greater compliment in government work than plagiarism.” It's also more likely to pass the “censors” and “audits” that most of our policies have to go through.

and Secondary Education Act of 1965, as amended by the Every Student Succeeds Act of

2015.

States are encouraged to review their plans and update them as State needs change,

and States should submit amendments to ED if significant changes are made. A well-

developed plan provides a snapshot of the current status of the program and a clear road

map, including measurable goals, for future endeavors that can guide long range and day-

to-day planning. After becoming familiar with the McKinney-Vento Act, new State

Coordinators should consider the State Plan the next critical document for review.

A State Plan should be a living, working document that guides thoughtful practice. In

addition, it can serve as a basis or authority for making decisions to award subgrants that

address State goals and needs and in planning for and prioritizing State-level coordination

activities. There is great variability among States regarding the detail in State plans and the

role State plans play in shaping the day-to-day work of the State Coordinator.

While the State Coordinator may be the main author or reviser of the State Plan,

involving other stakeholders in its creation and revision, implementation, and monitoring

of progress can lead to a richer, more effective, and more useful document. If your State has

an advisory board for homeless education, charging the board to assist in the development

and review of the plan would be logical. If no such committee exists, consider inviting State

representation from other Federal programs and special education, local liaisons with and

without subgrants, shelter representatives, and groups that work with young children and

older youth. Some State Coordinators update their State Plans in conjunction with the

Federal program monitoring. Looking at your State’s schedule for an upcoming visit from

ED could provide the impetus to start your review.

B.4.1. Tips for Revising Your State Plan

Create a timeline. Work backward from the due date, making sure you leave

sufficient time for approvals through the State’s channels.

Review State plans from other States. Contact NCHE to request samples.

Use the legislative requirements listed in the McKinney-Vento Act as your road map.

Labeling each section of the plan with the legal citation will help locate the specific

requirements in the law at a later time when revising the State Plan.


Identify the data collected in assessing your State’s needs that addresses

requirements of the State Plan.

List current practices and activities in the State that address the plan.

Work with your team to identify practices that you wish to continue, adjust, delete,

and add.

Consider the benefits of specificity and generality in the plan. A plan that is too

general provides little guidance for next steps. Look at your plan and ask, “If I were

looking at this for the first time, would I know what I needed to do? Would I have

any idea about actions that have been taken and need to be taken?” On the other

hand, a plan that is too specific might require frequent amendments as the needs of

the program change. Does your plan include some general tasks that can be

addressed in a variety of ways? Does your plan leave room for new challenges to be

addressed as they emerge?

Follow your State’s protocol for obtaining public comment (if needed) and

review/approval through required channels.

B.4.2. Tips for Implementing the State Plan

As described in the steps to revise code, policies, and procedures (see Appendix B-

3), review all new activities and those that will be adjusted to determine where

change is needed. Consider color-coding your plan to identify changes that require

o State legislation,

o State policy,

o State practice in conjunction with other State agencies or education offices,

and

o practices within the State Coordinator’s office.

Prioritize next steps (steps critical to compliance and “low hanging fruit”). Consider

short term, midterm, and long-term goal setting.

o Serious compliance issues should be the first priority. See past Federal

monitoring reports and copies of SEA responses if there were any findings.


o Changes that require little effort and can be implemented quickly can be

included in the short-term goals. Completing activities is rejuvenating and

gives you more energy to take on slower moving initiatives.

Keep the plan alive.

o Make a commitment to conduct an annual review and update. Not only does

the review help the State Coordinator remember what is most critical and

required, the documentation developed can make Federal monitoring of the

State program less stressful since the work has been reviewed internally

multiple times.

o The review need not be a solo activity. Consider including participants who

assisted in the original plan’s development, your State advisory board, or

representatives from interagency committees.

o A summary document of progress on the State Plan should be shared with

supervisors, the State board of education (when appropriate), other State

Coordinators through regional collaborations, ED to simplify document

collection for monitoring, and the public through website postings,

newsletter articles, and presentations.

B.5. Working Smart

The day-to-day activities that confront a State Coordinator can keep you busy all day

and make you wonder on the way home, “What did I accomplish today?” It is easy to

become so absorbed in the problems and questions from phone calls and emails that the

thought of taking time to do long-range planning seems unmanageable. However, effective

leaders know that strategic planning, with specific goals and activities that are monitored,

measured, and celebrated upon completion, move a program from treading water to

continuous improvement.

B.5.1. Backward Design for State Coordinators

A well-respected approach to long-range planning used by teachers that has

emerged through the standards-based reform movement is the idea of Backward Design.3 3 UbD in a Nutshell. Retrieved July 1, 2016, from http://jaymctighe.com/wordpress/wp-content/uploads/2011/04/UbD-in-a-Nutshell.pdf .


http://jaymctighe.com/wordpress/wp-content/uploads/2011/04/UbD-in-a-Nutshell.pdf

Rather than “winging it” daily, sticking with content that is most interesting to the teacher,

or page-by-page through a textbook, Backward Design requires educators to start with the

standard that the State requires students to master. This must be unpacked to determine

exactly what essential questions students should be able to answer and what skills and

knowledge students must have to be able to determine that the standard has been met.

Once the skills and knowledge have been identified, educations can develop ways to

measure the students’ attainment of those skills and knowledge. Only then does the work

of determining what activities and resources are needed for lessons begin. Teachers are

being asked to plan with the end in mind.

Can this same process be applied to the work of a State Coordinator? Rather than

knowledge and skills for students, the State Plan should provide the road map for creating

an effective State EHCY program that, in turn, can nurture effective local programs. Annual

action plans and monthly plans have a lot in common with teachers’ pacing guides, and

weekly to-do lists and schedules are not so very different from weekly lesson plans. When

teachers take the time to thoughtfully identify their students’ needs and select activities

and resources to learn new concepts, they are better teachers. When State Coordinators

take the time to carefully identify barriers children and youth experiencing homelessness

face accessing and succeeding in school and take actions to remove those barriers and ease

greater access, they can become better State Coordinators.

B.5.2. Creating an Annual Action Plan

An annual action plan can provide the bridge between the State Plan and the day-to-

day activities of the office. ED strongly recommends that State Coordinators annually

assess their State’s progress toward achieving the goals in the State Plan and develop

annual action plans that identify priorities and activities to address continuing challenges

and emerging issues.4 A review of current status should be based on an analysis of available

data, including the annual LEA data workbook that NCHE develops for each State. (See

4 One of the Leading Indicators ED developed for the EHCY program in 2014 recommends tracking the number of States that have updated annual work plans based on data from a needs assessment and the establishment of measurable goals that address identified needs.


Appendix B-4. Sample Annual Scope of Work for North Carolina Homeless Education

Program.)

To make the annual action plan concrete, take the activities listed in the plan, target

deadlines for different items, and plot them on a calendar; be sure to include other

activities that occur each year whether or not there is a specific activity in the plan. (See

B.5.4. Making Time Visual for a sample calendar.) Don’t forget to look at the plan often! Add

a tickler to your monthly calendars with a date each month that you plan to spend 30

minutes reviewing your proposed activities. Make adjustments as needed. Most of us are

wonderful at underestimating the amount of time something will take to accomplish.

Plotting the time and making changes along the way can help you become more realistic in

your estimates.

For more information and tools for developing an annual action plan, visit NCHE’s

State Coordinators’ web page at for the Education for Homeless Children and Youth

Program: Guide to Developing an Annual Action Plan for State-Level Activities.

B.5.3. Prioritizing

One way to approach the multiple demands placed on State Coordinators is to look

at Stephen Covey’s Seven Habits of Effective People. Covey suggests that work can be

categorized into four quadrants, as illustrated in Figure B-1. Below we will provide

examples of State Coordinator duties that we think fit in each quadrant.

Figure B-1. Covey’s Quadrants5

Quadrant I

Important and Urgent

Quadrant II

Important and Not Urgent

Quadrant III

Not Important and Urgent

Quadrant IV

Not Important and Not Urgent

5 For more clarification, see Covey Quadrants. Retrieved July 13, 2016, from http://progmanager.files.wordpress.com/2008/06/covey-quadrants.jpg


http://progmanager.files.wordpress.com/2008/06/covey-quadrants.jpg

Effective people try to spend as much time as they can in Quadrant II and to limit

time spent in Quadrant IV. This proactive strategy of focusing on important work that is not

urgent and avoiding time wasters can reduce the need to address Quadrant I issues.

Prioritizing your work by determining in which quadrant the task would fall can help you

decide where to spend your time. Note that a number of tasks may begin in Quadrant II but

become Quadrant I if not completed in advance. For example, planning your EdFacts data

submission for the CSPR as a long range project may have a number of steps that, if

addressed early, are important but not urgent. Without preplanning, the submission of data

can “creep up on you” and become an urgent, deadline-driven project. The responsibilities

for State Coordinators listed in the McKinney-Vento Act should be included in your priority

activities. If you have additional responsibilities for other programs, consider creating a

merged list of priorities and identifying overlapping issues that can be addressed together.

Applying the quadrants to a State Coordinator’s responsibilities might look something like

Figure B-2.

Figure B-2. Applying Covey’s Quadrants to State Coordinator Activities

Quadrant I: Important and Urgent Quadrant II: Important and Not Urgent

Dispute to resolve Developing an annual planResponding to parents or LEAs to provide

critical technical assistance (ensure compliance when questions arise)

Developing relationships with partners who can move initiatives ahead

Intervening to get a child experiencing homelessness enrolled

Staff meetings to prioritize and assign work


Responding to time sensitive requests from lawmakers, media, public, supervisors

Conducting a comprehensive needs assessment or program evaluation

Finalizing the EDFacts data Providing liaison trainingsFinalizing budgets and subgrant awards Monitoring LEAs

Quadrant III: Not Important and Urgent Quadrant IV: Not Important and Not Urgent

Mandatory staff meetings not related to homeless students and their needs

Checking email every few minutes

Responding to requests for information that could be accomplished by clerical staff

“Visiting” with colleagues to avoid calling a dissatisfied parent or superintendent

Recreating summaries of data for special requests that could have been developed and posted to the website for easy public access

Re-copying to do lists

Looking for records that have not been organized and filed

Reading tangential newsletters or articles

B.5.4. Make Time Visual

Assigning tasks to specific blocks of time provides a visual representation of time

and can help you learn how to estimate the time needed for various activities. If you are

already a list maker, this approach just adds the time blocks. The time block could be a

year, quarter, month, week, day, or even an hour. The following sample calendars have a

number of Quadrant II tasks (that could become Quadrant I if not addressed). Items that

are done monthly or daily are not listed here but should be part of your

monthly/weekly/daily calendars. You can use a regular calendar.

Appendix B-5 is a sample calendar, which has been adjusted to reflect the fiscal

year and is more aligned to the school year.

Appendix B-6 is a sample monthly planning calendar for September.

Appendix B-7 takes one week from the September calendar and breaks the days

into hours.

Appendix B-4 is a sample annual work plan that North Carolina State

Coordinator developed.

Many State Coordinators must juggle their McKinney-Vento responsibilities with

those of other Federal and State programs. Taking the time to plan and prioritize what

steps must be taken is critical when time is limited. Here are some tips to assist you in

making the job more manageable:


Ask for assistance from the support network available to State Coordinators,

including

o NCHE,

o NAEHCY, and

o Other State Coordinators. (The culture among coordinators is very

collegial and willingness to share expertise, challenges, and successes is

the name of the game.)

Look for ways to infuse homeless education into issues with a higher profile in

the State. For example, Keeping Maine’s Children Connected was an initiative

that grew out of the recognition of overlapping goals and priorities among the

EHCY program, reintegration efforts for youth exiting correctional facilities,

improving educational outcomes for youth in foster care, and their psychiatric

facility and school transition initiative.

Use materials that have already been created. It is a compliment to have work

modified and used by another State Coordinator. Asking for permission (if the

material is not posted for sharing) and acknowledging the source is always

appreciated. The NCHE Resources by Topic web pages include samples of a

variety of materials from States and school districts. Use knowledgeable liaisons

to assist with training and technical assistance.

Form regional groups that can approach a seasoned liaison for assistance before

contacting the State Coordinator. With large States, like California, and smaller

States with part-time State Coordinators, such as New Hampshire, this approach

has been effective.

Designate knowledgeable and skilled liaisons to represent the State Coordinator

at interagency meetings and to present at conferences. Be sure to have a process

to oversee activities and receive updates from your designees.


Coordinator-to-Coordinator: Tips for Managing the Work

I’ve been able to use the tips on the Mind Tools website to refine my time management.

Prioritize your time.

Use materials already created and personalize for your State.

Use education initiatives already in place and use connections to other education resources.Infuse McKinney-Vento issues into other high profile issues.

Thoroughly understand the law and the requirements.

Use monitoring findings to understand expectations of your job better and to help align your program more to what the Federal government wants.

Plan! I can see the eyes rolling as I write this! You are thinking, “How can you expect me to spend time on planning when I don’t have the staff needed to meet my basic responsibilities?” Right? But think about it, if you lay out the “have to’s” and “would like to’s,” and estimate the time needed for each, the average work week, month, and year is unlikely to have the capacity needed. While economy will limit what can occur, aren’t you more likely to gain additional resources if you consistently present your supervisors and those with the purse strings with clear plans that delineate what needs to get done and what is needed to get it done? Do you ask your supervisor to help you make the tough choices and prioritize? Rather than solely focusing on those items you haven’t accomplished, do you have a means to identify and celebrate accomplishments? If you have the luxury of dedicated staff and resources, how do you ensure that these resources are perceived as well invested in your program? …Planning is critical to getting and maintaining needed resources. It will not happen overnight, but the person with multi-level plans that include the musts and “it would be nice” do receive the offers to explore initiatives when funds are available, especially when they maintain a well-organized and timely program.

Resources

NCHE’s brief “Ensuring Full Participation in Extra-Curricular Activities for Students Experiencing Homelessness.” Retrieved December 2016 https://nche.ed.gov/downloads/briefs/extra_curr.pdf

NCHE’s Education for Homeless Children and Youth Program: Guide to Developing an Annual Action Plan for State-Level Activities. Retrieved December 2016 https://nche.ed.gov/sc/sc.php

NCHE’s Resources by Topic web page at https://nche.ed.gov/ibt/ibt.php


https://nche.ed.gov/ibt/ibt.php


https://nche.ed.gov/downloads/briefs/extra_curr.pdf

NCHE’s State Profile Pages at https://nche.ed.gov/states/state_resources.php Title VII-B of the McKinney-Vento Homeless Assistance Act as amended by the Every

Student Succeeds Act, 42 U.S.C. § 11431 et seq., 2015. Retrieved December 2016 http://uscode.house.gov

U.S. Department of Education. (2016). Education for Homeless Children and Youths Program Non-Regulatory Guidance. Retrieved July 2016 http://www2.ed.gov/policy/elsec/leg/essa/160240ehcyguidance072716.pdf




https://nche.ed.gov/states/state_resources.php

Section C. Connections to Collaboration

Children and youth experiencing homelessness often face a vast array of challenges.

Meeting the needs of these young people requires a complex network of support. State

Coordinators may find themselves at meetings for infants and toddlers with developmental

delays and disabilities one day and at a summit on increasing the on-time graduation rate

and transition to college the next. In addition to other education programs, State

Coordinators must work with health, child welfare, and housing agencies. If you enjoy

learning about new issues, being a State Coordinator for the Education of Homeless

Children and Youth (EHCY) program may be an ideal assignment. Homeless education can

be a great vehicle for ongoing professional development and relationship building.

This section of the State Coordinators’ Handbook identifies the many players with

whom State Coordinators must interact and offers suggestions for how to make these

relationships work effectively. Descriptions of successful collaborations shared by fellow

State Coordinators are included to provide practical examples of the difference these

efforts make in the lives of children and youth experiencing homelessness.

Given the statutory requirements to bridge many programs and agencies and the

expansive needs of families and children experiencing homelessness, “SC” could as easily

be an abbreviation for “State collaborator” as “State Coordinator.” This section of the

handbook will offer some basics to hone your skills in collaboration as well as highlight the

many programs and people with whom State Coordinators must interact.

A Short Course in Human Relations (as amended)

The SEVEN most important words: “I don’t know, but I’ll find out.”

The SIX most important words: “I admit I made a mistake.”

The FIVE most important words: “You did a great job!”

The FOUR most important words: “What do you think?”

C-1 State Coordinators’ Handbook: Section C. Connections to Collaborations

The THREE most important words: “If you please...”

The TWO most important words: “Thank you.”

The ONE most important word: “We.”

The ONE least important word: “I” (St. Marie, n.d.)

C.1. What’s Required and What’s Recommended in Partnering Efforts

The seven functions of the Office of the Coordinator discussed in Section B of the

handbook cannot be fulfilled without partnerships, coordination, and collaboration. The

law specifies the following role groups, programs, and agencies with which the State

Coordinator must coordinate and collaborate:

(A) educators, including teachers, special education personnel, administrators, and

child development and preschool program personnel;

(B) providers of services to homeless children and youths and their families,

including public and private child welfare and social service agencies, law

enforcement agencies, juvenile and family courts, agencies providing mental health

services, domestic violence agencies, child care providers, runaway and homeless

youth centers, and providers of services and programs funded by the Runaway and

Homeless Youth Act (42 U.S.C. 5701 et seq.);

(C) providers of emergency, transitional, and permanent housing to homeless

children and youths, and their families, including public housing agencies, shelter

operators, operators of transitional housing facilities, and providers of transitional

living programs for homeless youths;

(D) local educational agency liaisons designated under subsection (g)(1)(J)(ii) for

homeless children and youths; and

(E) community organizations and groups representing homeless children and

youths and their families. [42 U.S.C. § 11432(f)(4)]6

State Coordinators must also “coordinate with State and local housing authorities

responsible for developing comprehensive affordable housing strategies under Section 105

of the Cranston/Gonzalez National Affordable Housing Act (P.L. 101-625) to minimize



educational disruption for children and youths who become homeless.” [42 U.S.C.

§ 11432(g)(5)(b)].

The 2016 Non-Regulatory Guidance recommends that State Coordinators

coordinate housing, health, and other services with the regional representatives

of the U.S. Interagency Council on Homelessness; and

coordinate and consult with State and local policymakers to ensure that

legislation and policies do not create barriers for the education of homeless

children and youths (ED, 2016, p. 14).

The guidance also speaks to other ED programs that have coordination requirements with

the EHCY program, including Title I, Part A of the ESEA; the Individuals with Disabilities

Education Act (IDEA) Parts B and C; and postsecondary education programs such as the

College Cost Reduction Act amendments to the Higher Education Act, which authorizes

local liaisons to verify unaccompanied homeless youth status for the purpose of applying

for independent student status on the Free Application for Federal Student Aid (FAFSA)

(ED, 2016, p. 34). The guidance reinforces the importance of State Coordinators and local

liaisons coordinating with Federal agencies that use the McKinney-Vento Act’s definition of

homeless, such as the U.S. Department of Agriculture and the U.S. Department of Health and

Human Services in order to “determine eligibility consistently across agencies and expedite

referrals for services” (ED, 34). The guidance also notes that while some programs

administered by Federal agencies may use different definitions of “homeless,” coordination

with these programs is critical to ensure that homeless students have access to services,

besides education, to address their basic needs, such as housing and health (ED, 2016, p.

35).

With the increasing focus on early childhood education, there are several programs

in this area with which State Coordinators must and should be involved.

IDEA requires State Coordinator or SEA-level participation on advisory councils,

Part B and C.

Advisory councils authorized under Head Start may require homeless education

expertise.


State Child Care agencies and administrators to U.S. Department of Health and

Human Services overseeing the Child Care Development Fund State Plans are a

critical opportunity for State Coordinators to ensure that serving young homeless

children is part of the discussion (ED, 2016, p. 35).

Appendix C-1. Connections to Consider summarizes partners with whom State

Coordinators should work.

C.2. How State Coordinators Can be Purposeful in their Collaborations

State Coordinators should engage in collaborative activities with a clear purpose in

mind, namely to increase resources, referrals, and partnerships to meet the complex needs

of children and youth experiencing homelessness. Moreover, with the increased emphasis

on using data to guide decision-making and activities, collaborations should have concrete

measurable goals so that it is possible to measure progress and determine the effectiveness

of each collaborative partnership or initiative. These measurable goals are also useful in

determining the type of partnership that would best meet specific goals, as different goals

will require different levels and types of working relationships. Some examples of broad

purposes for collaborative partnerships follow:

Enable programs and agencies to expand and/or customize their services through

greater awareness of the needs of homeless children and youth

Use resources efficiently by coordinating services

Remove barriers to services across programs and agencies by aligning policies and

practices

Build strong cross-agency advocacy and policy initiatives

As an example, let’s look at a particular problem where purposeful collaboration

could produce measurable outcomes. In a certain State, data and complaints from school

districts and homeless parents show that homeless students with disabilities are

experiencing delays with transportation to and from their school of origin. This would

certainly be a call for strong cross-program collaboration. A State Coordinator could

establish the following goals for collaborative activities with the State’s special education

program:


75% reduction in transportation delays of over two days for homeless children with

disabilities during the next school year

90% reduction in calls from school districts and parents resulting from conflicts

between homeless education and special education over transportation

responsibilities

With these goals in mind, the State Coordinator could identify very specific

collaborative activities for the next year, including for example, (1) ensuring that the issue

of coordination between homeless and special education transportation is an agenda item

at each quarterly meeting of the State special education advisory board, and (2) co-

developing with the State special education coordinator a memorandum for school districts

outlining the transportation responsibilities of the homeless education and special

education programs with strategies for coordination.

Appendix C-2. Collaboration Goals for State Coordinators is a table that provides

more examples of collaboration goals and strategies that State Coordinators should

consider as they strengthen partnerships in their State to address very specific needs of

homeless children and youth.

C.3. How State Coordinators Can Decide Which Partners with Whom to

Collaborate and the Level of Collaboration Needed

Appendix C-3. Evaluating Current Collaborations is a planning tool to help you look

at current partnerships in place in your State. If participation is mandated, reviewing the

legal requirements will help you determine what needs to occur. (You may wish to review

the requirements for coordination under the functions of a State Coordinator on page C-2,

and use Appendix C-1. Connections to Consider as starting points for this activity.) Conduct

an environmental scan by answering the following questions to decide which partners and

to what level you can or must participate. While the first question addresses legal

requirements, the remaining questions can be used for any efforts that require you to work

with other partners.

What does the law require?


How will I participate? How much time is required for each activity? (E.g., face-to-

face meetings, conference calls, email correspondence)

What level of interaction during and between meetings is required? (E.g.,

information sharing, sharing resources, leading initiatives, extensive participation in

planning and executing initiatives)

What level of participation is likely to be most effective based on identified goals for

the State’s EHCY program?

What is my organization’s level of commitment to this partnership?

Can I delegate my representation?

In addition to these questions, consider:

At what additional “tables” should I be seated to provide a homeless education

voice?

Are there “tables” where I serve under a different role that would benefit from a

homeless education voice?”

Do additional “tables” need to be created? Be sure to look carefully at your existing

“tables” before considering a new endeavor. With limited time, using existing

structures that are working can produce more immediate results.

C.4. Making Collaborations Work

While State Coordinators sometimes feel isolated as the only person in their State

who fulfills these responsibilities, they may also long for a little “alone time” without the

demands of multiple meetings, agency priorities, and diverse personalities. The

information and tips that follow will help you make the most of the time that you devote to

building and maintaining partnerships and collaborations.

Partnerships and connections exist along a continuum from very loosely structured

relationships to highly structured and formalized ones. State Coordinators will find the full

continuum of structures in their day-to-day work. Recognizing the possible connections

and selecting the most appropriate level of involvement allows programs to be tailored to

meet unique needs, resources, expertise, and interests.

Frequently we use the term “collaboration” to describe a wide variety of

connections, partnerships, and teaming efforts. A “collaboration” technically means a highly


developed, formalized system of sharing resources and responsibilities. However, in

general use, the term “collaboration” can suggest a variety of levels of interaction with

partners.

The Chandler Center for Community Leadership suggests five levels of interaction or

connection that range from loosely connected arrangements through highly formalized

structures. Figure C.1. A Continuum of Connections is a graphic representation of the levels

of interaction. The following is a summary of these five levels.

Networking offers opportunities for informal dialogue across different organizations to

develop common understanding. Networking acts as a clearinghouse for information

and requires low levels of leadership and minimal decision-making.

Cooperation or alliance requires semi-formal links with the beginning of role definition.

The purpose is to match needs and limit duplication of services while ensuring tasks are

accomplished. Leaders at the cooperation level should be facilitative due to the need for

complex decision making in which some conflict may occur as needs and duplication

are identified.

Coordination or partnership requires formalized links with a central body of decision

makers with defined roles. At this level, resources are shared to address common issues

and to create new resources. At this level, joint budgeting, frequent and clear

communication, and group decision making are necessary.

In a coalition, roles and timelines are defined and links have been formalized with a

written agreement. All members should be involved in the decision-making as ideas are

shared and resources are reassigned from existing systems as well as generated by the

group. A coalition generally calls for a commitment of at least three years, and shared

leadership and communication are considered a priority.

Collaboration requires a high level of trust, leadership, and productivity to realize a

shared vision through the building of an interdependent system. Consensus in decision

making, formalized work assignments, highly developed communication, and equal

sharing of ideas characterize a collaborative relationship (Chandler Center, no date).


Figure C.1. A Continuum of Connections

Level of shared responsibility for:

Type of Connection

low

high

Networking - info sharing

Coordination – changing services

Cooperation – sharing resources

Coalition – formal agreements

Collaboration• Decision

making

• Resources

• Open, Frequent

Communication

• Long-term Commitment

• Formalized Agreements

Another way to look at connections is by the expectations for how people will work

together. Bailey, Ross, Bailey, and Lumley (1998) suggest the following structures.

Committees have formal structures, with a chairperson and printed agenda that

follows Roberts’ Rules of Order, including voting, to make decisions. Examples

include the Special Education Advisory Council (SEAC) and Interagency

Coordinating Council (ICC) found in the Individuals with Disabilities Education

Act (IDEA).

Groups share information, have limited common purpose, and are directed by a

supervisor or outside leader to achieve specific tasks. Examples include a group

of stakeholders brought together to participate in strategic planning around a

statewide grant or a group brought together to review the State’s special

education benchmarks for its State improvement plan. A State Coordinator may

be asked to participate in strategic planning for the State’s family life education

grant from the Center for Disease Control or to be a stakeholder in the creation

of the State Systemic Improvement Plan (SSIP) for its early childhood special

education program.


Teams have members who share considerable information, have a clearer sense

of purpose and goals, share leadership roles, and are committed to operating

over a long period of time. The Florida Homeless Education program conducted

a comprehensive needs assessment of their statewide program over a number of

months in 2007. Some attendees at meetings changed, depending upon the

purpose of the meeting, but a core committee held ownership for identifying

needs and creating a plan that could be realistically implemented. States that

have begun Higher Education Networks, facilitated by the National Association

for the Education of Homeless Children and Youth (NAEHCY), often have core

team members who work toward smoother transitions for homeless students as

they graduate from high school and pursue post-secondary education. With

greater sophistication, teams can be categorized as high performance teams or

technology-based teams. (For more information on these specialized team

structures, see Bailey, Ross, Bailey, and Lumley.)

C.5. Elements of Successful Connections

As State Coordinators, legislative mandates for collaboration must be considered a

priority. However, the level of interaction can be altered to keep the work manageable.

When deciding which connections to pursue, expand, discontinue, or limit, think about the

following. Successful connections require dissimilarity among the participants. What are

the unique skills, knowledge, and resources that each partner brings to the table that the

other partners need? This dissimilarity gives you a reason for working together and can

help shape your goals. Related to this condition is the likelihood of mutual satisfaction. Will

all of the participants benefit from working together? Without mutual satisfaction, some

participants will be less likely to remain involved. Some required partnerships are with

programs for which homelessness or education is a very tangential issue. You are likely to

find sitting through multiple education meetings that never mention the word “homeless”

or housing meetings that never use the word “education” very discouraging. However, such

meetings may be an opportunity for you to raise issues related to the education of

homeless children and youth. If discussions on these issues have not occurred, you are

probably not the only one who will benefit from putting them on the table.


Success is also dependent upon the qualities of the participants. It often comes

down to the personalities of individuals. Qualities that should be present include

selflessness, commitment to the goals of the partnership, mutual trust and respect,

flexibility as goals are clarified, and willingness to take risks. These may be natural qualities

among some individuals, but trust, respect, commitment, etc. need intentional time to

nurture.

C.6. Tools to Enhance Connections

People skills and organizational skills both come into play when we need to work

with others. Some tricks of the trade follow.

C.6.1. Critical Communication Skills to Practice

Effective communication is critical to successful teams. Three key skills are

constructive assertiveness, empathic responding, and problem solving (Evertson & Emmer,

2013). Often we jump to problem solving without clearly articulating the issues at hand

and ensuring understanding of the different perspectives that exist. Therefore, it is

important to use constructive assertiveness and empathic responding techniques before

trying to solve the problem.

Using constructive assertiveness, individuals make their wants and needs known by

clearly stating the problem, identifying the behavior or issue in question, and describing its

effect. Being assertive means finding the middle ground being neither passive nor

aggressive. This is accomplished by using “I” messages, avoiding labeling, and using body

language with proper eye contact, posture and body orientation, and congruent facial

expressions. Remember that nonverbal communication accounts for 60% of the message

you communicate.

Empathic responding solicits and affirms the viewpoint of another person using of

listening and processing skills. Listening skills acknowledge the feelings and ideas of the

other person through nonverbal behaviors such as nodding, eye contact, and posture and

through verbal remarks such as, “I see, go on, that’s interesting.” These behaviors

communicate that you care about the other person and his/her ideas. Processing skills

allow you to confirm or clarify your perceptions by repeating or summarizing what the


other person says. Again, this demonstrates that you were really paying attention to the

other’s words. It also gives the other person an opportunity to correct any misconceptions

by re-explaining if the original explanation was not clear. If the issue is an emotional one, it

may give the other person a first glimpse at a more objective view of the issue.

The order of these two techniques can vary based on the situation. If you have an

issue you feel needs to be addressed, constructive assertiveness should come first; if you

sense another’s concern and want to unpack that issue, empathic responding may be a

more appropriate starting point. To see these skills in action, you may enjoy a video clip

from the Interpersonal Psychology Project.

One further consideration to keep in mind is how to include a guest or new partner.

Groups can get comfortable with their acronyms and expressions and not realize their

conversation would be difficult for a new member to understand. When a guest or new

member joins a meeting, appoint a “Code Buster” who is responsible for ensuring all terms

that might be confusing are explained.

A Few Language Tips

Avoid “but.” Use “and.”

I heard a rumor that the conference was being canceled, but no one told me what was going

on.

This conference really requires us to stay in touch, and if there is a possible change, let’s

make sure everyone hears about it.

Replace “should” with “next time,” “in the future,” or “from now on.”

Everyone should print the agendas and bring it to the meeting.

In the future, please print your agenda. To avoid wasting paper, we won’t make copies.

There are a variety of problem solving processes. All involve clearly identifying the

problem, brainstorming and evaluating possible solutions and selecting one or more to be

implemented. Figure C-2. A Problem Solving Process - LACE describes one example.


Readers are encouraged to visit the Mind Tools website, which has a rich variety of tools

for problem solving, leadership, time management, and decision-making.


Figure C.2. A Problem Solving Process – LACE

C.6.2. What State Coordinators Should Know about the Stages of Group Formation

It is helpful to recognize that that there are stages in the creation, development, and

possible dissolution of teams. Table C-1. Leadership Activities at Different Group Formation

Stages lists the stages of group formation and offers activities to assist leaders in nurturing

effective teaming.


Table C.1. Leadership Activities at Different Group Formation Stages7

Stage Activities

Forming Direct the team clearly. Establish objectives, perhaps with a

team charter or written description of the purpose of the team and desired outcome of its efforts.

Storming Establish process and structure, and work to smooth conflict

and build good relationships between team members. Generally provide support, especially to those team

members who are less secure. Remain positive and firm in the face of challenges to your

leadership or the team’s goal. Perhaps explain the “forming, storming, norming, and

performing” idea so that people understand why conflict is occurring and understand that things will get better in the future.

Norming Step back and help the team take responsibility for progress

towards the goal. This is a good time to arrange a social or team-building

event.

Performing Delegate as far as you sensibly can. Once the team has

achieved high performance, you should aim to have as “light a touch” as you can. You will now be able to start focusing on other goals and areas of work.

Adjourning When breaking up a team, take the time to celebrate its

achievements. After all, you may work with some of these people again, and this will be much easier if people view past experiences positively.

C.6.3. How State Coordinators Can Conduct Effective Meetings that Enhance Team

Building

Disorganized meetings not only waste time, they can dampen the commitment and

energy of even the most avid supporter of an issue and zap the willingness of participants

7 Reproduced with permission from: http://www.mindtools.com/pages/article/newLDR_86.htm.


http://www.mindtools.com/pages/article/newLDR_86.htm

to remain involved. Bailey, Ross, Bailey and Lumley propose that the following steps should

be a part of all meetings that require true teaming to meet their goals.

1. Set an agenda. Set clear expectations for the goals of a meeting and estimate time

to be allocated to avoid spending too much or too little time on items.

2. Assume team roles. Rotate responsibilities among members to enhance the sense

of shared leadership.

3. Initiate whip activities. Use a brief exercise to build relationship and set the stage

for team productivity. Icebreakers would fit in this category.

4. Monitor verbal and nonverbal behaviors. Hold each other accountable for

identifying, controlling, and modifying behaviors that affect team

communication.

5. Initiate fishbowling. Having a closure activity to analyze the team’s performance,

celebrate successes, and identify challenges sets the State for continued growth

at future meetings.

For an example of these steps in action, see Appendix C-4. The Early Childhood Priority

Project Agenda and Minutes Templates.

C.6.4. How State Coordinators Can Evaluate the Effectiveness of Their Partnerships

In high functioning teams where there are clear goals and teams will continue to

work together in the future, members often take the time to openly discuss the

effectiveness of the participants’ efforts and the team processes. If teams follow the

meeting steps listed above, evaluation will be a part of every meeting. If there is a shift in

team membership, the introduction of new projects occurs, or you have the luxury to

conduct a retreat with greater time for participants to reflect on their work, this is a good

time for a targeted assessment of team effectiveness. The evaluation may be as simple as

asking participants to identify what you do well together and what the team could do

better. Mindtools offers another example of an evaluation tool. If you are working with an

outside facilitator, the consultant should be able to offer a variety of tools to gain

participant insight.


Choose Your Battles Wisely

(Is it better to be right or in relationship?)

Ask yourself

1. Is the issue trivial?

2. Is it a persistent concern?

3. Is the behavior innocent or intentional?

4. What’s the history or context of the situation?

5. Can or will the behavior change?

6. Is this good timing?

7. How are you contributing to the problem? If others are complaining about you, is

what they’re saying at least partially true?

8. Would confronting someone result in a short-term win and a long-term loss?

“Good manners are made up of petty sacrifices.” Ralph Waldo Emerson (Letters and

Social Aims, 1875)

C.6.5. How State Coordinators Can Address Collaboration Challenges

Despite your best efforts to build strong relationships and plan productive meetings,

there will be times when a collaborative initiative will not thrive. Many factors impact

collaborative relationships, including the time members can devote to the initiative, the

sociopolitical climate, past history, amount of trust among partners, and competition for

limited resources. It is important to keep in mind that these challenges did not develop

overnight, and the time spend in building relationships and commitment to the effort is the

only way to overcome them. Persistence is key.

Appendix C-5. Overcoming Challenges to Collaboration is a table that lists common

barriers to effective collaborations with suggested strategies to address them.


Coordinator to Coordinator: Stories from Colleagues

Good leaders are good storytellers, and many State Coordinators love to share their

stories! Read about three colleagues and their ventures into collaborations that made a

difference for students experiencing homelessness by

developing a State advisory board (Appendix C-6),

establishing a close working relationship with Head Start (Appendix C-7), and

creating links to higher education (Appendix C-8).

C.7. How State Coordinators Can Encourage Local Liaisons to Develop

Collaborations

Developing cross-program and cross-agency collaborations requires significant time

along with knowledge of specific strategies to make collaborations productive and

sustainable. Local homeless liaisons who are new, who have very little time allocated to

homeless education duties, who do not see the value of collaboration, or who are

unfamiliar with collaborative strategies will need the support and guidance of the State

Coordinator to initiate both local educational agency (LEA) program collaborations and

community collaborations.

There are five main reasons that State Coordinators may provide to their local liaisons

to urge them to collaborate.

1. Collaboration is one of the responsibilities outlined in the McKinney-Vento Act. The

law states:

Each local educational agency serving homeless children and youths that

receive assistance under this subtitle shall coordinate (i) the provision of

services under this subtitle with local social services agencies and other

agencies or entities providing services to homeless children and youths and

their families, including services and programs funded under the Runaway

and Homeless Youth Act (42 U.S.C. 5701 et seq.); and (ii) transportation,

transfer of school records, and other interdistrict activities, with other local

educational agencies. [42 U.S.C. § 11432(g)(5)]


Moreover, the law requires coordination with Title I in determining the amount and

use of the Title I, Part A reservation of funds for homeless students.

2. States are required to oversee the implementation of the McKinney-Vento Act in all

LEAs, including those without subgrants. Therefore, State Coordinators should

include monitoring indicators specific to LEA collaboration.

3. Collaboration makes the work of the local liaison more effective to the extent that he

or she can call on community collaborations to provide services to homeless

families. Such collaborations also assist identification efforts.

4. Collaboration is a means of obtaining resources and funding for homeless children

and youth. One of the most critical collaborations is between the McKinney-Vento

and Title I, Part A programs. Local homeless liaisons work closely with the local

Title I coordinator to review data on homeless students and determine the amount

of the homeless set aside and ways in which the set aside should be spent.

5. Collaboration can result in policies and procedures that clarify the roles and

responsibilities of each agency. For example, homeless shelters funded by U.S.

Department of Housing and Urban Development program are required to

coordinate with school districts to ensure that homeless children and youth residing

with them are enrolled in and attending school. The local liaison is instrumental in

making sure this coordination is in place and in providing suggestions for specific

activities. Also, inter-district issues can be resolved before conflicts arise, such as

determining how two LEAs will share responsibilities for transporting homeless

children and youth to and from their school of origin.

C.8. How State Coordinators Can Assist LEAs with Collaborations

State Coordinators must model collaboration at the State level (“walk the walk”) as

well as nurture local collaboration (“talk the talk”).

1. State Coordinators can expand State-level collaborations to provide support for

similar collaborations between the LEA and other local agencies. For example, State-

level collaborations involving Head Start can result in joint policies or memoranda

of understanding (MOUs) that assist both Head Start programs and local homeless

education programs in coordinating their work. Similarly, cross-program


collaborations within the SEA (such as Title I, Part A; migrant education; IDEA; and

transportation) can develop State policies or guidance memos that clarify how these

programs should collaborate at the LEA level.

2. State-level collaborations can facilitate joint training opportunities in which State-

level staff in both the EHCY program and other programs can train each of their

local staffs to familiarize them with one another’s programs as well as bring them

face to face to begin conversations.

3. State Coordinators can include requirements for collaboration in their McKinney-

Vento subgrant applications so that LEAs that have active collaborations are more

competitive for funding. Many States require that subgrant applicants include

information on the coordination between Title I and homeless programs in

assessing needs of homeless students and determining the amount of the Title I,

Part A reservation of funds.

4. State Coordinators can provide training to local liaisons on ways that they can

initiate and sustain collaborations. The NCHE website includes a variety of

documents to assist with collaboration in its Resources by Topic section.

C.9. How State Coordinators Can Collaborate with Each Other

Even though such collaborations are not mandated, many State Coordinators find

that collaborations with their colleagues are an important method of collaboration and

working smarter. Over the years, several rich collaborative initiatives have existed among

groups of State Coordinators to conduct a range of activities, including

working together to form the local arrangements committee for the annual NAEHCY

conference;

conducting trainings for local liaisons from the States in the region (some States in

this type of collaborative have rotated the location of their annual joint training

from one State to another);

establishing a collaborative team to discuss and strategize issues they have in

common;

presenting in each other’s State;

serving as reviewers for one another’s subgrant applications;


offering to mentor a new State Coordinator; and

generally serving as a support and sounding board for one another.

Key benefits of State Coordinator collaboration include

increasing expertise by learning from colleagues (especially important for new State

Coordinators who have State Coordinator mentors; contact NCHE if you would like a

mentor);

getting different perspectives on disputes and learning from other State’s

approaches to managing disputes;

expanding support for local liaisons in your State (if one State Coordinator is

unavailable for assistance, a State Coordinator may arrange for local liaisons to call

another State Coordinator within a regional partnership);

establishing new supportive relationships to overcome feelings of being the “lone

ranger” in your department (State Coordinators and local liaisons often establish

collaborative relationships through meeting at regional trainings); and

developing policies and procedures to navigate inter-State issues.

Suggestions for building inter-State collaboration

Convene a group of State Coordinators informally at national conferences and

meetings to explore interest in establishing a regional group.

Attend other States’ training sessions to get ideas.

Start small and add other States to a regional collaboration when the interest arises.

(Distance may limit who can participate, but conference calls and online meeting

technology can mitigate this problem.)

Invite new State Coordinators to participate in order to build their capacity and to

bring fresh perspectives to existing collaborations.


Resources

1998 Amendments to the Higher Education Act of 1965, P.L. 105-244 (1998).

Bailey, G.D., Ross, T., Bailey, G. L., & Lumley, D. (1998). 101 tips, traps, and to-dos for

creating teams: A guidebook for school leaders. Bloomington, IN: National

Educational Service.

Chandler Center for Community Leadership. (no date). Community based collaboration:

Community wellness multiplied. Retrieved from

https://www.uvm.edu/extension/community/nnco/collab/wellness.html.

Evertson, C. M., Emmer, E. T. (2013). Classroom management for elementary teachers (9th ed.).

Needham Heights, MA: Pearson. (See especially Chapter 8.)

Individuals with Disabilities Education Act, 20 U.S.C. § 1400 (2004).

Interpersonal Psychology Project. (2008, April 21). Empathetic listening [video]. Retrieved

from http://www.youtube.com/watch?v=sz4dbYgiuT4.

Mind Tools. (no date). Evaluation Tool. Retrieved July 2016

http://www.mindtools.com/pages/article/newTMM_84.htm

National Association for the Education of Homeless Children and Youth. (no date). State

higher education networks. Retrieved from http://www.naehcy.org/legislation-and-

policy/state-he-networks

National Center for Homeless Education. Resources by Topic Web Page on Collaboration.

Retrieved from http://center.serve.org/nche/ibt/sc_collab.php

Runaway and Homeless Youth Act, 42 U.S.C. § 5701 et seq. (2008).

Section 105 of the Cranston/Gonzalez National Affordable Housing Act, P.L. 101-625

(1990).

Terry St. Marie. (no date). A short course in human relations. Retrieved from

http://cdn.terrystarbucker.com/wp-content/uploads/2012/02/A-Short-Course-In-

Human-Relations-as-amended.pdf

Title VII-B of the McKinney-Vento Homeless Assistance Act as amended by the Every

Student Succeeds Act, 42 U.S.C. § 11431 et seq., 2015. Retrieved December 2016

http://uscode.house.gov



http://cdn.terrystarbucker.com/wp-content/uploads/2012/02/A-Short-Course-In-Human-Relations-as-amended.pdf

http://cdn.terrystarbucker.com/wp-content/uploads/2012/02/A-Short-Course-In-Human-Relations-as-amended.pdf

http://www.naehcy.org/legislation-and-policy/state-he-networks

http://www.naehcy.org/legislation-and-policy/state-he-networks

http://www.mindtools.com/pages/article/newTMM_84.htm

http://www.youtube.com/watch?v=sz4dbYgiuT4

https://www.uvm.edu/extension/community/nnco/collab/wellness.html

U.S. Department of Education. (2016). Education for Homeless Children and Youth Program

Non-Regulatory Guidance. Retrieved from


U.S. Department of Education. (2016). Initiatives: Identifying and Supporting Students Experiencing Homelessness from Pre-School to Post-Secondary Ages. Retrieved from http://www2.ed.gov/about/inits/ed/supporting-homeless-students/index.html

U.S. Interagency Council on Homelessness. Retrieved from https://www.usich.gov


https://www.usich.gov/


Section D. Data Collection and Reporting for EDFacts

With an increasing emphasis on quality data as a foundation for program planning

at the Federal, State educational agency (SEA), and local educational agency (LEA) levels,

State Coordinators play a pivotal role in collecting data on homeless children and youth.

One of the functions of the Office of the Coordinator in the McKinney-Vento Act specifically

addresses collecting and submitting required data to the U.S. Department of Education

(ED). The McKinney-Vento Act states that the State Coordinator must

collect data for and transmit to the Secretary, at such time and in such a manner as the Secretary may reasonably require, a report containing information necessary to assess the educational needs of homeless children and youths within the State, including data necessary for the Secretary to fulfill the responsibilities under section 724. [42 U.S.C. § 11432(f)(3)]8

The law also addresses data collection in the context of coordination between local

liaisons and State Coordinators stating that “such coordination shall include collecting and

providing to the State Coordinator the reliable, valid, and comprehensive data needed to

meet the requirements of paragraph (1) and (3) of subsection (f).” [42 U.S.C. § 11432(g)(6)

(C)] Therefore, State Coordinators must work with LEAs, as well as State-level data

managers to ensure that the data collection process produces high quality data.

D.1. EDFacts, the EDEN Submission System, and Consolidated State Performance

Reports

ED created the EDFacts initiative to centralize data for use in education policy,

management, and budget decisions. EDFacts is a repository of data submitted by SEAs to

ED regarding the education of homeless children and youth, as well as other Federal


D-1 State Coordinators’ Handbook: Section D. Data Collection and Reporting for EDFacts

education programs. Although the data is aggregated and does not include personally

identifiable information, it allows ED to

determine the effectiveness of the Education for Homeless Children and Youth

(EHCY) program and its collaborations with Federal programs like Title I of the

Elementary and Secondary Education Act, as amended;

assess the effectiveness of States in helping homeless students access a free,

appropriate public education; and

identify technical assistance needs of States and LEAs and plan State monitoring

activities.

Similarly, ED expects States to utilize data collected through EDFacts to assess the

effectiveness of their own EHCY programs and guide State Coordinators in determining

technical assistance and monitoring activities for their LEAs. State Coordinators can in turn

encourage LEAs to utilize data for their EHCY program planning. LEAs that apply for

subgrant funds must include a needs assessment of the educational and related needs of

homeless children and youths in the school district [42 U.S.C. § 11433(b)(1)], and data

collected for EDFacts is a logical foundation for an LEA needs assessment.

All homeless education data submitted to ED is submitted via the EDEN Submission

System, or ESS. The ESS is an online tool that allows States to submit data files to ED,

review prepopulated reports, and enter comments regarding data quality or concerns. Each

State is required to have an EDFacts coordinator, who may grant access to additional

system users.

EDFacts coordinators serve as the official contact for ED and submit the State’s data

plan. They also ensure that data files are transmitted in a timely manner, that errors

in data are corrected, and that the SEA approves all files for storage in the EDFacts

Data Repository.

Other system users include SEA staff or contractors designated by the EDFacts

coordinator to serve as EDFacts submitters. EDFacts submitters are often

programmers or other data systems technicians who can extract the necessary

information from the SEA’s system, input it into the ESS, answer questions about the


data, or address programming issues that arise during data submission or

collections.

Each year, ED issues a Consolidated State Performance Report (CSPR) that is

populated by the data that SEAs and LEAs submit to EDFacts. In addition to reporting

information on the EHCY program, the CSPR includes information on Title I, teacher

quality, English language acquisition, grant programs for statewide assessments, and rural

education. CSPR reports may be viewed on the ED website.9 The ED Data Express website

provides the same data but allows you to build your own reports.

D.2. Overview of the EDFacts Data Collection Process

Data collection for the EHCY program begins at the LEA level. The LEA collects

homeless student data for any student identified as homeless during the school year. While

many of the data collection items specified by ED remain constant from year to year, such

as the number of homeless students enrolled and their primary nighttime residence, other

items may change, in which case ED would notify SEAs well in advance of the school year in

which the data collection takes place.

The LEA removes duplicate counts of homeless students who move from one school

to another in the LEA and sends the data to the SEA. After reviewing the data for accuracy

and completeness, the SEA submits the data received from the LEA directly to ED. This data

serves as the LEA level count. ED uses the LEA level data for the CSPR, LEA level workbooks

provided to SEAs, and online data releases.

The SEA also removes duplicates in the data received from LEAs, which allows for a

State count of homeless students that removes duplicates of homeless students who were

counted in one LEA and counted again when they moved to another LEA. The SEA submits

this data to ED as the SEA level count. The total count for the SEA level data does not equal

the total count for the LEA level data.

The National Center for Homeless Education (NCHE) uses the SEA level data for its

annual Federal summary of data, State profile pages on its website, and other reports.

(Note: when you see discrepancies among reports for the number of homeless students

9 Websites for resources mentioned are included in Resources at the end of this section.


enrolled in a school year, you should determine whether the counts are based on the LEA

level data submitted to EDFacts or the SEA level data submitted to EDFacts.)

D.3. Tasks and Timeline for the CSPR Data Review and Submission

Each year, after LEAs submit and certify their data as complete, the EDFacts

coordinator will begin preparing reports as outlined in ED’s rules for the file specifications.

The most commonly used report is the CSPR.

During the process of submitting data for the CSPR, SEAs and State Coordinators

have an opportunity to review the data and identify problems or discrepancies. Once the

State Coordinator has verified that the data are accurate and has provided any comments

or disclaimers, the EDFacts coordinator will submit the information to the ESS.

The CSPR data review and correction period consist of two discrete, narrow

windows for Part I and Part II of the CSPR. Each time period includes an opening date for

file submission, a due date for file submission, and a due date for certification. ED provides

the specific dates of the deadlines for these activities each year. Between the time of first

submission and resubmission, NCHE conducts a quality review of the data and sends

incongruities to ED. Then ED contacts States to review their data and make corrections for

resubmission.

Table D-1. Time Frame for CSPR File Submission provides a general sense of when

the EDFacts coordinator must submit the CSPR files.

Table D-1. Time Frame for CSPR File Submission

CSPR, Part I CSPR, Part II

Initial Period

October: Open date for file submission

December: Due date for file submission

December: Due date for certification

Initial Period

January: Open date for file submission

February: Due date for file submission

February: Due date for certification

Re-open Period

February: Open date for file re-submission

(with corrections)

Re-open Period

March: Open date for file re-submission

(with corrections)


Early March: Due date for file re-

submission

Early March: Due date for certification

Late March: Due date for file re-submission

Late March: Due date for certification

Once the data are entered into the ESS and certified by the SEA, LEA level data

automatically populates the online tool for the CSPR.

D.4. The State Coordinator’s Role in the EDFacts Data Collection Process

The State Coordinator plays several important roles in the EHCY data collection

process. Working closely with the SEA EDFacts coordinator and communicating updates

from the EHCY Federal coordinator, the State Coordinator ensures that all changes in the

CSPR are incorporated into the State’s data system well in advance of the school year for

which data are collected. The State Coordinator informs the local liaisons of the changes

and provides them with technical assistance needed to collect the required data.

The State Coordinator works with the SEA EDFacts coordinator to determine how

and when LEAs can submit their data in order to meet the deadlines for EDFacts

submission. Once this timeline is established, the State Coordinator communicates this

information to the local liaisons and sends reminders to ensure that all LEAs submit their

data on time. The EDFacts coordinator will conduct similar communication with the LEAs’

data coordinators.

State Coordinators are key to identifying incongruities in the data submitted by the

LEAs due to their familiarity with LEA EHCY programs. In reviewing the data submitted by

the LEAs, State Coordinators can

identify LEAs that are possibly misunderstanding the data elements;

identify trends and discrepancies in LEAs by reviewing current and past data for

homeless students, as well as related data like information on economically

disadvantaged students; and

determine which LEAs may be at risk of poor data quality due to EHCY staff

turnover.


D.5. Ensuring LEA Data Quality

Fundamentally, the CSPR and other data reports are only as good as the data that

the LEAs provide. Therefore, it is critical for State Coordinators to provide as much support

and accountability as possible to ensure that LEAs have the capacity and the commitment

to collect and submit quality data.

In their review of LEA data in the certification process, State Coordinators should

note which LEAs submit data that are insufficient or of poor quality and which data

elements pose challenges for data collection in the LEAs. This information should be

reflected in the annual training and monitoring plans for LEAs.

D.5.1. Providing Training and Technical Assistance

Clear communication on the expectations and timelines for data collection will

ensure that all local liaisons know when to collect and submit their data. Many State

Coordinators post this information on the State EHCY website and include it in routine

communication via a listserv and conference calls.

Annual trainings of local liaisons should include the topic of data collection. The

2016 Non-regulatory Guidance states, “Local liaisons, State Coordinators, EDFacts

coordinators, Consolidated State Performance Report (CSPR) coordinators, and data

stewards should coordinate training and technical assistance efforts to ensure that school,

LEA, and SEA personnel are aware of requirements and standards for data reporting” (ED,

2016, p. 13). Many State Coordinators include LEA data managers in the portion of liaison

trainings that address data. Not only do the local liaisons and data managers learn the same

information, but they have an opportunity to interact with one another and create a basis

for collaboration.

D.5.2. Ensuring Accountability through LEA Monitoring

Because the McKinney-Vento Act requires SEAs to monitor all LEAs on a regular

basis, monitoring provides a perfect opportunity to hold LEAs accountable for processes

and procedures to submit quality data on time. The LEA monitoring protocol should have

specific indicators related to data collection (and data use for program planning), and LEAs


with findings in this area should be required to provide a plan for how they will improve

their data collection.

D.5.3. Involving LEAs as Partners in Data Quality

One of the best ways to ensure data quality is to engage LEAs as partners. Through

training and technical assistance, State Coordinators, EDFacts coordinators, CSPR

coordinators, and data managers should demonstrate the value of data to LEAs and provide

them with easy access to the data they submit. Technical assistance should include

enabling local liaisons and LEA data managers to review their data to identify discrepancies

so that they may determine ways to improve data quality.

If LEAs come to rely on their data to make decisions regarding homeless children

and youth, they will be vested in the time and effort that goes into collecting quality data.

D.5. What resources are available to help with EHCY data collection?

ED’s system of data collection has been in place since 2004, so the EDFacts

coordinator in your State should be able to brief you on the requirements and systems in

place for data collection and submission.

In addition, NCHE publishes an annual Guide to Collecting & Reporting Federal Data,

which includes a more detailed overview of ED’s data collection system, including EDFacts;

updates from ED on upcoming changes to the data submission process and reporting

requirements; a timeline for data collection activities; an overview of the specific data

required on homeless children and youth; a glossary of terms; and other useful information

to build your capacity to ensure that quality data is submitted to ED.

The NCHE staff is available to answer your questions regarding data collection, and

NCHE provides webinars and trainings at the annual State Coordinators’ meeting on data

collection and use.

ED’s Partner Support Center (PSC) is available to assist States with technical

difficulties when submitting data to EDFacts, such as resetting passwords or

troubleshooting when a file fails to upload correctly.

Resources


NCHE’s Guide to Collecting & Reporting Federal Data (updated annually) at http://center.serve.org/nche/ibt/sc_data.php

NCHE’s Homeless Liaison Toolkit, Chapter 13: Data Collection and Requirements at http://center.serve.org/nche/pr/liaison_toolkit.php

Title VII-B of the McKinney-Vento Homeless Assistance Act as amended by the Every Student Succeeds Act, 42 U.S.C. § 11431 et seq., 2015. Retrieved December 2016 http://uscode.house.gov

U.S. Department of Education Consolidated State Performance Reports at http://www2.ed.gov/admins/lead/account/consolidated/index.html

U.S. Department of Education ED Data Express Website http://eddataexpress.ed.gov/ U.S. Department of Education EDFacts Web Page at

www2.ed.gov/about/inits/ed/edfacts/index.htmlU.S. Department of Education. (2016). Education for Homeless Children and Youth Program

Non-Regulatory Guidance. Retrieved July 2016 http://www2.ed.gov/policy/elsec/leg/essa/160240ehcyguidance072716.pdf

U.S. Department of Education’s Partner Support Center: Toll-free: 877.457.3336 (877.HLP.EDEN); TTY: 888.403.3336 (888.403-EDEN); Email: [email protected]




http://www2.ed.gov/about/inits/ed/edfacts/index.html

http://eddataexpress.ed.gov/

http://www2.ed.gov/admins/lead/account/consolidated/index.html


http://center.serve.org/nche/pr/liaison_toolkit.php

http://center.serve.org/nche/ibt/sc_data.php

Section E. Using Data for Decision Making

Advances in data technology along with an emphasis on performance management

from the U.S. Department of Education (ED) have resulted in the expectation that State

educational agencies (SEAs) and local educational agencies (LEAs) not only collect data on

homeless children and youth but utilize the data for program improvement. The following

excerpt from the McKinney-Vento Act reinforces the importance of data for identifying

barriers, assessing needs, and measuring progress related to homeless children and youth

and the Education for Homeless Children and Youth (EHCY) programs that serve them. The

law states that the State Coordinator must

(1) gather and make publicly available reliable, valid, and comprehensive

information on –

(A) the number of homeless children and youths identified in the State, which

shall be posted annually on the State educational agency’s website;

(B) the nature and extent of the problems homeless children and youths have in

gaining access to public preschool programs and to public elementary

schools and secondary schools;

(C) the difficulties in identifying the special needs and barriers to the

participation and achievement of such children and youths;

(D)any progress made by the State educational agency and local educational

agencies in the State in addressing such problems and difficulties; and

(E) the success of the programs under this subtitle in identifying homeless

children and youths and allowing such children and youths to enroll in,

attend, and succeed in, school. [42 U.S.C. § 11432(f)]10


E-1 State Coordinators’ Handbook: Section E: Using Data for Decision Making

E.1. Federal Performance Expectations

Several Federal level activities have precipitated an era of emphasis on performance

management and data use. With new expectations for data use, State Coordinators must

incorporate data review and utilization in their state planning activities and oversight of

LEA EHCY programs, and build their proficiency in analyzing data from various sources to

measure program progress and evaluate the effectiveness programmatic strategies.

Following is a brief summary of Federal initiatives on performance management.

E.1.1 Government Performance and Results Act Indicators

The Government Performance and Results Act (GPRA), which was amended by the

Government Performance and Results Modernization Act of 2010, requires Federal

agencies to outline a mission statement, long term goals, and performance measures as a

part of a five-year strategic plan. It also outlines requirements for annual reporting on the

progress made by Federal agencies in meeting their goals. Additionally, within the Federal

agencies, each program determines measurable goals and targets. GPRA goals for the EHCY

program focus on the participation and achievement of homeless students in State

assessments for English language arts and mathematics in grades 3 through 8.

E.1.2. U.S. Department of Education Strategic Plan

As a part of its strategic plan, ED has adopted a cradle-to-career education approach

to ensure that children have opportunities for learning across all levels of child

development, leading to graduates who are college and career ready. To support this

strategy, ED has developed the following six priority goals for its 2014-2018 strategic plan:

Goal 1: Postsecondary Education, Career and Technical Education, and Adult

Education. Increase college access, affordability, quality, and completion by

improving postsecondary education and lifelong learning opportunities for youths

and adults.

Goal 2: Elementary and Secondary Education. Improve the elementary and secondary

education system’s ability to consistently deliver excellent instruction aligned with

rigorous academic standards while providing effective support services to close


achievement and opportunity gaps, and ensure all students graduate high school

college- and career-ready.

Goal 3: Early Learning. Improve the health, social-emotional, and cognitive outcomes

for all children from birth through 3rd grade, so that all children, particularly those

with high needs, are on track for graduating from high school college- and career-

ready.

Goal 4: Equity. Increase educational opportunities for underserved students and

reduce discrimination so that all students are well-positioned to succeed.

Goal 5: Continuous Improvement of the U.S. Education System. Enhance the education

system’s ability to continuously improve through better and more widespread use

of data, research and evaluation, evidence, transparency, innovation, and

technology.

Goal 6: U.S. Department of Education Capacity. Improve the organizational capacities

of the Department to implement this strategic plan.

While each of the goals focuses on performance and improvement, there is a specific

emphasis in Goal 5 on the role of data in measuring progress toward goals.

E.1.3. Leading Indicators for the Education for Homeless Children and Youth

Program

With the priority goals in mind, in 2014, the Federal EHCY program developed

leading indicators to evaluate progress toward the goals, as they relate to homeless

education specifically. The leading indicators reflect the need to use data to measure

progress and ensure that only the most effective practices are supported in educating

students. The leading indicators are

the percentage of homeless students who are chronically absent during the school

year, at both the SEA and LEA levels;

the percentage of States monitored by ED in a fiscal year that used LEA data for a

risk assessment that results in monitoring and technical assistance based on LEA

needs; and

the number of States that have updated annual work plans based on data from a

needs assessment and measurable goals.


E.1.4. Uniform Guidance Requirement for Subgrantee Risk Assessment

The U.S. Office of Management and Budget’s Uniform Guidance, which consolidated

existing cost circulars along with new requirements for grant management, took effect on

July 1, 2015. According to the Uniform Guidance, prior to awarding funds, agencies

receiving Federal funds must conduct a risk assessment of subgrantees. This includes LEA

McKinney-Vento subgrantees.

Risk factors to consider include

financial stability;

quality of management systems;

history of performance regarding management of Federal awards, the applicant's

record in managing Federal awards, if it is a prior recipient of Federal awards,

including timeliness of compliance with applicable reporting requirements;

conformance to the terms and conditions of previous Federal awards;

if applicable, the extent to which any previously awarded amounts will be expended

prior to future awards;

audit findings; and

ability to implement statutory requirements. [2 C.F.R. § 200.205(c)]

More information on determining the risk of subawards is covered in Section I of

this handbook.

E.1.5. Performance Management as Part of Federal Monitoring of Education for

Homeless Children and Youth Programs

ED is also incorporating performance management in its EHCY monitoring

protocols, and will require corrective actions for states with poor data quality and offer

recommendations to strengthen more use of data for improving program performance.

E.2. Data Sources

State Coordinators have a wealth of data available to them from both ED and

external sources, not to mention data available through their own agencies.


E.2.1. Data from ED

Section D of the State Coordinators’ Handbook featured the data collected for

EDFacts that resulted in the development of the Consolidate State Performance Report

(CSPR) and customized reports developed from its online tool ED Data Express. While

some data elements may change, the CSPR provides aggregated student data on a wide

range of information on homeless students, including number enrolled, primary nighttime

residence, academic proficiency, adjusted cohort graduation rates, and chronic

absenteeism.

Other Federal programs submit data to ED, including special education, Title I, and

migrant. State Coordinators may wish to work with their data managers to cross reference

homeless students with other programs to gain even more information regarding the

performance of homeless students and to identify areas of need.

Following are examples of questions to explore:

How many LEAs submitted data on homeless students?

How has the number of homeless students enrolled in school changed over the past

few years?

Which LEAs report the highest number of homeless students? Which report the

lowest?

What percentage of homeless students receives special education services? How

does this compare to the State average?

What are the proficiency levels of homeless students? How do the proficiency levels

vary by grade? How do these levels compare to the State average?

E.2.1.1. LEA-level Data Workbooks

The National Center for Homeless Education (NCHE) develops Excel workbooks for

each State that includes the data submitted by LEAs for the CSPR and other indicators of

program performance such as identification in relation to poverty levels and Title I

participation. The workbooks are updated annually to include recent data, as well as other

upgrades based on requests from State Coordinators, current trends in program

development, and new program requirements. While the workbooks include basic

information about homeless students to help with planning activities, they are meant to be


working documents that State Coordinators can use by either manipulating data to address

specific concerns or by incorporating additional data to reflect the unique program goals of

the State. For example, discipline data and information about the reasons students have

individualized educational programs are not submitted to ED for homeless students, and

therefore are not included in the workbooks, but could have correlations to the dropout,

graduation, and academic performance data in the workbooks, and are worth exploration.

Due to the confidential nature of the data contained in the LEA workbooks, State

Coordinators must obtain a username and password from NCHE to access them. As student

data, all information in the workbooks is protected under Federal law. In addition to

protecting information about students that directly identifies them, Federal privacy laws

also consider information to be personally identifiable, and therefore protected, if the

identity of a student could be reasonably inferred by either direct or indirect means. As a

result, even aggregated data for an LEA may be considered protected information due to

the small population of students reported by some LEAs. Prior to releasing any data in the

LEA workbooks, NCHE requires that State Coordinators and any other authorized

personnel confirm the information to be released is covered under State policies related to

the secure handling of student data and under Federal privacy laws as well.

You may contact NCHE staff to obtain the log-in information to access your state’s

LEA-level data workbook, if you do not already have it. NCHE also provides technical

assistance in utilizing the workbooks during the annual State Coordinators meeting, in

webinars, and publications. In addition, NCHE staff will provide customized technical

assistance to individuals in gaining proficiency in using the workbooks effectively.

E.2.2. Data from National Resources and Federal Programs

Reviewing data from other Federal programs is helpful in understanding the bigger

picture of homelessness in the State. Several programs collect data and provide annual

reports, including

Annual Homeless Assessment Reports (AHAR) from the U.S. Department of Housing

and Urban Development, and

Program Service Reports from Head Start through the U.S. Department of Health

and Human Services Office of the Administration for Children and Families.


Demographics on poverty, unemployment, education, and child well-being are

helpful in identifying areas in your State where homelessness and economic challenges are

likely impacting EHCY programs. The following resources can provide this data:

Kids Count (data on child and family well-being in the U.S. that can be broken down

by various indicators and by State and locality)

National Center for Education Statistics (data on student demographics, including

families in poverty, that can be broken down by State and locality)

U.S. Census Bureau (poverty data from household surveys that can be broken down

by State and locality)

U.S. Bureau of Labor Statistics (data on unemployment rates that can be broken

down by various economic indicators and by State and locality)


In which LEAs is there alignment between the level of poverty and the number of

homeless children and youth one would expect to be enrolled in school? Which

districts appear to be under-identifying homeless children and youth?

Does the number of homeless children enrolled in Head Start align with the number

of homeless preschool-aged children the LEA identifies?

What do the economic trends in the State and in certain LEAs indicate about the

increase or decrease in the number of homeless families?

State Coordinators should be cautious in reviewing data on poverty and

homelessness from various sources. Reports are often based on widely differing definitions

of poverty and homelessness.

At best, the data can serve as a general indicator to generate a more thorough

review of the definitions on which the data is based and when and how the data were

collected. For example, a common estimate based on a report from the Urban Institute in

2001 is that approximately 10 per cent of all people living in poverty will experience

homelessness in a year. While this estimate is useful as a ball park estimate–in essence

confirming that people living in poverty are likely to have a higher incidence of

homelessness–you should keep in mind that the report is over 15 years old and was based

on a 1996 national survey of homeless service providers.


Along the same lines, many State Coordinators and local liaisons use the percentage

of students on free and reduced meals as an indicator of the level of poverty in a

community. However, some of the populations of students eligible for free meals do not

necessarily live in poverty. Moreover, the Community Eligibility Provision of the Healthy,

Hunger-Free Kids Act of 2010 allows schools and LEAs with high poverty rates to provide

free breakfast and lunch to all students, which could also provide a skewed view of the

level of poverty in the community.

When an estimate indicates that a LEA may be over-identifying or under-identifying

homeless students, State Coordinators and local liaisons should review other indicators of

poverty and homelessness from the community along with trends and events, such as a

natural disaster or factory opening that could impact housing, employment, and well-being.

E.2.4. Programmatic Data

State Coordinators should be attuned not only to how homeless children and youth

are performing in school, but also to the effectiveness of the State EHCY program and LEA

EHCY programs in complying with the McKinney-Vento Act and providing services to

homeless children and youth. The Federal EHCY program strongly recommends that State

Coordinators develop an annual action plan that is based on a needs assessment that

reflects programmatic data, as well as homeless student performance data.

Useful programmatic data sources include barrier tracking (phone and email) logs,

records of disputes, Federal monitoring reports, LEA monitoring reports, and subgrantee

needs assessments and end-of-year reports.


What areas of non-compliance at the State level were identified by Federal

monitors?

What are the most common topics for McKinney-Vento disputes?

What level of coordination is taking place between LEA EHCY and Title I programs

to determine the amounts of their homeless Title I, Part A set-asides?

What are the most common educational barriers faced by homeless children and

youth?

What are the characteristics of the most effective subgrant programs?


E.2.5. Stakeholder Data

State Coordinators should never underestimate the benefit of stakeholder data.

Local liaisons, pupil transportation directors, school personnel, Federal program

coordinators, community service providers, homeless parents, and unaccompanied youth,

to name a few, will have perspectives on the EHCY program and challenges faced by

homeless children and youth that are not necessarily captured in program data.

Data can be captured informally in individual conversations or in discussions at

trainings, or it can be captured formally in surveys and focus groups. Different groups of

stakeholders can be targeted for input over time to make the task of gathering data more

manageable if the time and resources for conducting an extensive needs assessment do not

exist.


What do local liaisons report as their biggest challenges in implementing the

McKinney-Vento Act?

What do pupil transportation directors report as the main challenges to inter-

district coordination?

What do unaccompanied homeless youth recommend for services that would help

them be successful in school?

What do local shelter directors recommend for increasing coordination between

LEAs and shelters?

E.3. Cautions about Data

With the increasing emphasis on examining and using data for monitoring and

improving your MV program, the data described in the previous section can provide

important information about your program’s status and how it’s changing. But data can

also be misleading if not used carefully. Here are some cautions about working with and

interpreting the data you collect.

Before doing anything with your data, check for anomalies. Look over your data set

for values that look too large or too small, based on what you know about the

program or the location. Data that don’t fit the expected pattern can be a sign of


something unusual happening (either good or bad) that you may want to investigate

further. For example, you may want to question a district that shows a 10 percent or

more change from the number of students reported as homeless the year before.

There could be something noteworthy happening there.

On the other hand, it may just be a data entry error. Having erroneous data will lead

to mistakes when summarizing the data (computing averages, displaying

distributions, etc.) so you need to be sure your data are “clean” before performing

any calculations or analyses. Procedures such as a local statement of assurance

about the collection methods and accuracy of the data can help with data quality. It

is unlikely that the liaison for your LEAs is the person who actually submits data to

your State agency. Procedural safeguards can help to ensure that the data steward

for the district submits accurate data received from the liaison.

Missing data is a particularly sticky issue. If your data set contains a blank, does that

mean “zero,” or were data not available, or were data available but not reported?

Emphasize with your LEAs the importance of not leaving blanks and of explaining

any blanks in their reporting.

Make sure the data you look at match the question you’re trying to answer. The data

collected for the McKinney-Vento program can help you answer many questions

about your program’s status and how it is changing. But your available data may not

be suitable for some questions you might have. For example, suppose you have data

on the number of schools and shelters in each LEA that have received NCHE’s poster

on parents’ rights under the McKinney-Vento Act. If you have a compliance question

about LEA efforts to inform parents of their rights, these data can be useful as a

minimal indicator. But if your question is more about effectiveness of the

dissemination – how knowledgeable are parents of homeless children about their

MV rights – then these data are insufficient. You know how many schools and

shelters received the posters, but you don’t know where the posters were placed (or

even if they were), whether the posters were in an appropriate language for the


parent population, or how many parents actually saw the posters. Be clear about

what your available data are telling you and how much you can reasonably infer

from the data.

As another example, suppose you want to know how your State is doing in

supporting the academic achievement of homeless students. One way might be to

compare the proportion of homeless students passing Statewide assessments in

your State to the proportion reported by other States. This may seem a reasonable

approach, but it has a large potential flaw – students in other States take different

assessments, which may test different things or have a different difficulty level than

your State’s assessment. Other States’ assessment data can’t answer a question

about your State’s assessments. On the other hand, comparing the performance of

homeless students in your State to other students in your State would be much

more meaningful, since it uses the same “yardstick” for the measurement. Perhaps

another subgroup of at-risk students would provide a useful comparison of

achievement.

Don’t assume that differences are meaningful until you look more closely. You may

notice that a piece of data – for example, the average score of a district’s fourth

grade homeless students on the State reading assessment – shows a change from

one year to the next, or is different for two similar districts. Such a change may or

may not be meaningful, especially if the number of students involved is small. If only

20 homeless students take the fourth grade assessment, then one or two students

having a bad day can have a tangible impact on the average for the group. Only by

looking at the distribution of scores can you tell if the average is really reflective of

the group’s performance.

There are other ways that the number of students can affect how you view a change

in your data. The starting size can matter when judging if a change is large or small.

For example, in a district that identified 50 students last year, identifying an

additional 25 students this year (for a total of 75 students) represents a 50 percent


increase. But in a district that identified 1,000 students last year, identifying an

additional 25 students represents only a 2.5 percent increase. The same increase of

25 students (in raw numbers) can be a large or a small change in proportional

(percentage) terms.

Another potential pitfall in comparing data from one year to the next is trying to

read too much into a change if you only have two data points. A change from one

year to the next might simply be the result of variation that normally occurs;

establishing whether the change represents a trend requires looking at the pattern

over a longer period of time. The more data points you have, the more confident you

can be that a trend is real.

Data only describe “what.” Be careful you don’t jump to conclusions about “why.”

Data provide a snapshot of some quantity at a particular time, for example the

suspension rate of homeless students during the academic year. It can be tempting

to come to a snap judgement about what the data mean, based on your own biases

and assumptions. Use caution as you start to interpret such information, because it

could be the result of several underlying factors. For example, suspension may be a

disciplinary consequence of a behavioral incident, but it could also result from poor

attendance related to issues of transportation. More digging may be needed to go

beyond the single summarized “suspension rate” to get more details on the various

reasons for the suspensions. Only then can you determine if the data are related to

something in the MV program that needs to be addressed.

Just because two things happen together doesn’t mean one caused the other. Most of

the time, your available data won’t support a conclusion that changing one thing

caused something else to change. Suppose, for example, a school district begins

providing school supplies to homeless students through their McKinney-Vento

subgrant and you notice an increase in their academic achievement scores the

following spring. It would be tempting to claim that providing the school supplies

was a significant factor in producing the increase. Such a claim might “make sense”


on its face, but there is insufficient information to justify such a conclusion. Schools

are complex systems and rarely can a change be traced to just one cause. Other

things going on in the schools unrelated to the school supplies may be the real

source of the improvement, such as professional development that strengthened

curriculum implementation or improved recruitment and participation in a tutoring

program. This is not to say that providing the supplies was unimportant; just that

you should be careful about claiming a causal link to the improved scores. Celebrate

the improved access to supplies and the improved performance and leave it at that.

To go deeper into your data requires more formal statistical techniques. You can get a

lot of information about your State’s McKinney-Vento program from looking at your

data and displaying it graphically. To really investigate if meaningful changes are taking

place, though, requires a more systematic approach. A deeper analysis can give you

much better insight into your McKinney-Vento program. Statistical techniques can

reveal whether two data elements are strongly related to each other (correlation),

whether differences are likely to be real or just due to normal variation (analysis of

variance), whether changes are large enough to be considered significant (effect size), or

whether some combination of factors may be useful in explaining an outcome

(regression analysis). If you are interested in these kinds of questions, you don’t have to

be a statistics expert yourself. Get assistance in from your SEA or at a university. If you

can articulate the questions you want to investigate, they’ll help you with the

mechanics.

E.4. Data Analysis – Focusing on Improvement

The starting point of data analysis is asking the right questions and determining

what evidence is needed to substantiate the answers. Ultimately, the purpose of the EHCY

program is to ensure that all homeless children and youth are able to succeed in school.

Their success is dependent upon the degree to which SEAs and LEAs identify them, provide

the support they need, and remove educational barriers. The “right” questions should be


those that enable SEAs and LEAs to determine how well they are doing in fostering the

success of homeless students:

Where are we now?

Where do we need to go?

Responses to these questions should be firmly grounded in data. Needs assessment

experts Witkin and Altschuld reinforce the importance of continually examining the gap

between “what is” and “what should be.” The best way to define the gap is to state the

current status of each area of focus based on data to support the statement and to establish

a concrete and measurable goal that defines the impact of the program. Note how this

analysis plays out in Table E-1. Data-based Need Analysis.

Table E-1. Data-based Need Analysis

What Is What Should Be Data to Review

In the 2016-2017 school year, 30% of the LEAs that were monitored had findings related to outreach and identification, indicating that they were under-identifying homeless children and youth.

By school year 2018-2019, 0 LEAs that are monitored should have findings related to outreach and identification; 100% of LEAs with prior findings should document increased strategies for outreach and identification.

Monitoring reports, after action reports from LEAs with findings, CSPR data on LEA enrollment of homeless children and youth

In the 2016-2017 school year, the State Coordinator received 15 complaints from unaccompanied youth and from LEAs regarding barriers to enrolling unaccompanied homeless youth.

By school year 2018-2019, the State Coordinator should receive less than 5 complaints regarding barriers to enrolling unaccompanied homeless youth.

Barrier tracking logs, records of disputes, focus group of unaccompanied homeless youth.

E.5. Using Data

The various types of data related to homeless children and youth can be used in

many ways to enhance program effectiveness, collaboration, and awareness of the needs of

homeless children and youth.

E.5.1. Using Data for Program Planning


In developing annual action plans, State Coordinators should use data to establish

measurable goals that address areas of needed improvement and determine a means of

collecting data to show the extent to which the goals have been achieved. Measuring and

reporting on program progress provides you with a level of accountability that can be used

to identify the strengths and weaknesses of the EHCY program and will help you in

strategically targeting your time and resources. Program data is also helpful when making

the case for greater resources to support your work.

E.5.2. Using Data for Determining Technical Assistance Needs and Compliance Risk of

LEAs

A review of LEA-level data, programmatic data, and stakeholder data will help

determine how to plan technical assistance in terms of both what topics to cover in training

and which LEAs need customized technical assistance. Using data to identify technical

assistance needs is an efficient way to make best use of time and resources. (See Section F:

Technical Assistance for LEAs.)

Also, ED recommends a data-based risk assessment approach to determining which

LEAs should be prioritized for monitoring, looking at information like numbers of homeless

students enrolled in relation to the level of poverty in the school district and turnover of

local liaisons. LEAs with the highest risk for non-compliance should be prioritized for

monitoring. (See Section H: LEA Monitoring.)

E.5.3. Using Data for Collaboration

Data is frequently an important bargaining chip to secure a place in a collaborative

partnership. Just as data from other programs can create a more robust picture of the

needs of homeless children, youth, and families, data on the educational needs of homeless

children and youth can add further dimension to a community’s efforts to address

homelessness. Sharing EHCY program data not only increases the understanding of

community agencies but is often perceived as a good faith effort to build trust in a

partnership.

You should become familiar with privacy laws that specify what data can and cannot

be shared. Review ED’s “Interagency Data Disclosure: A Tip Sheet on Interagency


Collaboration” that discusses (1) disclosure of aggregate data; (2) disclosure of individual

student data with consent; and (3) disclosure of individual student data without consent

under applicable exceptions outlined in the law. The brief also provides examples of EHCY

programs and community agencies that have developed data-sharing agreements and

strategies.

E.5.4. Using Data for Creating Public Awareness

State Coordinators are often called upon by legislators, policy makers, and

advocates to create a concrete picture of the challenges faced by homeless children and

youth and the educational services they receive. You must be ready to provide data in

clearly depicted and succinct ways. The McKinney-Vento Act requires that you post the

number of homeless children and youth enrolled in the State annually on the State website

[42 U.S.C. § 11432(g)(6)(B)]. You may also wish to direct requesters to your State profile

page on the NCHE website.

Some State Coordinators develop an annual brief that includes data on the State

EHCY program shown in graphically impactful ways to share upon request. Another

approach is to develop a template of a brief or slide presentation that can be updated from

year to year. See Appendix E-1. Template for Debunking Myths for an example of a

template that can be updated with data each year to utilize as a brief to create greater

awareness of homelessness and homeless children and youth in your State.

Resources

2 C.F.R. § 200.205(c) – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. Retrieved August 2016 https://www.gpo.gov/fdsys/search/pagedetails.action?collectionCode=CFR&searchPath=Title+2%2FSubtitle+A%2FChapter+II%2FSubchap%2FPart+200%2FSubpart+C&granuleId=CFR-2014-title2-vol1-sec200-205&packageId=CFR-2014-title2-vol1&oldPath=Title+2%2FSubtitle+A%2FChapter+II%2FSubchap%2FPart+200%2FSubpart+C%2FSection+200.205&fromPageDetails=true&collapse=false&ycord=951

Government Performance and Results Modernization Act of 2010. [H.R. 2142]. Retrieved August 2016 https://www.gpo.gov/fdsys/pkg/BILLS-111hr2142enr/pdf/BILLS-111hr2142enr.pdf


https://www.gpo.gov/fdsys/pkg/BILLS-111hr2142enr/pdf/BILLS-111hr2142enr.pdf

https://www.gpo.gov/fdsys/pkg/BILLS-111hr2142enr/pdf/BILLS-111hr2142enr.pdf

https://www.gpo.gov/fdsys/search/pagedetails.action?collectionCode=CFR&searchPath=Title+2%2FSubtitle+A%2FChapter+II%2FSubchap%2FPart+200%2FSubpart+C&granuleId=CFR-2014-title2-vol1-sec200-205&packageId=CFR-2014-title2-vol1&oldPath=Title+2%2FSubtitle+A%2FChapter+II%2FSubchap%2FPart+200%2FSubpart+C%2FSection+200.205&fromPageDetails=true&collapse=false&ycord=951



NCHE’s State Educational Agency Informal Needs Assessment. Retrieved https://nche.ed.gov/sc/sc.php

NCHE’s Guide to Collecting & Reporting Federal Data (updated annually) at http://center.serve.org/nche/ibt/sc_data.php

NCHE’s Homeless Liaison Toolkit, Chapter 13: Data Collection and Requirements at http://center.serve.org/nche/pr/liaison_toolkit.php

NCHE’s State Profiles Web Page at http://center.serve.org/nche/states/state_resources.php


Uniform Guidance Risk and Subaward Management. Retrieved August 2016 http://www2.ed.gov/policy/fund/guid/uniform-guidance/risk-subaward-management.html

U.S. Department of Agriculture, Food and Nutrition Service, Community Eligibility Provision Web Page at http://www.fns.usda.gov/school-meals/community- eligibility-provision

U.S. Department of Education Consolidated State Performance Reports at http://www2.ed.gov/admins/lead/account/consolidated/index.html

U.S. Department of Education. (2016). Education for Homeless Children and Youth Program Non-Regulatory Guidance. Retrieved July 2016 http://www2.ed.gov/policy/elsec/leg/essa/160240ehcyguidance072716.pdf

U.S. Department of Education ED Data Express Website http://eddataexpress.ed.gov/ U.S. Department of Education EDFacts Web Page at

www2.ed.gov/about/inits/ed/edfacts/index.htmlU.S. Department of Education. (2014). Proposed Education for Homeless Children and

Youth Leading Indicators. Retrieved August 2016 http://center.serve.org/nche/downloads/webinar/sc-jun-2014/draft-leading-indicators.pdf

U.S. Department of Education. (2015). Interagency Data Disclosure: A Tip Sheet on Interagency Collaboration. Retrieved August 2016 https://www2.ed.gov/programs/homeless/ehcy-interagency-data-disclosure.pdf

U.S. Department of Education. (no date). Strategic Plan for Fiscal Years 2014-2018. Retrieved August 2016 https://www2.ed.gov/about/reports/strat/plan2014-18/strategic-plan.pdf

Witkin, B.R. & Altschuld, J.W. (1995). Planning and Conducting Needs Assessments: A Practical Guide. Thousand Oaks, CA: SAGE Publications.

National Data Sources


https://www2.ed.gov/about/reports/strat/plan2014-18/strategic-plan.pdf

https://www2.ed.gov/programs/homeless/ehcy-interagency-data-disclosure.pdf

http://center.serve.org/nche/downloads/webinar/sc-jun-2014/draft-leading-indicators.pdf

http://center.serve.org/nche/downloads/webinar/sc-jun-2014/draft-leading-indicators.pdf

http://www2.ed.gov/about/inits/ed/edfacts/index.html

http://eddataexpress.ed.gov/


http://www2.ed.gov/admins/lead/account/consolidated/index.html

http://www.fns.usda.gov/school-meals/community-eligibility-provision

http://www.fns.usda.gov/school-meals/community-eligibility-provision

http://www2.ed.gov/policy/fund/guid/uniform-guidance/risk-subaward-management.html



http://center.serve.org/nche/states/state_resources.php

http://center.serve.org/nche/pr/liaison_toolkit.php

http://center.serve.org/nche/ibt/sc_data.php


Kids Count Data Center at http://datacenter.kidscount.org National Center for Education Statistics, Institute for Education Sciences at

https://nces.ed.gov/programs/coe/indicator_cce.asp U.S. Census Bureau at http://www.census.gov/topics/income-poverty/poverty.html U.S. Department of Health and Human Services Office of the Administration for Children

and Families Web Page for Head Start Program Service Reports at http://eclkc.ohs.acf.hhs.gov/hslc/data/psr

U.S. Department of Housing and Urban Development Web Page for Annual Homeless Assessment Report at https://www.hudexchange.info/hdx/guides/ahar

U.S. Department of Labor, Bureau of Labor Statistics at http://www.bls.gov


http://www.bls.gov/

https://www.hudexchange.info/hdx/guides/ahar

http://eclkc.ohs.acf.hhs.gov/hslc/data/psr

http://www.census.gov/topics/income-poverty/poverty.html

https://nces.ed.gov/programs/coe/indicator_cce.asp

http://datacenter.kidscount.org/

Section F. Technical Assistance for Local Educational Agencies

One of the key responsibilities of State Coordinators is to make sure that local

liaisons in every local educational agency (LEA) receive the training and technical

assistance they need to carry out their duties. The 2016 Non-regulatory Guidance states

Through strong leadership, and collaboration and communication with local liaisons, the State Coordinator should help ensure that districts carry out the requirements of the McKinney-Vento Act. State Coordinators should establish clear-cut policies and procedures at the State level and communicate this information to districts in order to facilitate the smooth and consistent implementation of the McKinney-Vento Act. [U.S. Department of Education (ED), 2016, p. 11]11

The guidance lists a wide range of possible technical assistance activities, including

conferences, guidance, a State website that addresses McKinney-Vento issues, a directory

of State resources, listservs, a toll-free helpline, and newsletters or bulletins (ED, 2016, p.

12).

The McKinney-Vento Act requires that every LEA designate a local homeless

education liaison. The law states:

The local educational agencies will designate an appropriate staff person, able to carry out the duties described in paragraph (6)(A), who may also be a coordinator for other Federal programs, as a local educational agency liaison for homeless children and youths. [42 U.S.C. § 11432(g)(1)(J)(ii)]

State Coordinators should have an up-to-date list of local liaisons and have

strategies in place to determine whether liaisons have the knowledge and skills needed to

perform the role adequately. This section of the State Coordinators’ Handbook will assist

State Coordinators in ensuring that LEAs receive the support they need to carry out their

responsibilities under the McKinney-Vento Act.

F.1. Ensuring Local Liaisons in Every LEA


F-1 State Coordinators’ Handbook: Section F. Technical Assistance for Local Educational Agencies

The requirement of a local liaison in every LEA, first written into the 2001

reauthorization of the McKinney-Vento Act, has been cited by State Coordinators and other

administrators, educators, and service providers as the most transformational part of the

law. The liaison provides a single point of contact and a vehicle for communicating changes

in policy and practices and for identifying challenges faced at the local level. Because this

network of support and communication is such a critical component,

some initial and enduring questions that State Coordinators must address include

Who are the local homeless liaisons?

How are changes in local staff reported?

Where is their contact information maintained?

What documentation do I have regarding their knowledge, skills, and training?

Keeping an accurate list of local liaisons will assist you in establishing and

maintaining an infrastructure for routine and effective communication and in determining

whether all liaisons have the knowledge and skills needed to perform the role adequately.

Maintaining effective communication is critical to all aspects of your Education for

Homeless Children and Youth (EHCY) program and should be given high priority as you

build your EHCY network. Some States have data management systems in place that

support the maintenance and quick update of local liaison contact information. If yours

does not, it is well worth your time to develop your own spreadsheet to keep your list as

accurate as possible. Here are a few suggestions to ensure that all LEAs have an appointed

liaison:

Require the LEA administrator who oversees the local liaison position to inform you

immediately of any changes in the role.

At the beginning of the school year, send a letter to local liaisons, Federal programs

administrators, and superintendents in every LEA reminding them of the

requirement to have a local liaison, and request that they inform you immediately of

any changes in the position. One way to make this less cumbersome is to use an

online survey, such as SurveyMonkey. Liaisons need only click on a link in an email,

check their contact information, and submit it. Then, the State Coordinator only

needs to follow up with the non-responders.


Send a back-to-school packet of materials (e.g., posters, family brochures, training

announcements, or some new resource) as a “gift” to the liaison annually with a

request for updated contact information in the cover letter. Remind liaisons that

their contact information must be posted on the State educational agency’s website

and updated annually [42 U.S.C. § 11432(g)(6)(B)].

If your liaisons are referenced by other programs in their applications, check for

consistency. For example, the local liaison may be identified in the Title I, Part A

application to describe the coordination between McKinney-Vento and Title I.

Follow up with any LEAs that indicate different names from the ones in your

records to verify that you have accurate information about who is actually managing

liaison responsibilities.

Note any changes that come to your attention as you communicate with the field,

and update your files as soon as possible.

LEA monitoring can be a means to ensure that a liaison is appointed. Schedule

phone monitoring with LEAs who have not communicated needed information.

Only a small percentage of LEAs have full-time staff dedicated to homeless education. The

smaller the school district, the more likely it is that the liaison responsibilities will be added to a

long list of duties held by one person at the district level. A variety of other roles are often

combined with the liaison responsibilities. School social workers, or the supervisor for these

personnel, can be a natural fit given the skill of social workers in networking to provide

community supports. A Federal program administrator, such as a Title I coordinator, can also be

a logical connection to provide the coordination across school-based programs. In addition, staff

members who work with truancy, collaborate with local community service boards, or facilitate

early childhood programs have been effective local liaisons. For more information on the

qualities and capacities of the local liaison, review the brief: “Local Homeless Liaisons for School

Districts: Making the Right Selection and Supporting Their Effectiveness” developed by the

National Center for Homeless Education (NCHE).

It is appropriate to include a question about the appropriateness of the local liaison

designation and the capacity of this person to carry out duties in your LEA monitoring.


Sometimes when LEA administrators review the requirements in monitoring questions,

they are more likely to comply with the law in order to avoid findings.

Even if LEAs have full-time liaisons, having only one staff person trained to comply

with the McKinney-Vento Act can leave gaps in services when liaisons are sick, on vacation,

or out of the office fulfilling other roles. Consider opening liaison training to additional

staff. This can build local capacity and bring more personnel with an interest in

homelessness to your attention. As the liaison role is better understood, as local structures

and staff members change, or as the needs of children in the community change, having

more people familiar with the position and the EHCY program increases the likelihood that

an appropriate person will assume the position and that the program will continue

without disruption.

F.2 Orienting Local Liaisons

How we orient new liaisons (or re-orient existing liaisons) can set the tone for

effective State-local collaboration. Once you know who have been designated as liaisons,

some logical next questions will be, “How do I know that the liaisons understand their

responsibilities? How do I ensure that they can fulfill their legal responsibilities?” Just as

there is a lot of information to wade through as a new State Coordinator, liaisons are

confronted with an expanse of resources that could be overwhelming without a guiding

hand. Consider these actions:

Create a generic “welcome” packet for new liaisons. Consider including these

resources.

o Contact information for the State Coordinator, including state educational

agency (SEA) website.

o A checklist of liaison responsibilities. These responsibilities are mentioned

specifically in the law, which you can find in Appendix F-1. Duties of Local

Liaisons. They are also described in Chapter 2 of NCHE’s Homeless Liaison

Toolkit and in NCHE’s brief: “Information for New Liaisons.”

o A schedule of upcoming trainings such as State conferences, national

conferences, and webinars.


o Suggested online training resources. NCHE offers a variety of self-paced,

online, and recorded trainings. Recommend NCHE’s webinars, which are

offered on a monthly basis for liaisons, and are especially helpful for new

liaisons who are unfamiliar with the McKinney-Vento Act.

o A copy of the McKinney-Vento Act.

o A copy of any State code/policy, laws, or regulations related to homeless

education.

o A contact list of liaisons throughout the State or link to the liaison list on the

SEA website.

o A template to compile important contacts in the State and locality that the

liaison should have for easy reference. (See Appendix F-2. Important

Contacts for Local Liaisons for a template that can be adapted for your State.)

o A copy of your State’s current McKinney-Vento LEA monitoring protocol.

Design a McKinney-Vento “scavenger hunt” for new liaisons, encouraging them to

contact you when items cannot be found. Consider including these items.

o The local homeless education policy, if the LEA has one.

o The part of the local Title I, Part A plan that includes a description of

coordination with the McKinney-Vento program, including reservation of

funds for homeless students.

o LEA processes and protocols for identifying students as homeless,

immediately enrolling students, ensuring free meals at school, and obtaining

school of origin transportation.

o The LEA’s McKinney-Vento subgrant application (if applicable).

o NCHE’s Homeless Liaison Toolkit or any State-developed resources you

provide to your liaisons.

o NCHE’s posters, Parent Packs, or parent booklets, or the link to NCHE’s web

page for ordering materials.

o A “MV Top 5s” list for local liaisons (See Appendix F-3. MV Top 5s for a

template adapted from a form originally created by a former State

Coordinator from Colorado.)


F.3. Creating a Network of Support for Local Liaisons

State Coordinators can create a variety of supports available for local liaisons. Here

are a few to consider.

Support regional liaison collaboration. Issues such as inter-district transportation or

unaccompanied homeless youth can be the impetus for a regional meeting that can

evolve into a regular opportunity to meet, share challenges, and brainstorm

solutions.

Identify veteran liaisons who can field questions or provide training when the State

Coordinator is not available.

Appoint a mentor to new liaisons.

Connect liaisons with any outsourced technical assistance to another agency,

intermediate education units, or universities that work with the State Coordinator.

Establish a listserv or email distribution list for liaisons.

Encourage liaisons to contact you with questions and concerns.

Provide liaisons with information on the NCHE Helpline for phone and email

technical assistance and other NCHE resources.

Encourage liaisons to join the NCHE listserv to keep up to date on emerging issues,

learning opportunities, legislative changes, and resources.

F.4. Conducting Professional Development

The McKinney-Vento Act requires State Coordinators to provide professional

development opportunities for LEA personnel and the LEA liaison to assist them in

identifying and meeting the needs of homeless children and youths, and to provide training

on the definitions of terms related to homelessness. [42 U.S.C. § 11432(f)(6)]. In addition,

the law requires States to adopt policies and practices to ensure participation by liaisons in

professional development and other technical assistance activities. [42 U.S.C. § 11432(g)(1)

(J)(iv)].

Federal monitoring indicators for the EHCY program generally address these

requirements by requiring documentation/evidence of activities, such as


providing ongoing technical assistance to LEAs to ensure appropriate

implementation of the statute,

maintaining records of liaison participation in professional development activities,

monitoring changes in staffing of local liaisons,

assisting new liaisons in learning their new responsibilities, and

providing training and technical assistance to LEAs to ensure that community

agencies are aware of the rights of homeless students.

F.4.1. Identification of Technical Assistance Needs of LEAs and Liaisons

The 2016 Non-regulatory Guidance provides a number of examples of technical

assistance or professional development that LEAs may need and that State Coordinators

should keep in mind when planning and reviewing the assistance they have in place,

including

understanding the requirements of the McKinney-Vento Act;

establishing procedures to address problems related to school enrollment and

selection;

establishing procedures to ensure homeless children and youth receive full and

partial credit for work completed;

arranging transportation, including across district and state lines;

resolving disputes in an efficient and effective manner;

determining LEA needs and developing a plan for services;

creating school district and community awareness of the needs of eligible students;

identifying federal, state, and local resources;

identifying homeless children and youths;

monitoring attendance, chronic absenteeism, dropout rates, suspensions, and

expulsions among homeless children and youths;

collecting and reporting data;

enhancing parental involvement activities; and

identifying strategies for improving academic achievement (ED, 2016, p. 12].


Ensuring LEA compliance with the statutory requirements of McKinney-Vento

requires an assessment of LEA capacity and a plan for addressing areas of concern. A useful

first step in planning and delivering technical assistance to LEAs is to analyze any available

needs assessment efforts already initiated. As more importance is placed on data-based

decision making, it becomes more imperative that a focus on the collection of needs

assessment and program evaluation data is given high priority.

NCHE’s “Local Educational Agency Informal Needs Assessment” supports needs

assessment and program evaluation in building EHCY programs. State Coordinators find

this guide to be useful, not only for collecting State level data, but also in assisting LEAs to

collect data needed to inform program decisions at the local level. ED suggests that States

require all LEAs to conduct some type of formal or informal needs assessment activities

annually and require subgrantee LEAs to conduct more comprehensive and formal needs

assessments at least once every three years.12 Important decisions about programming

and resources (e.g., the determination and use of Title I, Part A funds for homeless students

or the determination of the needs of special populations of homeless children and youth)

should also be based on systematic collection and review of accurate data.

Additional strategies to determine LEA needs for technical assistance include a

review of any available monitoring reports, end-of-year subgrant reports, data from the

Consolidated State Performance Report (CSPR), and technical assistance logs maintained

by the State Coordinator. (See Appendix F-4. Sample Technical Assistance Log that you may

customize for your State.)

Every year, NCHE provides each State Coordinator with an electronic LEA-level

Excel data workbook that includes information submitted to EDFacts for the CSPR for the

previous year. The workbook provides valuable information that will enable you to identify

LEAs at risk of noncompliance and in need of technical assistance based on data, such as

the number of students identified as homeless as compared to the level of poverty in the

LEA. If you do not have access to the most current data workbook, contact NCHE to obtain

12 State Coordinators will need to know the way their States operate. In States with local control, Coordinators may be limited in how directive they are with non-legislated suggestions. The same challenges may exist at the State level. State Coordinators must be able to recognize mandates in code and those suggestions that exceed the law. Progress may be made as State Coordinators are able to justify how implementing suggestions beyond the mandates improve the lives of students and benefit the State.


the individual link to your State’s workbook for download. Here are some questions to

consider as you analyze the technical assistance needs of liaisons:

Is the LEA identifying appropriate numbers of homeless children and youth? Do the

numbers appear to be aligned with poverty data; number of students eligible for

free/reduced meals; size of Title I, Part A allocation; and number of students

identified as homeless in previous years, in nearby localities and reported by other

agencies?

Are there any identified (or emerging) compliance issues apparent in technical

assistance logs and monitoring reports?

Has there been significant turnover among local liaisons?

Here are some strategies to consider as you develop technical assistance plans for LEAs.

Develop strong relationships with local liaisons built on mutual trust. Liaisons

should feel comfortable in contacting you for advice and technical assistance on

emerging issues in their LEA.

Monitor the amount of liaison time allocated to McKinney-Vento responsibilities.

For example, homeless liaisons assigned to multiple programs might have

diminished capacity relative to the EHCY program and need additional supports to

carry out their responsibilities. Be prepared to communicate with supervisors if

there are capacity concerns related to compliance or program quality issues.

Consider whether the liaison position has the authority needed to effect change and

whether your communication with the supervisor would be helpful.

Develop a packet of information to be shared with superintendents and/or other

program administrators to clarify the responsibilities of the liaison.

Conduct a quick survey of basic information from each LEA demonstrating that

someone is addressing all requirements, and require the signature of the person

held accountable.

Make LEA needs assessment mandatory, and analyze results to determine gaps.

Get to know local issues, look for patterns across regions, and provide technical

assistance to groups with common needs.


Review local Title I, Part A plans, and determine whether updates or revisions are

needed to support homeless children and youth.

Use a State map of LEAs, to analyze identification results. Look at potential

indicators, such as

o number of homeless students identified relative to surrounding districts,

o economic indicators relative to surrounding districts,

o number of homeless students identified relative to the size of Title I

allocations (e.g., the number of districts with large Title I allocations

reporting low numbers),

o economic indicators (e.g., poverty data, foreclosures, etc.), and

o number and location of homeless shelters.

Use mentoring or buddy assignments to pair struggling liaisons with knowledgeable

mentor liaisons.

Provide targeted technical assistance to struggling LEAs through site-visits when

necessary; follow up communications should be routine and systematic until

pressing issues are resolved or significant improvement has been achieved.

F.4.2. Provision of Training for LEAs and Liaisons

When planning LEA training, it is helpful to organize the content according to (1)

what is necessary for compliance, (2) what a quality program that goes beyond compliance

looks like, and (3) what characteristics define a robust, mature, model homeless education

program. The overall plan should include several different models, depending on the target

audience and identified needs. Some suggested models include

training for all liaisons – what everyone needs to know;

training for non-grantee liaisons, especially targeting those with less experience

and/or an emerging understanding of the statutory requirements of the McKinney-

Vento Act;

training modules for other school and agency personnel that is role specific;

issue-focused training for specific issues, problems, or situations;


advanced training for experienced liaisons to grow their leadership among the

liaisons and in the community; and

multi-program training opportunities, such as State or Federal homeless program

conferences, other education conferences, or housing conferences.

When determining topics for training, use the following questions as you make decisions

about content.

How many liaisons have already received basic McKinney-Vento training?

Are there updates from ED, national organizations, the State EHCY program, or

other programs or agencies that need to be provided?

What topics do liaisons identify as needs for training?

Are experienced liaisons willing to share their expertise in a training event?

Would sharing model programs or best and promising practices from national

experts or other State Coordinators be helpful?

With a firm handle on the content of training needed, you are ready to begin

planning for the most effective delivery of training. A wide variety of formats and venues

should be considered as decisions are made regarding delivery methods.

Written briefs, newsletters, memos, emails and other communication can provide

the basic legislative requirements of the McKinney-Vento Act.

Webinars are helpful to address travel restrictions or challenges related to

climate/geography that limit on-site training opportunities.

o NCHE offers frequent webinars.

o NCHE can assist State Coordinators in customizing a webinar for a specific

State.

o Conference calls provide an excellent venue to communicate important but

briefer information to a large number or wide geographic area at one time.

o Work groups on specific topics allow liaisons separated by physical distance

to learn together and think through issues.

Liaison workshops can be held in a variety of ways, such as

o regional meetings with LEAs clustered geographically,


o compliance meetings with LEAs clustered according to issues or identified

needs,

o single LEA teams to allow intensive work with team of people representing

several different role groups within an LEA, and

o trainings linked to other program meetings or trainings.

Conferences can be stand-alone homeless education events or part of other

conferences on related topics. Consider

o a State homeless education conference,

o a pre-conference workshop targeting a specific group (regional cluster, or

needs/issue based),

o a homeless liaison strand at a State Title I conference or other related agency

conferences, and

o the annual conference of the National Association for the Education of

Homeless Children and Youth (NAEHCY); consider planning ahead to

convene a meeting of liaisons from your State who are attending.

Face-to-face opportunities to share successes and challenges in on-site trainings can

personalize the process and allow for two-way communication. The State Coordinator can

gain insights from presentations to liaisons and other local personnel and directly respond

to their questions or areas of confusion. In addition, liaisons and other participants often

establish connections that support them beyond the workshop event. However, keep in

mind that developing LEA expertise does not have to be a one-person show. Many States

have developed ways of sharing the responsibility. Some States have established a regional

infrastructure to strengthen statewide implementation of homeless programs, with

subgrant funds or State-level activity funds allocated to “lead” LEAs who share some of the

training and technical assistance responsibilities with the State Coordinator. Some State

Coordinators have identified experienced local liaisons to assist with training or mentoring

liaisons, following a train-the-trainer model. These same experienced liaisons/mentors are

often asked to make presentations at State and/or regional conferences, workshops,

compliance meetings, etc. State Coordinators should provide materials and support to

these experienced liaisons to ensure that they convey consistent information across the


State. These regional technical assistance activities can lead to productive partnerships in

the development of local expertise that builds strong programs.

Regardless of the delivery method, systematic follow up is the key to determining

the effectiveness of your training efforts and to the maintenance and generalization of new

knowledge and skills. Successful State EHCY programs approach training as an ongoing

process, not an event. The ongoing nature of the process is supported by a systematic

follow up through routine communication with liaisons. These communications can be

casual or formal; held via phone, email, or conference call; and conducted as part of a desk

review in your monitoring process.

Some examples of follow up communications include quick surveys of changes that

have occurred since training, conference calls discussing challenges related to training

topics, discussion of local policies/regulations that remain barriers to the education of

homeless students, and postings to a listserv or social media sharing success stories.

Despite thoughtful planning and preparation, the provision of training and technical

assistance to local liaisons is likely to have its challenges. (See Appendix F-5. Potential

Pitfalls and Possible Solutions for Liaison Trainings for some common problems State

Coordinators encounter in their trainings.)

F.4.3. Effective Professional Development for Adult Learners

The importance of understanding effective professional development for adult

learners cannot be overstated. Dr. Malcolm Knowles is known as the father of Adult

Learning Theory and was one of the first educators to write about how adults differ from

children as learners. It is important to recognize that adults bring knowledge and

experience to the professional development event which may positively or negatively affect

how they learn and participate. Mandatory training and negative prior experiences can

lead some to limit their participation or to try and control the conversation and limit the

participation of others. Since adults bring their own internal motivation and goal

orientation to trainings, they must feel that they need the information being provided.

Adult learners desire relevancy and practicality, and they want information that can be put

into practice immediately. Finally, adult learners need to feel respected as individuals.


Professional development providers should acknowledge and respect the individual needs

and differences of participants (Maclachlan, 2015).

The following eight questions, originally proposed in relation to professional

development for teachers, have been adjusted to refer to homeless liaisons. These

questions will help you determine if your plan will produce effective professional

development.

1. Does it further LEA or school goals and objectives? Look for ways to demonstrate

that the information you are providing is aligned with other State and local

initiatives. Homeless education does not operate in a vacuum. Make connections

between the work of liaisons and student achievement, attendance and truancy,

healthy schools, etc.

2. Is it something that the liaison can use? Liaisons often wear multiple hats; even

when liaisons’ time is dedicated solely to McKinney-Vento, the needs outpace the

time. In other words, be sure there is a usable “take away” from any professional

development activity offered. Ask yourself, “If I were a liaison, what would I do with

this information tomorrow?”

3. Do liaisons have input? Adults need input in designing professional development

choices. These are the people that are in the trenches; they are the ones who know

what is genuinely useful. Do not leave liaisons out of the planning aspect of

professional development.

90/20/8 Rule

Most adults can listen with understanding for 90 minutes; therefore, no

module of your training should exceed 90 minutes.

Most adults can listen with retention for 20 minutes; therefore, presenters

should change the pace every 20 minutes and involve participants with the

content every 8 minutes. For webinars, trainers need to remember that

participants can be easily distracted and less accountable for their attention

to content. (Have you ever checked email during a webinar?) To counter the

temptation to get off task, the literature recommends having an interactive


activity for participants during a webinar every 4 minutes to maintain

engagement (Pluth, 2010).

Have real-life scenarios available for problem solving activities. Collect your

technical assistance requests to create miniature case studies that small groups can

discuss, and build sessions around frequently asked questions. Allow seasoned

liaisons to describe their programs and approaches to resolving challenges. This is

an interactive way to review basic content and legislative requirements and model

decision-making and problem-solving strategies that can be applied to novel

situations liaisons may encounter. (Don’t just give the liaison a fish; teach him or her

how to catch fish.)

4. Do liaisons have choices? There is no one “right” way to learn. Providing liaisons

with a menu of options is more likely to meet the individual needs of liaisons than a

“one-size-fits-all” approach to professional development. Consider using State-level

activity funds to reimburse liaisons who pursue professional development to cover

travel and other expenses. Reimbursement or honorariums could be tied to giving

back through a workshop, conference presentation, webinar, or newsletter article to

be shared with other liaisons.

5. Will there be buy-in? Generating staff buy-in is the only way to have effective

professional development. Liaisons must see a connection between the skills and

knowledge provided in professional development, their responsibilities, and the

effect fulfilling such responsibilities has on students. Incorporate a variety of

messages in your professional development. Some people want to know, “What does

the law say I have to do?” Others want to know, “Why will this make a difference for

the children I serve?” Still others may want to know, “How can I ‘sell’ this message in

my community?” Whether the motivation is heart, head, or bottom line, include

something for everyone. Collect poignant stories, be able to offer assistance for

compliance and continual program improvement, and know facts and figures to

support your suggestions and challenge common misconceptions.


6. Is there time for liaisons to implement the professional development? Provide or

request that liaisons bring local data to training. This will require additional pre-

planning, but will offer a more personalized approach. If liaisons recognize the

professional development as a tool that helps them do their work, it is more likely to

have an impact.

7. Is there follow up and accountability? “One shot” professional development can be

ineffective if there is no follow-up. It is a dead end. Annual reports for subgrantees

and local homeless education program monitoring are logical accountability

measures. It is okay to assign “homework” as long as it is meaningful. Consider a

menu of options, which could include sharing updates with a partner in the training

or sending updates on issues via listserv or newsletter. Ongoing professional

development can be nurtured by follow up conference calls after a workshop,

webinars, videoconferencing, blogs, or other electronic communication.

8. Is there an evaluation? Professional development must include evaluation to

determine how effective it was and how well liaisons are incorporating the training.

State Coordinators should follow each training with an online survey to determine

the effectiveness of the event, how participants plan to use the information, and

what additional information and training the participants need. (See Appendix F-6.

Quick Tips for Presenters for more effective training strategies.)

F.5. Developing a State Homeless Education Website

State homeless education websites are an essential repository of information about

a State’s homeless education program, as well as a portal to link to a myriad of additional

information and resources. The McKinney-Vento Act includes a couple of specific

requirements for information to be posted on the SEA’s website. The law requires that the

SEA post annually

the number of homeless children and youths identified in the State [42 U.S.C.

§ 11432(f)(1)(A)], and

an updated list of the local liaisons [42 U.S.C. § 11432(g)(6)(B)].

State homeless education websites should also include at a minimum

contact information for the State Coordinator for homeless education;


a list of subgrantees and coordinator contact information;

an overview of the McKinney-Vento Act and a link to the law;

homeless education state policies, including the dispute resolution policy;

announcements of trainings and events; and

a link to the NCHE webpage and/or links to specific NCHE webpages such as

webinars, briefs, Helpline, the State’s profile page, and products to order online.

In addition, many States include

guidance and policy memos and updates;

clarifying documents and briefs from NCHE and NCHE’s Homeless Liaison Toolkit;

link to the NAEHCY website;

State publications and resources related to homeless education;

forms that LEAs may use, such as those for enrollment and notification of rights;

good practices that feature specific LEAs;

links to posters and awareness materials, either those produced by the State or by

NCHE; and

the State’s “211” phone resource and information helpline.

State Coordinators should work with their SEA’s web designer to ensure that

proposed information aligns with the SEA’s policies and content requirements and reflects

good design principles. Moreover, State Coordinators must take into account the level of

effort they will be able to provide to keep the website current and the frequency with

which they will be able to update the site. Even a simple website can be very effective as

long as it is targeted to specific needs, easy to navigate, and up to date.

The State Coordinator should consider who the target audiences are for the

homeless education website. A website that is a tool specifically for local liaisons would be

significantly different from a website geared for a wider audience, such as homeless service

providers and parents.

Periodically conducting an external review of the homeless education website will

provide valuable feedback on its effectiveness and utility. In annual reviews of its website,

NCHE has utilized the following statements rated on a Likert scale in an online survey of a

sample of its constituents:


The organization of the website is very logical.

Navigability of the website is very efficient.

The content provided on the website if of high quality.

The information posted to the website addresses current issues in the field.

The website is comprehensive enough to meet my needs.

State Coordinators may view State homeless education websites from across the

country on the NCHE’s State profiles webpage. Clicking on any State on the map posted at

this site will lead to a page that includes a link to each State’s homeless education website.

F.6. Developing State Forms

Developing State forms for LEAs to use creates consistency across the LEAs and sets

expectations for record keeping and documentation. Some of the more commonly used

State forms include enrollment or student residency forms, written notification of

enrollment decision for parents, and forms for documenting issues as they arise as barriers

to identification and enrollment (barrier tracking forms). See Appendix F-7. Barrier

Tracking Form for Phone and Email Contacts for a sample form that LEAs (and State

Coordinators) may use to document their conversations with those discussing challenges

they are facing.

NCHE’s Homeless Liaison Toolkit and Resources by Topic webpages include sample

forms that can be adapted for use by all LEAs.

Resources

National Center for Homeless Education. Local Educational Agency Informal Needs

Assessment. Retrieved https://nche.ed.gov/ll/ll.php

National Center for Homeless Education. Helpline for Phone and Email Technical

Assistance. 800-308-2145 or [email protected]

National Center for Homeless Education. Homeless Education Issue Briefs. Retrieved from

https://nche.ed.gov/pr/briefs.php

National Center for Homeless Education. Homeless Education Listserv. Retrieved from

https://nche.ed.gov/listserv.php





https://nche.ed.gov/ll/ll.php

National Center for Homeless Education. (2013). Homeless liaison toolkit. Retrieved from

https://nche.ed.gov/pr/liaison_toolkit.php

National Center for Homeless Education. (2015). Local homeless education liaisons for

school districts: Making the right selection and supporting their effectiveness.

Retrieved from

https://nche.ed.gov/downloads/briefs/liaison-selection.pdf

National Center for Homeless Education. (2015). Local homeless education liaisons:

Information for new liaisons . Retrieved from

https://nche.ed.gov/downloads/briefs/new-liaisons.pdf

National Center for Homeless Education. Order NCHE Products and Publications webpage.

Publications Ordering Webpage. Retrieved from

https://nche.ed.gov/online_order.php

National Center for Homeless Education. Resources by Topic webpage. Retrieved from


National Center for Homeless Education. Self-Paced Online Training. Retrieved from

https://nche.ed.gov/web/s_p.php

National Center for Homeless Education. State Resources webpage. Retrieved from


References

Maclachlan, A. (2015). Become familiar with adult learning theory and the six principles of

adult learning. Retrieved from https://www.linkedin.com/pulse/become-familiar-

adult-learning-theory-six-principles-alan-maclachlan

Pike Pluth, B. (2010). Webinars with WOW factor: Tips, tricks, and interactive activities for

virtual training. Eugene, OR: Pluth & Pluth.

The Pike Group. Retrieved from https://www.bobpikegroup.com




https://www.bobpikegroup.com/

https://www.linkedin.com/pulse/become-familiar-adult-learning-theory-six-principles-alan-maclachlan

https://www.linkedin.com/pulse/become-familiar-adult-learning-theory-six-principles-alan-maclachlan


https://nche.ed.gov/web/s_p.php


https://nche.ed.gov/online_order.php

https://nche.ed.gov/downloads/briefs/new-liaisons.pdf

https://nche.ed.gov/downloads/briefs/liaison-selection.pdf


U.S. Department of Education. (2016). Education for Homeless Children and Youths Program





Section G. Dispute Resolution13

G.1 Introduction

The McKinney-Vento Act requires that State educational agencies (SEAs) develop a

dispute resolution policy as part of the State Plan, which must include “[a] description of

procedures for the prompt resolution of disputes regarding the educational placement of

homeless children and youths” [42 U.S.C. § 11432(g)(1)(C].14 The law requires local

homeless liaisons to ensure that disputes are mediated in accordance with the State’s

dispute procedures [42 U.S.C. § 11432(g)(6)(A)(vii)].

Section G of the State Coordinators’ Handbook offers State Coordinators a menu of

options for developing and implementing an effective dispute resolution process based on

the experiences of colleagues over the past decade. Furthermore, taking a broad

perspective on conflict, this section explores additional best practices that State

Coordinators can employ to ensure effective compliance and implementation of the

McKinney-Vento Act. Because many disputes occur over SEA or local educational agency

(LEA) actions that do not align with the law, making sure that SEAs and LEAs operate their

Education for Homeless Children and Youth (EHCY) program in full compliance is a

primary means of avoiding disputes.

While resolving disputes is required, not all disagreements are covered by the

dispute resolution process. Therefore, Section G offers a continuum for resolving conflicts

including proactive strategies to avoid or reduce conflicts, complaints not covered by the

dispute resolution process, and issues that require the use of dispute processes in other

legislation, as well as those clearly covered by formal McKinney-Vento resolution 13The Dispute Resolution section of the State Coordinators’ Handbook was originally co-authored by Patricia Julianelle, former attorney for the National Association for the Education of Homeless Children and Youth, and Patricia Popp, State Coordinator for Virginia’s Project HOPE. 14 All resources and references mentioned are found in the Resources at the end of this section, with their links, if available.

G-1 State Coordinators’ Handbook: Section G. Dispute Resolution

requirements. The section will clearly distinguish the legal requirements, current U. S.

Department of Education (ED) guidance, and best practices supported by the field.

Communication is not a perfect science. Words may have multiple meanings,

and multiple perspectives on an issue can result in multiple interpretations. It is not

surprising that our laws, being composed of words, are subject to the disagreements

and conflict that result from such imperfection. Revisions to legislation, issuance of

guidance and regulation, and case law are some of the ways we attempt to add clarity

to the words of our laws. Conflict is normal in life and law; how we respond is key. This

is no less true when working on behalf of students experiencing homelessness under

the McKinney-Vento Act.

State Coordinators have seen an increase in the number of disputes over the

years and have identified the following possible explanations for in the increase:

greater parental awareness of their children’s educational rights under

the McKinney-Vento Act due to appropriate outreach by schools;

economic factors that have led to

o increasing numbers of children identified as experiencing homelessness,

o increasing durations of homelessness for children, and

o decreasing funding for schools.

State Coordinators have observed increasing needs in a climate of decreasing

resources. For example, as LEAs struggle financially to provide services to homeless

students, schools are more likely to question a family’s eligibility for McKinney-Vento

services or school of origin placement, which usually includes the LEA providing

transportation, when a family has been doubled up for multiple years. Subsequently,

the parent or guardian may initiate a dispute. In addition, increasing accountability for

student achievement creates further potential for conflict. Some schools may be more

reluctant to enroll students they perceive to be academically at-risk, and in some cases

parents may claim homelessness to access schools they perceive as better for their

children. Furthermore, funding and accountability can lead to inter-district

disagreements related to serving homeless students.


The increase in disagreements has led to State Coordinators spending more time

dealing with disputes. This document attempts to capture promising practices that can

be used across the Nation, including tools and templates that State Coordinators may

customize to fit the needs of their State.

G.2 Inform, Explain and Support: Resolving Conflicts before They Rise to the

Level of a Dispute

The old adage that an ounce of prevention is worth a pound of cure certainly has its

value when thinking about the dispute resolution process. While having proactive

policies and activities in place does not eliminate the possibility of disputes, it certainly

can limit disputes and lessen the confrontational/adversarial tone that often

accompanies such disagreements. State Coordinators have found the following

practices especially useful:

A. Adequately train local liaisons. The more knowledgeable about the law and

skilled in working with families and students experiencing homelessness liaisons

are, the more likely appropriate procedures will occur at the school door and the

less likely that errors and/or misunderstandings will arise that become contentious

enough to require formal dispute processes at the local and State levels. Well-

trained liaisons conduct proactive identification of students, including awareness

building within their schools and communities. Liaisons trained to be sensitive to

the stressors and trauma that families experience are less likely to exacerbate those

stressors, reducing the potential for conflict. Liaison training should include how to

carry out an effective dispute resolution process and how to help families

understand their educational rights. The National Center for Homeless Education

(NCHE) provides a variety of materials and webinars developed for liaison training.

While some State Coordinators are able to meet the training demands in their

States, others have limited opportunities to provide direct training and ensure the

field receives the needed information in a number of ways:

1) contracting with a university or educational technical assistance provider,

2) using veteran liaisons to provide peer-to-peer support in their regions,


3) publicizing and supporting attendance at NCHE webinars and the annual

conference of the National Association for the Education of Homeless

Children and Youth, and

4) collaborating to have sessions for liaison training as part of larger training

and conference events hosted by the SEA or other State education groups.

B. Conduct monitoring of LEAs as specified in the McKinney-Vento Act. Ensuring

that all LEAs in the State are accountable and fulfilling their responsibilities to

serve homeless students is one purpose for monitoring. Moreover, monitoring

can increase compliance at the local level and increase knowledge of best

practices, making it less likely that an LEA will violate McKinney-Vento and

more likely that liaisons will be able to adequately explain decisions to parents,

guardians, or unaccompanied youth15. The SEA can also review how the LEA

resolves disputes during monitoring to ensure compliance with that specific

procedure.

C. Track technical assistance requests at the State level. Analyze the questions that

frequently arise and identify issues that require clarification. Problem areas can

be addressed through training or through the creation of sample forms or other

resources, preventing emerging issues from becoming more pervasive and

leading to an increase in disputes.

D. Track complaints that come to the State level. Analyzing issues that arise more

frequently may lead to targeted technical assistance and/or shape monitoring

questions and prioritize certain LEAs for monitoring.

E. Inform advocacy groups. Making sure that advocacy groups have accurate

information about the educational rights of children and youth experiencing

homelessness is critical to avoiding misinformation being shared with parents

and the community. Making sure such groups know what processes can be used

when a difference of opinion occurs, including opportunities for informal

resolution of problems can lessen the need for more formal disputes.

15 In this publication, the term “unaccompanied youth” is used according to its definition in the McKinney-Vento Act: “a homeless child or youth not in the physical custody of a parent or guardian.” 42 U.S.C. § 11434a(6).


F. Ensure LEAs use checklists for determining eligibility for McKinney-Vento

services or best interest for school selection, such as the one found in the NCHE

Local Homeless Education Liaison Toolkit, Appendix 6.A: School Selection

Checklist for Decision Making. State Coordinators may request LEAs to provide

copies of such documents when written notice is given to families or as

required documentation to review during a monitoring visit. McKinney-Vento is

explicit about the need for written notification when there is a disagreement

about school selection. However, without documentation that shows how a

decision was reached (and that a process was used to reach a decision), it is

difficult to know whether the intent of the law is being fulfilled. Using best

interest for school selection worksheets and checklists to determine eligibility

increases the transparency of decision making and provides the paper trail

should a decision be challenged. A formal dispute resolution process is

adversarial in its structure. By ensuring that these early, informal processes

occur, there will be less need to use the formal dispute resolution process. This

is important in building and maintaining trusting relationships between school

staff and homeless families.

G. Assist LEAs in establishing clear expectations. Clear roles, responsibilities, and

procedures remove the ambiguity that increases the likelihood of a conflict. For

example, transportation decisions should be revisited when students do not

attend school regularly or a safety concern arises. A contract between the

school and parents that describes district, parent, and student responsibilities

as well as the consequences when those responsibilities are not met can diffuse

many transportation conflicts. (A sample contract is included in Appendix G-1.

Sample Transportation Contract between a Parent and the LEA).

H. Encourage trauma-informed responses. Families experiencing homelessness

are often facing high stress and trauma. Training staff to recognize the signs of

trauma and use appropriate strategies to diffuse interactions when a parent or

student is upset can mitigate adversarial relationships.

I. Withhold judgment while collecting information from all parties. State

Coordinators receive calls from parents, guardians, unaccompanied youth, and


LEA administrators when a conflict arises. The information provided is often

one-sided. If you offer an opinion based on such information, you may have to

rescind comments once additional information is obtained. This affects

credibility and may actually increase the level of conflict. To help convey a need

to explore all information necessary to make a determination, include

disclaimers in verbal or written communication such as, “Based upon the

information you have shared with me……” or, “Let me look into this a little

further before responding…”

J. Use an intake/technical assistance form to collect the basic information that

will be needed while exploring a case. (Appendix G-3. Information to Include in

an Intake Form When a Call or Email is Received includes a sample intake form

that can be adapted to your needs.)

K. If your State does not have a uniform dispute resolution process for use at the

district level, require dispute resolution policies as a part of the McKinney-

Vento subgrant request for proposals and require a copy during LEA

monitoring.

L. Establish a statewide advisory board that includes service providers and

liaisons. Consider including homeless or formerly homeless parents, when

possible. A responsibility of the advisory board could include offering input on

disputes that require more input due to the multiple factors being considered.

The board may develop a process for making determinations, including what

information to obtain and how that information is organized and weighted.

Such a process could be replicated with future cases. A consistent process

should lead to less confusion when families navigate the system and reduce the

likelihood of conflicts caused by such confusion or miscommunication.

M. Review the State-level dispute resolution process on a regular basis. Consider

conducting a focus group with local liaisons who have worked through a

dispute to explain the questions and challenges that arose and to offer

suggestions for improving the process. Consider sharing the State process with

other State Coordinators.


G.3 Dispute Resolution: Law and Practice Basics

The McKinney-Vento Act provides minimum standards for the resolution of

disputes that arise under the Act. However, the statute leaves most of the specific

procedures to the discretion of each State. Every State must establish procedures for

the prompt resolution of disputes regarding the educational placement of homeless

children and youth. These procedures must be described in the State’s McKinney-

Vento State Plan that is submitted to ED. Dispute procedures also may be formalized in

the State education code; school board policy; or policies, procedures or guidance from

the SEA. Every State’s dispute procedures must uphold all the rights the McKinney-

Vento Act provides to homeless children, youth, parents, and guardians.

The Act mandates basic protections and procedures that must be in place when a

dispute arises “over eligibility, or school selection or enrollment in a school” [42 U.S.C.

§ 11432(g)(3)(E)]. Therefore, the protections and procedures must be available to

address any dispute about whether a student has the right to enroll in a particular

school, whether based on eligibility, best interest, school selection, or immediate

enrollment. The law also defines “enrollment” as “attending classes and participating

fully in school activities” [42 U.S.C. § 11434a(1)]. Therefore, McKinney-Vento dispute

procedures apply to any dispute arising under the Act, including disputes over issues

such as the following:

Eligibility: When a parent seeks to enroll a child, or an unaccompanied youth

seeks enrollment in a particular school under the McKinney-Vento Act, does the

child or youth meet the definition of “homeless” such that immediate

enrollment in school is required, regardless of missing school records, proof of

residency, immunization and other health records, lack of a parent or guardian,

or other documentation?

School selection: Is it in the child’s or youth’s best interest to continue attending

the school of origin or to enroll in the local attendance area school?

Participation: Is the child or youth attending classes immediately, even if the

school has not yet received school records, special education records,

immunization or other health documents? Is the child being provided full

participation in school activities? Has enrollment been immediate in any public


school that nonhomeless students who live in the attendance area in which the

child or youth is actually living are eligible to attend?

Transportation: Is the school district required to provide transportation to a

student in a particular situation? Does the transportation provided permit the

child to attend classes and participate fully in school activities?

When a dispute arises under the McKinney-Vento Act, the law requires the LEA

to follow a set of minimum procedures. Following are excerpts from the law describing

these procedures:

The child or youth “shall be immediately enrolled in the school in which

enrollment is sought, pending final resolution of the dispute, including all

available appeals.” [42 U.S.C. § 11432(g)(3)(E)(i)]

“In the case of an unaccompanied youth, the liaison shall ensure that the youth

is immediately enrolled in the school in which the youth seeks enrollment

pending resolution of the dispute.” [42 U.S.C. § 11432(g)(3)(E)(iv)]

Since enrollment includes “attending classes and participating fully in school

activities” [42 U.S.C. § 11434a(1)], while disputes are pending, students must be

able to participate fully in school and receive all services to which they are

entitled. This includes transportation services that are specified in the law.

“The parent or guardian of the child or youth or (in the case of an

unaccompanied youth) the youth shall be provided with a written explanation

of any decisions related to school selection or enrollment made by the school,

the local educational agency, or the State educational agency involved, including

the rights of the parent, guardian, or unaccompanied youth to appeal such

decisions.” [42 U.S.C. § 11432(g)(3)(E)(ii)].

o In addition, “if … the local educational agency determines that it is not in the

child’s or youth’s best interest to attend the school of origin or the school

requested by the parent or guardian, or (in the case of an unaccompanied

youth) the youth,” the LEA must “provide the child’s or youth’s parent or

guardian or the unaccompanied youth with a written explanation of the

reasons for its determination, in a manner and form understandable to such


parent, guardian, or unaccompanied youth, including information regarding

the right to appeal under subparagraph (E).”

[42 U.S.C. § 11432(g)(3)(B)(iii)]

o “In the case of an unaccompanied youth, the LEA must ensure that the local

liaison … “assists in placement or enrollment decisions under this

subparagraph, gives priority to the views of such unaccompanied youth, and

provides notice to such youth of the right to appeal under subparagraph

(E).” [42 U.S.C. § 11432(g)(3)(B)(iv)]

“If a dispute arises over eligibility, or school selection or enrollment in a

school…the parent, guardian, or unaccompanied youth shall be referred to the

local educational agency liaison … who shall carry out the dispute resolution

process … as expeditiously as possible after receiving notice of such dispute.”

[42 U.S.C. § 11432(g)(3)(E)(iii)]

Simply put, when a McKinney-Vento dispute occurs

1. the child or youth must be admitted to the school in which enrollment is sought

pending final resolution of the dispute;

2. the parent, guardian, or unaccompanied youth must be provided written notice

of the school’s, LEA’s, or SEA’s decision, which must include the reasons for its

decision and the right to appeal; and

3. the parent, guardian, or unaccompanied youth must be referred to the local

liaison to carry out the dispute process.

These procedures are fairly minimal when compared to dispute processes

outlined in other education laws, such as the Individuals with Disabilities Education

Act (IDEA) and the Family Education Rights and Privacy Act (FERPA). Congress has

allowed LEAs and SEAs considerable leeway in their McKinney-Vento procedures.

However, of all the procedures and rights Congress could have mandated, they focused

only on these three. States and school districts should carefully design and review their

procedures to ensure a student never misses school due to a dispute; parents,

guardians, and youth know their rights and are able to appeal decisions; and the

liaison is the key player in carrying out the dispute process quickly. We will suggest

strategies to ensure these three key requirements are met in the following section.


Every LEA in every State must follow McKinney-Vento’s dispute resolution

procedures. The McKinney-Vento Act applies to every LEA in every State, regardless of

whether the LEA receives McKinney-Vento funds. If dispute processes are not

followed, or if a parent, guardian, or unaccompanied youth is not satisfied with the

final resolution of a dispute at the State level, the parent, guardian or unaccompanied

youth can sue in Federal court (and in some States, in State court as well). Any issue

under the McKinney-Vento Act can be enforced through a private right of action in

court against both the SEA and LEA. Since the prior reauthorization of the McKinney-

Vento Act in 2001, parents have sued SEAs and/or LEAs under the McKinney-Vento

Act in Hawaii, Illinois, Maryland, New York, and Pennsylvania. In every case, the

parents either have won their case in court or settled out of court, and States and

school districts have paid significant legal fees and implemented new policies and

procedures. (For more information on litigation related to the McKinney-Vento Act,

review a publication from the National Law Center on Homelessness & Poverty

entitled No barriers: A Legal Advocate’s Guide to Ensuring Compliance with the

Education Program of the McKinney-Vento Act.) To summarize, it is important for SEAs

and LEAs to understand they can be sued, and if they are not in compliance with the

McKinney-Vento Act, they will likely lose the lawsuit.

G.4 Dispute resolution: Designing and Implementing Clear, Strong Procedures

There are many overarching aspects of the process to consider when designing

and implementing both State and local McKinney-Vento dispute procedures.

G.4.1 The McKinney-Vento Dispute Procedure: Its Own Process Versus Part of a

Broader State Appeals Process

Whether your State chooses to develop its own McKinney-Vento dispute

procedure or incorporate it within or utilize a broader State appeals process will

depend largely on the appeals processes available in your State. If your State has an

existing appeals process that can render decisions quickly; is fully accessible to

parents, guardians, and youth struggling with the challenges of homelessness; can


provide an adequate opportunity for schools, parents and youth to present

information; and includes liaisons and decision-makers who are well-versed on the

McKinney-Vento Act, then that appeals process may be appropriate for McKinney-

Vento disputes. Utilizing the broader appeals process may have the added benefit of

involving stakeholders in the SEA and adding greater weight and importance to the

McKinney-Vento Act. If school district administrators are familiar with the process,

they may take McKinney-Vento disputes more seriously. However, State Coordinators

must ensure the process meets the McKinney-Vento Act’s basic requirements and

should pay particular attention to ensuring immediate enrollment of students while

disputes are pending.

Many States have found it helpful to have McKinney-Vento dispute procedures

included in their State education laws or issued as regulations. The McKinney-Vento

Act does not require that its dispute process appear in statute or regulations, but

experience indicates that raising the procedures to the level of statutory or regulatory

requirements enhances compliance by LEAs and uniformity across the State.

G.4.2 A State-created Process that All LEAs Must Follow Versus LEA-

created Processes

While the McKinney-Vento Act does not specifically require LEAs to have

written dispute policies, LEAs are required to provide written explanations of their

decisions and the right to appeal and refer youth, parents, and guardians to the liaison

to carry out the dispute resolution process expeditiously. It is a good practice for LEAs

to have written policies and procedures in place to ensure McKinney-Vento’s mandates

are carried out. Written policies can protect students, parents, and the school district

by providing a clear, objective procedure for disputes.

In general, a single, uniform process for McKinney-Vento disputes for all LEAs is

preferable for several reasons. First, homeless families and youth by definition are

highly mobile, which makes it likely they will come into contact with several different

school districts over a single school year. Having to learn how to access and navigate a

different dispute procedure in each district places an added and unnecessary burden

on them. Second, disputes often involve more than one district. It can be challenging


for parents, students, districts, and the State to navigate an inter-district dispute that

implicates two different dispute processes. Finally, it will be more difficult for the State

Coordinator to ensure that all LEAs have dispute procedures that comply with the

McKinney-Vento Act if each LEA has its own, unique process.

For these reasons, the State Coordinator may want to develop a local dispute

resolution policy and procedure to be implemented by all LEAs in the State. If the SEA

is not willing or able to develop a uniform policy, the State Coordinator at least should

have a recommended process available and strongly encourage school districts to use

it. In developing the policies, the State Coordinator should consult with other

stakeholders at the SEA, such as his or her supervisor; Title I, Part A administrators;

special education administrators; SEA legal counsel; the State school boards

association; and a focus group of local liaisons and school district administrators.

Involving stakeholders in the process to develop the policies should increase buy-in

and compliance and ensure strong, efficient dispute procedures.

For example, the state of Washington developed a dispute resolution procedure

for use in all LEAs. The Washington State School Directors’ Association (WSDDA) adopted

the policy as a model and disseminated it to its members across the State. To ensure all LEAs

have adopted and are implementing the policy, Washington’s consolidated program review

specifically monitors that all LEAs have incorporated it. Washington’s dispute policy can be

found in Appendix G.2. Sample State Policy.

Similarly, State Coordinators in Oregon, Virginia, and other States have collaborated

with their school board associations, with the result that they produce McKinney-Vento

policies that LEAs generally adopt as a matter of course. State Coordinators should contact

their State school board association to find out if they have current McKinney-Vento Act

policies and, if not, work with these groups to develop strong policies and support their

implementation.

G.4.3 Timelines for Local and State-level Appeals

While the McKinney-Vento Act does not mandate specific timelines, it does require

“prompt” resolution of disputes. SEAs should establish timelines to resolve disputes at the

local and State level. Timelines should balance several competing factors:

the requirement to resolve disputes promptly,


the recognition that parents and youth struggling with homelessness are likely to need

extra time to file a dispute and prepare information for decision-makers,

the desire to provide stability and predictability to students and schools, and

time left in the school year.

In general, fairly short timelines are appropriate for McKinney-Vento disputes. For

example, North Carolina provides five business days for submission of materials; Florida

provides ten days. Situations will arise in which parents, guardians, or youth may need

additional time to present information, and procedures. In particular, parents, guardians, and

youth may not be able to meet tight deadlines due to the upheaval of homelessness and crises

that arise in their lives. Therefore, the dispute policy should allow for them to request

additional time on a case-by-case basis. Allowing the parent, guardian, or unaccompanied

youth to request a few extra days if they can justify that request with a description of exigent

circumstances increases fairness and helps ensure that decision-makers receive complete

information. Timelines and the grounds for requesting extensions of time should be made clear

in the procedures, in language understandable to homeless parents, guardians, and youth.

G.4.4 Procedures to Ensure that Parents, Guardians and Unaccompanied Youth Know

their Rights

Local liaisons must make sure that families are aware of the educational and

related opportunities available to their children (including transportation) [42 U.S.C.

§ 11432(g)(6)(A)(v)] and must post public notice of the educational rights of homeless

children and youths [42 U.S.C. § 11432(g)(6)(A)(vi)]. Posters, such as the ones

available from NCHE and other information translated into languages represented in

the community must be placed where homeless families and youths receive services. It

is also a good practice to provide all parents with a written statement of McKinney-

Vento rights at the time of enrollment, post such a statement on the LEA website, and

include it as part of parent/student handbooks. NCHE provides sample informational

materials for parents on its website under Resources by Topic.

Moreover, ED’s 2016 Non-Regulatory Guidance suggests that LEAs include the

following information when distributing information on the dispute process:

Notice of the right to file a complaint, raise a compliance issue, or file an appeal;

A step-by-step description of how to appeal the school’s decision that includes a


simple form parents, guardians, or unaccompanied youths can complete and

submit to the school to initiate the dispute process. Copies should be provided

to the parent, guardian, or youth for their records;

Notice that, if the parent, guardian, or unaccompanied youth are English

learners, use a native language other than English, or need additional supports

because of a disability, translators, interpreters, or other support services will

be made available without charge in the appropriate language;

Notice of the right to be enrolled immediately in the school in which enrollment

is sought pending the final resolution of the dispute;

Notice that immediate enrollment includes receiving adequate and appropriate

transportation to and from the school of origin and the ability to fully

participate in all school activities;

List of legal and advocacy service providers in the area that can provide

additional assistance during any part of the process;

Contact information for the local liaison and State Coordinator, with a brief

description of their roles; and

Timelines for resolving district- and State-level appeals. (ED, 2016, p. 31).

G.4.5 Procedures to Ensure that Parents, Guardians, and Unaccompanied Youth

are Able to Appeal Decisions at the Local and State Levels

Most parents and youth experiencing homelessness have limited resources,

little to no ability to secure attorneys or advocates, and are dealing with the extreme

stressors of homelessness. To ensure that McKinney-Vento dispute procedures are

accessible to them, procedures should be as informal and streamlined as possible,

consistent with impartial and complete review. Parents, guardians, and

unaccompanied youth must receive clear and simple information about their right to

dispute decisions, how to initiate the dispute, how the procedure will unfold, whom in

the school district and SEA they can contact with questions, and the timeline for the

process. Schools should provide this information in writing, but the local liaison (or a

designee trained in the McKinney-Vento Act and skilled at effective communication

with parents and youth) should also explain the process orally to ensure parents,


guardians, and youth understand.

In addition, the parents, guardians, and unaccompanied youth should be able to

initiate the dispute resolution process directly at the school they choose, as well as at

the district or local liaison’s office. Most homeless families and unaccompanied youth

struggle with transportation. They may not have a way to travel to a particular office to

initiate the dispute process. The need to travel may delay them initiating the dispute. If

timelines are short, the family or youth may be unable to initiate the dispute within the

time frame. To eliminate transportation barriers, parents, guardians, and youth should

be provided the maximum flexibility to initiate the dispute and submit appeals

documents at the most convenient school or district office.

The paperwork necessary to initiate a dispute also should be minimal, to

eliminate barriers to parents and students accessing the process. For example, when a

school or school district provides written notice of a decision to a parent, guardian, or

unaccompanied youth, the written notice could include a space where the parent,

guardian, or youth indicates whether he or she agrees with the decision. If the parent,

guardian, or youth indicates disagreement, that should trigger a conversation about

the dispute process. A particularly effective process is for the liaison or trained

designee to explain the grounds for the dispute and the dispute process, ask the

parent, guardian, or youth if he or she wishes to dispute the decision, and initiate the

dispute immediately. The liaison or designee can check the appropriate box on the

form that indicates a dispute has been initiated. This can be accomplished via

telephone, if it is difficult for the parent, guardian, or youth to get to a school site.

G.4.6 Recommended Elements of Strong Written Notices

Written notice protects both students and schools by outlining the specific

reasons for the school’s decision. It facilitates dispute resolution by providing decision-

makers with documents to guide their determinations. Written notice should be

complete, as brief as possible, simply stated, and provided in a language the parent,

guardian, or unaccompanied youth can understand. The NCHE Homeless Liaison

Toolkit includes a sample of such written notice in Appendix 8.A: Written Enrollment

Decision Notice.


The 2016 Non-regulatory Guidance suggests that notice and written explanation

from the LEA about the reason for its decision at a minimum should include the

following:

An explanation of how the school reached its decision regarding eligibility,

school selection, or enrollment, which should include:

o a description of the action proposed or refused by the school;

o an explanation of why the action is proposed or refused;

o a description of any other options the school considered;

o the reasons why any other options were rejected;

o a description of any other factors relevant to the school’s decision and

information related to the eligibility or best interest determination including

the facts, witnesses, and evidence relied upon and their sources;

o appropriate timelines to ensure any relevant deadlines are not missed; and

Contact information for the local liaison and State Coordinator, and a brief

description of their roles. (ED, 2016, p. 31)

G.4.7 Strategies to Ensure that Decision-makers have all the Information They

Need to Make Impartial Decisions Consistent with the McKinney-Vento Act

To help ensure that local and State decision-makers have all the information

they need, schools, parents, guardians, and unaccompanied youth should be informed

that they can provide written or oral documentation to support their position. If the

parent, guardian, or youth provides information to the school, the LEA should include

that information with the materials it submits to the State should the local decision be

appealed, along with a list of what the parent or unaccompanied youth has provided.

Examples of helpful written documentation include

a clear, concise description of the issue (e.g., why the student does / does not

meet the definition of “homeless”; why the student does / does not have the

right to immediate enrollment in an attendance area school; why attendance in

the school of origin is / is not in the student’s best interest)

a timeline of contacts between the school and the parent/guardian or youth


copies of emails between the school and parent/guardian or youth

a log of phone contacts and meetings between the school and parent/guardian

or youth

for disputes involving eligibility, information documenting responses to the

following questions is helpful:

o Has a local liaison from another school district found the student eligible?

o Can the parents or youth describe their living situation? Where are they

living? How long have they been there? Do they know how long they will

stay? Do they have a legal right to be there? Why did they leave their last

residence? Where would they go if they had to leave where they are

staying?16

o Can parents or unaccompanied youth provide any documentation of their

living situation, such as a motel receipt, letter from a case manager, or an

eviction notice? Such documentation cannot be required and often is

impossible for families or youth to obtain. Families or youth may be

unwilling to provide such information. However, if available, it can be

helpful in resolving the dispute, and schools should tell parents and youth

that this documentation can support their claim of eligibility.

o Can the school or LEA articulate its reasons for believing the student does

not “lack a fixed, regular, and adequate nighttime residence?”

(For more information on determining eligibility, see NCHE’s brief on

“Determining Eligibility for Rights and Services under the McKinney-Vento

Act.”)

For disputes involving school of origin attendance, the following information

can be useful:

oHas each side completed the checklist included in NCHE’s brief “School

Selection?”

16 When working with unaccompanied youths, accessing such information can be especially challenging. Unaccompanied youths often are apprehensive about sharing such details, particularly in cases of abuse or neglect where the youth does not want to get his or her parent in trouble or to invite the involvement of child protective services. Local liaisons should keep in mind that unaccompanied youths are eligible for the McKinney-Vento Act’s services, even when the precise reason for their homelessness cannot be established.


oCan each side explain why attending the school of origin is, or is not, in the

student’s best interest?

For disputes involving immediate enrollment and full participation in school,

decision-makers may need to know the following information:

o What is the school’s reason for denying enrollment and full participation?

o Can the parents or youth provide information about where they are staying

and why the school in which they are seeking enrollment is a “school that

nonhomeless students who live in the same attendance area are eligible to

attend?”

Schools may also inform parents, guardians, and unaccompanied youth that

they can seek the assistance of advocates or attorneys and may wish to provide a list of

local attorneys and advocates who have thorough knowledge of the McKinney-Vento

Act and are willing to work with parents, guardians, and youth, if available. The

support of a trained advocate can be critical to a parent, guardian, or youth, to ensure

they submit the necessary dispute documents, provide appropriate information about

their situation, and receive their McKinney-Vento rights. Parents, guardians, and youth

often need help to know what information to provide, how to obtain it, and how to

present it. Without an advocate, it is uncommon for a parent, guardian, or youth to

have the training and skill in dispute resolution or access to documentation

comparable to that of a school district attorney or administrator.

While the McKinney-Vento Act does not require the liaison to be the actual

decision-maker, the liaison must carry out the dispute resolution process. Therefore,

the liaison must be closely involved every step of the way. In fact, in most cases it

would make sense for the liaison to be the decision-maker at the first level of appeal,

since the liaison is likely to have the most in-depth knowledge of both the law and the

particular factual situation. Ensuring the involvement of the local liaison in local

dispute procedures and the State Coordinator in both local and State-level disputes is

another way to promote informed, consistent decision-making.

Similarly, State Coordinators can be critical partners in resolving disagreements

informally and ensuring disputes are mediated fairly and successfully. They are the


State-level expert on the McKinney-Vento Act with access to NCHE and other national

colleagues. Being involved in local level disputes can help avoid unnecessary appeals,

promote uniformity in implementation across the State, and increase compliance with

the law.

G.4.8 Best Practices for State-level Appeals

The McKinney-Vento Act does not specify how appeals beyond the school

district level should operate or who should make final decisions at the State level.

However, the law strongly implies that State Coordinators should be involved in State-

level appeals. The McKinney-Vento Act includes as one of the functions of the State

Coordinator to ensure that school districts comply with the Act [42 U.S.C. § 11432(f)

(5)].

In practice, it is critical that State Coordinators play a role in the process and

resolution of disputes. They are the McKinney-Vento experts at their SEAs and bear the

responsibility of ensuring compliance with the Act statewide. However, in some States

it can be a conflict of interest for a State Coordinator who is the sole, final decision-

maker to get involved with the dispute at the local level. Contacts with the school,

parent, or youth at that stage in the process can color the State Coordinator’s judgment

over the final appeal. Since the State Coordinator can play a critical role in mediating

local disputes, it would be impractical to create an appeals system that restricted the

Coordinator’s ability to become involved early in the process. In addition, the State

Coordinator’s legal duty to ensure statewide compliance and provide technical

assistance to LEAs can be complicated if the Coordinator is the sole decision-maker on

appeals. Such decisions can strain relationships with local liaisons or school district

administrators.

Following are some methods to ensure the State Coordinator has appropriate

involvement in both local- and State-level disputes:

Strongly encourage local liaisons to notify the State Coordinator any time they

provide written notice of a disputable decision. For example, in Oregon, local

liaisons automatically copy the State Coordinator on written notices. Often, the

Coordinator identifies the issue as a compliance issue, rather than a dispute,


and is able to contact the district to induce compliance. In other cases, he/she

can provide valuable legal and policy information to the liaison to help facilitate

a fair, informal resolution to the situation.

Create a McKinney-Vento advisory board. This body can review appeals, as well

as support the program in other ways. The advisory board could include

veteran liaisons, colleagues at the SEA, and State Coordinators from other

States.

Create a special McKinney-Vento dispute panel of three to five people to make

decisions on State-level appeals. Panel members can be SEA employees who are

chosen by the State Coordinator and thoroughly trained on the McKinney-Vento

Act. The State Coordinator may or may not be a member of the panel. In

addition, State Coordinators from other States may serve on the panel, to bring

their expertise and perspective to the dispute, without the conflicts that can

arise when a State Coordinator is making decisions in his or her own State.

Designate administrative law judges, ombudspersons, or other decision-makers

who are independent but receive comprehensive training on the McKinney-

Vento Act from the State Coordinator and can consult with the Coordinator, as

needed.

G.4.9 Effectively Addressing Inter-district Issues

Due to the high mobility intrinsic to homelessness, it is not uncommon for a

McKinney-Vento dispute to involve more than one LEA. In particular, disputes over

attendance at the school of origin and transportation are likely to involve two LEAs.

Inter-district disputes should be resolved at the SEA level, and parents and youth

should be shielded from these disputes unless they possess information essential to a

resolution. Regardless of the subject matter of the dispute, State Coordinators must be

vigilant to ensure students are not out of school while inter-district disputes are

pending.

State Coordinators may resolve inter-district disputes using the same State-

level procedures as they use for other disputes. There should be a forum for both LEAs

—as well as the parent, guardian, or unaccompanied youth, if applicable—to provide


documentation to support their position. If the dispute involves other education laws,

such as IDEA, the State Coordinator should consult with colleagues at the SEA

responsible for implementing those laws. If the dispute involves LEAs in two different

States, the Coordinators of both States should be involved as early as possible in the

process.

G.5 Special Considerations

Dispute resolution is a complex and nuanced process. This section explores

some common types of disputes and provides suggestions for how to approach their

complexities.

G.5.1 Compliance Issues Versus Disputes

States are required to ensure that all LEAs in the State comply with the

McKinney-Vento Act. Often, McKinney-Vento disputes indicate more systemic

compliance issues, such as many disputes related to enrollment. When a school district

refuses to enroll a student due to lack of records, time in the school year, lack of a

guardian, or similar issue, the matter is not a dispute as much as a systemic compliance

issue. In such cases, the State Coordinator should use the tools at his or her disposal to

induce immediate compliance, rather than burden the parent, guardian,

unaccompanied youth or school system with the need to follow the dispute process. If

a parent, guardian, or youth seeks to file a dispute, the State Coordinator should

explain that the problem is a compliance issue, not a dispute, and tell the parent,

guardian, or youth what specific steps he or she (the State Coordinator) will take to

resolve the problem quickly. The Coordinator may wish to develop a form

distinguishing between compliance issues and disputes, which can be used with LEAs,

parents, or youth to help ensure a quick and effective resolution. Appendix G-3. A

Differentiated Process to Address Conflicts may provide a template for such a form.

A State has several different means to ensure compliance, including the

following strategies:

Provide regular, on-going technical assistance and professional development to

LEAs.


Seek the support of other SEA professionals to ensure they emphasize

McKinney-Vento Act compliance in their contacts with schools. For example, the

following SEA staff should ensure their local counterparts are aware of and

complying with the McKinney-Vento Act’s requirements: Title I, Part A;

migrant; special education; charter schools; Title I, Part D; school health and

nurses; school counselors; etc.

Monitor all school districts regularly.

Sanction noncompliant school districts by withholding Federal funds, including

Title I, Part A funds (usually warning a district that this may be done will result

in improved compliance).

G.5.2 Complaints or Appeals Involving Issues Outside of the McKinney-Vento

Act

The McKinney-Vento Act’s dispute provisions and procedures apply to any

dispute related to eligibility, school selection, or enrollment in a school under the

McKinney-Vento Act. However, disputes involving homeless children and youth may

include other laws. For example, a student who is homeless may also have a disability

and may allege violations of IDEA. Disputes could arise under other Federal education

laws, civil rights laws, State laws, and even the Federal or State constitutions.

When disputes arise under other laws, homeless students must be provided

access to the appropriate dispute procedures provided under those laws. The

McKinney-Vento dispute process is not the appropriate forum for disputes involving

other laws, as it may not include the procedural protections required or decision-

makers who are trained in other laws. The 2016 Non-regulatory Guidance states

Not all eligibility or enrollment disputes initiated by a parent, guardian, or unaccompanied youth are eligible to go through a dispute process at the LEA or SEA level. For example, when the child or youth is not residing in a homeless situation in the boundaries of an LEA, but the parent, guardian, or unaccompanied youth seeks to initiate an enrollment dispute in that particular LEA. Or, for example, a parent, guardian, or unaccompanied youth may wish to use the dispute resolution process to resolve a disagreement that in unrelated to the McKinney-Vento Act, such as a special education issue. In these cases, the LEA should refer the parent, guardian, or


unaccompanied youth to the program or administrator that would more effectively address the complaint. (ED, 2016, p.32)

When complaints involve issues outside the McKinney-Vento Act, the State

Coordinator should convene a meeting with colleagues in the SEA who implement the

other laws to determine the appropriate forum for the dispute. Some complaints can

be disputed under both the McKinney-Vento dispute procedures and those under

other statutes. A group of colleagues can tease out the different legal issues and

determine the most expeditious and fair way to resolve the complaint, in accordance

with the laws governing each issue area. In addition, when disputes are mediated

through another State or Federally mandated process, State Coordinators should

participate, as appropriate, to ensure McKinney-Vento rights and responsibilities do

not get lost in the process.

G.5.3 Charter Schools

Charter school laws vary by State. Depending on State law and/or the school’s

charter, charter schools are either part of an existing LEA or organized as their own

LEA. In either case charter schools must follow the McKinney-Vento Act’s mandates. A

charter school determined to be a school must follow the McKinney-Vento Act’s

requirements for schools and must collaborate with the liaison for the LEA to which it

belongs. A charter school determined to be its own LEA must follow the Act’s

requirements for LEAs. Charter school students who are homeless have the right to

immediate enrollment in school, school of origin attendance, transportation, and other

services the McKinney-Vento Act provides.17 In the case of a dispute, students must be

immediately admitted to the school in which enrollment is sought, pending resolution.

Depending upon how charter schools are organized under State law, there may

be differences in specific procedures for resolving disputes. When charter schools are

part of another LEA, the charter school must follow the dispute procedures of that LEA.

The local liaison will manage the dispute process and guide parents, guardians, and

unaccompanied youth through the process in the same way as for any student of any

17 If the charter school has particular, skills-related entrance requirements, the student must meet those criteria (for example, a fine arts charter school with requirements related to artistic ability).


school in the district. Local-level and State-level appeals will apply as they would in

any case.

When a charter school is organized as its own LEA, the charter school must

designate its own local liaison. That liaison would have the responsibility to carry out

dispute procedures. If the State has established dispute procedures for LEAs, the

charter school must follow those procedures. If the State allows LEAs to develop their

own procedures, the charter school may establish its own process or follow the

process of a neighboring LEA. The charter school is legally required to meet all the

same McKinney-Vento procedural requirements as other LEAs.

G.6 Navigating Conflict Resolution

As the previous sections describe the many nuances in determining what can be

disputed and how to handle other compliance issues, State Coordinators are left with a

maze of decisions. This section proposes a template for a differentiated process to

address conflicts brought to the attention of the State Coordinator. The process

suggests that there are four basic types of conflicts/complaints:

conflicts clearly addressed by the McKinney-Vento Act that require use of the

dispute resolution process;

conflicts clearly addressed by the McKinney-Vento Act that are compliance

issues, which parents or youth should not have to dispute;

conflicts that involve the intent of the McKinney-Vento Act but are not explicitly

compliance issues; and

conflicts that are outside the purview of the McKinney-Vento Act.

Table 1 offers several examples of each conflict for illustrative purposes. This

section will elaborate further on these situations and the decision making process the

State Coordinator may use to determine the proper course.

Table 1. Types of Conflict and Examples

Type of Conflict ExamplesMcKinney-Vento dispute resolution conflicts

Disagreement about remaining in school of origin


Type of Conflict Examples Disagreement about immediate

enrollment in school of residency Disagreement about homeless status

when student was appropriately identified as homeless previously (e.g., doubled-up in same location for two years)

Conflicts not appropriate for dispute resolution, but which are MV compliance issues

School failed to inform of MV educational rights

Student is not provided free meals Systemic non-compliance by an LEA

which requires State intervention (failure to identify homelessness; lack of outreach and coordination within schools and community)

Issues which do not implicate MV compliance, but address services which are allowable/beneficial

Additional activities could enhance homeless identification (e.g., using a residency questionnaire)

Summer school could improve student’s academic performance but is not required to pass a course

Non MV Student wishes to enroll in a school that is not an option for students in the residency area and is not a school of origin

Parent disagrees with the services being offered in an Individualized Education Program

Student never lost housing

Appendix G-3. A Differentiated Process to Address Conflicts provides a graphic

representation of the basic steps to be followed when a complaint/question from the

field is received by the State Coordinator. Note that whenever possible, the first steps

are to collect basic information and attempt to resolve the issue informally. State

Coordinators should maintain records for issues resolved informally as well as those

that require more formal interventions. Such information is critical to designing the

guidance, resources, and training needed in the State.


Additional appendices for this section provide tools and templates that you

may find helpful in approaching disputes.

Appendix G.4. Information to Include in an Intake Form When a Call or Email is

Received

Appendix G-5. Common Disagreements

Appendix G-6. LEA Noncompliance Letter Template

Appendix G-7. Template for Letter to Parents when Student is Not Considered

Eligible for McKinney-Vento Services

Appendix G-8. Template for Letter for Parent when Complaint is Not a

McKinney-Vento Issue

G.7 Getting the Facts: What is Legal and what is Reasonable

When a dispute arises under the McKinney-Vento Act, particularly in regard to

eligibility, school districts may wish to look further into a family’s or youth’s situation

to compile evidence in support of its position. It is absolutely critical that all such

efforts be grounded in sensitivity and respect, keeping the academic well-being and best

interest of the child or youth in the forefront. Invasive or threatening techniques to

confirm eligibility or explore a family’s or youth’s situation violate the McKinney-Vento

Act, may violate FERPA, humiliate families and youth, and may put temporary housing

arrangements in jeopardy.

Acceptable and unacceptable ways to gather facts about a family’s or youth’s

situation can be found in the NCHE briefs “Confirming Eligibility for McKinney-Vento

Services: Do’s and Don’t’s for Local Liaisons” and “Confirming Eligibility for McKinney-

Vento Services: Do’s and Don’t’s for School Districts.” Additionally, many school

districts and States have developed enrollment forms with informative, yet sensitive,

questions to help determine eligibility and gather information. (See NCHE’s Resources

by Topic web page on Enrollment.) State Coordinators may find some of these

questions helpful along with NCHE’s brief “Determining Eligibility for Rights and

Services under the McKinney-Vento Act” when navigating an appeal in a dispute

process.


Resources

National Center for Homeless Education. Issue Brief “Determining Eligibility for Rights

and Services under the McKinney-Vento Act.” Retrieved from

https://nche.ed.gov/downloads/briefs/det_elig.pdf

National Center for Homeless Education. Issue Brief “Confirming Eligibility for

McKinney-Vento Services: Do’s and Don’t’s for Local Liaisons.” Retrieved from

https://nche.ed.gov/downloads/briefs/verif_ll.pdf

National Center for Homeless Education. Issue Brief “Confirming Eligibility for

McKinney-Vento Services: Do’s and Don’t’s for School Districts.” Retrieved from

https://nche.ed.gov/downloads/briefs/verif_sch.pdf

National Center for Homeless Education. Issue Brief “Dispute Resolution.” Retrieved

from https://nche.ed.gov/downloads/briefs/resolution.pdf

National Center for Homeless Education. Issue Brief “School Selection.” Retrieved from

https://nche.ed.gov/downloads/briefs/school_selection.pdf

National Center for Homeless Education. (2016). Homeless Liaison Toolkit. Chapter 8:

Dispute Resolution. Retrieved from https://nche.ed.gov/pr/liaison_toolkit.php

National Center for Homeless Education. Resources by Topic Web Page. Enrolling

Children and Youth Experiencing Homelessness in School at


National Center for Homeless Education. Resources by Topic Web Page. Translations of

Homeless Education Materials at https://nche.ed.gov/ibt/ibt.php

National Center for Homeless Education. Resources by Topic Web Page. Parent

Resources at https://nche.ed.gov/ibt/ibt.php

National Center for Homeless Education. Education Rights Posters, Brochures, Parent

Packs at https://nche.ed.gov/products.php

National Law Center on Homelessness & Poverty. (2016). No Barriers: A Legal

Advocate’s Guide to Ensuring Compliance with the Education Program of the

McKinney-Vento Act. Retrieved from

https://www.nlchp.org/documents/NoBarriers


https://www.nlchp.org/documents/NoBarriers

https://nche.ed.gov/products.php





https://nche.ed.gov/downloads/briefs/school_selection.pdf

https://nche.ed.gov/downloads/briefs/resolution.pdf

https://nche.ed.gov/downloads/briefs/verif_sch.pdf

https://nche.ed.gov/downloads/briefs/verif_ll.pdf



Student Succeeds Act, 42 U.S.C. § 11431 et seq., 2015. Retrieved from


U.S. Department of Education. (2016). Education for Homeless Children and Youths

Program Non-Regulatory Guidance. Retrieved from





Section H. State Monitoring of Local Educational Agency

McKinney-Vento Programs

Monitoring local educational agency (LEA) Education for Homeless Children and

Youth (EHCY) programs for compliance with the McKinney-Vento Act is a key

responsibility of State Coordinators. State Coordinators must “provide technical assistance

to and conduct monitoring of local educational agencies” [42 U.S.C. § 11432(f)(5)].18 This

provision applies to LEAs both with and without subgrants.

While the monitoring process for LEAs with McKinney-Vento subgrants may include

additional elements to evaluate the effectiveness of funded programs, State educational

agency (SEA) monitoring of LEAs for compliance with the McKinney-Vento Act should be

comparable for LEAs with and without subgrants. Under the McKinney-Vento Act, whether

or not an LEA has a subgrant, all LEAs have the same responsibility to identify, enroll, and

support students experiencing homelessness.

Compliance monitoring not only ensures that LEAs meet their legal responsibilities;

an effective monitoring process also can serve to strengthen the quality of programs

serving homeless children and youth in all communities. Information gathered during the

monitoring process provides evidence of quality implementation and, perhaps equally

important, can inform decisions about the kinds of technical assistance that would best

serve the school community on behalf of children and families in homeless situations. An

effective monitoring process also allows State Coordinators to seek out and identify local

practices and procedures that can be shared with others as promising solutions to LEAs

whose programs are in various stages of development and implementation. Lastly, an

effective monitoring process will convey to LEAs the importance of developing quality 18 All resources and references mentioned are found in the Resources at the end of this section, with their links, if available.

H-1 State Coordinators’ Handbook: Section H. State Monitoring of Local Educational Agency McKinney-Vento Programs

homeless education programs, not only for purposes of complying with legislation, but also

for continuous improvement in services to homeless children and youth. When LEAs take

the time to prepare for a monitoring visit, they have the opportunity to reflect on current

practices and often identify ways to make their program more effective; such ownership in

the process increases the likelihood that changes will be implemented.

Good practice recommended by the U. S. Department of Education (ED) suggests

that all LEAs should be monitored on a regular basis, with many States conducting on-site

monitoring every three years, and more frequently for LEAs with McKinney-Vento

subgrants. LEA monitoring of EHCY programs can accomplish several important goals,

including

ensuring that local programs are providing quality and comprehensive services for

homeless children and youth;

bringing local EHCY programs identified as at risk of compliance, based on a review

of needs assessment data or past findings, into compliance;19

providing ongoing motivation for LEAs to comply with the McKinney-Vento Act;

creating an opportunity for LEAs to conduct a critical review of their EHCY program;

bringing greater authority and visibility to the program among LEA administrators;

identifying areas for needed technical assistance; and

identifying good practices to share with other LEAs.

H.1. Prioritizing LEAs for Monitoring

Mirroring the approach for selecting States for Federal EHCY monitoring, ED

recommends a risk-assessment approach to selecting LEAs when you develop your annual

monitoring schedule. With the availability of data, provided in NCHE’s LEA-level data

workbooks developed for each State and provided in other records, State Coordinators

should prioritize LEAs to monitor according to those at the greatest risk of non-compliance

with the McKinney-Vento Act. A checklist for risk factors to consider may include19 The State Coordinator should encourage LEAs to review their program periodically in order to assess needs and identify compliance issues that they can address on an ongoing basis. NCHE developed an informal needs assessment tool for LEAs.


amount of time since the LEA was last monitored;

number of findings in the previous monitoring;

indications that the LEA may be under-identifying homeless students;

number of complaints related to serving homeless children and youth received at

the State level;

quality of data submitted to the SEA and EDFacts;

amount of turnover in the local liaison position and liaison participation in

professional development offerings; and

for subgrantees, submission of required records, end-of-year reports, and

appropriate use of funds, including timely expenditures.

H.2. Approaches to LEA Monitoring

A State’s best approach to LEA monitoring is dependent upon numerous factors,

such as the

number of LEAs in the State,

time allotted for the position of EHCY coordinator,

State’s system of Federal programs monitoring (e.g., separate monitoring for each

program or consolidated monitoring), and

unique characteristics of or challenges in the State educational system.

Many State Coordinators agree that the biggest challenge in LEA monitoring is the time

required to arrange and conduct monitoring. The following approaches will help you weigh

the advantages and disadvantages of different ways to conduct monitoring and to select the

approach or the combination of approaches that would best fit the needs of your State and

your LEAs.

H.2.1. On-site Monitoring of LEA EHCY Programs

On-site monitoring of LEAs can enable the State Coordinator to gain first-hand

knowledge of every local EHCY program and to build rapport with the local liaison and

other LEA administrators. In smaller States with a limited number of LEAs, a State


Coordinator may have the luxury of visiting every LEA at least once every three years, or

more frequently if necessary, and focusing on each LEA’s unique characteristics and

challenges. However, for many States, this is not possible, and State Coordinators must

develop alternatives that ensure sufficient oversight of local programs that are economical

and efficient. Still, in some instances, there is no substitute for an on-site monitoring visit,

particularly in LEAs where there is significant noncompliance.

H.2.2. Consolidated Federal Program Monitoring

Some States combine their monitoring of Federal programs into one consolidated

monitoring process. Each program coordinator develops a set of questions related to his or

her program and provides the questions to a team that visits each LEA. Spreading the

monitoring across all Federal program staff increases the breadth of the monitoring. The

disadvantage is that while the EHCY State Coordinator will likely participate on a Federal

monitoring team and interview staff from some local EHCY programs, there are many LEAs

that will be monitored by staff who may not be very familiar with the EHCY program.

Moreover, because consolidated monitoring includes several Federal programs, the time

allotted to the EHCY program may be minimal, as compared to larger Federal programs like

Title I.

H.2.3. Desk Monitoring

Desk monitoring entails a review of LEA documents, records, and needs assessment

information (see Section H.2.6) to determine the level of compliance with the law. The State

Coordinator sends the local liaison a list of documents to provide to the SEA for review.

Desk monitoring is usually combined with either an on-site or remote interview of LEA

staff following the review of documents, in order for State Coordinators to ask clarifying

questions and get more details on the operation of the local EHCY program. Common items

requested for desk monitoring include

enrollment residency questionnaire;

LEA board policies related to the EHCY program, including the dispute policy;


agendas and participant logs for training;

phone and email logs for tracking barriers;

brochures, flyers, resource lists that are given to identified families and youth or a

link to a web page that includes information for homeless parents and youth;

Title I, Part A set-aside amount, including how the amount was determined and how

the funds will be used;

records of transportation provided for homeless children and youth to and from the

school of origin;

logs/agendas for collaborative activities with community agencies;

informal and formal agreements with agencies;

data and needs assessment documents; and

the LEA’s McKinney-Vento subgrant application, budget logs, and end-of-year

reports, if the LEA has a subgrant.

H.2.4. Remote Reviews

With advances in technology, remote monitoring has become an economical and

convenient alternative to on-site monitoring. Remote monitoring takes place without the

expense and time involved in traveling to an LEA. Interviews can be quite personal and

interactive with LEA participants and State administrators being visible to one another

through video conferencing. While not a substitute for face-to-face meetings where State

Coordinators can actually visit schools and see the context in which the EHCY program

operates, State Coordinators can alternate desk monitoring and on-site visits with an LEA,

or conduct remote reviews of only those LEAs with the least risk for non-compliance.

H.2.5. Using Contractors

Some State Coordinators contract with external agencies or former local EHCY

program staff to conduct LEA monitoring. Contractors must be very familiar with the EHCY

program and well-trained in the monitoring process, shadowing the State Coordinator or

other experienced monitors before conducting monitoring visits on their own. When


experienced contractors continue in the role for several years, they become very

knowledgeable about the EHCY program and can be a wealth of information for the State

Coordinator. It is important for contractors to communicate frequently with the State

Coordinator, especially to alert him or her to any particular compliance problems in an LEA

that would require the State Coordinator’s intervention and follow up.

H.2.6. Annual LEA Needs Assessment

Many State Coordinators have found that an LEA self-assessment is especially useful

as an initial phase of the monitoring process. A set of questions provided as a self-

assessment can be the basis for a desk review and/or on-site monitoring. The self-

assessment can even be administered as an online survey, either as a full set of questions

related to the local EHCY program or as a few key questions that could identify possible

areas of non-compliance and would prioritize an LEA for an on-site or remote review.

While the value of LEA self-assessment to the State Coordinator is considerable, the

utility of such an instrument to the local liaison can be immeasurable. The use of a well-

designed self-assessment tool can help keep program implementation on track, as well as

identify areas of concern for LEAs seeking to strengthen specific program components they

find in need of further development. Therefore, the LEA self-assessment can serve a dual

role, for local progress checks and as a component of the State’s monitoring process. (See

the Resource and Reference List for NCHE’s Educating Homeless Children and Youth:

Conducting Needs Assessments and Evaluating Services - A Guide for SEAs, LEAs, and Local

Schools for a self-assessment tool in Appendix B that may be customized to your state’s

needs.)

H.2.7. Regional Reviews

Some State Coordinators have become creative with maximizing their time and

resources for LEA monitoring. One approach is to conduct regional reviews, in which local

liaisons come to a central location to meet with the State Coordinator. Some time is spent

discussing as a group the challenges local liaisons face in administering their local EHCY


http://center.serve.org/nche/pr/na_eval.php



program. This is a time where the liaisons establish rapport with one another as well. The

State Coordinator also spends time interviewing each liaison. The State Coordinator can

follow up with any LEA that appears to have compliance problems with a more extensive

on-site review.

Another approach to maximize time is to offer regional training while visiting an

area for monitoring. Even if a regional review is not possible, State Coordinators can still

target regions for a series of LEA monitorings during the same visit and follow the

monitoring with a training open to the LEAs in the area. This can be especially helpful in

rural areas and LEAs that are a significant distance from the State Coordinator’s office.

H.3. Developing a Monitoring Protocol

The development, acquisition, or adaptation of appropriate and useful tools is a

critical part of designing an effective LEA monitoring process. Building a strong monitoring

system begins with a set of questions that captures the program requirements and the

LEA’s implementation of activities that meet those requirements. The questions should

represent the law and guidance and should be detailed enough to capture an accurate

assessment of program implementation. You should also include questions related to

record keeping; the tracking of barriers, such as a log of interactions between parents and

local liaisons; or documentation of emerging issues and problems and how they were

addressed.

You should include additional questions for subgrantees that relate to fiscal

management and carrying out specific program activities that were approved in their

application for funding. Items to include in the protocol should include both general

questions and optional probe questions that capture specific examples of implementation.

These probe questions can often illuminate an otherwise too general response, providing

details of implementation that can differentiate a program that looks good on paper but

might be less robust in reality. The optional probe questions will also be helpful to

interviewers who are part of a larger monitoring team and may or may not be familiar with

the various elements of implementation of effective McKinney-Vento programs.


Most written monitoring protocols include the following elements, which are

modeled on former ED protocols for State EHCY monitoring:

name of the LEA;

local liaison and contact information;

date of the monitoring visit or remote interviews;

names of the monitors, including anyone asking questions and the person who will

develop the monitoring report;

LEA and school representatives present during the monitoring;

documents reviewed before, during, and after the monitoring;

rating rubric (criteria for meeting requirements and receiving findings and

recommendations);

monitoring topics (e.g., local policy/infrastructure, identification, enrollment, school

stability, dispute resolution, fiscal);

general questions for each topic, probing questions, and sample evidence, and

recommended role groups present for responding to the questions (local liaison,

Title I coordinator, pupil transportation director, school registrar, etc.); and

space for the monitor to record detailed notes.

Most monitoring protocols include eight to ten general areas of inquiry that could be

covered in three to four hours for smaller LEAs and in a longer period of time for larger

LEAs. State Coordinators should review the requirements in the McKinney-Vento Act for

the State Plan [42 U.S.C. § 11432(g)(1)],

LEA requirements [42 U.S.C. § 11432(g)(3)],

coordination requirements [42 U.S.C. § 11432(g)(5)], and

local liaison duties [42 U.S.C. § 11432(g)(6)].

State Coordinators should also review any current protocols utilized for Federal

monitoring to determine ED’s priorities. Depending on concerns identified in materials

reviewed before the monitoring review, the State Coordinator or monitor may want to

expand interviews with a particular role group.


For an example of a State’s monitoring protocol, see Appendix H-1. North Carolina

Homeless Education Program LEA Monitoring Interview Protocol. Keep in mind that the

protocol must be reviewed and updated annually, as your State program evolves and as

new priorities come from ED. NCHE has posted other examples of monitoring protocols on

its Resources by Topic web page for monitoring and program evaluation.

H.4. Arranging Monitoring for an LEA’s EHCY Program

The 2016 Non-regulatory Guidance for the EHCY program states, “The monitoring

process should include a formal letter of notification; protocols for interviews,

observations, and document review, as applicable; a written report of whether

requirements were met or corrective actions required; and a process for resolving

corrective actions.” (ED, 2016, p. 14).

In arranging the LEA monitoring schedule for the year, the State Coordinator should

send a letter to each local liaison and superintendent in LEAs selected for monitoring

notifying them that the LEA will be undergoing a monitoring review and that the State

Coordinator will contact the local liaison to schedule a time for the review.

LEAs find it helpful to have a published schedule of all LEAs and the year monitoring

is likely to occur; there can be a notation that adjustments may be made based on identified

needs. Several months before the review, the State Coordinator should publish the list for

the current year. A webinar can be helpful to ensure LEAs are prepared when the

monitoring occurs. Topics that can be covered include

reviewing the state’s process and the protocol and explaining any changes since the

previous monitoring,

who will be conducting the monitoring,

what logistical tasks the liaison should undertake to prepare,

what records and documents the liaison should send ahead of time (and by what

date),

what records and documents the liaison should have on hand during the interview,

and


what other administrators or role groups should be present for the review.

After providing this information, the State Coordinator should contact the liaison and

superintendent with further details of the review, including whether the review will be on-

site on remote and who the monitor will be. The State Coordinator should also share the

monitoring protocol and rating rubric at this time. Approximately one week before the

review, the State Coordinator or monitor should provide an agenda for the review.

The State Coordinator may also request that the local liaison arrange meetings with

other administrators and role groups (e.g., Title I coordinator, pupil transportation

director, school social worker, data manager, or community service providers). You may

want to develop additional questions for these individuals. Including visits to a few schools

will indicate if McKinney-Vento education rights posters are prominently displayed, and a

conversation with the enrollment staff will reveal if school-level staff is aware of the

McKinney-Vento Act and the right to immediate enrollment.

Many State Coordinators approach LEA monitoring as a technical assistance

opportunity. During the review, in addition to identifying areas of noncompliance and good

practice, the monitor can provide information on good practices to meet specific challenges

learned from other LEAs. The monitor should take detailed notes for all questions during

the review.

After the review, the monitor should develop a report of findings, commendations,

and recommendations. The State Coordinator should send the report to the local liaison,

superintendent, and Federal programs coordinator, with instructions for how the LEA

should respond to any findings, including the deadline for the response. Monitoring reports

are important documents to help State Coordinators develop their annual action plans for

technical assistance. In addition, the State Coordinator should review the quality of the

report to determine what changes need to be made to the LEA monitoring system or the

monitors, if completed by someone other than the State Coordinator.

H.5. Providing Technical Assistance to LEAs to Prepare for Monitoring


Remember that an effective monitoring system is one component of a well-

implemented McKinney-Vento program. While critical for accountability purposes, the

overall monitoring process also should be viewed as an important piece of the program

infrastructure, which is interwoven with professional development, program design, data

collection, program evaluation, and communication and coordination with all segments of

the LEA and community.

The best way to prepare an LEA for monitoring is to provide the information,

training, and technical assistance needed for an LEA to build a strong local EHCY program.

Since the monitoring protocol should set the expectations for the local EHCY program, the

content of LEA training should align with it. LEAs that have the knowledge, skills, and tools

to build stronger, more compliant McKinney-Vento programs should generally have a

smooth monitoring process with few findings.

Section H.6. Customizing the Process for Your State

While SEAs must meet the legislative requirement for monitoring their LEAs for

McKinney-Vento compliance, the monitoring process will look different in every State.

Appendix H-2. Case Studies illustrates ways that SEAs can customize the process for States

of varying sizes and characteristics. Appendix H-3. Problems and Suggested Solutions in

LEA Monitoring provides strategies to address some common challenges that State

Coordinators face in establishing their LEA monitoring system. There is no one right way to

conduct LEA monitoring, and the process should change as States, laws, and program needs

change.

Resources

NCHE. (2016). Local Educational Agency Informal Needs Assessment. Retrieved https://nche.ed.gov/ll/ll.php

NCHE’s Resources by Topic web page on Program Evaluation and Monitoring at http://nche.ed.gov/ibt/sc_eval.php




http://nche.ed.gov/ibt/sc_eval.php

https://nche.ed.gov/ll/ll.php

U.S. Department of Education. (2016). Education for Homeless Children and Youth Program Non-Regulatory Guidance. Retrieved July 2016 http://www2.ed.gov/policy/elsec/leg/essa/160240ehcyguidance072716.pdf



Section I. The McKinney-Vento Subgrant Process

Each year, the State educational agency (SEA) must make subgrants to local

educational agencies (LEAs) “for the purpose of facilitating the identification, enrollment,

attendance, and success in school of homeless children and youths.” (42 U.S.C. § 11433(a)

(1))20 These subgrants are competitive and awarded based on need and quality of the

application. (42 U.S.C. § 11433(c)(1)).

Included in this section of the handbook is a review of the requirements of the

subgrant program described in Section 723 of the McKinney-Vento Act (42 U.S.C.

§ 11433)). Additionally, the handbook summarizes many years of good practice on the part

of States that can guide both new and experienced State Coordinators through a process of

reviewing their program’s current subgrant process against accepted good practice so that

State Coordinators can make refinements as necessary.

An LEA’s McKinney-Vento subgrant program is likely to be only as good as the

process by which subgrants are awarded and overseen. As the State Coordinator, you play

a vital role in developing a process that enables subgrantees to link needs, goals, activities,

and expenses and holds subgrantees accountable for implementing strong programs.

I.1. Requirements in the McKinney-Vento Act Related to Subgrants

Section 723 of the McKinney-Vento Act details the intent and requirements for the

McKinney-Vento subgrant program.

The SEAs must distribute not less than 75 percent of its annual McKinney-Vento

allocation in subgrants to LEAs (except for States funded at the minimum level that must

distribute not less than 50 percent in subgrants to LEAs). (42 U.S.C. § 11432(e)(1)).

Subgrant terms may be for up to three years (42 U.S.C. § 11433(a)(4)) although subgrant


I-1 State Coordinators’ Handbook: The McKinney-Vento Subgrant Process

funds should be distributed annually. The full competitive process and selection of LEAs to

fund can be done once every two or three years with funds awarded on an annual basis.

The following is a summary of key provisions in the law related to services provided

through subgrants. Subgrants are designed to expand or improve upon services provided

as part of a school’s regular academic program; but not to replace any existing services. (42

U.S.C. § 11433(a)(2)(A)(iii)). The services may be provided through programs on school

grounds or other facilities and must, to the maximum extent practicable, be provided

through existing programs that integrate homeless children and youth with nonhomeless

children and youth. (42 U.S.C. §§ 11433(a)(2)(A)(i),(ii)).

If services are provided on school grounds, recipients of services may include other

children and youth who are at risk of failing in or dropping out of school (42 U.S.C.

§ 11433(a)(2)(B)(i)). However, the main purpose of the subgrant is to meet the needs of

homeless children and youths. In addition, services provided through the subgrants in

schools should not segregate homeless children and youths except for short periods of time

for health and safety emergencies or to provide temporary, special, and supplementary

services to meet the unique needs of homeless children and youths. (42 U.S.C. § 11433(a)

(2)(ii)).

LEAs must submit an application to the SEA for a subgrant that includes the

following:

(1) An assessment of the educational and related needs of homeless children and

youths in the area served by the LEA;

(2) A description of services and programs for which assistance is sought;

(3) An assurance that the LEA’s combined fiscal effort per student, or aggregate

expenditures of the LEA and State with respect to the provision of free public

education by the LEA for the fiscal year preceding the fiscal year for which the

determination is made, was not less than 90 percent combined fiscal effort or

aggregate expenditures for the second fiscal year preceding the fiscal year for which

the determination is made;

(4) An assurance that the applicant complies with, or will use requested funds to

comply with, paragraphs (3) through (7) of Section 722(g);


(5) A description of policies and procedures to ensure that activities will not isolate or

stigmatize homeless children and youth;

(6) An assurance that the LEA will collect and promptly provide data requested by the

State Coordinator pursuant to paragraphs (1) and (3) of Section 722(f); and

(7) An assurance that the LEA will meet the requirements of Section 722(g)(3). (42

U.S.C. § 11433)(b)).

The SEA must conduct award competitions for LEAs and award subgrants on the

basis of need and quality of the application submitted. (42 U.S.C. § 11433)(c)(1)). The SEA

may consider the number of homeless children and youths enrolled in early childhood

education and other preschool programs, elementary schools, and secondary schools

within the area served by the LEA and must consider the needs of such children and youths

and the ability of the LEA to meet such needs. (42 U.S.C. § 11433)(c)(2)).

The SEA may also consider:

(A) The extent to which the proposed use of funds will facilitate the identification,

enrollment, retention, and educational success of homeless children and youths;

(B) The extent to which the application reflects coordination with other local and State

agencies that serve homeless children and youths;

(C) The extent to which the applicant exhibits in the application and in current practice

a commitment to education for all homeless children and youths.

In determining the quality of the application, the SEA must consider the following:

(A) The applicant’s needs assessment and the likelihood that the proposed program will

meet such needs;

(B) The types, intensity, and coordination of the services to be provided;

(C) The extent to which the applicant will promote the meaningful involvement of

parents or guardians of homeless children and youths in the education of their

children;

(D)The extent to which homeless children and youths will be integrated into the

regular education program;

(E) The quality of the applicant’s evaluation plan for the program;


(F) The extent to which services provided by the subgrant will be coordinated with

other services available to homeless children and youths and their families;

(G) The extent to which the LEA will use the subgrant to leverage resources, including

by maximizing nonsubgrant funding for the local liaison position and for the

provision of transportation;

(H)How the LEA will use funds to serve homeless children and youths under Section

1113(c)(3)(A) of the Elementary and Secondary Education Act (Title I, Part A) (20

U.S.C. § 6313(c)(3)); and

(I) The extent to which the applicant’s program meets such other measures as the SEA

considers indicative of a high-quality program. (42 U.S.C. § 11433)(c)(3)).

The law includes a list of authorized LEA activities that may be funded to carry out the

purpose of the subgrant program. These are included in Appendix I-1. McKinney-Vento

Subgrants Authorized Activities. (See Section J: Management and Oversight of Education for

Homeless Children and Youth Program Grants for more information on allowable expenses

for McKinney-Vento subgrants.)


I.2. Risk Assessment Requirements in the Uniform Guidance

The U.S. Office of Management and Budget’s Uniform Guidance,21 which consolidated

existing cost circulars along with new requirements for grant management, took effect on

July 1, 2015. According to the Uniform Guidance, prior to awarding Federal funds, agencies

serving as pass-through entities must conduct a risk assessment of subawardees. To

comply with the requirements of the Uniform Guidance for subawards, the State

Coordinator must gather data to determine the ability of an LEA applying for a subgrant to

manage the award. (For more information on the types of information that State

Coordinators should obtain prior to making a subgrant award, see Section J: Management

and Fiscal Oversight of Education for Homeless Children and Youth Program Grants.)

I.3. State Policies

You should be familiar with your SEA’s policies regarding awarding funds and

grants to LEAs. States may have specific requirements related to the allocation of funds,

State board involvement, proposal review, etc. Moreover, it is important to ensure that the

SEA administration and budget office understand the intent and legislative requirements

for the McKinney-Vento subgrant program.

I.4. Planning the Process

As a first step in the subgrant cycle, approximately one year before the end of the

current cycle, you should notify your supervisor, Federal programs officer, State

superintendent, grants office, and budget office that by law, the State must conduct a

competitive grant process. This should initiate discussions on SEA policies and procedures

for grant competitions and ensure that you have the time and support needed to carry out

the process.

There are a number of questions to consider before preparing the subgrant process.

I.4.1 How long should the subgrant cycle be?

The McKinney-Vento Act states that subgrants can be awarded for terms not to

exceed three years. (42 U.S.C. § 11433(a)(4)). Most States implement a three-year cycle; in

21 Websites for resources mentioned are included in the Resources at the end of this section.


monitoring visits, Federal Education for Homeless Children and Youths (EHCY) program

monitors have recommended that States with a cycle of less than three years change to a

three-year cycle. The longer cycle allows for greater program continuity and enables State

Coordinators to monitor and assist subgrantees in strengthening their program during the

implementation phase. In addition, the application and award process requires significant

time and effort both at the State and local levels. Any benefits in conducting the process

more frequently than three years do not outweigh the time and effort taken away from

providing programmatic activities and services.

I.4.2. How many and what size subgrants should be awarded?

The size and number of subgrants awarded in a State varies widely. To see the range

in number of subgrants awarded by State in more recent years, see Table 1 in NCHE’s

Federal Data Summary School Years 2011-2012, 2012-2013, and 2013-2014.

The determination of the number and size of subgrants should be based on the

demographics and needs of each State. Table I-1. Determining Amount and Number of

Subgrant Awards illustrates benefits and concerns related to how subgrant funds are

disbursed.

Table I-1. Determining Amount and Number of Subgrant Awards

Amount Benefits Concerns

Small subgrants/many awards

Good for States that have small to moderate numbers of homeless students in most districts

Good for States that have districts that could benefit from startup funds to build their MV program

Provides broad coverage of LEAs

May spread the funds too thin for significant program impact

Not the best choice if some LEAs have large numbers of homeless students, such as urban areas, that have need for greater amounts of funding

Large subgrants/few awards

Most beneficial in States with a few high need districts and most districts with lower numbers of homeless students and needs

Enables funds to be concentrated where the needs are greatest

Districts with smaller numbers would not receive funding but could benefit from award funds and a program plan to help identify homeless students and build a program


Some States use a tiered approach to making subgrant awards. In these States,

districts are categorized according to the number of homeless students identified, and each

category is eligible for a certain range of funding, with lower amounts available to those

with lower numbers of homeless students and higher amounts available to those with

higher numbers. The tiered approach enables the greatest amount of the subgrant funds to

target the districts with the greatest need while enabling districts with lower numbers to

have funding to build their program.

If you decide to implement a tiered approach to subgrantee awards, consider the

following questions:

What source of data on the number of homeless children and youth identified will

you use or require LEAs to use to determine their award tier? And, for what period

of time (e.g., past school year)?

How will you handle LEAs who fall into a low tier based on the previous school year

but can document more students in the current school year in which the subgrant

competition will take place that would push them into a higher tier?

I.4.3. Can subgrants be awarded to regional entities?

Some States award subgrants to regional entities or consortia of LEAs. Michigan,

with over 800 LEAs, is an example of a State that awards subgrants in this way. In 2009, the

State Coordinator explained that regional subgrants enabled the State to maximize the

distribution of the subgrant funds and include more LEAs. Smaller districts with lower

numbers that had not participated in the competitive subgrant process were able to

increase services for their homeless students through the regional consortium approach.

The regional approach decreased administrative costs and fostered greater collaboration

among LEAs. Moreover, the State Coordinator reported that she was able to more

effectively oversee the work of and train 30 regional consortia coordinators, instead of

coordinators in each participating LEA. In turn, a regional grant coordinator reported that

she is more easily accessible to participating district homeless liaisons for consultation and

assistance than SEA staff.

However, Federal monitoring of some States utilizing the regional approach has

raised concerns related to compromising the competitive process and divesting tasks,


authority, and oversight that should rest with the office of the State Coordinator.

Additionally, subgrants must be awarded on the basis of need and quality of the

application. Procedures and safeguards must be implemented such that a regional

approach to awarding subgrants ensures that (1) the State Coordinator retains sufficient

authority and oversight of the local level implementation of the McKinney-Vento Act, and

(2) local capacity is sufficient to carry out the required tasks. In addition, the regional

approach should ensure that LEAs with the greatest need are provided funds to meet the

needs of homeless students and that funds are not spread too thin to have significant

impact. States that disseminate McKinney-Vento funds in regional grants should evaluate

the effectiveness of this approach on an ongoing basis.

I.4.4. What are some considerations for developing a timeline to conduct the

subgrant process?

McKinney-Vento subgrants should be awarded to LEAs in a timely way, namely,

before the beginning of each school year to ensure optimal program implementation. In

planning the subgrant process, you should allow sufficient time for LEAs to develop their

proposals and avoid coinciding application deadlines with the times of the year when they

are likely to be extraordinarily busy, such as during State assessments. Also, you should be

aware of other discretionary grant processes taking place at the same time and select

another time for the McKinney-Vento subgrant process. Small LEAs frequently have staff

available only on a nine-month contract, so they would not be able to effectively complete

an application during the summer break.

Other considerations for the timeline include

technical assistance activities to familiarize LEAs with the application and

proposal development process

announcing the availability of the request for proposals (RFP)

training for proposal reviewers

the proposal review process

State processes for grant approval

State processes for disbursing funds to awardees

the award notification process


See Appendix I-2. Sample Timeline for the McKinney-Vento Subgrant Process.

I.5. Developing or Revising the Request for Proposals (RFP)

Well in advance of the McKinney-Vento subgrant process, State Coordinators should

review the application in the RFP for the past cycle and determine if and/or how it should

be revised. Recommendations in the following section along with a review of examples of

subgrant RFPs from other States will provide you with the guidance you need to ensure

that your RFP meets the requirements of the law and helps applicants envision and develop

competitive proposals. (See the subgrant section of NCHE’s Resources by Topic web page.)

I.5.1. Purpose of the RFP

The RFP should be viewed as a blueprint for the subgrant program and a contractual

agreement for how the LEA will spend the funds. It should be detailed enough to lead the

LEA through a process to link its needs for homeless children and youth with goals,

objectives, activities, and expenditures. However, it should not require so much detail that

it will create a barrier for LEAs that need the funds to apply, especially for ones that do not

have grant writers. The application must require sufficient detail, nevertheless, for

reviewers to evaluate the needs of homeless children and youth in the LEA and the quality

of the proposal for the competitive process.

After each subgrant process, you should review the submitted applications to

determine the strengths and weaknesses of the RFP and make any needed revisions to the

process for the next cycle.

I.5.2. Program Perspective Reflected in the RFP

LEAs should view the subgrant as a program, not a set of activities. The program

should be an integrated and comprehensive approach to providing services for homeless

children and youth that shows a direct connection between needs, goals, objectives,

activities, and expenses. The strength of the proposal should derive from the linkages

between program elements and illustrate how the funding will be leveraged with other

LEA, Federal, and community resources to address the specific needs and goals. Therefore,

an LEA that proposes to spend the funds only on a limited set of activities or on one type of


activity such as transportation would most likely not be competitive. The RFP should be

designed in a way to enable the LEA to show how all program elements and resources are

linked.

I.5.3. Critical Components of the RFP

In reviewing the RFP, make sure the following components are clearly addressed:

Eligibility requirements for application. Grants must be awarded to LEAs as the fiscal

agent. Some States limit eligibility to LEAs that have identified a certain number of

homeless children and youth to ensure that funds target LEAs with the greatest need.

Instructions for completing the application. The application should include

information on the following:

Deadline for submission and method of submission

Length of the application, line spacing, margins

Signatures required

Proposal components to be completed by the applicant

Date by which applicants will be notified of an award

The following are the most common components of McKinney-Vento subgrant

applications:

Statement of need. Applicants should provide information on the number of

homeless students identified, socio-economic and demographic data and trends,

data from a needs assessment, status of the current program, and community

resources.

Program description. The proposal should include prioritized needs, goals,

objectives, activities, measurable outcomes with a clear depiction of the linkages

between each. Staffing and program management should be included as well.

The application should provide a timeline for program implementation and

address any changes that will occur from year to year in a multiple-year award.

o Collaborations. The proposal should include a description of collaborations in

place both within the LEA and within the community. Some State

Coordinators require evidence of input from collaborators such as signatures


or memoranda of agreement. The application should require evidence of

collaboration with Title I, Part A and should require applicants to include the

amount of the Title I set aside for homeless students and an explanation for

how the funds will be spent.

o Staff. Applicants should include a staffing plan for the program with duties

that link clearly to the activities, goals, and needs.

o Budget. The budget should be detailed and link clearly to the program

activities and expenses. Moreover, the budget should reflect only allowable

expenses. The budget should also show cost and resource sharing with the

LEA, other Federal programs, and external agencies. A budget should be

included for each year of the program if the program activities will differ

from year to year.

o Program Evaluation. With an increasing emphasis on accountability and

effectiveness for all Federal programs, the proposal should include a strong

evaluation plan with strategies for collecting data on measurable goals and

objectives that will demonstrate the program’s progress.

o Signatures and Assurances. The proposal should provide evidence that the

LEA is committed to carrying out the subgrant program in the form of

signatures from administrators for assurances that reflect the requirements

of the subgrant program.

Supporting Information. State Coordinators should make supporting information

available to subgrant applicants as appendices to the RFP or web links. The

objective of providing this information is to clarify requirements and expectations

for the subgrant program so that applicants can develop a quality application and

program coordinators can be clear on the expectations for the subgrant program.

The following are items that would be useful as supporting information:

o Background on the McKinney-Vento Act and legislative requirements for

subgrants, including the 16 allowable activities listed in section 723 (42

U.S.C. § 11433(d))

o Criteria for a review and scoring rubric


o Needs assessment template, such as the one found in Appendix B in NCHE’s

Educating Homeless Children and Youth: Conducting Needs Assessments and

Evaluating Services - A Guide for SEAs, LEAs, and Local Schools

o Subgrantee monitoring indicators developed by the State Coordinator

o Forms (e.g., signature page; budget; program components chart – measurable

goals, objectives, activities, timeline; program evaluation template; staffing

chart)

o End-of-year report template

I.5.4. Announcing the Availability of the RFP

State Coordinators should announce the availability of the RFP foremost to local

homeless liaisons. In addition, local superintendents, budget offices, Title I coordinators,

and development offices should be aware of the process. State Coordinators should

coordinate with SEA administrators for a statewide dissemination of the announcement

through multiple venues so that several people in each LEA will be aware.

I.5.5. Providing Training and Technical Assistance to LEAs on Developing their

Subgrant Proposal

The time spent helping LEAs understand the expectations of the subgrant program

and the criteria for quality applications will pay off when applications reflect an

understanding of the program and provide a clear picture of what the LEA plans to do with

the funding. Moreover, training and technical assistance levels the playing field among

LEAs, some of which have grant writers available but most of which do not. The RFP packet

should include detailed instructions for how to complete the application, including forms

and checklists. In addition, the State Coordinator should be available to answer questions

from specific LEAs during the proposal writing process. Keep in mind that many SEAs have

policies regarding the type of communication that administrators of grant competitions

may conduct with applicants to ensure a fair and equitable process.


I.6. Application Review Process

A carefully planned application review process will ensure that decisions for

subgrant awards are objective and fair. Ultimately, the process should result in reviewer

consensus on the most well-conceived proposals and ones that are the most responsive to

the RFP.

I.6.1. Review your State requirements

Many States have requirements for the review process for discretionary grants, such

as requirements for the number and types of reviewers, the type of rubric or criteria, and

documentation of the review process. State Coordinators should be familiar with their

State’s policies for grant review.

I.6.2. Develop a rubric

A rubric is a scoring or rating guide that can help standardize the evaluation of

proposals. It is more than a checklist in that it provides a way to identify various levels of

quality. It is often presented in matrix form with the levels of quality described in detail. A

strong rubric will assist reviewers in determining the quality of the subgrant applications.

The rubric, provided as supporting material, will assist applicants in writing to specific

criteria.

Following are some tips on creating a rubric for subgrant proposals:

Identify the elements or criteria that will be used to evaluate the proposal. Keep

the list manageable (8-10 items) and focus on the most important qualities you

would like to see in the proposal. You may identify these from the requirements

in the law, elements that generally comprise strong grant proposals, and/or

qualities that you have identified from strong subgrant proposals received in the

past.

Assign values, either numeric or descriptive, to varying levels of proposal

quality, such as a 5-0 rating or categories such as excellent, adequate, fair, and

unacceptable.

Develop a clear description for these values for each of the proposal elements.

One strategy is to describe the characteristics of the best case and the worst


case, and then develop intermediate examples that feature the most frequent

short comings in the proposals which make these elements fall short of the ideal

or of the redeeming qualities that make an element better than the worst case.

Review proposals from an earlier subgrant cycle and divide them into best,

adequate, fair, and unacceptable groups and describe the qualities that

characterize these groups. Then use these descriptions for the values for the

rubric.

An alternative to starting from scratch is to review the scoring guide or rubric from

an earlier subgrant cycle and to revise and build on it. Or, State Coordinators may want to

adapt a scoring guide from another State’s subgrant review process.

State Coordinators should test the rubric by scoring a few grant proposals and

identifying parts that need clarification or revision.

I.6.3. Train reviewers

Each proposal should be read by at least two reviewers, preferably three. Reviewers

with a background in the McKinney-Vento program will be familiar with the intent of the

subgrants. However, a reviewer from another program who has proposal writing

experience could provide an objective perspective on the quality of the subgrant proposals.

Reviewers should receive training on the review process to become familiar with

Federal and State requirements for the subgrants and to become familiar with the rubric.

An opportunity for the reviewers to meet and review several proposals together using the

rubric will establish inter-rater reliability and decrease the likelihood of wide

discrepancies in individual scoring. This meeting will also serve as a pilot test for the rubric

so that any needed revisions can be made before it is used for all the applications.

After reviews and score sheets are submitted, the State Coordinator should convene

a meeting of reviewers to discuss proposals with divergent scores.

I.7. Award Selection

The State Coordinator should review the recommendations of the reviewers against

the amount of funds available for subgrants, and decide how to award the funds. In some

instances, the State Coordinator will fully award as many of the top scoring proposals as


the funds will allow. In other instances, the State Coordinator will spread the funds over

more LEAs by awarding a percentage of the amount requested by the LEAs recommended

for funding. In all cases, the funds awarded must be at least 75 percent of the State’s annual

McKinney-Vento allocation (unless the State is a minimum funded State in which at least 50

percent must be awarded) (42 U.S.C. § 11432(e)(1)).

The State Coordinator should develop an award letter and determine who should

receive and be copied on the letter (e.g., the local liaison, superintendent, Federal programs

coordinator, and budget office). Award letters should include:

the amount of the award for the first year of the subgrant cycle (with an

explanation of the multi-year award);

a disclaimer that the amount is contingent upon the annual McKinney-Vento

allocation provided to the State;

duration of the grant;

date of availability of the funds; and

a statement that the award is contingent upon the LEA implementing the

program as described in the proposal and meeting State requirements for

reporting and monitoring.

I.8. Subgrantee Oversight

State Coordinators should have several means to ensure that local program

coordinators serve homeless students effectively and spend funds in allowable and

strategic ways. LEAs with subgrants must comply with the requirements in the McKinney-

Vento Act and in the Uniform Guidance, as subrecipients of Federal funds. (See Section J:

Management and Oversight of Education for Homeless Children and Youth Program

Grants.) Subgrantees should maintain documentation of program activities and impact so

that it may be periodically reviewed by their State Coordinator, as in end-of-year reports

and monitoring visits.

I.8.1. Training and Technical Assistance


All LEAs should receive training and technical assistance on implementing the

McKinney-Vento Act. Subgrantees should receive additional support in implementing their

program, spending funds appropriately, and evaluating their program.

I.8.2. End-of-year Reports

Requiring an end-of-year report from each subgrantee is an effective way to desk

monitor the implementation of the program. Additionally, developing the report enables

the State Coordinator and local program coordinator to review the year’s activities against

the proposed activities and reinforces grant accountability. The report should include the

activities undertaken, barriers, successes, and evaluation data to show progress toward

attaining goals listed in the proposal. The report format should strike a balance between

including enough detail to depict the status of the program without burdening the program

coordinator to unduly detract from providing services.

I.8.3. Budget Oversight

There should be a formal process to follow in the event that a grantee wishes to

amend the subgrant budget. The process should align with SEA budgetary procedures and

require the approval of the State Coordinator. The State Coordinator should review all

budget amendment requests in light of the allowable expenses, the subgrant application,

and the LEA’s justification for why the amendment is necessary. The State Coordinator

should also review yearly expenditures in end-of-year reports and during monitoring

reviews.

I.8.4. Monitoring Subgrantees

ED expects that each subgrantee will be monitored on site during the subgrant cycle.

State Coordinators should include additional monitoring indicators for subgrantees,

particularly in the areas of program evaluation and fiscal accountability, in their LEA

monitoring protocol. For suggestions on monitoring, see Section H: State Monitoring of

Local Educational Agency Education for Homeless Children and Youth Programs.


Resources

NCHE. (2012). Educating Homeless Children and Youth: Conducting Needs Assessments and Evaluating Services - A Guide for SEAs, LEAs, and Local Schools. Retrieved July 2016. http://nche.ed.gov/nche/pr/na_eval.php

NCHE. (2015). Federal Data Summary School Years 2011-2012, 2012-2013, 2013-2014, Table 1. Number of LEAs with and without MV subgrants by State. Retrieved July 2016. https://nche.ed.gov/downloads/data-comp-1112-1314.pdf

NCHE. (2013). Homeless Liaison Toolkit: Chapter 14 Subgrants. Retrieved December 2016. https://nche.ed.gov/pr/liaison_toolkit.php

NCHE’s Resources by Topic web page on Subgrants at https://nche.ed.gov/ibt/sc_subgrants.php

Title VII-B of the McKinney-Vento Homeless Assistance Act (42 U.S.C. § 11431 et seq.), 2015. Retrieved December 2016. http://uscode.house.gov

U.S. Office of Management and Budget (2014). Uniform Guidance. Retrieved August 2016. http://www.grants.gov/web/grants/learn-grants/grant-policies/omb-uniform-guidance-2014.html

U.S. Department of Education. (2016). Education for Homeless Children and Youths Program Non-Regulatory Guidance. Retrieved July 2016. http://www2.ed.gov/policy/elsec/leg/essa/160240ehcyguidance072716.pdf



http://www.grants.gov/web/grants/learn-grants/grant-policies/omb-uniform-guidance-2014.html



https://nche.ed.gov/ibt/sc_subgrants.php


https://nche.ed.gov/downloads/data-comp-1112-1314.pdf

http://nche.ed.gov/nche/pr/na_eval.php

Section J. Management and Fiscal Oversight of Education for

Homeless Children and Youth Program Grants

Each year, the U.S. Department of Education (ED) allocates funds to each State

educational agency (SEA) on a formula basis [42 U.S.C. § 11432(c)(1)].22 SEAs must award

not less than 75 percent of their McKinney-Vento funding in subgrants to LEAs (not less

than 50 percent for minimum-funded States)[42 U.S.C. § 11432(e)(1)]. SEAs may use the

remaining funds to conduct State-level activities [42 U.S.C. § 11432(e)(2)]. State

Coordinators are the primary stewards of the State McKinney-Vento grant and therefore

must be skilled in Federal grants management and fiscal oversight.

J.1. State Fiscal Responsibilities Outlined in the McKinney-Vento Act

The McKinney-Vento Act states that SEAs may use McKinney-Vento funds for the

following:

(1) To carry out the policies set forth in section 721 in the State.

(2) To provide services and activities to improve the identification of homeless

children and youths (including preschool-aged homeless children) and enable

such children and youths to enroll in, attend, and succeed in school, including, if

appropriate, in preschool programs.

(3) To establish or designate in the State educational agency an Office of the

Coordinator for Education of Homeless Children and Youths that can sufficiently

carry out the duties described for the Office in this subtitle in accordance with

subsection (f).

(4) To prepare and carry out the State plan described in subsection (g).


J-1 State Coordinators’ Handbook: Section J. Management and Fiscal Oversight of Education for Homeless Children and Youth Program Grants

(5) To develop and implement professional development programs for liaisons

designated under subsection (g)(1)(J)(ii) and other local educational agency

personnel –

(A) to improve their identification of homeless children and youths; and

(B) to heighten the awareness of the liaisons and personnel of, and their

capacity to respond to, specific needs in the education of homeless

children and youths. [42 U.S.C. § 11432(d)].

J.1.1 Allowable Uses of Funds for State-level Activities

In developing an annual budget and determining if expenses are allowable and

appropriate, consider the following questions:

Does the expense support the responsibilities of State-level coordination and

administration outlined in law?

Does this expense cover services that apply only to the homeless education program

and are specifically connected to the educational needs of homeless children and

youth?

Does the expense align with Federal grant and State budget administrative

guidelines?

Does the expense fit within goals articulated in the State Plan and annual plan?

Does the expense address a need that was identified as a priority based on a needs

assessment?

Is the expense included, and was it approved, in the annual budget proposal

developed as part of the annual plan?

Is the expense necessary for efficient operation of the homeless education program

at the State level?

Is there reasonability in proportion of specific budget items?

Is the cost for a particular service reasonable?

Following is a list of some of the more common uses of State-level activity funds:

Salary for the State Coordinator and other homeless education staff

State or regional trainings for local liaisons


State conferences

Individualized technical assistance

State-level collaborations (e.g., advisory boards, cross-agency task forces,

collaborative initiatives)

Homeless education website

Awareness materials

Training materials

State Coordinator professional development (conference and meeting attendance)

LEA Monitoring

Conducting the McKinney-Vento subgrant process

Policy review and revision

Data collection

Other uses of State-level activity funds may include the following:

Contracted services when available time is an issue or when additional expertise is

needed

Minigrants to LEA homeless projects (e.g., identification activities in districts with

few or no homeless students identified, transportation support, local liaison

conference attendance)

Statewide needs assessment and program evaluation activities

Activities that focus on homeless preschool and/or unaccompanied youth

Regional technical assistance projects

J.2. Federal Fiscal Management Policies

The U.S. Office of Management and Budget’s (OMB) Uniform Guidance, which

consolidated existing cost circulars along with new requirements for grant management,

took effect on July 1, 2015. Because the SEA is a recipient of Federal funds, it must abide by

the Federal grants management requirements in the Uniform Guidance. Although it is likely

that the budget and financial management offices of the SEA have procedures and protocols

in place that align with the Uniform Guidance, State Coordinators should review relevant

requirements in order to


ensure that they are conforming to the requirements in managing the State’s

McKinney-Vento grant;

provide appropriate guidance and oversight to McKinney-Vento subgrantees

(subawards); and

manage any contracts that assist with carrying out State-level activities related to

the Education for Homeless Children and Youths (EHCY) program in accordance

with the Uniform Guidance.

ED maintains a Uniform Guidance portal on its website that includes links to OMB’s

resources and to resources developed by ED, including

frequently Asked Questions (FAQs);

Uniform Guidance Overview Webcast for Grantees;

information on Audit Requirements, Cost Principles, Indirect Costs, Internal

Controls, Procurement, and Risk and Subaward Management; and

crosswalks showing differences between the Uniform Guidance and the OMB

Circulars and EDGAR Parts, which it replaces.

What follows is a review of certain parts of the Uniform Guidance that directly

impact the work of State Coordinators.

J.2.1. Allowability of Costs

The Uniform Guidance includes a number of criteria for allowable costs in a Federal

grant. Among the criteria are those that specify that costs must

be necessary to the administration and performance of the grant;

be reasonable, in that it does not exceed that which would be incurred by a prudent

person under the circumstances prevailing at the time the decision was made to

incur the cost;

be allocable, that is incurred specifically for the award;

conform to any limitations specified in the award (e.g., for EHCY programs, those

specified in the McKinney-Vento Act);

be accorded consistent treatment across awards;

be determined in accordance with generally accepted accounting principles;


be allowable under Federal, State, and local laws; and

be adequately documented. [2 C.F.R. § 200.403, 2 C.F.R. § 200.405, 2 C.F.R.

§ 200.331]

J.2.2. Travel Costs

The Uniform Guidance considers travel costs to be the expenses for transportation,

lodging, subsistence, and related items incurred by employees in non-Federal entities (SEA

or LEA grantees) who are in travel status on official business. Costs incurred must be

considered reasonable and otherwise allowable only to the extent they do not exceed

charges normally allowed by the non-Federal entity in its regular operations specified in

the agency’s written travel policy. [2 C.F.R. § 200.474]

J.2.3. Food at Conferences

The Uniform Guidance states that “conference hosts/sponsors must exercise

discretion and judgment in ensuring that conference costs are appropriate, necessary and

managed in a manner that minimizes costs to the Federal award.” [2 C.F.R. § 200.432]. ED

guidance in “Frequently Asked Questions to Assist U.S. Department of Education Grantees

to Appropriately Use Federal Funds for Conferences and Meeting” further clarifies the

limited use of Federal funds for food at conferences. The ED guidance states

Generally, there is a very high burden of proof to show that paying for food and

beverages with Federal funds is necessary to meet the goals and objectives of a Federal

grant. When a grantee is hosting a meeting, the grantee should structure the agenda for

the meeting so that there is time for participants to purchase their own food, beverages,

and snacks. In addition, when planning a meeting, grantees may want to consider a

location in which participants have easy access to food and beverages.

While these determinations will be made on a case-by-case basis, and there may be

some circumstances where the cost would be permissible, it is likely that those

circumstances will be rare. Grantees, therefore, will have to make a compelling case

that the unique circumstances they have identified would justify these costs as

reasonable and necessary. (ED, 2012, p.2)


J.2.4. Record Keeping

The Uniform Guidance requires that financial records, supporting documents,

statistical records, and all other non-Federal entity records pertinent to a Federal award

must be retained for a period of three years from the date of submission of the final

expenditure report [2 C.F.R. § 200.333].

J.2.5. Closeout and Carry Over

A non-Federal entity (grantee or contractor) must submit, no later than 90 calendar

days after the end date of the period of performance, all financial, performance, and other

reports as required by the terms and conditions of the Federal award. The Federal

awarding agency or pass-through entity may approve extensions when requested by the

non-Federal entity. [2 C.F.R. § 200.343(a)].

ED’s “Questions and Answers Regarding 2 CFR Part 200” states “The new carryover

rules in the Uniform Guidance are consistent with the ED’s pre-existing regulations in

EDGAR Parts 75 and 76. So there are no substantive changes to the carryover rules for ED

grantees and subgrantees.” The Tydings Amendment [section 421(b)] of the General

Education Provisions Act (GEPA) and § 76.709 and § 76.710 of EDGAR provides education

agencies additional time to spend the Federal funds they receive. Based on the Tydings

Amendment, grantees may carry over for one additional year any Federal education funds

that were not obligated in the period for which they were appropriated. For grants that are

forward-funded, grantees can have up to 27 months to obligate appropriated funds

beginning as early as July 1 of the Federal fiscal year. Unless an extension is approved,

grantees must liquidate obligations within 90 days of the end of the funding period. (2

C.F.R. § 200.343(b)).

J.3. State-level Budgeting

State Coordinators should develop an annual action plan for State-level activities

based on statewide needs assessment and program evaluation data, responsibilities

outlined in the law, and Federal expectations detailed in monitoring indicators. (See

Section B – Charting the Course.)


In much the same way as one would develop a grant proposal, the State Coordinator

should develop annual goals, objectives, and activities in preparation for developing an

annual budget that includes expenses, staff, travel, indirect costs, etc. Each budget item

should connect to the annual action plan so that it can be justified as supporting an activity

related to the education of homeless children and youth. This approach positions the State

EHCY program well for the fiscal accountability and transparency needed for Federal

monitoring reviews as well as fiscal audits.

Recent Federal monitoring protocols require State Coordinators to provide budget

sheets that are detailed and transparent to account for how all State activity funds are

spent and how and when all subgrant funds are disbursed to LEAs. State Coordinators must

ensure that all funds are spent on activities allowed by the McKinney-Vento Act. In order to

do this, State Coordinators should submit an annual budget for State activities for approval

to the SEA administration and follow up periodically to ensure accountability.

J.4 Oversight of LEAs without Subgrants

All LEAs are required to implement the McKinney-Vento Act whether or not they

receive subgrant funds. Certain requirements in the law necessitate that LEAs provide

resources and support serving homeless children and youth. Although LEAs without

subgrants are not required to report district expenses related to the McKinney-Vento Act to

the State Coordinator, documenting time and effort and salary for the local liaison and for

expenses such as transportation or academic support is helpful for needs assessment

purposes to determine the level of need for serving homeless students in the district and

for positioning the LEA to successfully apply for a subgrant. Moreover, the LEA should

document community resources that are contributed to serve homeless students. In

trainings, you should encourage LEAs to document expenses related to homeless children

and youth. As part of LEA monitoring, you may request a review of fiscal records related to

the EHCY program, especially for the time and effort allocated to the local liaison position

since one of the SEA assurances for the State Plan is that liaisons are able to carry out

required duties. [42 U.S.C. § 11432(g)(1)(J)(ii)].


J.5. Management and Fiscal Oversight of LEAs with Subgrants

State Coordinators are responsible for overseeing McKinney-Vento subgrantees, as

they are considered subrecipients of Federal funds that pass to them through the SEA. The

Uniform Guidance focuses on both the performance and fiscal accountability of

subrecipents to ensure they use Federal funds appropriately and comply with the laws and

regulations of their program.

All grant recipients, including subrecipients (or with regard to the EHCY program,

subgrantees), must have financial management systems that include written procedures

for ensuring all expenditures conform to the terms and conditions of the grant as well as

the cost principles. Specifically, the Uniform Guidance states

Each state must expend and account for the Federal award in accordance with state laws and procedures for expending and accounting for the state's own funds. In addition, the state's and the other non-Federal entity's financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award. [2 C.F.R. § 200.302(a)].

Agencies serving as pass-through entities for Federal awards, such as SEAs, must

undertake the following responsibilities:

Implementing strong internal controls for managing subawards

Communicating with ED staff and with subrecipients

Documenting all activities

Monitoring subawards

Verifying subrecipients are audited, if required. (See, generally, 2 C.F.R. § 200,

Subpart D).

Pass-through entities must conduct a risk assessment prior to awarding funds to a

subrecipient, such as a McKinney-Vento subgrantee. The Uniform Guidance suggests items

such as the following to assess the risks in awarding funds to a subrecipient:

financial stability;

quality of management systems;


history of performance regarding management of Federal awards, the applicant's

record in managing Federal awards, if it is a prior recipient of Federal awards,

including timeliness of compliance with applicable reporting requirements;

conformance to the terms and conditions of previous Federal awards;

if applicable, the extent to which any previously awarded amounts will be expended

prior to future awards;

audit findings; and

ability to implement statutory requirements. [2 C.F.R. § 200.205(c)]

The Uniform Guidance also requires the awarding agency to monitor the

subrecipient, including the following activities:

Reviewing financial and performance reports,

Ensuring that the subrecipient takes timely and appropriate action on all

deficiencies, and

Issuing a management decision for audit findings pertaining to the award. [2 C.F.R.

§ 200.331(d)]

The State Coordinator must include these activities in the award and monitoring processes

for McKinney-Vento subgrantees. (See Section H: State Monitoring of LEA Education for

Homeless Children and Youth Programs and Section I: Subgrants.)

For more information on the requirements to manage and oversee Federal funds

that flow through as subawards, see ED’s tip sheet entitled “Key Sections of Uniform

Guidance Related to Subawards.”

J.6. Managing and Overseeing McKinney-Vento Subgrantee Expenditures

State Coordinators are responsible for ensuring that subgrantees understand what

expenses are allowable under their grant and spend their funds appropriately. (See the

discussion of Federal requirements for McKinney-Vento subgrants in Section I: McKinney-

Vento Subgrants and a list of allowable subgrant expenditures in Section 723 of the

McKinney-Vento Act in Appendix I-1.) In addition, subgrant expenditures are subject to the

requirements for administration of Federal grants and cost principles in the Uniform

Guidance.


J.6.1. Subgrantee Budget Oversight

Part of the SEA’s responsibility for McKinney-Vento subgrants includes oversight of

the budget, including approving budget amendments for individual grantees. This

oversight entails having access to the SEA’s system for expenditure reports for the

subgrants and requiring a budget sheet and/or budget narrative in the subgrantees’ end-

of-year reports. You will also need to review the budget of each subgrantee during

monitoring.

Discrepancies between proposed expenses and actual expenses must be addressed

with the subgrantee. The State Coordinator should require that the subgrantee provide an

explanation for any budget amendments so that he or she can review and approve the

amendments. This process will likely require coordination with the SEA budget office.

State Coordinators should discourage subgrantees from having significant

unobligated funds to be carried over. If a subgrantee has carryover funds, the local program

coordinator should provide an explanation in the end-of-year report and submit a plan for

how the funds will be spent in the following year. Significant carryover funds could indicate

that the LEA overestimated the need for homeless students in the LEA or has had difficulty

committing adequate time and effort to the program, potentially impacting subsequent

funding.

J.6.2. McKinney-Vento Act Requirements for LEA Subgrantee Fiscal Effort

The McKinney-Vento Act intends that services provided through subgrants to LEAs

will expand upon or improve (and not replace) services provided as part of a school’s

regular academic program. [42 U.S.C. § 11433(a)(3)]. This provision is similar to the

supplement not supplant provisions of other Federal programs, and subgrantees should

demonstrate in a fiscal review that funds are not being used for activities and services that

were formerly provided by the LEA or through other programs.

In addition, the law requires that LEAs with subgrants must maintain their

expenditures for public education from State and local funds from one year to the next. The

2016 Non-regulatory Guidance explains, “An LEA cannot reduce its own spending for public


education and replace those funds with Federal funds” (ED, 2016, p. 20). The McKinney-

Vento Act specifies that applicants must assure that

the local educational agency’s combined fiscal effort per student, or the aggregate expenditures of that agency and the State with respect to the provision of free public education by such agency for the fiscal year preceding the fiscal year for which the determination is made, was not less than 90 percent of such combined fiscal effort or aggregate expenditures for the second fiscal year for which the determination is made. [42 U.S.C. § 11433(b)(3)]

As part of the records review and monitoring processes for LEAs with subgrants, State

Coordinators must determine if the LEA has maintained the required level of effort with

regard to services for homeless students that supplemented the regular academic program.

J.6.3. Use of Funds for McKinney-Vento Subgrants

SEAs award McKinney-Vento subgrants to LEAs to provide services to ensure the

identification, enrollment, attendance, and success in school of children and youth

experiencing homelessness. The McKinney-Vento Act provides explicit information on the

purpose and uses of the funds; nevertheless, questions frequently arise as to the

appropriate use of funds. State Coordinators and local program coordinators in their

oversight of the subgrant program must determine if certain expenditures are appropriate.

When determining if a subgrant expense is appropriate, see the list of questions

provided in Appendix J-1. Guiding Questions for Use of Subgrant Funds.

J.5.3. Discussion of Categories of Expenses for McKinney-Vento Subgrant Funds

The following discussion of subgrant expenditures is meant not to serve as guidance

on what expenditures are allowable or not allowable but to illustrate a process for thinking

through what expenses should be approved. All expenditures should be considered in

reference to the Guiding Questions listed in Appendix J-1.

Supplies and Fees for Homeless Children and Youth. In general, subgrant funds can be

used to purchase supplies to enable homeless children and youth to participate fully in

school activities. These supplies would include school supplies, clothing, backpacks, and

calculators. However, before spending subgrant funds, the program coordinator should

ensure that these supplies (1) are not already provided by the LEA to needy students and


therefore should be provided to homeless students as comparable services; (2) are not

available through other sources, such as business partners or service agencies; and (3)

reflect coordination with Title I for using the Title I homeless set aside.

Academic Services/School Activities. Subgrant funds may be used to pay fees for field

trips, summer programs, and before- and after-school programs that have an educational

purpose or component overseen by qualified staff. Daycare or after-school care would not

be an appropriate use of funds, unless there is an educational component, such as tutoring,

homework help, or educational enrichment overseen by a professional educator. The

program coordinator should look at comparable services – does the LEA support other

students who cannot afford to participate in these activities? Or is there a Title I after-

school program already available in which the student may participate?

Health Services. Homeless education programs should make referrals for counseling,

medical, and dental services. The intent of the subgrant program is not to provide ongoing

medical and dental services, but to initiate collaborations for medical services and identify

resources for referrals. However, subgrant funds can cover times when a homeless child

needs medical or dental care in an emergency when other resources are not available. Also,

the Title I, Part A reservation of funds for homeless students may be used for counseling

services and health services. Local homeless liaisons should coordinate with the Title I

program to cover these types of costs.

Transportation. LEAs are required to provide transportation to and from the school

of origin when attending the school of origin is in the best interest of the student. [42 U.S.C.

§ 11432(g)(1)(J)(iii)]. LEAs are also required to provide homeless students transportation

services that are comparable to those for housed students. [42 U.S.C. § 11432(g)(4)(A)].

Subgrant funds may cover the “excess cost of transportation” for homeless students.

[42 U.S.C. § 11433(d)(5)]. Many school districts use some of their subgrant funds to

supplement the cost of transporting homeless students when they have a large number of

homeless students needing transportation to and from the school of origin, have a wide

geographical area to cover, or need to provide specialized transportation services for

educational activities that go beyond the comparable services the LEA provides to all


students. These circumstances are what the law intended as an allowable use of a portion

of subgrant funds for transportation.

Subgrant funds should be viewed in the context of the total McKinney-Vento

subgrant proposal for meeting the broad range of need of homeless students, not just used

for transportation. Fundable transportation strategies may include reimbursing parents for

mileage, providing gas cards, and arranging taxicabs when no other affordable options are

available.

Emergency Services. Emergency services are those that will alleviate a crisis that

would prevent a homeless student from attending school and participating fully in school

activities. These services usually require short-term expenses to resolve a crisis or to

provide an interim service until a more permanent solution is attained. For example,

subgrant funds could be used to obtain a birth certificate or temporarily pay for child care

for a homeless teen parent to attend school until other arrangements are made.

Funds may not be used to pay hotel, motel, or utility bills for a student or his or her

family because these expenses are outside of the scope of the purpose of the grant to

support the educational needs of homeless students. Community collaborations should be

in place for referrals to cover basic needs of families.

Salaries and Program Administration. All LEAs are required to designate a local

liaison. However, if the need for serving homeless students is greater than what the LEA

provides in its responsibility to implement the McKinney-Vento Act, then subgrant funds

can support the expansion of the duties of the local liaison, and include other staff, if

necessary, to carry out the authorized activities and facilitate the efficient administration of

the subgrant program. Staffing included in the subgrant must be incorporated in the overall

program plan to ensure that identified priorities and needs are met. Moreover, any funds

provided for salaries must support duties to serve only homeless students and relate to the

allowable activities.

Training. Professional development is one of the authorized activities for subgrants.

Professional development may include training that the program provides to the LEA or

community or training that McKinney-Vento program staff attends. Professional


development or training activities should be justified in the subgrant proposal as they

relate to stated needs, program goals, and the overall budget for the program.

Resources


Student Succeeds Act, 42 U.S.C. § 11431 et seq., 2015. Retrieved from


Uniform Guidance, 2 C.F.R. § 200, 2014. Retrieved from http://www.ecfr.gov/cgi-bin/text-

idx?SID=6214841a79953f26c5c230d72d6b70a1&tpl=/ecfrbrowse/

Title02/2cfr200_main_02.tpl

U.S. Department of Education. (2016). Education for Homeless Children and Youths Program



U.S. Department of Education. (2012). “Use of Federal Grant Funds for Conferences and

Meetings —CFO Memo to Grantees.” Retrieved from

http://www2.ed.gov/policy/fund/guid/gposbul/gposbul.html

U.S. Department of Education. (n.d.) “Key Sections of Uniform Guidance Related to

Subawards.” Retrieved from http://www2.ed.gov/policy/fund/guid/uniform-

guidance/risk-subaward-management.html

U.S. Department of Education. (2015). “Questions and Answers Regarding 2 CFR Part 200.”

Retrieved from

https://www2.ed.gov/policy/fund/guid/uniform-guidance/faq62515.pdf

U.S. Department of Education Website Uniform Guidance Portal at

http://www2.ed.gov/policy/fund/guid/uniform-guidance/index.html

U.S. Office of Management and Budget. (2014). Uniform Guidance. Retrieved from

http://www.grants.gov/web/grants/learn-grants/grant-policies/omb-uniform-

guidance-2014.html




http://www2.ed.gov/policy/fund/guid/uniform-guidance/index.html

https://www2.ed.gov/policy/fund/guid/uniform-guidance/faq62515.pdf



http://www2.ed.gov/policy/fund/guid/gposbul/gposbul.html


http://www.ecfr.gov/cgi-bin/text-idx?SID=6214841a79953f26c5c230d72d6b70a1&tpl=/ecfrbrowse/Title02/2cfr200_main_02.tpl




Section K. Preparing for Federal Monitoring of the State

Education for Homeless Children and Youth Program

In a 2014 report, the Government Accountability Office (GAO) stated that

“monitoring is a key management tool for assessing the quality of performance over time

and resolving problems promptly.” However, the report continued, “[The U.S. Department

of] Education has protocols for monitoring State Education for Homeless Children and

Youths programs, but no plan to ensure adequate oversight for all states.”23 The U.S.

Department of Education (ED) has monitored every State Education for Homeless Children

and Youth (EHCY) program at least twice since 2003. The GAO report’s emphasis on

Federal program accountability and compliance, the availability of State educational agency

(SEA) and local educational agency (LEA) data, and increased expectations for SEAs in the

2015 reauthorization of the McKinney-Vento Act have resulted in ED reviewing its

monitoring processes and protocols to develop a system of State EHCY program monitoring

that is effective in assessing State EHCY compliance and efficient in making best use of staff

time, data, and technology to ensure that every State is monitored on a regular basis.

According to the Federal coordinator for the EHCY program, every State must be prepared

for Federal monitoring to take place at least every five years.

Immediate preparation for Federal monitoring entails providing records and

documents for review and answering questions in a set of interviews. However, true

preparation for monitoring is more a matter of ensuring ongoing compliance with the

McKinney-Vento Act at both the SEA and LEA levels.

State EHCY programs that work to ensure compliance with the McKinney-Vento Act,

or even go beyond compliance to ensure that the State and LEAs carry out the intent of the


K-1 State Coordinators’ Handbook: Section K. Preparing for Federal Monitoring of the State Education for Homeless Children and Youth Program

law, generally have very few findings or recommendations for improvement. In addition,

these States often welcome a review as an opportunity to showcase good practices and to

identify areas for needed technical assistance. Federal monitoring often raises the profile of

the State EHCY program in the SEA, resulting in greater support and resources for

implementation.

K.1. The Process of Federal Monitoring of State EHCY Programs

Each year, the Federal coordinator for the EHCY program determines a monitoring

schedule for States and makes this information public several months in advance of

monitoring. Approximately two months before the scheduled monitoring, the Federal

coordinator will send a letter to the State Coordinator, SEA Federal programs coordinator,

and State superintendent with an overview of the monitoring process and expectations for

the SEA. These expectations will include a list of records and documents that the State

Coordinator must upload to the National Center for Homeless Education’s (NCHE’s)

extranet by a specified deadline.

The Federal coordinator or other staff or contractors assigned monitoring tasks will

review all documents and develop clarifying questions to add to the questions in the

monitoring protocol.

The Federal coordinator will schedule a set of interviews that includes the State

Coordinator and other SEA and LEA administrators, and in some cases, community service

providers or other stakeholders. These interviews may be on site, in which case, the

coordinator may request one or two site visits to LEAs of his or her choosing (usually in

consultation with the State Coordinator). Remote interviews are conducted via video

conferencing or conference call arranged by the Federal program office.

Following the monitoring activities, the Federal EHCY office issues a report to the

SEA that includes findings, recommendations, and commendations, and requests a

response by a certain deadline. If the State had significant findings of noncompliance, the

Federal coordinator will request that the State Coordinator contact NCHE to arrange

technical assistance.


For assistance in preparing for a monitoring review, see Appendix K-1. Tips for

Preparing for EHCY Monitoring.

K.2. Monitoring Indicators

Periodically, the Federal coordinator, with input from Federal staff and SEA and LEA

EHCY program administrators, will develop or revise a monitoring protocol that includes

eight to ten indicators for areas of inquiry and reflects State EHCY requirements in the

McKinney-Vento Act and other ED priorities. The protocol may change from year to year as

the EHCY program evolves. The Federal coordinator will make the protocol publicly

available, which can serve as a framework for SEA compliance and the State Coordinator’s

annual action plan.

Specifically, the monitoring indicators derive from the parts of the McKinney-Vento

Act that include the functions of the Office of Coordinator [42 U.S.C. § 11432(f)],

requirements and assurances in the State Plan [42 U.S.C. § 11432(g)(1)], LEA requirements

[42 U.S.C. § 11432(g)(3)], and duties of the local liaison [42 U.S.C. § 11432(g)(6)].(You may

review these sections of the law in Section B: Charting the Course and Section F: Technical

Assistance for Local Educational Agencies in the Handbook.)

In addition, the protocol will include questions to determine fiscal management of

the State EHCY grant and coordination with Title I and other Federal programs. Some

questions will pertain to ED’s general administrative regulations and the U.S. Office of

Management and Budget’s cost circulars, now consolidated in the Uniform Guidance.

Questions in past protocols have included a review of the State’s McKinney-Vento dispute

resolution process along with the number and types of disputes that the State EHCY

program has encountered.

ED also may include some indicators in its monitoring protocol that go beyond

compliance but ensure that States are carrying out practices that align with the intent of

the law to create a strong State EHCY program and remove educational barriers for

homeless children and youth. For example, additional priorities, not directly specified in

the law, come from the Leading Indicators of Quality McKinney-Vento programs that ED

developed in 2014:


1. The percentage of homeless students who are chronically absent during the school

year, by State and LEA. (The protocol may require that SEAs demonstrate that they

are reviewing data on the number of homeless students who are chronically

absent and addressing how to reduce this number.)

2. The percentage of States monitored by ED in a fiscal year that used LEA-level data

for a risk assessment to target monitoring and technical assistance in that year.

(The protocol may require SEAs to demonstrate that they are utilizing LEA-level

data to ensure that their monitoring and technical assistance focuses on LEAs at

most risk of non-compliance.)

3. The number of States that have updated annual work plans based on data from a

needs assessment and the establishment of measurable goals that address

identified needs. (The protocol may require State Coordinators to demonstrate

that they use data to assess needs and establish annual goals in the development

of an annual work plan.)

Items such as these included in the monitoring protocol will result in recommendations for

States, rather than findings, since they are not requirements stated in the law.

ED will also review the quality of the data that the LEAs and SEAs submit to EDFacts

for the annual Consolidated State Performance Report and may include monitoring

questions related to the State’s data quality for homeless children and youth.

The monitoring protocol will always include indicators that reflect compliance with

specific provisions of the McKinney-Vento Act but will also remain fluid as it is updated to

reflect new ED priorities and emerging issues. ED will communicate these changing

priorities to State Coordinators as they develop, and NCHE will provide technical assistance

to enable SEAs to address these in their State and local EHCY programs.

K.3 Determining the Likelihood that Your State will be Selected for EHCY Program

Monitoring: Federal Risk Assessment

ED utilizes a risk assessment approach to identify which States to prioritize for

monitoring each year. While all States will undergo monitoring, States that have the


highest risk factors for noncompliance will be scheduled before those with fewer risk

factors. Risk factors may include

the frequency with which a State experiences turnover in the State Coordinator

position,

the time since the last State review,

the amount of funds that a State allows to revert to the Federal government due to a

failure to spend them in a timely manner,

the number of LEAs that identify fewer than ten homeless students,

data quality problems in annual submissions to EDFacts,

the performance of homeless students on statewide assessments, and

the number of findings identified during the last review or the number of findings

left unaddressed between reviews that lead to repeated findings in a particular area.

ED will include other risk factors as new issues emerge, and the Federal program officer

will inform State Coordinators of these through routine communications and updates.

These risk factors are useful for State Coordinators to assess not only the likelihood

of being monitored but also to consider for State planning to strengthen their EHCY

program. Furthermore, State Coordinators may wish to mirror this risk assessment in

monitoring LEAs.

K.4. Conducting Your State EHCY Program as if Your State Could be Monitored

Tomorrow

As mentioned earlier, the best way to sail through a Federal monitoring review is to

maintain full compliance with the McKinney-Vento Act on a day-to-day basis. State

Coordinators should conduct ongoing needs assessment to identify areas of challenge to

ensure they are carrying out all the functions of the State Office of the Coordinator

and implementing all provisions of the law;

review and revise policies that conflict with the McKinney-Vento Act;

provide the technical assistance, training, and monitoring needed for strong local

EHCY programs; and

build an infrastructure for ongoing improvement of the EHCY program.


Most noncompliance results from problems that have existed for a long time and

cannot be resolved between the time a State is notified of a monitoring review and when

that review takes place. Therefore, it only makes sense for States to devote time, effort, and

resources on an ongoing basis to build a strong EHCY program, rather than respond to

monitoring findings under crisis circumstances.

This argument should be shared with SEA higher level administrators in the event

that the State Coordinator’s position in your State is under-staffed and under-resourced

(which in itself poses a compliance problem). On the issue of State Coordinator capacity,

the law notes that State grants shall be used for several activities, one of them being “to

establish or designate in the State educational agency an Office of the Coordinator for

Education of Homeless Children and Youths that can sufficiently carry out the duties

described for the Office in this subtitle in accordance with subsection (f)” [emphasis added]

[42 U.S.C. § 11432(d)(3)].

K.5 What to Have in Place to Anticipate a Smooth Federal Monitoring Review

In addition to an EHCY program that operates in compliance with the law, a State

that is in a good position for developing a strong EHCY program that could undergo a

monitoring review with the least amount of anxiety should have the following in place:

EHCY records and documents from the past three years, as required by the Uniform

Guidance [2 C.F.R. § 200.333], organized and stored for easy access;

a system to support, train, and monitor all LEAs;

a system for quality data collection from all LEAs;

detailed and transparent fiscal management of the EHCY program, both at the SEA

level and for subgrantees;

support from the State superintendent, State board of education, and other high-

level SEA and State administrators; and

coordination among Federal program administrators, and especially the Title I

coordinator, who have an in-depth knowledge of the McKinney-Vento Act.

K.6 How to Follow Up after the Monitoring Report is Issued


The report ED issues after an EHCY monitoring review serves not only as a record of

the State’s compliance with the McKinney-Vento Act, but also as an important planning

tool. It is critical to conduct a debrief of the monitoring review that includes State-level

administrators to determine what actions must be taken in the immediate future to comply

with any after-action directives from ED. This debrief also offers an opportunity to improve

the State’s EHCY program in the long term. States should request technical assistance from

NCHE as needed to address specific findings and recommendations in the report.

In addition, the State Coordinator should utilize the report in the development of the

annual action plan to specifically address items featured in the report. Support from high-

level administrators will ensure that the State Coordinator and the EHCY program have the

resources and capacity needed to strengthen the program.

Resources

Government Accountability Office. (2014). Education of homeless students: Improved program oversight needed. GAO-14-465. Retrieved from http://www.gao.gov/assets/670/665185.pdf


U.S. Office of Management and Budget. (2014). Uniform Guidance. Retrieved from http://www.grants.gov/web/grants/learn-grants/grant-policies/omb-uniform-guidance-2014.html





http://www.gao.gov/assets/670/665185.pdf

Section L: Building Capacity to Support Native American

Children and Youth Experiencing Homelessness

Introduction/Purpose

The purpose of this document is to build the capacity of State educational agencies

(SEAs) and local educational agencies (LEAs) to provide effective services for Native

American children in homeless situations. The information provided here is intended to

guide State Coordinators in assisting Native American families, children, and youth who are

experiencing homelessness. The optimal outcome is for readers to conduct a data driven

needs assessment and to develop a plan to identify key partners who can assist with

building collaborative networks to improve educational services for Native American

students experiencing homelessness in their respective States.

To produce a “guide” or “handbook” that honors the integrity of each culture is

challenging because of the great diversity among various Native American Tribal

communities; for that reason, this document includes a needs assessment tool, with a

series of questions that is designed to lead State Coordinators to explore the demographics,

resources, existing partnerships, and opportunities for enhanced collaboration that are

unique to their respective States. It is impossible to adequately discuss the variety of Native

American cultural practices in this document, but it is important to understand each

culture’s specific practices regarding caring for children. It is not uncommon, and it is

culturally appropriate for children to be taken in by family members, relatives, or Tribal

members who may share the duties of raising children. When explaining the education

provisions of the McKinney-Vento Homeless Assistance Act (McKinney-Vento Act), and in

particular the need to identify and assist unaccompanied homeless youth, care must be

taken to clarify that the federal designation does not discredit the care being given to the

child by the family or community. It is also important for caregivers to understand that the

definition of homelessness24 is not limited to situations in which a student has no housing

24 See the statutory definition at http://uscode.house.gov/view.xhtml?path=/prelim@title42/chapter119/subchapter6/partB&edition=prelim, Section 11434a or explained in our technical assistance at https://nche.ed.gov/ibt/sc_eligibility.php

L-1 State Coordinators’ Handbook: Section L. Building Capacity to Support Native American Children and Youth Experiencing Homelessness

http://uscode.house.gov/view.xhtml?path=/prelim@title42/chapter119/subchapter6/partB&edition=prelim

http://uscode.house.gov/view.xhtml?path=/prelim@title42/chapter119/subchapter6/partB&edition=prelim

at all. Instead, the definition includes a broad range of situations, including temporary,

unstable, and substandard housing situations, which may not fit into a caregiver’s cultural

understanding of “homelessness.”

In addition to the Needs Assessment for McKinney-Vento Services to American

Indian and Alaskan Native Students in the Appendix, this document features information

on past and current efforts to address the many challenges related to the education of

Native American students. These efforts include a series of federal initiatives as well as

information about State specific efforts to address the educational needs of Native

American students, including State laws, grant projects, and various collaborative efforts by

States or communities that have formed coalitions on behalf of Native American children

and youth. Links to examples of already established, successful initiatives are provided.

Finally, this document features a selection of links to national, State, and local

resources. While not exhaustive, these lists do represent, in general, the types of

organizations, projects, or resources that can be explored by State Coordinators seeking to

learn of existing partnerships and collaborative opportunities to address the educational

stability of Native American students experiencing homelessness. It must be noted that

while the topic of homelessness in general may be included in discussions among these

collaborative groups, the McKinney-Vento Act may not always be specifically addressed in

these discussions. State Coordinators are urged to look for opportunities to bring

McKinney-Vento into the dialogue as new partnerships or collaborative efforts are

explored.

Please note: the terms American Indian, American Indian/Alaska Native, Indian and

Native American will be used interchangeably throughout this document.

Some Notes on Context

State Coordinators are urged to consider the following points as they seek strategies

to improve services for highly mobile Native American children:

The Elementary and Secondary Education Act of 1965 (ESEA) requires that schools

where Native American students are 50% or more of the total enrollment, or who


receive $40,000 or more in Title VI funds, engage in consultation with local Tribes

prior to submitting a plan or application for a covered program.

Almost 90% of American Indian and Alaska Native students, approximately

644,000, are educated in public school systems.

The Bureau of Indian Education (BIE) serves as the principal government agency in

upholding the United States’ educational obligations to Indian Tribes and their

eligible Indian students. As stated in Title 25 CFR Part 32.3, BIE’s mission is to

provide quality education opportunities from early childhood through life in

accordance with a Tribe’s needs for cultural and economic wellbeing, in keeping

with the wide diversity of Indian Tribes and Alaska Native villages as distinct

cultural and sovereign governmental entities.

Currently, the BIE oversees a total of 183 elementary, secondary, residential and

peripheral dormitories across 23 states. The 183 BIE–funded schools vary

considerably by size, Tribal culture, and a multitude of other socioeconomic and

geographic factors. 130 schools are Tribally controlled under P.L. 93-638 Indian Self

Determination Contracts or P.L. 100-297 Tribally Controlled Grant Schools Act. 53

schools are directly operated by the BIE. The BIE also oversees two postsecondary

schools: Haskell Indian Nations University and Southwestern Indian Polytechnic

Institute. For more information on BIE schools in your State, visit

https://www.bie.edu/index.htm

States in which Native American students comprise the largest proportions of the

total student populations include Alaska (27%), Oklahoma (19%), South Dakota

(12%), Montana (11%), New Mexico (11%), and North Dakota (11%). Visit

www.ncai.org/policy-issues/education-health-human-services/education for

additional information.

Under section 8538 of the ESEA, LEAs serving Native student populations of not less

than 50% of the total student enrollment, or who receive more than $40,000 in

funding under Title VI must have timely and meaningful consultation with Tribes

and Tribal organizations on issues affecting American Indian and Alaska Native

Students prior to submitting a plan or application for a covered program. These


http://www.ncai.org/policy-issues/education-health-human-services/education

LEAs must maintain in their records and provide to their SEA a written affirmation

signed by the appropriate officials of the participating Tribes that the required

consultation occurred. As a best practice, LEAs serving Native students should

consult with the Tribe or Tribes which students identify with. It is important to

recognize that a student need not be formally enrolled in a Tribe to identify with

and belong to the culture of a particular Tribe. Criteria for enrollment vary from

Tribe to Tribe based on blood quantum or a number of generations of descent.

There are 576 federally-recognized Native American Tribes in the United States;

each Tribe has its own unique set of customs, values, traditions, and culture and

may be affiliated with an indigenous language family Additional information is

available at http://www.ncsl.org/research/state-Tribal-institute/list-of-federal-

and-state-recognized-tribes.aspx.

The relationship between federally recognized Tribes and the United States is one

between sovereigns, i.e., between a government and a government. This

“government-to-government” principle, which is grounded in the United States

Constitution, has helped to shape the long history of relations between the federal

government and these Tribal nations. To understand more about Tribal sovereignty,

please visit https://www.bia.gov/frequently-asked-questions.

Given the significant diversity among the Indian Tribes, State Coordinators are

encouraged to become familiar with the uniqueness of the Tribal communities in

their State.

Information and resources related to Tribal training and mental health technical

assistance are available at https://www.samhsa.gov/Tribal-ttac.

Other examples include:

This resource defines and explains the onset and ongoing effects of historical

trauma: https://extension.umn.edu/mental-health/historical-trauma-and-cultural-

healing

There are substantial gaps in our knowledge about Native American student

achievement compared to our knowledge of the achievement of other racial/ethnic

groups. Data collection efforts often are compromised by the small sample size of


https://extension.umn.edu/mental-health/historical-trauma-and-cultural-healing

https://extension.umn.edu/mental-health/historical-trauma-and-cultural-healing

https://www.samhsa.gov/tribal-ttac

https://www.bia.gov/frequently-asked-questions

http://www.ncsl.org/research/state-tribal-institute/list-of-federal-and-state-recognized-tribes.aspx

http://www.ncsl.org/research/state-tribal-institute/list-of-federal-and-state-recognized-tribes.aspx

Native American students in many school settings.

https://edtrust.org/resource/the-state-of-education-for-native-students/

The NAEP – NIES 2015 data summaries are available for review at

https://nces.ed.gov/nationsreportcard/nies/; it is noted that only fourteen States

had samples of American Indian/Alaska Native students large enough to report

results separately at the State level.

There is wide variance among States in the collection data specific to Native

American students. State Coordinators are encouraged to work with SEA data

specialists to determine availability of data for these students.

Federal and State Partners in Indian Education

Native American Tribes are deeply invested in improving education. Many believe

that strengthening Tribal control over education is key to the success of Native American

students. Tribal involvement is increasing in the operation of BIE schools, and BIE’s federal

employees are encouraged to work with Tribal school boards selected from the Native

American communities where schools are located.

Tribal Educational Agencies (TEAs), sometimes referred to as Tribal Education

Departments (TEDs), or Education Divisions, are increasing in number and are addressing

issues in Native American education. TEAs are responsible for many of the functions for

which an SEA would be responsible, including the establishment of educational policies and

regulations, collection and analysis of education data, and other functions related to

curriculum and assessment of progress for Native American students. They are currently

serving thousands of Tribal students nationwide in BIE, Tribal, and public schools, and are

increasing their efforts to strengthen the education provided to their Tribal communities

and students by partnering with federal and State governments. Congress has authorized

funding for TEAs under the Bureau of Indian Affairs (BIA) of the U.S. Department of the

Interior. It should be noted that a current grant initiative administered by the U.S.

Department of Education, the State Tribal Education Partnership (STEP), is a grant fund to

increase collaboration between the SEA, LEA and TEA. The purposes of the STEP grant are

to: (1) Promote increased collaboration between TEAs and the SEAs and LEAs that serve


https://nces.ed.gov/nationsreportcard/nies/

https://edtrust.org/resource/the-state-of-education-for-native-students/

students from affected Tribes; and (2) build the capacity of TEAs to conduct certain

administrative functions under certain ESEA formula grant programs for eligible schools,

as determined by the TEA, SEA, and LEA. Additional information is available at

http://www2.ed.gov/programs/step/index.html.

The U.S. Department of Education is committed to strengthening educational

services in Native American communities. The Office of Indian Education (OIE), housed

within the Office of Elementary and Secondary Education (OESE), states that its mission is:

to support the efforts of local educational agencies, Indian Tribes and organizations,

postsecondary institutions, and other entities to meet the unique educational and culturally

related academic needs of American Indians and Alaska Natives so that these students can

achieve to the same challenging State standards as all students.

Title VI of the ESEA authorizes the Indian, Native Hawaiian, and Alaska Native

Education Programs (Parts A-C, respectively). Furthermore, Title VII of the ESEA, the

Impact Aid program, authorizes direct payments to public school districts to offset the loss

of traditional property taxes due to the presence of federal activity, including the presence

of federally recognized native lands. Since public schools cannot draw tax revenue from

Native American land or sales made on Native American land, many of the Native

American-impacted school districts are highly dependent on these Federal education

resources to operate.

OIE grant initiatives include the Indian Education Formula Grants, Demonstration

Grants for Indian Children, Indian Professional Development Grants, Native American

Language Program, and the State Tribal Education Partnership (STEP). Information about

current competitions and past awards can be accessed on the OIE/OESE webpage:

https://www2.ed.gov/about/offices/list/oese/oie/index.html. It should be noted that 26

States have an SEA contact person designated for the State for Indian Education. These

contacts have primary oversight over Indian Education programs in their respective State.

The Office of Indian Education maintains an updated list of these contacts at

https://www2.ed.gov/about/offices/list/oese/oie/statecontacts.html.

In addition, the White House Initiative on American Indian and Alaska Native

Education (WHIAIANE) leads Executive Order 13592, Improving American Indian and


https://www2.ed.gov/about/offices/list/oese/oie/statecontacts.html

https://www2.ed.gov/about/offices/list/oese/oie/index.html

http://www2.ed.gov/programs/step/index.html

Alaska Native Educational Opportunities and Strengthening Tribal Colleges and

Universities. WHIAIANE Implements ED’s Tribal Consultation Policy which lays out ED’s

commitment to consult with Tribal leaders and representatives. WHIAIANE’s executive

director serves as the Tribal Consultation Official for a Department of Education and is

responsible for assuring the Department fulfills its trust responsibility. At times, the U.S.

Department of the Interior and the U.S. Department of Education have jointly participated

in Tribal Consultations.

Originally established as the White House Initiative on Tribal Colleges and

Universities (TCUs), in 1996 and continued through the George W. Bush Administration

and was expanded in 2011 to include to all Native American students. The United States

has a unique political and legal relationship with the federally recognized Native American

Tribes, as set forth in the Constitution of the United States, treaties, Executive Orders (EOs),

and court decisions. For centuries, the Federal Government’s relationship with these Tribes

has been guided by a trust responsibility – a long-standing commitment of our Government

to protect the unique rights and help ensure the well-being of Tribes, while respecting their

Tribal sovereignty.

Legislation Enacted to Address Native American Education

Over a period of years, the U.S. Congress has enacted federal legislation addressing

the education of Native American students. Landmark federal legislation and Executive

Orders addressing the civil rights and education of Native American students are listed in

the following chart:

Year Legislation Enacted or Latest Authorization

2011 President’s Executive Order on Improving American Indian and Alaska Native

Education Opportunities and Strengthening Tribal Colleges and Universities

(TCUs), Executive Order 13592

2004 President’s Executive Order on American Indian and Alaska Native Education,

No. 13336


https://www.gpo.gov/fdsys/pkg/WCPD-2004-05-03/pdf/WCPD-2004-05-03-Pg713.pdf


https://www.gpo.gov/fdsys/granule/CFR-2012-title3-vol1/CFR-2012-title3-vol1-eo13592



2000 President’s Executive Order on Indian Education

1996 Native American Educational Assistance (Amends Indian Self-Determination

and Education Assistance Act)

1996 Executive Order 13021—Tribal Colleges and Universities

October 19, 1996

1994 Indian Education Assistance Act

1992 Native American Languages Act

1988 Indian Education Act

1988 Indian Self-Determination and Education Assistance Act

1988 Tribally Controlled Schools Act

1978 National Indian Child Welfare Act

1965 Head Start Act

1958

1957

1924

Johnson O’Malley Act

Civil Rights Act of 1957 (guaranteed the right to vote to American Indians)

Indian Citizenship Act (granted citizenship to American Indians)

In addition to federal activity, many States have also enacted legislation to further

address Indian Education issues. A source of State-specific information is available from the

Native American Rights Fund’s publication, which has compiled Tribal, federal, and State

laws related to Tribal education, available at http://www.narf.org/wordpress/wp-

content/uploads/2015/01/blue.pdf.

Some noteworthy examples of State specific legislation include: Montana’s Indian

Education for All Act, requiring that all of Montana’s children learn the histories and

cultures of the 12 Tribes and seven reservations across the State; South Dakota’s Indian

Education Act, establishing the Montana Office of Indian Education, the Indian Education

Advisory Council, and the American Indian Language Revitalization Program; and New


http://www.narf.org/wordpress/wp-content/uploads/2015/01/blue.pdf


https://www.archives.gov/historical-docs/todays-doc/?dod-date=602

https://www.govtrack.us/congress/votes/85-1957/s75

https://www.congress.gov/bill/114th-congress/house-bill/4390/text

https://www.congress.gov/congressional-report/108th-congress/senate-report/208/1?overview=closed

https://www.govtrack.us/congress/bills/95/s1214/text

http://uscode.house.gov/view.xhtml?path=/prelim@title25/chapter27&edition=prelim

https://www.congress.gov/bill/100th-congress/house-bill/1223

https://www.gpo.gov/fdsys/pkg/STATUTE-102/pdf/STATUTE-102-Pg1603.pdf

https://www.congress.gov/congressional-report/106th-congress/senate-report/467/1

https://www.congress.gov/bill/103rd-congress/house-bill/4842/text





https://www.federalregister.gov/documents/2000/11/09/00-29003/consultation-and-coordination-with-indian-tribal-governments

Mexico’s Indian Education Act, ensuring equitable and culturally relevant learning

environments, maintenance of native languages, collaboration with other States and

entities, and establishing an Indian Education Advisory Council. State Coordinators are

encouraged to look for examples of interagency collaboration, especially in States with

significant numbers of Native American students, and work toward ensuring that the

McKinney-Vento Act is part of the conversation.

Other significant State, regional, and/or local initiatives are worthy of note. While

not necessarily required by law, groups have collaborated to engage in dialogue targeting

improving educational opportunities for Native American students, in some cases securing

grant or similar funding to implement programs to strengthen education for this student

population.

A noteworthy example of such a coalition is the Wyoming Tribal Children’s Triad, a

partnership composed of over two dozen entities, including Tribal governments and

programs, community organizations working with families and children, and schools and

education-related associations. Launched in 2009 through the cooperation of the Wyoming

Department of Education and the Arapaho and Shoshone Tribal Councils, the Triad

Partnership seeks to improve school enrollment, attendance, and achievement rates among

Tribal children, thus helping them to succeed in school and life. More information is

available at https://edu.wyoming.gov/in-the-classroom/native-american/Tribal-triad/.

State Coordinators are encouraged to look for similar examples of interagency

collaboration, especially in States with significant numbers of Native American students,

and work toward ensuring that the McKinney-Vento Act is part of the conversation.

Recommendations for Moving the Dialogue Forward

The information and needs assessment questions in this document are offered to

guide the State Coordinator in handling the unique challenges of providing effective

educational services to Native American students who are experiencing homelessness. The

reader is urged to think critically about how and where to obtain the most accurate

information available about the status of education for Native American students and how

to build a strong collaborative network representing all stakeholders with interest in


https://edu.wyoming.gov/in-the-classroom/native-american/tribal-triad/

improving educational opportunity for this often-underserved student population. In

summary, some suggested next steps might include:

Make connections with your SEA Indian Education Coordinator and other key

stakeholders at the State level to become familiar with the unique circumstances

and needs of Native American children experiencing homelessness; determine

what resources are available to these children and their families and how to

refer families to needed resources.

Create a task force comprised of SEA, LEA, and Native American service agencies

to address the needs of Native American children and youth; increase everyone’s

awareness of educational challenges that are faced by Native American children

and youth experiencing homelessness.

Invite Native American educators, administrators, Tribal leaders, and service

providers to participate in McKinney-Vento trainings; provide trainings that will

benefit SEAs and LEAs in addressing the needs of Native American children

experiencing homelessness.

Consider ways to plan joint trainings in which agenda and content are shared

among SEA, LEA, and Tribal representatives for purposes of deeper

understanding of respective issues and concerns.

Request meetings with your SEA data specialist to determine the adequacy of

data collection specific to Native American students; brainstorm additional data

elements that might be collected relative to homelessness for this student group.

Establish regular contact with another State Coordinator whose State

demographics are similar to yours for purposes of sharing ideas and promising

practices in addressing these challenges.

Set aside some time to explore the websites listed in the following section to

learn more about resources that might be available to Native American students

in your State.

The provision of culturally responsive and effective services for Native American children

and youth, and for Native American children and youth experiencing homelessness, is

critical to their educational success. We hope that this document assists you in developing a


plan to engage with and support Tribal communities in your State. For additional

information on supporting Native American students experiencing homelessness, please

contact the National Center for Homeless Education (NCHE) at www.nche.ed.gov.


Section M. When Disaster Strikes: What State Coordinators

Need to Know and Do

The Challenges

When a natural or manmade disaster strikes a community, the profound impact on

all of its citizens can be overwhelming and can create an urgent need for a variety of

comprehensive support systems. When a Federally-declared disaster occurs, it is

important to know which closed schools were in disaster-declared areas, and whether

displaced and homeless students were residing in declared areas when the disaster

occurred. Relief agencies are typically focused on providing emergency assistance,

including food, clothing, shelter, and safety. However, in the wake of a disaster, relief

agencies do not always recognize the benefits of the school setting for children of displaced

families as a top priority. The safety and stability of the school setting may provide a calming

environment for these students, assisting them in moving forward after experiencing the trauma of

a disaster.

Unfortunately, the challenges that schools face in their efforts to provide the much-

needed safety and stability are numerous, often driven by circumstances outside of the

control of school district personnel to address or alleviate. While Federal relief funding can

at times be made available to states and local educational agencies (LEAs), there may be

LEAs receiving large numbers of displaced students due to disaster who may not have the

capacity to identify, enroll, and serve McKinney-Vento eligible students. Physical damage to

infrastructures may have destroyed internal technology capacity to access needed student

data. School transportation departments may be unprepared for large numbers of

displaced children and youth. Families already identified as homeless may have moved to

temporary housing outside of the school district, or roads may be obstructed such that

transportation to the school of origin may no longer be possible. In some cases, schools

may be destroyed, or damaged to the degree that the infrastructure cannot support a

normal school experience. Additionally, LEA and/or school staff members may have

M-1 State Coordinators’ Handbook: Section M. When Disaster Strikes: What State Coordinators Need to Know and Do

experienced their own trauma or losses, leading to reduced personnel supports in the

school setting.

During a disaster, and in its immediate aftermath, displaced families may experience

any number of difficulties, including serious injuries, loss of loved ones, loss of belongings,

anxiety, and fear of separation. They may be traumatized by the event to the extent that

they do not recognize the potential safety and stability that schools may be able to provide

them. Many displaced families may have never considered that they could become

homeless and may be unaware of the McKinney-Vento Homeless Assistance Act

(McKinney-Vento) and the services that may be available to them. Families may not realize

that they meet the McKinney-Vento definition of eligibility. Furthermore, some scenarios

of temporary housing are complex; eligibility determinations may become difficult as

families sometimes stay in hotels while their homes are being rebuilt. Due to the impact on

the school district itself, LEAs may refrain from providing services for an extended time

period after a disaster even though families are still in temporary housing.

Another set of challenges relates to the pressing need for immediate collaboration

and coordinated community activity during a disaster. Relationships between LEAs and

community-based relief agencies may not be strong enough to support the sharing of

needed information. Even in school districts with active interagency networks, a disaster

can interrupt or even completely disable the communication infrastructure needed for the

sharing of critical information and the coordination of response activity. A basic barrier

may be the lack of reciprocal knowledge and understanding of agency roles,

responsibilities, and services or resources provided. LEAs may not be familiar with

emergency management agencies (EMAs) and resources they provide; EMA staff may not

be familiar with McKinney-Vento rights. Unfortunately, a lack of mutual knowledge

between LEAs and the Federal Emergency Management Agency (FEMA) and other relief

agency resources may limit swift and effective communication between schools and relief

agency staff. Additionally, EMAs may not prioritize educational continuity, and/or they

may not be able to meet with homeless education staff while addressing the basic needs of

families during and immediately after a disaster.


Further challenges may result from ongoing capacity issues unrelated to a disaster.

For example, the local homeless education liaison (local liaison) may be new to the position

and lack a full understanding of McKinney-Vento requirements, or the local liaison may

have insufficient time assigned to McKinney-Vento responsibilities, limiting time available

for effective collaboration with community partners and relief agency staff. In some cases,

LEA administrators may not have adequate knowledge or understanding of McKinney-

Vento, which may result in confusion about what services and supports are allowed and

what is required by the McKinney-Vento Act.

The Goals

This document was initially developed by a work group of State Coordinators with

first-hand experience in dealing with disasters and informed by subsequent disaster

response work of State Coordinators related to hurricanes Harvey, Irma, and Maria as well

as the 2017 California wildfires. It provides State Coordinators with information and

resources to assist in developing a statewide disaster response plan specific to supporting

educational continuity for children and youth displaced by disasters, and to support local

liaisons in developing an effective response to the educational needs of children and youth

in their school communities when a disaster strikes. To optimize services and supports,

State Coordinators are encouraged to develop a comprehensive plan, along with specific

tools and processes, to guide local liaisons and other stakeholders in each community. The

plan should be developed collaboratively with representatives from key groups, including

other state educational agency (SEA) programs (e.g., student services, school health, and

school transportation), state agencies, local liaisons, school principals, and district

administrators, as well as state and community-based relief agencies that serve homeless

families.

With a view toward continuity in the education of students impacted by a disaster,

the following goals are suggested for use in the development of an effective disaster

response plan:


Goal 1 - Children and youth made homeless by a disaster are able to return as soon as possible

to the normalcy afforded by stable schooling.

A. Families and youth made homeless by a disaster are made aware of and

understand their educational rights.

B. Local school districts are prepared to address both the academic and the

trauma needs of children and youth impacted by a

disaster.

Goal 2 - Local school districts are prepared to collaborate with other agencies to implement

McKinney-Vento Act services for children and youth impacted by disasters.

A. Local liaisons have the information and resources they need to ensure

appropriate connections and linkages with key agencies in support of

educational stability for children and youth made homeless by a disaster.

B. School districts are prepared to play a role in linking families and youth

made homeless by a disaster with community services.

C. Emergency management agencies support educational continuity for

children and youth made homeless due to a disaster.

Goal 3 - State agencies, SEAs, and LEAs have mechanisms in place to share appropriate data

so that children and youth made homeless by a disaster are appropriately coded,

counted, and provided with immediate supports.

Goal 4 - Legislators, granting agencies, and other funders understand the need to provide

financial support for the educational needs of children and youth made

homeless by a disaster.

State Coordinators may use these goals in discussions with key stakeholders and

partners to help develop a comprehensive statewide approach to enable local communities

to plan for continuity in the education of students impacted by disaster. Appendix A – Goals

and Strategies for State-Level Support for McKinney-Vento Services for Students Displaced by

Disasters, provides a detailed description of potential challenges relative to each of the

preceding four goals, along with suggested strategies, activities, and possible practices for

consideration during the planning process. Strong collaboration between school personnel


and relief agency staff is imperative to ensure that the educational needs of displaced

children and youth are considered essential in planning for disaster relief, and in assessing

needs in the immediate aftermath of a disaster.

Recommendations

The following recommendations are offered here to guide discussion and advance

planning as State Coordinators work to prepare for a disaster in their school communities.

Please note that these recommendations are in addition to, and in support of, the

Strategies/Activities/ Practices section of Appendix A.

1. Be prepared to provide quick training, critical information, and support to key role

groups.

Establish a work group of local liaisons to engage in local planning; develop

guidance and tools for distribution to all liaisons so that all LEAs are prepared in

the event a disaster strikes.

Ensure that schools are following the provisions of McKinney-Vento by

reminding the local liaisons to work with schools regarding the enrollment of

students made homeless due to a disaster.

Explore ways that McKinney-Vento state level activity funds may be provided to

LEAs to enroll and serve children and youth made homeless by a disaster.

Ensure students made homeless by a disaster are coded in database systems as

McKinney-Vento eligible and flagged as students made homeless by the specific

disaster.

Centralize communication, making sure that all key organizations are part of the

communication plan.

Recruit and train volunteers to assist with enrolling large numbers of students

made homeless by the disaster.

Use Appendix A of this document to guide discussions with key groups.

Bookmark the disaster page from the NCHE website at

https://nche.ed.gov/ibt/dis_prep.php for quick access to sample tools,

documents, and other materials to support planning for a disaster response for


https://nche.ed.gov/ibt/dis_prep.php

SEAs and LEAs, as well as ED’s Readiness and Emergency Management for

Schools (REMS) Technical Assistance Center at www.rems.ed.gov.

Include the topic of disaster planning as part of all liaison training events.

Include information for parents in district’s parent handbook to let them know

of resources available to them in the event of a disaster.

2. Build an interagency network for the purposes of sharing information and resources in

planning for collaborative response to disaster.

The State Coordinator should be part of the advance planning team at the state

level. If not already connected, reach out to leaders in statewide relief agencies

to build important relationships.

Connect with the Federal Emergency Management Agency (FEMA) and other

disaster relief agencies with state and local presence.

Identify available mental health resources and provide liaisons with lists of

agencies and contacts.

Identify and communicate with other state-level educational program partners

(e.g., student services, school health, school transportation, etc.) and other state

agencies; make sure they are aware of the McKinney-Vento Act, the supports

that are available in schools, and the importance of school stability for students

made homeless by a disaster.

Ask other state leaders whether a disaster task force with focus on children has

been developed. If so, join the task force; if not, begin discussions with others

about establishing one.

Ensure that a communication protocol or system is in place so that in the event

of a disaster, state leaders can quickly and collaboratively determine the scope of

the problem, such as number of families impacted, number of schools destroyed,

infrastructure damage, and facilities needed for temporary relocation.

Network with State Coordinators in states impacted by disasters to learn about

their preparations, procedures, and lessons learned.

Identify or establish a webpage for purposes of immediate communications

among key individuals, groups, agencies, organizations; update website often.


http://www.rems.ed.gov/

Develop an interactive map with hot links to available resources as part of a

disaster webpage for your state.

Examples of Promising Practices

State, local, and national groups have developed a variety of strategies in response

to disaster and its aftermath. A critical element common to the strategies and promising

practices is that of effective communication and collaborative planning. The development

and maintenance of community partnerships are at the core of any effective response to

disaster in a school community. It should be noted that one of the most important

elements of strong disaster response is the existence of a robust McKinney-Vento program

of services and supports already in place prior to the onset of a disaster.

State Examples

McKinney-Vento State Coordinators in a number of states have experienced and

helped LEAs address the devastating effects of both manmade and natural disasters,

including hurricanes, tornadoes, floods, and fires. Examples of natural disaster planning

tools and other materials are described here to showcase promising practices and lessons

learned through working collaboratively at all levels to provide supports for students made

homeless by disaster. The examples described here, and others, are available for review

and downloading from the NCHE disaster webpage

(https://nche.ed.gov/ibt/dis_prep.php).

Florida:

The Florida Department of Education (FLDOE) has a number of practices in places

for implementation when disasters strike. Given the frequency of hurricanes and other

disasters in the area, the FLDOE is often challenged to respond quickly and effectively to

the immediate needs of school-aged children and youth made homeless by disaster. The

McKinney-Vento State Coordinator at FLDOE has collected a variety of materials

specifically related to the full implementation of the McKinney-Vento Act in times of

disaster for inclusion in this document. The FLDOE disaster resources, available on the



NCHE disaster webpage, contain samples of essential communications between and among

key groups, including:

Sample emails to local liaisons with information about disaster-related data

elements needed for accurate coding of homeless students and other items related

to McKinney-Vento requirements;

Timeline and agenda for conference calls;

The FLDOE Disaster Phone Contact Tree, designating FLDOE phone contacts for all

school districts, community colleges, and universities as part of its role in providing

outreach and assistance to them during hurricane disasters;

Sample letters from FLDOE leadership to district school superintendents pertaining

to enrollment of students affected by disasters, testing, etc.;

Directives to LEAs regarding enrollment in private schools; and

Disaster-related press releases and news updates.

Links to other organizations for information, referral, technical assistance, and

potential collaboration are included in the FLDOE disaster resources. The K-20 Summary of

Hurricane Recovery Efforts: The Department’s Role in Emergency Management and Recovery

Efforts, a one-page bulleted list of Response Team activities, provides useful information.

Colorado:

In response to flooding in Colorado in 2013, the Colorado Department of Education

(CDE) implemented many of the activities listed above, resulting in the development of

valuable tools and processes to address the immediate needs of children and youth

impacted by natural disaster. The State Coordinator took the lead in developing a variety

of communications, guidance documents and other tools and processes to strengthen CDE’s

response to disaster.

A one-page memorandum, Expediting Identification for Displaced Students, provided

suggestions for quick and effective identification of McKinney-Vento students. Suggestions

included training front-line school staff members who can become “initial identifiers” to

help families with completing the necessary forms and expedite identification process.

Initial identifiers used the McKinney-Vento Identification Template to expedite the process.


The development of a CDE regional leadership team, in strong collaboration with the

McKinney-Vento program, provided support for connecting families and students with

much-needed resources. Two PowerPoint presentations, Serving Displaced and Homeless

Students Under Title IA and Transportation Collaboration Efforts on the Colorado Flood

2013, may be of particular interest to State Coordinators interested in the inclusion of Title

IA program support in the advance planning phase of disaster response. CDE developed a

set of flood resources, including a McKinney-Vento Q&A. CDE distributed these resources

to key stakeholders at SEA and LEA levels, clarifying what services and supports are

available through schools. A one-page document, McKinney-Vento Homeless Assistance Act:

Expediting Identification for Displaced Students, offers critical information in a concise

format and suggests a number of ideas for quick and effective identification of McKinney-

Vento students. CDE developed a Disaster Distress Helpline and a dedicated webpage

providing information on educational resources and state agency links. As in Florida, a

collaborative approach to advance training for key role groups in disaster response was an

essential part of the statewide plan in Colorado. Sample communications from the State

Coordinator to local liaisons, superintendents, community agency staff and other key

stakeholders are available for review on the NCHE disaster webpage.

Examples of Local Efforts

Wisconsin:

A sampling of efforts by LEAs to ensure the continuity of education for

children and youth made homeless by disaster includes a guide developed by the

Madison Metropolitan School District (MMSD). This document, A Madison Metropolitan

School District: Guide on Enrollment and Service Provision for Students Displaced by

Hurricane Katrina, details plans for MMSD response to the needs of displaced students

who might seek to attend school in this district after Hurricane Katrina. The guide, posted

on the NCHE disaster webpage, covers issues such as immediate enrollment, free and

reduced lunch, and post-trauma intervention services. Also included is guidance specific to

special education, English as a Second Language (ESL), and bilingual education students.


Kansas:

Frequent tornadoes in Kansas have required local homeless liaisons and other

program administrators to think creatively in addressing the educational needs of students

impacted by disaster. With support from the State Coordinator, many districts assign a

new local liaison to address the needs of students displaced by the disaster. For example,

when one small town suffered from a tornado, but the rest of the LEA did not, the LEA

assigned homeless liaison duties to the principal in that small town. The district made this

decision because the principal was in a better position to know about the displaced families

and their needs than LEA level staff.

Following the occurrence of three tornadoes in rapid succession in Greensburg,

Kansas, in 2007, over 95% of the students became homeless. LEA administrators were able

to get permission from the state to end the school year officially at the time of the tornado.

Similarly, other LEAs were able to grant certain students who they could not reasonably

transport, the option to end the school year at the time the disaster struck, if the family and

school agreed.

In the preparation for a disaster, Kansas LEAs are encouraged to establish a small

group at the district level to receive and disseminate all state level communications. This

ensures consistency in all outgoing communications to all involved, including the local

liaison, any temporary liaisons designated because of disaster, the food and nutrition

director, the transportation director, the Federal programs director, the superintendent,

etc. Relief agencies are encouraged to refer questions regarding education to the local

liaison to ensure accuracy of information.

Federal Information and Resources

During times of disaster, whether a natural or man-made event, a series of

responses take place through coordinated efforts of local, state, and Federal Government

agencies. These emergency responses include implementation of established procedures

relative to communication protocols, organizational structures, terminology, and key

resources to engage appropriate agencies in effective response at all levels of government.


Section 401 of the Robert T. Stafford Disaster Relief and Emergency Assistance Act requires

that all requests for a declaration by the President that a major disaster has occurred be

made by the Governor of the affected State. This request from the Governor is made

through the regional FEMA office, and is followed by a preliminary damage assessment

(PDA) conducted by state and Federal officials. Once a declaration has been made that a

major disaster or emergency exists, an array of Federal programs may be activated to assist

in state and local response and recovery efforts.

State Coordinators are encouraged to be attuned to the process of declaration of

disaster, and in the unfortunate event of a major disaster, to be poised to communicate

with the appropriate regional FEMA office regarding educational and related needs of

children and youth made homeless by the disaster and ensure that such needs are included

in the preliminary damage assessment. FEMA’s Guide to the Disaster Declaration Process

and Federal Disaster Assistance can be viewed at

http://www.fema.gov/pdf/rrr/dec_proc.pdf. This document also includes contact

information for FEMA’s ten regional offices.

Federal response to several disasters, including Hurricanes Harvey, Irma, and Maria

and the 2017 California wildfires, has included a series of efforts announced by the U.S.

Department of Education (ED) to assist state and local governments in addressing the

needs of children and youth made homeless by these disastrous events. State Coordinators

are urged to remain alert to any guidance from ED in the event of disaster declaration that

may address potential waivers of statutory requirements or any relevant changes to

legislation, policies, rules and regulations.

Interagency Collaboration

Interagency collaboration has been the hallmark of several efforts for disaster

response at the Federal level. The Children’s Working Group (CWG) was established in

2009 to provide leadership in FEMA’s efforts to form partnerships with Federal and non-

governmental agencies to ensure that the needs of children are integrated into all disaster

planning, preparedness, response and recovery efforts initiated at the Federal level. Key

focus areas of the CWG include:


http://www.fema.gov/pdf/rrr/dec_proc.pdf

Supporting state and local efforts in evacuation, tracking, and reunification of

families;

Addressing the needs of children with disabilities during disasters;

Support for case management and crisis counseling for children and families

through the U.S. Department of Health and Human Services;

Increasing public awareness efforts to educate youth and families about emergency

preparedness;

Restoration and reimbursement of child care facilities;

Integrating needs of children into planning and sheltering guidance, emergency

management grants, and overall emergency planning; and

Improving coordination across the Federal government and with state, local, tribal

and territorial partners in support of children’s disaster related needs.

The Federal Administration for Children and Families (ACF) Office of Human Services

Emergency Preparedness and Response (OHSEPR) developed a model, Children and Youth

Task Force in Disasters, to support state and local partners in building capacity to respond

effectively to various types of disasters that may strike a community. The model is based

on lessons learned from four case studies following devastating natural disasters: The

Joplin Child Care Task Force, The Hurricane Isaac Children’s Needs Task Force, The

Superstorm Sandy New Jersey State-led Task Force, and The Superstorm Sandy New York

Children’s Task Force. Based on these four examples, the model offers guidelines for the

development of a state-driven process to assist state and local planners in creating a

community task force that they can tailor to individual communities and to specific

disasters. The model offers recommendations for states and local communities interested

in launching their own task forces in efforts to coordinate an effective planning process for

addressing the needs of children and youth during emergency preparedness, response and

recovery, including starting in the preparedness phase to forge partnerships with local,

state, and Federal agencies prior to disaster striking the community. Strong partnerships

require that the aforementioned agencies work together to share a common assessment of

community needs and to develop an integrated strategy to address those needs.


The model offers a comprehensive list of potential partners, representing Federal,

state, and local agencies. The deliberate and strategic inclusion of school personnel who

understand McKinney-Vento would certainly optimize outcomes for children and youth

impacted by disaster. The full document, Children and Youth Task Force in Disasters:

Guidelines for Development, is available at

https://www.acf.hhs.gov/ohsepr/resource/children-and-youth-task-force-in-disasters.

ED’s Readiness and Emergency Management for Schools (REMS) Technical Assistance

Center (http://rems.ed.gov) is a key source of information and resources on K-12 school

emergency management and planning. The Federal Guide for Developing High-Quality

Emergency Operations Plans can be found there. Schools can use the Guide to create new

emergency operations plans (EOPs), as well as to revise and update existing plans and align

their emergency planning practices with those at the national, state, and local levels. The

Guide provides schools with:

The principles of school emergency management planning; A process for developing, implementing, and continually refining a school EOP with community

partners (e.g., first responders and emergency management personnel) at the school building level; A discussion of the form, function, and content of school EOPs; Additional information on the critical operational functions and courses of action developed to

carry them out that schools should address in developing a comprehensive, high-quality school EOP; and

Additional information on the courses of action unique to particular threats and hazards.

The REMS TA Center provides further information about school emergency

management through publications, webinars, training, and other resources. State

Coordinators are urged to support local liaisons in building the relationships with local

emergency management staff needed to increase their knowledge of the McKinney-Vento

Act and their understanding of the importance of educational stability in helping them to

meet their goals.

For more information on promising practices, and available resources, see Appendix

B – Annotated List of Available Resources for State Coordinators and Local Liaisons. State

Coordinators are encouraged to review these materials, along with sample documents and

other tools on the NCHE website.



https://rems.ed.gov/K12ThreatAndHSAnnex.aspx

https://rems.ed.gov/K12FuncAnnex.aspx

https://rems.ed.gov/K12PlanContent.aspx

https://rems.ed.gov/K12PlanningProcess.aspx

https://rems.ed.gov/K12PlanningPrinciples.aspx

http://rems.ed.gov/

https://www.acf.hhs.gov/ohsepr/resource/children-and-youth-task-force-in-disasters

Conclusion

Disasters are unpredictable and devastating, each with its own unique set of

challenges and impacts on children, youth, and families. The question is not if a disaster

will occur in a community, but when will a disaster occur. States and communities must be

prepared to respond quickly and efficiently. Schools fulfill a critical role in ensuring safety,

routine, and healing from trauma for children and youth who have been displaced by a

disaster. State- and local-level McKinney-Vento programs are instrumental in identifying

impacted children and youth and reconnecting them to school as quickly as possible.

To facilitate this quick response, State Coordinators should incorporate disaster

preparedness in their work plans by;

Familiarizing themselves with all provisions of the McKinney-Vento Act to ensure

that the requirements for implementation can be communicated clearly in disaster

situations (particularly in regard to determining eligibility for McKinney-Vento

services, school selection, and transportation),

Familiarizing themselves with Federal disaster resources and processes,

Joining state emergency management and disaster response teams,

Developing a process for using McKinney-Vento state-level activity funds to support

the educational needs of children and youth displaced by disasters, and

Including disaster preparedness in their liaison trainings.

By taking these preliminary steps, State Coordinators and local liaisons will be well-

positioned to be proactive and efficient in the event that a disaster occurs.


Appendix A-1. State Coordinator Preassessment

The following questions are intended to provide an overview of the topics covered in this handbook. A pretest format will allow you to quiz yourself and determine which sections to visit.

Getting the Lay of the LandWhat are the seven functions of the office of the state coordinator under the McKinney-Vento Act? What additional responsibilities must the state coordinator fulfill?How does your state address each?

Appendix B-1: Functions of the State Coordinator

What federal legislation impacts your responsibilities as a state coordinator for the EHCY program?

What laws are referenced most often?What requirements should be highlighted?How can you learn more?

Section B - Charting the Course

What does the McKinney-Vento EHCY program look like in your state?What is your state allocation?

What is the budget for the state and subgrants? Are there other federal or state funds that support your

program at the state level? What are the Title I, Part A reservation for homeless

students amounts for each LEA?What data are available to describe your state’s program? Where can you find the data?

How many children and youth experiencing homelessness have been identified in your state?

How has the number of children and youth changed over time?

What are the most pressing barriers homeless children and youth face accessing education?

What are the most common needs of homeless children and youth?

How are homeless children and youth performing on state assessments?

How does the percentage of students experiencing homelessness compare to the state average for the on-time graduation rate?

What actions did your state plan to implement in its State Plan? What is the status of those actions?

Are there any current initiatives in your state that focus

Section B - Charting the CourseSection D- Data Collection and Reporting

A-1-1 State Coordinators’ Handbook: IntroductionAppendix A-1. State Coordinator Pretest

on homeless children and youth or a special subgroup (e.g., early childhood, unaccompanied youth)?

What were the results of your state’s most recent federal program monitoring of the EHCY program?

Has there been a formal program evaluation or statewide needs assessment of the state’s EHCY program? What were the identified strengths and weaknesses? What recommendations were made for program improvement?

What is the McKinney-Vento dispute resolution process for your state? What have been the primary topics for formal disputes between school/school districts and parents, guardians, or unaccompanied youth? How long does the dispute process usually take?

Section G – Dispute Resolution

Building the “To Do List”What do you need to do? Today? Tomorrow? This year?How do you prioritize and plan?Do you have a checklist? What’s on it? Where can you get help?

Section B - Charting the Course

With whom do you currently collaborate?Who is missing from your collaborative partners?How do you decide where to focus your limited resources?How can you enhance your partnerships?

Section C- Collaboration

How can you enhance your program? Section E – Using Data to Inform PracticeSection H- Monitoring, Program Evaluation

Carrying Out Your ResponsibilitiesWhat types of training and technical assistance do you provide?

Who, what, when (frequency), how?- How do you ensure that all local liaisons are trained on the

McKinney-Vento Act and the requirements of their role?

Section F- Technical Assistance for LEAsSection G – Dispute Resolution


- How do you ensure that all local liaisons are familiar with the state’s McKinney-Vento dispute resolution policy and are able to conduct the dispute process when needed?

How do you ensure LEA compliance with the McKinney-Vento Act?How often do you monitor LEA’s with subgrants?How often do you monitor LEA’s without subgrants?What is the LEA monitoring process for the McKinney-Vento program?When was the LEA monitoring protocol last revised?

Section E – Using Data to Inform PracticeSection H – LEA Monitoring

What is your process for awarding subgrants? How many LEAs have subgrants? How long is your state’s cycle for subgrants? When is the next year in which the subgrant process must take place?

Section - McKinney-Vento Subgrant Process

How do you ensure fiscal responsibility and appropriate expenditures?

Section J- Fiscal Management

How do you ensure your state’s compliance? How do you document compliance? How do you prepare for and successfully complete a

federal monitoring visit?

Section D- Data Collection and Reporting

Section E – Using Data to Inform Practice

Section H- Preparing for Federal Monitoring of the EHCY Program

With all there is to do, how do you manage the work load? Section B - Working Smart


Appendix B-1. Functions and Requirements of the Office of Coordinator for the Education of Homeless Children and Youth Program, Current Activities, and Next Steps

Appendix B-1 provides excerpts from the McKinney-Vento Act regarding the functions of the State Coordinator and other activities required by the law. Included also are references to relevant sections of the handbook and to other resources. You can use this appendix as a worksheet to list current activities and next steps to add in as you become more familiar with your role as State Coordinator. You may get some ideas from the sample activities listed.

Function 1: Make Information Available

Gather and make available reliable, valid, and comprehensive information on (A) the number of homeless children and youths identified in the State, which shall be posted annually on the State educational agency’s website; (B) the nature and extent of the problems homeless children and youths have in gaining access to public preschool programs and to public elementary schools and secondary schools;(C) the difficulties in identifying the special needs and barriers to the participation and achievement of such children and youths;(D) any progress made by the State educational agency and local educational agencies in the State in addressing such problems and difficulties; and (E) the success of the programs under this subtitle in identifying homeless children and youths and allowing such children and youths to enroll in, attend, and succeed in, school.

[42 U.S.C. § 11432(f)(1)]

Resources

State Coordinators’ Handbook Section C. Connections to Collaborations, Section D. Data Collection and Reporting

NCHE’s State Educational Agency Informal Needs Assessment

Current Activities

Example: CSPR data is reported on time and used for annual planning. State website includes a description of activities

Next Steps

Example: Create template for posting data to website, post data and revise annually, and add to yearly calendar.

B-1-1 State Coordinators’ Handbook: Section B. Charting the Course. Appendix B-1. Function and Requirements for the Office of Coordinator for Education of Homeless Children and Youth Program, Current Activities, and Next Steps

conducted by subgrantees.

Function 2: Develop and Carry Out State Plan

Develop and carry out the State plan described in subsection (g).

[42 U.S.C. § 11432(f)(2)]

Resources

State Coordinators’ Handbook Section B. Charting the Course

NCHE’s Education for Homeless Children and Youth Program: Guide to Developing an Annual Action Plan for State-Level Activities https://nche.ed.gov/sc/sc.php

Current Activities

Example: Reviewed State Plan annually and incorporated into annual action plan.

Next Steps

Example: Identify and convene group to review State Plan with the State Coordinator.



Function 3: Collect Data

Collect data for and transmit to the Secretary, at such time and in such manner as the Secretary may reasonably require, a report containing information necessary to assess the educational needs of homeless children and youths within the State, including data necessary for the Secretary to fulfill the responsibilities under section 724(h)

[42 U.S.C. § 11432(f)(3)]

Resources

State Coordinators’ Handbook Section D. Data Collection

Current Activities

Example: EDFacts data for the CSPR submitted on time.

Next Steps

Example: Work with State EDFacts coordinator on new data collection memo.


Function 4: Coordinate and Collaborate

In order to improve the provision of comprehensive education and related services to homeless children and youths and their families, coordinate activities and collaborate with …

[42 U.S.C. § 11432(f)(4)(A-E)]

Resources

State Coordinators’ Handbook Section C. Connections to Collaboration: Yours, Mine, and Ours; Section F. Technical Assistance for Local Educational Agencies

A) educators, including teachers, special education personnel, administrators, and child development and preschool program personnel;

Current Activities

Example: Serve on Interagency Coordinating Council (ICC), Special Education Advisory Council (SEAC), Head Start Collaboration Advisory Council.

Next Steps

Example: Invite a school principal or non-liaison central office administrator to serve on State advisory board.

B) providers of services to homeless children and youths and their families, including public and private child welfare and social services agencies, law enforcement agencies, juvenile and family courts, agencies providing mental health services, domestic violence agencies, child care providers, runaway and homeless youth centers, and providers of services and programs funded under the Runaway and Homeless Youth Act (42 U.S.C. 5701 et seq.);

Current Activities

Example: Coordinating with Department of Social Services for Child Care Block Grant Development plan and training, serve on CASA/CJA Advisory Committee.

Next Steps

Example: Ensure identification of any RHYA programs funded in the state; add to work calendar checking RHYA grant award cycle so new awards are added to contact list.


C) providers of emergency, transitional, and permanent housing to homeless children and youths, and their families, including public housing agencies, shelter operators, operators of transitional housing facilities, and providers of transitional living programs for homeless youths;

Current Activities

Example: Attend annual conference of State homeless coalition.

Next Steps

Example: Participate in Balance of State Continuum of Care.

(D) local educational agency liaisons designated under subsection (g)(1)(J)(ii) for homeless children and youths; and

Current Activities

Example: Yearly annual regional trainings are conducted; newsletter is distributed 1-2 times/year.

Next Steps

Example: Add date liaison was designated to database of contacts; establish a running list of liaison outreach.

(E) community organizations and groups representing homeless children and youths and their families;

Current Activities

Example: Attend and present at local meetings and conferences hosted by community organizations.

Next Steps

Example: Invite State poverty law center advocates to planning meeting.

Function 5: Provide Technical Assistance


Provide technical assistance to and conduct monitoring of local educational agencies in coordination with local educational agency liaisons designated under subsection (g)(1)(J)(ii), to ensure that local educational agencies comply with the requirements of subsection (e)(3) and paragraphs (3) through (7) of subsection (g)

[42 U.S.C. § 11432(f)(5)]

Resources

State Coordinators Handbook, Section H. State Monitoring of Local Educational Agency Education for Education of Homeless Children and Youth Programs

Current Activities

Example: Maintain state website, conduct ongoing TA from calls and emails; conduct monitoring of all LEAs (on site or desk review) over three-year cycle.

Next Steps

Example: Review and revise monitoring protocols based on ESSA requirements and issues identified in previous year’s monitoring, clarify process for prioritizing selection of LEAs and format(s) of monitoring to be used.


Function 6: Provide Professional Development

Provide professional development opportunities for local educational agency personnel and the local educational agency liaison designated under subsection (g)(1)(J)(ii) to assist such personnel and liaison in identifying and meeting the needs of homeless children and youths, and provide training on the definitions of terms related to homelessness specified in sections 103, 401, and 725 to the liaison.

[42 U.S.C. § 11432(f)(6)]

Resources

State Coordinators Handbook, Section F. Technical Assistance for Local Educational Agencies

NCHE’s Homeless Liaison Toolkit at https://nche.ed.gov/pr/liaison_toolkit.php

NCHE Issue Briefs at https://nche.ed.gov/pr/briefs.php

NCHE Training Resources at https://nche.ed.gov/web/online_tr.php

Current Activities

Example: Conduct regional trainings across the State each year.

Next Steps

Example: Review TA logs from LEAs and monitoring reports to determine areas of needed training; schedule trainings; work with HUD State/regional partners to develop training on definitions and referral process.


https://nche.ed.gov/web/online_tr.php



Function 7: Respond to Inquiries from Parents and Guardians

Respond to inquiries from parents and guardians of homeless children and youths and (in the case of unaccompanied youths) such youths, to ensure that each child or youth who is the subject of such an inquiry receives the full protections and services provided by this subtitle.

[42 U.S.C. § 11432(f)(7)]

Resources

State Coordinators’ Handbook Section G. Disputes

Current Activities

Example: Maintain a log of phone and email inquiries and the follow up provided.

Next Steps

Example: Create a “tickler” file to ensure follow up on resolution of inquiries.


Additional Requirements

Ensure that States are following the law.

The following is the policy of the Congress: [42 U.S.C. § 11431] (See below)

Resources

State Coordinators’ Handbook Section B. Charting the Course

(1) Each State educational agency shall ensure that each child of a homeless individual and each homeless youth has equal access to the same free, appropriate public education, including a public preschool education, as provided to other children and youths.

Current Activities

Example: Review local policies; participate in statewide early childhood initiatives and advisory boards.

Next Steps

Example: Track TA and barrier calls that suggest access challenges, increase awareness of need to flag pre-K students enrolled; create longitudinal tracking of pre-K enrollment.

(2) In any State where compulsory residency requirements or other requirements, in laws, regulations, practices, or policies, may act as a barrier to the identification of, or the enrollment, attendance, or success in school of, homeless children and youths, the State educational agency and local educational agencies in the State will review and undertake steps to revise such laws, regulations, practices, or policies to ensure that homeless children and youths are afforded the same free, appropriate public education as provided to other children and youths.

Current Activities

Example: State code reviewed to align with McKinney-Vento.

Next Steps

Example: Explore State regulations to identify potential barriers.


(3) Homelessness is not sufficient reason to separate students from the mainstream school environment.

Current Activities

Example: No separate public schools exist in state.

Next Steps

Example: Compare suspension and expulsion rates for students experiencing homelessness to overall rate in SEA and rates for more segregating placements in special education; look at same data at the LEA level during monitoring.

(4) Homeless children and youths should have access to the education and other services that such children and youths need to ensure that such children and youths have an opportunity to meet the same challenging State academic standards to which all students are held.

Current Activities

Example: Longitudinal tracking of State achievement data compared to State totals and other disaggregated groups; use these data during trainings.

Next Steps

Example: Review academic achievement data for LEAs in NCHE’s LEA-level data workbook to identify areas or grade-levels with low achievement for homeless students to target technical assistance.


Managing Subgrants

Grants under this section shall be used for the following:

[42 U.S.C. § 11432(d)]

Resources

NCHE’s Local Educational Agency Informal Needs Assessment

(1) To carry out the policies set forth in section 721 in the State.

Current Activities

Example: Subgrant rubric includes reference to policies in section 721.

Next Steps

Example: See suggestions in previous section; prioritize subgrantees for early review.

(2) To provide services and activities to improve the identification of homeless children and youths (including preschool-aged homeless children) and enable such children and youths to enroll in, attend, and succeed in school, including, if appropriate, in preschool programs.

Current Activities

Example: Provide common residency form for all LEAs to use for enrollment.

Next Steps

Example: Review NCHE’s LEA-level data workbook for your state to note LEAs that may be under identifying homeless students, and provide TA.

(3) To establish or designate in the State educational agency an Office of the Coordinator for Education of Homeless Children and Youths that can sufficiently carry out the duties described for the Office in this subtitle in accordance with subsection (f).


Current Activities

Example: Office established in 1987 and included in current department since 2000.

Next Steps

Example: Talk to supervisor regarding providing sufficient time and capacity to carry out State Coordinator responsibilities.

(4) To prepare and carry out the State plan described in subsection (g).

Current Activities

Example: Plan is easily accessible for quick reference and is reviewed annually.

Next Steps

Example: Review progress toward annual goals and develop an annual plan to that focuses on specific activities to achieve the goals.


Distribute State and Local Subgrants

(B) MINIMUM DISBURSEMENTS BY STATES – From the sums made available each year to a State through grants under subsection (a) to carry out this subtitle, the State educational agency shall distribute not less than 75 percent in subgrants to local educational agencies for the purposes of carrying out section 723, except that States funded at the minimum level set forth in subsection (c)(1) shall distribute not less than 50 percent in subgrants to local educational agencies for the purposes of carrying out section 723.

[42 U.S.C. § 11432(e)]

Resources

State Coordinators’ Handbook Section I. The McKinney-Vento Subgrant Process, Section J. Fiscal Oversight

Current Activities

Example: Allocations consistent with the law.

Next Steps

Example: Continue current process.


Use of Grant Funds

2) USE BY STATE EDUCATIONAL AGENCY- A State educational agency may use the grant funds remaining after the State educational agency distributes subgrants under paragraph (1) to conduct activities under subsection (f) directly or through grants or contracts.

[42 U.S.C. § 11432(e)]

Resources

State Coordinators’ Handbook Section B. Charting the Course; Section J. Fiscal Oversight

Current Activities

Example: Fiscal monitoring in place.

Next Steps

Example: Reference the appropriate subsection of law when creating budget and processing reimbursements.


State Compliance Plan

(A) IN GENERAL- Each plan adopted under this subsection shall also describe how the State will ensure that local educational agencies in the State will comply with the requirements of paragraphs (3) through (7).(B) COORDINATION- Such plan shall indicate what technical assistance the State will furnish to local educational agencies and how compliance efforts will be coordinated with the local educational agency liaisons designated under paragraph (1)(J)(ii).

[42 U.S.C. § 11432(g)(2)]

Resources

State Coordinators’ Handbook Section D. Data Collection and Reporting; Section H: State Monitoring of Local Educational Agency Education for Homeless Children and Youth Programs

Current Activities

Example: LEA monitoring plan in place.

Next Steps

Example: Review and revise monitoring protocols to reflect Federal requirements and priorities.


Appendix B-2. Federal Legislation State Coordinators Should Know

Legislation Highlights for SC Responsibilities Sources and Resources

Education for Homeless Children and Youth Program in the McKinney-Vento Homeless Assistance Act

This is the primary law that directs the work of State Coordinators. Becoming familiar with this legislation is an important first step to understanding the responsibilities of State Coordinators. The role of the State Coordinator and the requirements for a State plan are addressed in Sections 722(f) and 722(g). These sections provide the structure to State level activities related to homeless education.

McKinney-Vento Homeless Assistance Act (42 U.S.C. §§ 11431 et seq.) http://uscode.house.gov

Title I, Part A of the Elementary and Secondary Education Act of 1965 (ESEA)

Students experiencing homelessness are automatically eligible for services under Title I, Part A of the ESEA. McKinney-Vento and Title I, Part A require collaboration between the two programs in planning. LEAs are required to reserve Title I, Part A funds to serve homeless students for educationally related support services. Funds may be used for transportation to and from the school of origin and for the position of local liaison.

Title I, Part A (20 U.S.C. § 6311 et seq.) http://uscode.house.gov

(Title I of the ESEA, as amended by the ESSA, becomes effective with the 2017-18 school year. The ESSA is P.L. 114-95.)

Non-regulatory Guidance, 2016, M-4 http://www2.ed.gov/policy/elsec/leg/essa/160240ehcyguidance072716.pdf

NCHE Brief: “Serving Students Experiencing Homelessness under Title I, Part A” https://nche.ed.gov/downloads/br

B-2-1 State Coordinators’ Handbook: Section B. Charting the Course. Appendix B-2. Federal Legislation State Coordinators Should Know

https://nche.ed.gov/downloads/briefs/titlei.pdf







iefs/titlei.pdf Education of Migratory Children, Title I, Part C of the ESEA

By definition, a migrant student who lacks a fixed, regular, and adequate nighttime residence should be considered homeless and served under both Title I, Part C of the ESEA and the McKinney-Vento Act. Coordination with the migrant education program can assist in accurate identification and outreach for these students.

Title I, Part C (20 U.S.C. § 6391 et seq.) http://uscode.house.govNCHE Brief: “ Migrant Students Experiencing Homelessness: Rights and Services under the McKinney-Vento Act” https://nche.ed.gov/downloads/briefs/migrant.pdf

The Individuals With Disabilities Educational Improvement Act (IDEA)

Students experiencing homelessness are more likely than their housed peers to be diagnosed with a disability, making special education an important partner for serving homeless students. Homeless educators have the responsibility to ensure students have access to needed services, including special education, and early intervention services for infants and toddlers served by Part C. IDEA has specific mandates that support this objective, including targeting homeless children and youth in Child Find activities, addressing mobility during evaluation and once services are in place, and ensuring unaccompanied homeless youth with disabilities have access to special education.

Individuals with Disabilities Education Improvement Act (20 U.S.C. § 1400-1444 et seq.) http://uscode.house.gov Early Childhood Technical Assistance Center, Early Intervention Program http://ectacenter.org/partc/partc.asp NCHE Brief: “Supporting Homeless Children and Youth with Disabilities- Legislative Provisions in the McKinney-Vento Act and Individuals with Disabilities Education Act” https://nche.ed.gov/downloads/briefs/idea.pdf

Higher Education Opportunity Act

Students identified as unaccompanied homeless youth may complete the Free Application for Federal Student

McKinney-Vento Homeless Assistance Act (42 U.S.C. §§ 11431


https://nche.ed.gov/downloads/briefs/idea.pdf

https://nche.ed.gov/downloads/briefs/idea.pdf

http://ectacenter.org/partc/partc.asp

http://ectacenter.org/partc/partc.asp


https://nche.ed.gov/downloads/briefs/migrant.pdf

https://nche.ed.gov/downloads/briefs/migrant.pdf


https://nche.ed.gov/downloads/briefs/titlei.pdf


Aid (FAFSA) as independent students. Liaisons can provide verification of status. Note: Under the McKinney-Vento Act, as amended by the ESSA, unaccompanied homeless youth must be informed of their status as independent students under section 480 of the Higher Education Opportunity Act of 1965. Youths may obtain assistance from the local educational agency liaison to receive verification of such status for purposes of the Free Application for Federal Student Aid described in section 483 of such Act (20 U.S.C. § 1090).

et seq.) http://uscode.house.gov

Higher Education Opportunity Act of 1965 (20 U.S.C. § 1087vv) http://uscode.house.govNCHE Brief: Increasing Access to Higher Education for Unaccompanied Homeless Youth https://nche.ed.gov/downloads/briefs/higher_ed.pdf

Homeless Emergency Assistance and Rapid Transition to Housing (HEARTH) Act

The HUD definition of homeless in the HEARTH Act is less expansive than the McKinney-Vento definition. With a greater emphasis on homeless prevention in HEARTH, the opportunities to work with housing partners have increased. Furthermore, the HUD assurances in the SuperNOFA (notice of funds available) place greater emphasis on housing coordination with education. The McKinney-Vento Act also has a mandate for coordination.

McKinney-Vento Homeless Assistance Act (42 U.S.C. § 11301 et seq.), amended by the HEARTH Act in 2009 http://uscode.house.govU.S. Interagency Council on Homelessness (USICH)

Improving Head Start for School Readiness Act of 2007

Young children experiencing homelessness are automatically eligible for Head Start services. Homelessness is one of the priority populations Head Start must serve. Head Start grants go directly to localities, but each State has a State collaboration director. Both the McKinney-Vento and Head Start laws require communication and collaboration between the two programs.

Head Start Act ( 42 U.S.C. § 9831 et seq.) as amended by the Improving Head Start for School Readiness Act of 2007, P.L. 110-134 http://uscode.house.gov

Office of Head Start https://eclkc.ohs.acf.hhs.gov/hslc/standards/law/HS_ACT_PL_110-134.pdf


https://eclkc.ohs.acf.hhs.gov/hslc/standards/law/HS_ACT_PL_110-134.pdf





https://nche.ed.gov/downloads/briefs/higher_ed.pdf

https://nche.ed.gov/downloads/briefs/higher_ed.pdf




Office of Head Start list of State Collaboration Directors http://eclkc.ohs.acf.hhs.gov/hslc/HeadStartOffices

Runaway and Homeless Youth Act (RHYA)

This act provides funding to local programs that serve a subpopulation of youth included in the definition for homeless in the McKinney-Vento Act. Street outreach programs, basic center programs, transitional living programs, and maternity group homes are funded by RHYA. Coordination with these programs is required in the McKinney-Vento Act [42 U.S.C. § 11432(f)(4)(B)].

Runaway and Homeless Youth Act,(42 U.S.C. § 5701 et seq.), as amended by P.L. 108-96 http://uscode.house.gov

List of RHYA subgrants http://www.acf.hhs.gov/programs/fysb U.S. Department of Health and Human Services, Administration on Children, Youth, and Families https://www.acf.hhs.gov/acyf

Child Nutrition and WIC Reauthorization Act

Children who are homeless are categorically eligible for free meals. With verification by a homeless liaison or shelter director, no application is required.

Richard B. Russell National School Lunch Act (42 U.S.C. § 1758) reauthorized by the Child Nutrition and WIC Reauthorization Act (P.L. 108-265) http://uscode.house.govU.S. Department of Agriculture Memos https://nche.ed.gov/legis/cn_wic.php NCHE brief: “Access to Food for Homeless and Highly Mobile


https://nche.ed.gov/legis/cn_wic.php

https://nche.ed.gov/legis/cn_wic.php

http://www.frac.org/

http://www.frac.org/


https://www.acf.hhs.gov/acyf

http://www.acf.hhs.gov/programs/fysb

http://www.acf.hhs.gov/programs/fysb



Students” https://nche.ed.gov/downloads/briefs/nutrition.pdf


Appendix B-3. Steps for Revising State Code, Policies, or Procedures

1. Clearly define the problem and who needs to be involved (locus of control). Determining what a successful outcome would be should be part of this process. That way, you can embed evaluation throughout the process and have the needed evidence of the change’s effects and the success of your efforts.

Type of Problem Who Needs to be Involved?Legal conflict requiring change to State law

State education attorneys, Attorney General’s Office (advocacy lawyers may be involved)

Procedural/implementation challenge that requires communication across agencies

Depends on level of oversight or independence the State Coordinator has in working with other State agencies

Policy conflict requiring amendment to State policy

State board of education, State department of policy education staff

Procedural/implementation challenge that requires communication across programs

Depends on level of oversight or independence the State Coordinator has in working within the State educational agency and the organization of programs within the agency

Procedural/implementation challenge specific to homeless education practices

Primarily in-house efforts by the State Coordinator and staff and working with local homeless education liaisons (may still need sanction of supervisors and/or State superintendent)

2. Obtain “buy-in” for change

Select key informants. Invite knowledgeable people to suggest changes and comment on changes. Note that this may need to follow a public comment process for State policies. (Who are the experts? Who administers the programs involved? Who is affected by the changes?)

Justify the need for a change. May include legal mandates, impact on students (including anecdotal stories), and/or impact on school accountability (adequate yearly progress, on-time graduation rate, other available data)

3. Work with key informants to generate alternatives and select actions that are most promising.

4. Roll out the change and include your key informants in planning how to announce and implement the change

Shape the message. Provide context and justification for change.

B-3-1 State Coordinators’ Handbook: Section B. Charting the Course. Appendix B-3. Steps for Revising State Code, Policies, or Procedures

Emphasize the intended benefit, including how the change builds on previous efforts if appropriate. Be honest about the effort that may be required and acknowledge those efforts. Consider: if multiple audiences will need the information, will it need to be presented with different emphases to have the most impact?

Identify audiences and vehicles for the message.

Who needs the information? How does the message go out? (State level memoranda, letters, email, web announcements, trainings, articles/announcements in newsletters)

5. Monitor the effect of change. Do not forget to plan from the start how you will know if the change has been effective (build in evaluation).

B-3-2 State Coordinators’ Handbook: Section B. Charting the Course. Appendix B-3. Steps for Revising State Code, Policies, or Procedures

Appendix B-4. Sample Annual Scope of Work for the North Carolina Homeless Education Program July 1, 2009 - June 30, 2010

Task 1. Data Collection

Coordinate with NC DPI (Department of Public Instruction) data and Consolidated

State Performance Report staff on annual Federal data collection. NCHEP staff will

o work with NC DPI data staff and keep them apprised of all communication

and guidance from the Federal Education for Homeless Children and Youth

program related to annual data collection,

o review problems with past data collection and discuss ways to address the

problems, and

o provide training and TA to local educational agencies (LEAs) specific to

Federal data collection.

Collect data on educational barriers for homeless students by maintaining technical

assistance and barrier tracking logs; these logs will be kept in a database and

reviewed to identify common barriers and specific LEAs where barriers exist. This

information will inform technical assistance to LEAs and state policy review and

revision.

Provide training and information to LEAs to assist them with data collection for

needs assessment.

Task 2. Collaboration within the SEA

Be part of the NC DPI Compensatory Education team by maintaining ongoing

communication and attending regular meetings of the Committee of Practitioners.

Identify areas of intersection between McKinney-Vento and other program areas,

(including Title I, Part A, special education, charter schools, early childhood, migrant

education, pupil transportation, food and nutrition). Meet with coordinators to

review and revise policies as needed and identify areas of coordination.

B-4-1 State Coordinators’ Handbook: Section B. Charting the Course. Appendix B-4. Sample Annual Scope of Work for the North Carolina Homeless Education Program July 1, 2009-June 30 2010

o Title I, Part A is a priority area – NCHEP staff will meet with Title I, Part A

staff to develop consistent policies and guidance between Title I and

McKinney-Vento, develop articles for the Title I newsletter, present at Title I

conferences, provide guidance and technical assistance to help Title I staff (1)

systematically identify appropriate Title I, Part A set aside amounts, (2)

determine appropriate ways in which Title I, Part A funds are to be spent on

homeless children and youth; and (3) show accountability for the amount set

aside and spent on homeless children and youth.

o IDEA requires representation from homeless education on its state advisory

council; NCHEP staff will follow up with this requirement and attend

scheduled meetings.

Task 3. Collaboration with other agencies, not SEA

Contact agencies, such as the Interagency Council on Homelessness, Head Start,

Governor’s Advocacy Council on Children and Youth, HUD Continuum of Care, North

Carolina Homeless Coalition, and set up meetings to inform them of the McKinney-

Vento Act and request to serve on their committees. Have links to NCHEP on their

website, submit articles to their newsletters, and present at their conferences

Task 4. Training, TA, support for LEAs and local liaisons (priority area)

Maintain an updated contact list for all local liaisons.

Develop and provide an orientation packet for all new liaisons; refer them to NCHE

webinars on the basics of the McKinney-Vento Act.

Provide regular communication to local liaisons via listserv.

Conduct five regional trainings during the school year for LEA liaisons and school

personnel that includes a McKinney-Vento Act overview and implementation

strategies, coordination with Title I, updates from the U.S. Department of Education,

and networking.


Conduct quarterly conference calls and/or webinars for all liaisons; provide notes

via listserv for those not in attendance.

Maintain and continually update a website with state policies, contacts for local

liaisons, links to national organizations.

Provide phone and email technical assistance to local liaisons.

Provide on-site technical assistance when necessary.

Resolve disputes.

Require LEAs to maintain technical assistance and intervention logs and provide

sample forms.

Provide materials (NCHE), such as posters, parent brochures, and school enrollment

guides, for local liaisons to conduct training and share information with school

personnel, including principals, school enrollment staff, teachers, school social

workers, pupil transportation, and attendance officers and to create community

awareness.

Task 5. Conduct, oversee, and monitor the McKinney-Vento subgrant program (priority

area)

Review end-of-the-year reports and budgets; identify technical assistance needs.

Allocate funds when received in July.

Conduct on-site monitoring of each subgrant in the course of the two-year cycle

(monitor half of subgrants in FY 2009).

o Develop a monitoring protocol that includes a review of expenditures and

project plans (Summer 2009).

o Develop a schedule for monitoring (Summer 2009).

Task 6. Monitoring of LEAs (priority area)

Conduct on-site or desk monitoring of approximately 20 percent of LEAs. Every LEA

will be monitored over a five-year period. Monitoring will include a review of


Federal data, technical assistance/barrier log entries, and policies and procedures.

Districts with indications that they are not in compliance will be prioritized for

monitoring and scheduled for customized technical assistance.

Develop desk and on-site monitoring protocols (Summer 2009).

o Develop a schedule for desk and on-site monitoring (Summer 2009).

Task 7. Policy review and development (priority area)

Review NC homeless education policies and procedures with regard to

identification, enrollment, and retention of homeless students and in the areas of

preschool and unaccompanied youth, Title IA, and charter schools.

Review Federal data and technical assistance/barrier logs for areas where policy

revision or clarification is needed.

Develop or revise policies and provide technical assistance on implementation.

Task 8. Reporting and administration

Provide monthly performance reports to NC DPI; have monthly meeting/call with

NC DPI.

Provide annual report and annual projected scope of work to NC DPI.

Have weekly team meetings with staff.

Attend NAEHCY conference, both State Coordinator and grant administrator.

Attend annual meeting in Washington D.C. (State Coordinator only).

Task 9. Overseeing the implementation of ARRA-MV grant funds

Provide technical assistance and guidance to LEAs on planning appropriate

expenditures.

Oversee LEA reporting requirements.

Provide onsite technical assistance to LEAs as necessary.

Submit required reports to U.S. Department of Education.


Appendix B-5. Sample Annual Planning Calendar (aligned for State fiscal year)

July Complete annual report Develop new annual

action plan and budget Prepare subgrant

proposals for reviewers and hold award meeting

Special Education Advisory Council (SEAC)

Interagency Council on Homelessness (ICH) meeting

Check on publications; order any needed for back-to-school mailing

August Make new subgrant

awards Schedule fall subgrant

meeting and regional trainings

Prepare back-to-school mailing for liaisons

Review budgets and balance accounts to ensure those that expire on September 30 are fully expended

Review Title I, Part A homeless reservations

Make travel arrangements for annual NAEHCY conference

September Conduct liaison trainings Hold subgrant webinar Close out expiring grants Interagency

Coordinating Council (ICC) meeting

Update liaison listing and list of subgrantees

Quarterly planning update

Update website (post new liaisons, awards, check hotlinks)

Close out expiring budget accounts

Prepare dates for year’s advisory board meetings

October Conduct liaison

trainings SEAC Review data for

submission to EDFacts; have LEAs verify local data

November NAEHCY Conference Complete LEA review of

EDFacts data, prepare state report

ICH meeting National Hunger and

Homeless Awareness Week

December Finalize data submission

to EDFacts for the CSPR ICC meeting Quarterly planning

update Make travel

arrangements for annual State Coordinators’ Meeting

January Prepare subgrant RFP

process for posting in March

SEAC ICH meeting

February Conduct subgrant

proposal training Begin monitoring visits Post LEA counts for

previous year once

March Attend State

Coordinators’ Meeting Conduct state

monitoring visits ICC meeting

B-5-1 State Coordinators’ Handbook: Section B. Charting the Course. Appendix B-5. Sample Annual Planning Calendar

Conduct LEA monitoring training; schedule LEA monitoring visits

Monitor state legislative session

Set up and disseminate state seminar registration

data are verified Quarterly planning update

Finalize seminar program and check with speakers

Update website (post new liaisons, awards, check hotlinks)

April Meet with EDFacts staff

to be clear on data collection responsibilities

SEAC ICH meeting Continue monitoring State seminar Advisory Board Meeting

May Complete monitoring

reports Provide guidance on

data collection to LEAs Recruit reviewers for

subgrant proposals Final report on

seminar (fiscal and evaluations) and follow up with speakers

Form seminar planning team; set date and location for next year’s seminar

Send reminder for NAEHCY scholarship to liaisons

June Collect materials for

annual report; review technical assistance and barriers

ICC meeting Quarterly planning

update Follow up on any

monitoring findings

B-5-2 State Coordinators’ Handbook: Section B. Charting the Course. Appendix B-5. Sample Annual Planning Calendar

Appendix B-6. Sample Monthly Planning Calendar (September)

Monday Tuesday Wednesday Thursday Friday3 Labor Day 4 Staff meeting

Make fall travel arrangements Review documents for Early Childhood Education (ECE) meeting

5 ECE Partnership Meeting

6 Prepare materials for trainings Schedule advisory board dates

7 Work on budget closeout

10 Prepare for training

11 Regional Liaison Training

12 Regional Liaison Training

13 14 Finalize budget closeout

17 Update liaison listing and post to website

18 Conference call with subgrantees regarding data collectionQuarterly SC Call with EDReview documents for Interagency Coordinating Council (ICC)

19 ICC meeting 20 21 Prepare materials for trainings

24 25 Travel day 26 Regional liaison training

27 Regional liaison training

28 Quarterly planning update

B-6-1 State Coordinators’ Handbook: Section B. Charting the Course. Appendix B-6. Sample Monthly Planning Calendar (September)

Appendix B-7. Sample Weekly Planning Calendar

Monday

September 17

Tuesday

September 18

Wednesday

September 19

Thursday

September 20

Friday

September 21

8 correspondence correspondence travel time correspondence correspondence

9 pay conference invoices; process

LEA reimbursements

pay conference invoices pay conference invoices process LEA reimbursements

10 liaison list update data collection call ICC Meeting travel authorizations for rest of month

11

12 lunch lunch

(walk and talk with assistant)

lunch

(check voicemail/email)

lunch lunch

1 review agenda and comments for

Tuesday’s data call

state coordinator quarterly call

ICC Meeting prepare for training

2 follow up on liaison listing inconsistencies

3 email

newsletter reading

prepare for Interagency Coordinating Council (ICC) meeting (read

minutes, updates, and pull files needed)

check voicemail/email

4

B-7-1 State Coordinators’ Handbook: Charting the CourseAppendix B-7. Sample Weekly Planning Calendar

5

B-7-2 State Coordinators’ Handbook: Charting the CourseAppendix B-7. Sample Weekly Planning Calendar

Appendix C-1. Connections to Consider

Required Connections

PartnerVehicle for

ParticipationLegal Citation Type of Structure

Title I, Part A Unspecified McKinney-Vento (MV) and Title I

Unspecified (however, both Title I, Part A and MV State Plans reference serving homeless students through Title I, Part A)

Special Education

State Special Education Advisory Committee

Individuals with Disabilities Education Act (IDEA), Part B

Committee

Early Intervention

Interagency Coordinating Council

IDEA, Part C Committee

Head Start Head Start Collaboration Project

MV and Head Start

Unspecified (coordination activities may include serving on a Head Start advisory board, conducting joint trainings, jointly developing a state memo)

School Nutrition State policy and procedures must be in place to ensure categorical eligibility for free meals to homeless students

Child Nutrition Act

Unspecified

EDFacts/CSPR Coordinators

State structure for submission

MV (in order to fulfill data

Unspecified

C-1-1 State Coordinators’ Handbook: Section C: Connections to Collaboration. Appendix C-1. Connections to Consider

PartnerVehicle for

ParticipationLegal Citation Type of Structure

(Data Stewards) of data to EDFacts for completion of the CSPR

request, this coordination is needed)

CASA-CJA Advisory Committee CASA-CJA

Homeless education representation is mandated in the Criminal Justice Act [Section 107 (c) of CAPTA]

Committee

HUD Interagency Coalition on Homelessness

Homeless Emergency Assistance and Rapid Transition to Housing (HEARTH) Act

Unspecified


Common Examples

Partner Activity

Title I, Part A Joint trainings, State Coordinator reviews reservation and plan for coordinating with MV in Title I application, shared monitoring of LEAs

State Homeless Coalitions

Making homeless a strand at a broader statewide conference on homelessness(If your State coalition has a newsletter, include education articles and distribute to educators rather than creating a separate newsletter.)

Pupil Transportation

Making funding available to provide school of origin transportation and conduct a study of impact

Regional State Coordinator Teams

Hosting regional/national conferences and liaison trainings, sharing policies and procedures, addressing border issues, reviewing each other’s subgrant applications, mentoring new coordinators

Higher Education Higher Education Networks bring K-12, Higher Education and other agencies to ensure successful transition to postsecondary study for students experiencing homelessness

Less Common/Emerging

Partner Activity

Higher Education Outsourcing of state MV administration

Financial Aid Administrators in higher education

Collaborative training, strategic planning that leads to the identification of liaisons on college campuses to assist with the transition from K-12 to higher education

Student Assistance Programs (SAP)

Joint training for McKinney-Vento Liaisons and SAP teams to introduce SAP teams to McKinney-Vento and explore the application of SAP to supporting students experiencing homelessness


Appendix C-2. Collaboration Goals for State Coordinators*

GoalIndicators or Measures

of EffectivenessSuccess Stories Strategies

Role of the State Coordinator (or

Designee)To increase awareness of the needs of homeless children and youth so that programs and agencies can expand and/or customize their services

Increased number of services for homeless children and youth

Increased number of services in collaborating agencies that have been customized to meet the unique needs of homeless children and youth

A medical clinic provides services to unaccompanied homeless youth.

A homeless shelter designates a “homework room” for school-aged children and youth.

Request to attend a staff or board meeting to do a short presentation on the educational needs of homeless children and youth; have a homeless child or youth speak.

Suggest concrete practices. Offer follow up meeting to

provide consultation services or to explore coordination of services.

Participate on State-level advisory boards or coalitions.

Increase awareness at State agencies through presentations so that they will provide information to LEA and community agencies.

Plan joint trainings with staff at State agencies for local meetings and conferences.

Provide contact information for local agencies to local liaisons and encourage them to make contact.

Provide an awareness presentation that local liaisons can use.

C-2-3 State Coordinators’ Handbook: Section C: Connections to Collaborations. Appendix C-2. Collaboration Goals for State Coordinators




Designee)

To coordinate services for efficient use of resources for a comprehensive approach to serving homeless children and youth and their families

Memorandum of agreement or plan for coordination that lists what each partner will contribute

Plan for integrated services that exceed what each individual agency offers

Process for mutual referrals

Increased number of homeless children, youth, and families that receive services from each agency involved in the partnership

A Head Start program and school district share enrollment forms. The Head Start program has families with school-aged children complete a school enrollment form and sends it to the local liaison. Local liaison has families with preschool-aged children complete a Head Start enrollment form.

Offer resources (consultation services, staffing, or funding) to increase services.

Conduct a needs assessment to identify areas of common need.

Meet with State-level agencies or programs to develop an MOU that can be used at the local level.

Award extra points for LEAs to include coordination activities in their subgrant applications, including a letter of commitment from potential collaborator.

To expand resources for homeless children, youth, and their families

Increased number of services for homeless children and youth

A faith-based organization provides backpacks with food and supplies for homeless children.

Conduct awareness activities in the community (at churches, civic organizations, colleges, and universities.)

Contact businesses with specific requests; get media coverage for their

Provide awareness presentations and materials to local liaisons.

Provide info on grant opportunities.

Include presentations on increasing





Designee)contributions.

Write grant proposals.resources at trainings.

To align policies and practices to remove barriers to services across programs and agencies

Aligned policies to which collaborating agencies agree

MOUs between collaborating agencies

The IDEA coordinator and local liaison agree on how to coordinate transportation to and from the school of origin for homeless children with special education needs.

Review phone calls and emails to identify areas of non-alignment.

Convene a meeting or task force to discuss the issue and identify how to align policies.

Develop a memo that clarifies how each program and agency will align its policies.

Meet with State-level programs and agencies to identify areas of non-alignment and develop policies at the State level to guide local alignment.

To build strong cross-agency advocacy and policy initiatives.

Proposed or enacted policies or laws that benefit homeless children, youth, and families

Youth agencies create a local task force to identify and address challenges for unaccompanied homeless youth to access programs and services.

Share data with agencies on barriers that result from policies or laws needed or in need of revision.

Identify champions with political power and provide information.

Participate on State-level advisory boards or coalitions.

*Developed for the 2015 State Coordinators Meeting by NCHE


Appendix C-3. Evaluating Current Collaborations

Appendix C-3 is a tool that can help you plan your collaboration activities. After reviewing required and recommended collaborations in Appendix C-1 and purposes for collaboration in Appendix C-2, consider current EHCY program collaborative opportunities, the status of the collaboration, and next steps.

At what tables am I required to participate?

How effective is the current arrangement?

What do I bring to the table that other participants need?

What do I need from the other participants?

How will the time I spend with these programs enhance the lives of children and youth experiencing homeless?

What should happen next?

Initiate? Maintain? Refine? (expand, limit,

change) Postpone?

Looking at outstanding needs of homeless children and youth, what participation goals should I set and what activities should I plan?

C-3-1 State Coordinators’ Handbook: Section C: Connections to Collaborations. Appendix C-3. Evaluating Current Collaborations

Appendix C-4. The Early Childhood Priority Project Agenda and Minutes Templates

The following meeting agenda and minute templates are used by the Virginia Early Childhood Priority Project (ECPP). A yearly schedule of meetings and rotating role assignments is prepared for members. In addition to pre-identified agenda items, members brainstorm additional issues that need to be addressed and estimate the amount of time required to address each one. The members always begin with celebrations (personal and professional) and announcements and often revisit their effectiveness as a team as part of the closure. 25

Meeting Agenda

[Date]

Facilitator: [assign] Recorder: [assign] Timekeeper: [assign]

Item or Issue Action TimePerson

Responsible

Celebrations

Announcements

Review past meeting notes, process observations

Item

Item

Item

Item

Meeting debrief or “check out”

Prioritize Issues

Total Amount of Time Needed:

25 Reprinted with permission from the ECPP.

C-4-1 State Coordinators’ Handbook: Section C: Connections to Collaboration. Appendix C-4. The Early Childhood Priority Project Agenda and Minutes Templates

Team Meeting Notes

Location:___________________ Time:________ Date:_______

Team members present:

Via phone:

Who will give handouts to and update each absent team member?____________________

Team roles: (the specific roles used may vary by team needs; roles are rotated among

members)

Facilitator______________ Co-facilitator_______________ Timekeeper_________________

Encourager_____________ Recorder__________________

Process observer (for fishbowling) Other__________________________________

Celebrations: (whip activity)

Announcements:

Review of past meeting minutes, process observations: (Record responses, comments,

corrections.)

Current agenda items: (List here.)


Carryover items and other agenda items for next meeting:

____________________________________ _________________________________________

____________________________________ _________________________________________

____________________________________ _________________________________________

Next meeting: Location: ________________________ Time: __________ Date:____________

_____________________________________________________________________________________

Agenda item:

Discussion:

Task:

Persons responsible:

When needed:


Appendix C-5. Overcoming Challenges to Collaboration*

Challenge Strategies

Lack of time Prioritize collaborative activities according to importance of goals, what is required by law, and amount of time needed.

Think in terms of a multiple-year strategy. Not all goals have to be accomplished in one year. Identify the type of activity needed for collaboration goals. Not all collaborations require extensive

investments of time. Don’t feel the need to attend every meeting.

o Review agendas ahead of time to note which meetings will address issues of relevance for homeless children and youth.

o Participate via conference call.o Review minutes of meetings that you do not attend and offer feedback by email or in a conversation

with the leadership.o Consider the possibility of delegating your representation.

Not welcomed at the table

Build the relationship. Give it the time it needs. Identify individuals who are open to building the collaboration. Let them be your champions. Be persistent in contacts. “Gentle pressure relentlessly applied over time, can change the course of a

river.” Offer something from which the agency will benefit (e.g., consultation, hosting a meeting, presentation). Consider how important it is to be at the table. Sometimes you will have to be patient and focus on those

places where you are welcome. Be open and sensitive to changes so you are ready to “jump in” when the climate changes.

Collaboration has no clear direction or goals

Suggest that the group conduct a formal or informal needs assessment to identify a common agenda and goals.

Identify short-term, easily attainable goals to “test the waters” (e.g., develop a joint memo, co-present at a

C-5-1 State Coordinators’ Handbook: Section C: Connections to Collaboration. Appendix C-5. Overcoming Challenges to Collaboration

conference).The SEA has no tangible resources to contribute

Promote the value of your expertise and connection to educational agencies. Provide support by hosting a meeting, conducting a presentation, or sending information to local

liaisons.Meetings are unproductive

Help with tasks that will make meetings productive (e.g., solicit items for and provide a written agenda, help with goal setting).

Suggest that the team conduct a self-assessment using a tool such as one provided through Mind Tools. If not mandated, determine whether you need to participate or should elect to leave the group. Leave the

door open to future work.Vast differences in culture, purpose, and goals

Build the relationship. Identify champions in other organizations who would be most likely to support you, and cultivate those relationships first.

Conduct conversations at meetings or with participants individually to identify areas of common need and interest.

Provide awareness of the perspective of education for homeless children and youth. Help create understanding of how the collaborating agency is and is not like education agencies.

Give members opportunities to share information about their organizations and how work is done.Negative history, lack of trust

Build the relationship. Identify champions in other organizations who would be most likely to support you, and cultivate those relationships first.

Maintain clear, transparent communication.*Developed for the 2015 State Coordinators Meeting by NCHE

C-5-2 State Coordinators’ Handbook: Section C: Connections to Collaboration. Appendix C-5. Overcoming Challenges to Collaboration

Appendix C-6. Creating a Statewide Advisory Board

By Brenda Myers, Former South Carolina State Coordinator

I became the State Coordinator shortly after the last reauthorization of the ESEA in

2002, so I inherited an approved State Plan. One of the items proposed in the State Plan

was the creation of a statewide advisory board. Since I wasn’t in the role when the plan was

written, I’m not sure where the idea for the board originated. One of the first steps we took

was to develop a comprehensive list of all the agency heads that might need to be included.

An invitation was sent to the agency heads as an official request from our State

superintendent, which gave it more clout than just coming from me. People accepted,

declined, or provided an alternate person to participate. We had about 22 agencies

involved, with 30-34 people at the table. We had representation from the University of

South Carolina, Department of Health and Environmental Control, South Carolina Housing

Authority, the United Way, faith-based organizations, the Red Cross, Department of

Juvenile Justice, HUD Continuum of Care, Veterans Administration, Department of Mental

Health, Department of Health and Human Services, Department of Social Services, early

childhood and Head Start, Hispanics Connections, Pupil Transportation, Title I, Special

Education, and School Nutrition. Later, we added law enforcement. I also had six homeless

liaisons – two with subgrants and four without grants. Since I worked more closely with my

subgrantees, I had a pretty good idea about what they would say. I wanted more

nongrantees to add a voice I didn’t know as well.

I never had fewer than 25 people at a meeting. We met quarterly, and our meetings

were a full day. At the first meeting, I provided an overview of the McKinney-Vento Act and

set the purpose of the board. We identified the big needs at that time: immediate

enrollment, school selection, Title I, transportation, and development of our dispute

resolution. (Now the foci would be different; it would probably be unaccompanied

homeless youth, Title I, transportation, and early childhood.) We divided into

subcommittees for each of the initiatives, and I included a liaison on each. I facilitated the

meetings, but I didn’t chair any of the subcommittees. There was a chair and vice chair for

each, and they took ownership for their charge. We would start each meeting as a whole

C-6-1 State Coordinators’ Handbook: Section C: Connections to Collaboration. Appendix C-6. Creating a Statewide Advisory Board

group and update everyone, and then we would break out into the committees to do the

actual work.

It really was not hard to start this initiative. It did save time because it brought all

the players to me. Before having the board, I always had to invite myself to the table. After

starting the board, things changed. There was more awareness, the Coalition president and

our HUD staff knew who I was and they knew I’d attend, so they recommend me to be at

other tables. Some great relationships came from this. For example, the Department of

Juvenile Justice recognized that one of their problems was figuring out what to do when a

youth was ready to leave but couldn’t go home. I was able to help them connect with the

shelters and group homes, so they got their needs met, too. We developed a State manual

that offered guidance to our school districts and drafted forms that could be used across

the State.

One of the hardest parts was deciding which agencies to include and how to involve

key folks without having such a large group that it wouldn’t work. Another major challenge

was getting agency folks who had such a strong policy focus to see CHILDREN FIRST and

keep the human focus. That was necessary to break down barriers and look outside the box

for solutions.

Yes, it was worth it. I enjoyed listening to outside groups and how they saw the issue

of homelessness. I was opening eyes! (2008)

C-6-2 State Coordinators’ Handbook: Section C: Connections to Collaboration. Appendix C-6. Creating a Statewide Advisory Board

Appendix C-7. Collaborating With Head Start

By Louis Tallarita, Connecticut State Coordinator

The job of State Coordinator is a challenge when you consider the range of children

and youth who are homeless and the variation of needs associated. Similarly, serving in the

role of State Coordinator, specifically within a respective State educational agency, it can

seem somewhat isolating being the sole entity advocating for the diverse needs of children,

youth and families experiencing homelessness. When the opportunity arises to involve

other professionals in beneficial collaboration to expand both the awareness and the

delivery of needed services, you grab it. A working collaboration between Head Start and

McKinney-Vento was a clear fit considering the crossover that exists in the target

populations.

Shortly after assuming the role of coordinator and soon after the reauthorization of

the Elementary and Secondary Education Act in 2002, I was asked to serve on the

statewide homeless advisory council that included the Head Start State Collaboration

director. During our service to the council, we met and began sharing information about

our program efforts and finding ways to include each other in the planning and

development of services to address the educational needs of young homeless children in

Connecticut. Our collaboration began with offers to read one another’s plans and proposals

and developing cross-training events. Over the years, it has remained a stable collaborative

effort and grown to include working together to fund and conduct a statewide needs

assessment and developing small grant programs to improve local partnerships and

increase enrollment of young children living in shelters into Head Start and other programs

that meet their health and learning needs.

As a “part-time” State Coordinator, collaboration items are likely to be some of the

more difficult ones to accomplish. I am largely focused upon the more immediate concerns

and less on long term goals and objectives that can ultimately improve systems; however,

developing these important partnerships is instrumental to this work, so the time

somehow seems to fit into my schedule when I plan accordingly, share responsibilities, and

value the efforts that are being combined. I’d have to say that no specific challenges come

C-7-1 State Coordinators’ Handbook: Section C: Connections to Collaborations. Appendix C-7. Collaborating with Head Start

to mind in the way this partnership evolved, although I would have to point back to the

“time” issue with competing priorities and a challenging workload.

It has absolutely been worth it. Not only I have I gained a partner, but also a friend

and ally. We remain committed to a goal that all young children who experience

homelessness arrive at the schoolhouse door, side by side with their housed peers, eager

and ready to succeed. Even our small steps forward have led the way to stronger and more

meaningful partnerships to assist families experiencing homelessness. (2008)

C-7-2 State Coordinators’ Handbook: Section C: Connections to Collaborations. Appendix C-7. Collaborating with Head Start

Appendix C-8. Collaborating With Higher Education

By Dana Scott, Former Colorado State Coordinator

When the College Cost Reduction and Access Act passed in 2007, my liaisons began

asking questions and saying things like, “What is a FAFSA? What do we do? Who do we

contact in higher education, and what do we say?” At the same time, I got a call from Misti

Ruthven, who works with College Invest, a division of the Colorado Department of Higher

Education. Misti called because she was getting questions from higher education financial

aid officers who wanted to know what this new “McKinney-Vento” requirement was about

following the first Application and Verification Guide (AVG). It was something like, “You

have your chocolate in my peanut butter; you have your peanut butter in my chocolate.”

We had something special when we put our skills together. I invited Misti to talk at

subgrant meetings, and Misti invited me to her higher education meetings so we could give

each group an introduction to the other’s work.

We started discussing how we could expand upon the partnership to bring these

stakeholders together statewide and create a systemic way of helping to support successful

transitions into higher education for unaccompanied homeless youth (UHY). We decided to

invite McKinney-Vento homeless liaisons, representatives from higher education (in

financial aid, admissions and student services), K-12 counselors, scholarship providers and

homeless service providers to join the Colorado Taskforce on Higher Education for

Unaccompanied Homeless Youth. During our first meeting with the group, one of the

greatest challenges was helping the higher education folks get comfortable with being

verifiers and understanding that they could do it. They were OK with using the other

verifiers for independent student status listed in the legislation (homeless liaisons, shelter

providers, and HUD or RHYA staff) but preparing them to make the determination when

none of these people were involved with the student took a lot of work. We had to address

jargon differences and provide sensitivity training to make sure the verification would be

handled respectfully with youth. They needed to understand how really vulnerable some of

these young people are. We realized we needed at least one person on each higher

education campus who understood the McKinney-Vento Act and would be willing to do the

outreach for unaccompanied homeless youth.

C-8-1 State Coordinators’ Handbook: Section C: Connections to Collaborations. Appendix C-8. Collaborating with Higher Education

Now we have a single point of contact at every college and university in Colorado,

who we have informally nicknamed our SPOCs (for Single Points of Contact) and more

formally refer to as our McKinney-Vento Higher Education Liaisons. SPOCs could be in

admissions, student services, or financial aid. They not only take care of verification, but

they help with the whole transition into college, as well as offer support throughout the

college experience. It’s amazing! We have teams of folks at the colleges and universities

who have taken this work and run with it. They put together welcome baskets that have

coupons for haircuts and movie tickets, along with basic necessities. SPOCs not only

connect students with financial aid and admissions, but they also connect our students with

housing services, tutoring, and FAFSA assistance for the next year.

Another challenge had to do with scheduling. The financial aid staff members

typically have only certain days they meet with students, and students have to schedule an

appointment on those days. If one of our students came by without an appointment or on

the wrong day, they would be turned away. We have been able to help staff in these offices

understand how difficult it could be for some of our youth to return, and now they make an

extra effort to try and assist the day the student comes to the office.

We developed a standardized process and form using the NAEHCY template (which

we modified a bit). It is used by liaisons, financial aid administrators, and service providers

and is recognized by all our SPOCs. Under FERPA, our liaisons are allowed to communicate

with higher education; however, since service providers are bound by HIPAA, we added a

signature line for youth to approve the communication between the provider and the

college. Interestingly, the form actually became a barrier for a while. The financial aid folks

were telling students they had to get the form completed, which actually put more work on

the student. We added financial aid as a verifier on the form to reinforce the fact that they

did not need anyone else to verify.

I don’t know how we found the time; we just found it. I do have more gray hairs! We

did 80 presentations/trainings across the state in 18 months. It does align with our work as

State Coordinators; it’s about successful transition for our students and helping to further

build the asset of education. While the collaboration may not save time, it certainly makes

our work far more effective. Misti and I have received great participation. We both have


strong relationships with our folks, and saying “You really need to come!” has been enough

to get involvement. I could not have done this work without my higher education partner.

Public K-12 education and higher education have different cultures and ways of doing

things, and this can, at times, cause tension, and the jargon differences can lead to

miscommunication. Misti and I helped each other understand when the differences

surfaced, and this allowed us to bridge and address those different cultures. Getting the

liaisons and high school counselors to talk with each is another part of the collaboration.

Now we highly recommend that our liaisons complete the form automatically whenever

they identify an unaccompanied homeless youth. They keep a copy, give one to the student,

and fax one to the high school counselor who is more likely to be in communication with

colleges. It really has filled communication gaps and sped up time for successful FAFSA

verifications.

The collaboration has created many new and exciting initiatives. Our SPOCs have

given us feedback that has led to incorporating “tips from higher education” in our

trainings. For example, they recommend that K-12 liaisons or counselors help youth set up

email accounts and make sure the students always have their name written the same way

on all forms. Sometimes our students have street names, which may not match their vital

documents; this has posed a big barrier to approving the FAFSA in the past. Access to vital

documents was another barrier for our youth. Now we have a partnership with College

Invest so there is a free web space where our youth can scan and store their documents,

making it a lot easier to have what is needed in a convenient place.

We are starting annual trainings for our SPOCs and will be asking them what we can

do to make the process better. For example, they have asked for a tip sheet to help them

with asking the right questions in an interview to use for verification.

Was it worth it? Absolutely! It seems daunting looking back; we were flying the

airplane while building it. Now we have food banks on campuses, dorms that are open on

breaks so our students have a place to stay, welcome baskets, and a sincere message to our

youth that, “We’re glad you’re here!” Peers are talking to each other and spreading the

word about this work. Now there is at least one person on each campus. Early on, I got a

call at 3:45 p.m. about a college student who was going to be evicted from her residence


hall at 5:00 p.m. because her financial aid was delayed due to lack of parent signature.

Everyone knew that going to a shelter would not be good for her. I told the liaison to

contact the SPOC at her university. Once they connected, they were able to postpone the

eviction and work out a process so the student could sign the FAFSA for herself. Events like

this make it all worthwhile. Two years ago, I had a college student transferring from a

Colorado college to Texas A&M. She was having a hard time getting the new school to work

with her (the law was just starting to be implemented). I was able to share the Application

Verification Guide with school and explain the process, and I copied the Texas State

Coordinator to keep her in the loop. The school took the information and ran with it. The

student was SO appreciative, and I did very little – she was the self-advocate. That was one

of my best days on the job!

This collaboration was one of the best things that has happened! Having a

passionate partner in higher education is a vital component. The extra time all of us put in

made it work. One Colorado school district has had a greater percentage of their UHY

graduate and go on to college than the overall district’s percentage (and their overall rate is

strong!). Liaisons and SPOCs can really be champions for UHY in a tangible realistic way

and show that college can be a reality. They can be the “caring, supportive adults” that our

students talk about who make all the difference in opening up doors and helping to

navigate systems that can be daunting for all of us. (2008)


Appendix E-1. Template for Debunking Myths About Homelessness*

Debunking Myths About Homelessness

Ask a roomful of people to describe a homeless person, and you are likely to get a wide variety of answers, but words like young, preschool, child, or toddler are not likely to be among the descriptions. Unfortunately, those words accurately describe many homeless persons, with more than 1.3 million homeless students identified by public schools across the country (NCHE, 2013). Moreover, as many as 42% of children who experience homelessness are under the age of six (National Center for Family Homelessness, 2010).

Many myths swirl around the definition of homelessness and the people who meet it, often making it difficult to accurately identify children who are homeless and link them to needed resources. This brief is designed to examine common myths and the reasons they are untrue.

Nearly [insert number] children from [insert State name] experience homelessness in a single year. This number has risen for the last [insert number] years, with a [insert number] percent increase in the number of children identified by public schools between the [insert school year] and [insert school year] school years. [Insert percentage] percent of children identified during the [insert school year] school year were pre-

school aged or in first to third grade.

[Insert a bar chart showing the number of homeless students enrolled in your state here. Include three to five years of data.]

In [insert year], [insert number] of [state name]’s [insert total number of counties] counties identified homeless students. Considering that [insert percentage] percent of the State’s population lives in rural communities of 10,000 people or less, this means a significant number of homeless in our State defy this myth.

Despite the common belief that homeless people live on the streets of large cities, the reality is that homeless children and youth live in a variety of places. A Federal law, the McKinney-Vento Homeless Assistance Act, defines homeless children and youths as individuals who lack a fixed, regular, and adequate nighttime residence. [42 U.S.C § 11434a(2)(A)] This can include children and youths who are sharing the housing of other

E-1-1 State Coordinators’ Handbook: Using Data Appendix E-1. Template for Debunking Myths About Homelessness

M Y T H : H O M E L E S S

P E O P L E A R E M O S T L Y

A D U L T S W H O M A D E

B A D C H O I C E S .

M Y T H : H O M E L E S S N E S S

I S A N U R B A N

P R O B L E M ; I T D O E S N ’ T

E X I S T I N R U R A L

A R E A S .

persons due to loss of housing, economic hardship, or a similar reason; are living in motels, hotels, trailer parks, or camping grounds due to the lack of alternative adequate accommodations; are living in emergency or transitional shelters; or are abandoned in hospitals. [42 U.S.C. § 11434a(2)(B)(i)] It also includes children and youths who have a primary nighttime residence that is a public or private place not designed for or ordinarily used as a regular sleeping accommodation for human beings; children and youths who are living in cars, parks, public spaces, abandoned buildings, substandard housing, bus or train stations, or similar settings; and migratory children who are living in one of the previously mentioned circumstances. [42 U.S.C. §§ 11434a(2)(B)(ii)-(iv)]

While homeless shelters and housing programs do a great deal to help people experiencing homelessness, they are not an option for everyone. During [insert year], [state name] had [insert number] shelter beds for homeless families, including adults. Only [insert number] beds were dedicated for exclusive use by homeless children (reference data from HUD’s AHAR report), but nearly [insert number from schools] children were identified as homeless during the [insert year] school year. Services provided by

housing programs for homeless families vary as well. For example, while [insert number] of the State’s counties have an emergency shelter, some shelters focus only on survivors of domestic violence or persons with substance abuse issues. Others only provide housing to women or families but will not accept adolescent boys.

People need a mode of transportation to get to work, and for many people that requires a car. While buses and other public transportation do provide an option for persons living in the larger cities, rural and suburban areas do not have a public transportation system. For this reason, many families will make a car or vehicle insurance payment over a mortgage payment, or they may own their car outright and therefore have more limited costs associated with its ownership.

Cell phones are also not an accurate indication of a person’s housing situation. Staying in contact with potential employers is especially important for homeless persons who are in need of a job. Homeless families have the same need to be easily reached or to easily reach others in case of an emergency regarding their children. Furthermore, survivors of domestic violence may be given cell phones free of charge for safety reasons.


M Y T H : H O M E L E S S S H E L T E R S

P R O V I D E E V E R Y T H I N G A

H O M E L E S S P E R S O N N E E D S T O

G E T B A C K O N T H E I R F E E T ;

P E O P L E S H O U L D J U S T G O T O

T H E S H E L T E R I F T H E Y ’ R E

H O M E L E S S .

M Y T H : H O M E L E S S P E O P L E

D O N ’ T H A V E T H I N G S L I K E

C A R S O R C E L L P H O N E S . I F

T H E Y D O , T H E Y ’ R E P R O B A B L Y

L Y I N G A B O U T T H E I R H O U S I N G

S I T U A T I O N .

Most homeless families cannot be distinguished from others just by looking at them or their belongings. They may still have possessions from the time before they lost their homes, or they may have received some of their possessions from organizations or individuals who work with homeless families.

Ideally, this would be true. Unfortunately, going home is not an option for many unaccompanied homeless youth. The most commonly cited reason for crisis calls received by the National Runaway Safeline (NRS) is family dynamics. While 30% of callers to the NRS crisis line stated they had run away from home, nearly half said they had been thrown out of their homes, and another 22% said they experienced a

combination of being thrown out and leaving on their own. More than a quarter of the youth had parents who knew where they were at the time they called NRS for help (2014). Further complicating things, nearly half of youth living on the street and a third of those living in shelters report having ever been pregnant, meaning that some youth may be homeless and parenting young children (NRS, 2014).

Data from the [SEA name] show that homeless high school seniors come back for an extra year to complete high school graduation requirements, with [insert number] percent more homeless seniors completing the requirements in the additional year than the State average. Additionally, over a four year period of time, homeless students improved their

graduation rate by [insert number] percent.

It is true, however, that homeless students of all ages experience challenges to getting an education. Laws and programs like the McKinney-Vento Act, the Head Start Act, and the Individuals with Disabilities Act (IDEA) provide supports for students experiencing homelessness that make it possible for them to participate in their education, even without stable housing. For example, an early intervention specialist may arrange to provide services at the homeless shelter, meeting the needs of the family and IDEA’s requirement to provide services in the natural environment.

Homeless families in particular are often desperate to avoid homelessness with their children. Sometimes they are even referred to as the invisible homeless due to the steps parents and caregivers take to avoid living in places that make it obvious they are

homeless, such as on the streets or even in shelters. Many live in fear that their children will be taken away from them due to their homelessness, even when they are providing quality care for


M Y T H : I F A T E E N A G E R I S N ’ T

L I V I N G A T H O M E , T H E Y

S H O U L D J U S T G O H O M E A N D

T H E I R P A R E N T S S H O U L D

T A K E C A R E O F T H E M .

M Y T H : I F I A D M I T A

H O M E L E S S P E R S O N I N T O M Y

P R O G R A M O R S C H O O L ,

T H E Y ’ L L J U S T D R O P O U T .

M Y T H : P E O P L E W H O A R E

H O M E L E S S J U S T T A K E

A D V A N T A G E O F T H E S Y S T E M .

their children. Rates of homelessness and unemployment in the United States during the Great Recession and its aftermath can only be rivaled by three other times in U.S. history: the Civil War, the Great Depression, and the economic downturn of the 1980s. Rising costs for housing, high unemployment rates and stagnating salaries, high healthcare and daycare costs, and natural disasters all impact a family’s ability to maintain regular housing.

Almost half of Americans reported they have a hard time meeting monthly financial obligations, and only slightly over half of Americans say they have a rainy day fund to support them during times of economic

shock (Lusardi, 2010). While it may be easy to think that it is only those with low incomes who fall into the category of financially fragile, 47% of persons surveyed from a middle income group indicated they had difficulty making ends meet (Lusardi, 2010). The causes of homelessness also include things beyond human control, with 144 natural disasters since 1980 that totaled $1 billion or more in damages to communities (National Weather Service, n.d.). As a result of these factors and more, homelessness can happen to anyone at any time.

While no one individual can end homelessness on a global scale, you can make a large impact on the life of an individual in your community. Volunteering at an agency that serves homeless students, sharing information about homelessness with early childhood programs and public schools, reading to or tutoring children experiencing homelessness, or serving as

your agency’s liaison for homeless families are all examples of ways to impact people and your entire community.

For more information on homelessness and education, please visit the website of the National Center for Homeless Education at http://center.serve.org/nche/ .

[Insert additional information about your SEA website or liaison contact information.]

References

[Insert reference from HUD’s AHAR and any references appropriate to your data.]

Lusardi, A., Mitchell, O.S., & Curto, V., (2010) Financial literacy among the young. Journal of Consumer Affairs, 44(2), 358-380.

National Runaway Safeline, (2014) Why they run. Retrieved from http://www.1800runaway.org/homeless-teen-research/why-they-run/.


M Y T H : H O M E L E S S N E S S W I L L

N E V E R H A P P E N T O M E .

M Y T H : I C A N ’ T D O A N Y T H I N G

T O I M P A C T H O M E L E S S N E S S ;

T H I S I S S U E I S B I G G E R T H A N

M E .

National Weather Service Weather Forecast Office. (n.d.). Climate feature: NCDC billion dollar disasters. Retrieved August 2016 http://www.ncdc.noaa.gov/billions/events

*Developed by Christina Endres, National Center for Homeless Education


http://www.ncdc.noaa.gov/billions/events

Appendix F-1. Duties of Local Liaisons

(A) DUTIES – Each local educational agency liaison for homeless children and

youths, designated under paragraph (1)(J)(ii), shall ensure that—

(i) homeless children and youths are identified by school personnel through

outreach and coordination activities with other entities and agencies;

(ii) homeless children and youths are enrolled in, and have a full and equal

opportunity to succeed in, schools of that local educational agency;

(iii) homeless families and homeless children and youths have access to and

receive educational services for which such families, children, and youths

are eligible, including services through Head Start programs (including

Early Head Start programs) under the Head Start Act (42 U.S.C. 9831 et

seq.), early intervention services under part C of the Individuals with

Disabilities Education Act (20 U.S.C. 1431 et seq.), and other preschool

programs administered by the local educational agency;

(iv) homeless families and homeless children and youths receive referrals to

health care services, dental services, mental health and substance abuse

services, housing services, and other appropriate services;

(v) the parents or guardians of homeless children and youths are informed of

the educational and related opportunities available to their children and

are provided with meaningful opportunities to participate in the education

of their children;

(vi) public notice of the educational rights of homeless children and youths is

disseminated in locations frequented by parents or guardians of such

children and youths, and unaccompanied youths, including schools,

shelters, public libraries, and soup kitchens, in a manner and form

understandable to the parents and guardians of homeless children and

youths, and unaccompanied youths;

(vii) enrollment disputes are mediated in accordance with paragraph (3)(E);

(viii) the parent or guardian of a homeless child or youth, and any

unaccompanied youth, is fully informed of all transportation services,

F-1-1 State Coordinators’ Handbook: Section F. Technical Assistance for Local Educational Agencies. Appendix F-1. Duties of Local Liaisons

including transportation to the school of origin , as described in paragraph

(1)(J)(iii), and is assisted in accessing transportation to the school that is

selected under paragraph (3)(A);

(ix) school personnel providing services under this subtitle receive professional

development and other support; and

(x) unaccompanied youths—

I. are enrolled in school;

II. have opportunities to meet the same challenging State academic

standards as the State establishes for other children and youth, including

through implementation of the procedures under paragraph (1)(F)(ii);

and

III. are informed of their status as independent students under section 480

of the Higher Education Act of 1965 (20 U.S.C. 1087vv) and that the

youths may obtain assistance from the local educational agency liaison

to receive verification of such status for purposes of the Free Application

for Federal Student Aid described in section 483 of such Act (20 U.S.C.

1090). [42 U.S.C. § 11432(g)(6)(A)]

LOCAL AND STATE COORDINATION – Local educational agency liaisons for homeless children and youths shall, as a part of their duties, coordinate and collaborate with State Coordinators and community and school personnel responsible for the provision of education and related services to homeless children and youths. Such coordination shall include collecting and providing to the State Coordinator the reliable, valid, and comprehensive data needed to meet the requirements of paragraphs (1) and (3) of subsection (f). [42 U.S.C. § 11432(g)(6)(C)]

F-1-2 State Coordinators’ Handbook: Section F. Technical Assistance for Local Educational Agencies. Appendix F-1. Duties of Local Liaisons

Appendix F-2. Important Contacts for Local Liaisons

Contact Phone; Email; Website Type of support

State and National

State Coordinator Technical assistance

NCHE Helpline 1-800-308-2145 (toll-free) or [email protected]

Technical assistance

NCHE listserv https://nche.ed.gov/listserv.php Requesting and sharing information

NAEHCY http://www.naehcy.org Work occurring in other states, legislative updates, conference opportunities

Local Educational Agency

Title I Coordinator

School Nutrition Coordinator

Pupil Transportation Director

Special Education Coordinator (including Child Find)

Drop-out/Truancy Administrator

Enrollment Coordinator

Head Start, Early Head Start, and other public preschool administrators

LEA administered

F-2-1 State Coordinators’ Handbook: Section F. Technical Assistance for Local Educational Agencies. Appendix F-2. Important Contacts for Local Homeless Liaisons

http://www.naehcy.org/


mailto:[email protected]?subject=homeless%20education%20helpline%20request

preschool programs, including Early Childhood Special Education

Early Intervention (IDEA Part C)

HUD Local Continuum of Care Director

Local Shelters

Homeless Coalition Partners

Housing Coalition Partners

United Way

Salvation Army

Food Banks

Medical Clinics

Other Providers

F-2-2 State Coordinators’ Handbook: Section F. Technical Assistance for Local Educational Agencies. Appendix F-2. Important Contacts for Local Homeless Liaisons

Appendix F.3. McKinney-Vento Top Fives

This template may be customized to reflect the most important items in each category that you would like to include for local liaisons in your State.

MV TOP 5S5 Documents to Read

1. McKinney-Vento Act – EHCY Program, Title IX, Part A of the ESSA

2. Homeless Liaison Toolkit3. Intro to Homelessness Brief4. Determining Eligibility

Document5. Unaccompanied Youth Brief

5 People to Know in Your District1. Title I Coordinator 2. Director of Transportation3. Head of Enrollment4. Head of Nutrition Services5. Information Technology Staff

(who submit data to the SEA)

5 Resources to Utilize1. State Department of

Education2. Other Liaisons3. National Center for Homeless

Education (NCHE)4. National Association for the

Education of Homeless Children and Youth (NAEHCY)

5. State Higher Education Network

5 Handouts to Distribute:1. Enrollment Cards/Forms2. Brochures/Posters/Flyers 3. Homeless Rights Handout4. Resource Cards5. School Toolkits

5 (+ 1) Audiences for Training1. Secretaries/Registrars/Enrollment Staff2. Title I Staff 3. Principals, Superintendents and Other

Administrators4. Social Workers and School Counselors5. Teachers6. Nurses

5 Action Steps after this Training1. Develop an Enrollment Form. (Be sure it

includes data collection for unaccompanied youth.)

2. Create a Training Schedule with Target Audiences. (It is often helpful to have a first tier and second tier training schedule.)

3. Make an appointment with your Title I Coordinator. (Discuss your District’s Title I plan to serve homeless students and the level of reserved homeless set-asides.)

4. Meet with your data manager.5. Hang posters in all school sites and

community venues.

F-3-1 State Coordinators’ Handbook: Section F. Technical Assistance for Local Educational Agencies. Appendix F-3. McKinney-Vento Top Fives

Appendix F-4. Sample Technical Assistance LogsThe following template can be replicated for each technical assistance request. Technical assistance requests will come from local liaisons, State or local agencies, or homeless service providers who either have questions about the McKinney-Vento Act or the EHCY program, or will specifically request training or information. Note that this log is different from the Barrier Tracking Log in Appendix F-7. The Barrier Tracking Log is for the documentation of barriers or complaints. To determine if a contact should be logged in the Barrier Tracking Log, consider the following question: “Does it appear that this contact pertains to a homeless student who is being denied access to an appropriate public education or that a school or LEA is out of compliance with the McKinney-Vento Act?” If the answer is yes, this contact should be logged in a form similar to the template provided in Appendix F-7.

Date Summary of Discussion

Follow up?

To/From

Phone #

LEA, Program, or Agency

Topic or Need

Summary of Assistance/ Materials Provided/ Activity Planned

F-4-2 State Coordinators’ Handbook: Section F. Technical Assistance for Local Educational Agencies. Appendix F-4. Sample Technical Assistance Logs

The following table may be used in conjunction with the Technical Assistance Log as a quick reference to the topic of the contact. This table may be adapted to your State’s needs by revising or adding to the list of suggested topic.

Caller City/

Region Phone # LEA Title/Role

Date ResolvedDate

general Information M-V subgrantees enrollment access to services NAEHCY collab./resources/referrals assistance for another state national level assistance research questions

budget/project activities preschool proposal preparation unaccompanied youth other fiscal questions

immigration LEA responsibilities special education/eligibility local policies Title I and other federal programs data collection definition of homeless nutrition services

med/dent/health referrals identification mentoring duration of homelessness school supplies/clothing verify homeless/eligibility tutoring residency summer school

family violence-safety physical/immunizations guardianship community-school communication school records housing support referral immigration previous expulsion statistics/history/background

training-regional requests/seminar

school of origin (SOO)

poor attendance/misbehavior written notification transportation dispute resolution procedure

F-4-3 State Coordinators’ Handbook: Section F. Technical Assistance for Local Educational Agencies. Appendix F-4. Sample Technical Assistance Logs

Appendix F-5. Potential Pitfalls and Possible Solutions for Liaison Training

Potential Pitfalls Possible Solutions

Resistant liaisons who see their new responsibilities as a burden

Maintain a focus on the student. Remember that most educators choose the field because they want to improve the lives of children.

Acknowledge the challenges while highlighting how compliance has the potential to improve educational experiences for all children.

Liaisons with no background in homelessness

Include cases studies and awareness-building activities to build context.

Pair experienced and new liaisons during training. Consider separate trainings for liaisons with varied experiences. Differentiate group activities based on levels of experience.

Limited staff capacity at LEA; % FTE allocated to liaison position is not adequate

Consider writing a letter or other communication with the liaison’s supervisor/program director outlining LEA responsibilities and the importance of compliance with McKinney-Vento and Title I requirements.

Ask that the supervisor be present for local monitoring visits, and/or other site visits to LEA.

Include capacity requirement in applications for McKinney-Vento or other grants awarded by SEA.

Low attendance at trainings

Explore the possibility of assigning certification/re-licensure points for participation.

Analyze the convenience of times and locations. “Piggy-back” with other training/conference events that attract the

needed audience. Explore the possibility of making training attendance a State-level

requirement. Call the meetings “mandatory compliance meetings.” Hold regional meetings so that liaisons don’t have far to travel;

host webinars for the same reason.

Training sessions that tend to get derailed by discussion of individual problems and/or worst case scenarios

Maintain a “parking lot” flipchart page of issues that can be discussed later (if time allows) or addressed through subsequent mailings/trainings.

Remind participants that “worst case scenarios” are infrequent and redirect to most common situations as quickly as possible. (Experienced liaisons who can support such comments are extremely helpful here.)

Invite participants who are derailing the session to discuss the issue with you later.

F-5-4 State Coordinators’ Handbook: Section F. Technical Assistance for Local Educational Agencies. Appendix F-5. Potential Pitfalls and Possible Solutions for Liaison Training

Appendix F-6. Quick Tips for Presenters

Power of 3/Getting the Point Across

Many practiced public speakers ranging from pastors to politicians repeat important points three times. They introduce the points in the opening, elaborate on each during the presentation, and summarize each in the closing statements.

Time Use Imagine that your presentation time is divided into three parts: an introduction, an explanation/interaction, and a wrap-up. Try to spend approximately 25% of the time on the introduction, 50% of the time on the explanation, and 25% on the wrap-up.

Handouts People are most likely to read handouts when they get them, so give time to look over the materials before launching into your presentation or immediately asking participants to look for or do something in the handout.

Assure participants that information on the slides is included in the handouts so they will not have to spend time during the presentation taking lots of notes.

Participant Involvement

A quick activity, demonstration of technique, or non-threatening question can enhance audience participation.

Slide Presentation

Prepare slides that all participants can see by using a plain font (such as Times Roman, Helvetica, or Arial), selecting a large font size (18 point or larger), including no more than eight lines of text per slide.

Be familiar with the slides so that you do not have to read them.

Movement Limit your movement when speaking. Some participants may be very distracted if you “talk with your hands” or play with items in your pockets.

Information If referencing a book, know the title, author, and ISBN number. People always ask.

Provide URLs in your handouts for information and resources available on line; provide handouts electronically so that online information can be accessed quickly.

Provide contact data including phone number, e-mail address, and/or

F-6-5 State Coordinators’ Handbook: Technical Assistance for Local Educational AgenciesAppendix F-6. Quick Tips for Presenters

mailing address.

Adult Learners

Adult learners are different from students in K-12 classrooms. Adult learners are responsible for their own learning, and they seek ways to fill that need.

Adult learners are involved in workshops for a variety of reasons, such as professional benefit, benefits to their students, mandatory attendance requirement, or personal interest.

Adult learners are professionals in their field and can benefit from both the presentation and the opportunity to interact with colleagues.

Participants like to leave knowing how they can affect positive change. One way to ensure this is to offer them something that they can try immediately when they get back to school. It should be fairly easy to implement with few, if any, materials needed.

F-6-6 State Coordinators’ Handbook: Technical Assistance for Local Educational AgenciesAppendix F-6. Quick Tips for Presenters

Appendix F-7. Barrier Tracking Form for Phone and Email Contacts

The following log should be completed for each phone or email contact related to a barrier or complaint, and kept on record in a file separate from other types of contacts. To determine if the contact is a technical assistance request or barrier issue, ask yourself, “Does it appear that the homeless student referenced in the contact is being denied access to an appropriate public education, or that a school or LEA may be out of compliance with the McKinney-Vento Act?”

Contact DateResponse DateContact NameContact RoleSchool or AgencyPhone or EmailBarrier TopicDetails

Response

Follow-up Needed

Responder’s NameResponder’s RolePhone or Email

F-7-1 State Coordinators’ Handbook: Technical Assistance for Local Educational AgenciesAppendix F-7. Barrier Tracking Form for Phone and Email Contacts

Appendix G-2. Sample State EHCY Dispute Resolution Policy

DISPUTE RESOLUTION PROCESS

SCHOOL DISTRICT PLACEMENT OF CHILDREN AND YOUTHS

IN HOMELESS SITUATIONS

Washington, State (2013)

(Note – this inclusion in the handbook has not been updated to reflect the 2015 reauthorized law.)

BACKGROUND INFORMATION

The McKinney-Vento Homeless Assistance Act (also referred to as the Act or the McKinney-Vento Act) acknowledges that disputes may arise between the school district and homeless students and their parents, or unaccompanied youth, when the district seeks to place a student in a school other than the school of origin or the school requested by the parent or unaccompanied youth. The Act includes dispute resolution among the required duties of the local education agency (LEA) liaison. The Washington State Office of Superintendent of Public Instruction (OSPI) has developed a dispute resolution process as required by the McKinney-Vento Act.

Districts should bear in mind that disputes related to school selection or enrollment should be initiated at the request of the parent or unaccompanied youth and not at the request or convenience of the school district. Additionally, issues related to the definition of homelessness, the responsibilities of the school district to serve homeless children and youth, and/or the explicit rights of homeless children and youth are addressed in the McKinney-Vento Act. Disputes related to the school placement and enrollment of homeless children and youths shall be resolved within the parameters of the federal McKinney-Vento Act. The dispute resolution process for the school placement of homeless children and youths shall not be used in an effort to circumvent or supersede any part of the federal McKinney-Vento Act.

The following procedures are specified in the Act:

G-2-1 State Coordinators’ Handbook: Dispute Resolution. Appendix G-2. Sample State EHCY Dispute Resolution Policy

Enrollment: If a dispute arises over school selection or enrollment in a school, the child or youth shall be immediately admitted to the school in which enrollment is sought, pending resolution of the dispute. In the case of an unaccompanied youth, the homeless liaison shall ensure that the youth is immediately enrolled in the school in which enrollment is sought, pending resolution of the dispute.

Written Explanation: The district must provide a written explanation of the school placement decision to the parent or, in the case of an unaccompanied youth, to the unaccompanied youth. (The written explanation must include a description of the parent’s or unaccompanied youth’s right to appeal the decision.)

Liaison: The designated LEA homeless liaison is assigned to carry out the dispute resolution process in an expeditious manner.

Responsibility: The school district, usually the district’s homeless liaison, is responsible to inform the parent of the homeless student(s) or the unaccompanied youth of the dispute resolution process.

OVERVIEW

In a case where a dispute occurs regarding the enrollment of a homeless child or youth, the following process must be used: Level I of the appeal is to the district’s homeless liaison. If unresolved at this level, the case is appealed to the local school district superintendent (Level II), and if the dispute continues to be unresolved, the final appeal (Level III) is to OSPI. Every effort must be made to resolve the complaint or dispute at the local level before it is brought to OSPI.

INITIATION OF THE DISPUTE RESOLUTION PROCESS

If a school district seeks to place a homeless child or youth in a school other than the school of origin, or the school requested by the parent or unaccompanied youth, the child’s/youth’s parent or the unaccompanied youth shall be informed in a language and format


understandable to the parent or unaccompanied youth of their right to appeal the decision made by the school district and be provided the following:

1. Written contact information for the LEA homeless liaison and State Coordinator, with a brief description of their roles.

2. A simple, written detachable form that parents, guardians, or unaccompanied youth can complete and turn in to the school to initiate the dispute process (the school should copy the form and return the copy to the parent, guardian, or youth for their records when it is submitted.)

3. A written step-by-step description of how to dispute the school district’s decision.4. Written notice of the right to enroll immediately in the school of choice pending resolution

of the dispute.5. Written notice of the right to appeal to the state if the district-level resolution is not

satisfactory.6. Written timelines for resolving district- and state-level appeals.

Level I: LEA Liaison Communication

If a parent or unaccompanied youth wishes to appeal a school district’s decision related to a student’s placement:

1. The parent or unaccompanied youth must file a request for dispute resolution with the district’s homeless liaison by submitting a form that initiates the dispute resolution process. The request for dispute resolution must be submitted by the parent or the unaccompanied youth to the district liaison within fifteen (15) business days of receiving notification that the district intends to enroll the student in a school other than that requested by the family or the unaccompanied youth. The parent or unaccompanied youth may submit the request directly to the homeless liaison or they may submit the request to the school where the dispute is taking place. If the request is submitted to the school where the dispute is taking place, the school shall immediately forward the request to the district’s homeless liaison. In the event that the district’s homeless liaison is unavailable, a school district designee may receive the parent's or unaccompanied youth's request to initiate the dispute resolution process.

2. The homeless liaison must log their receipt of the complaint, including the date and time, with a written description of the situation and the reason for the dispute, and a copy of the complaint must be forwarded to the liaison’s immediate supervisor and the district superintendent.

3. Within five (5) business days of their receipt of the complaint, the liaison must make a decision on the complaint and inform the parent or unaccompanied youth in writing of the result. It is the responsibility of the district to verify the parent’s or unaccompanied youth’s receipt of the written notification regarding the homeless liaison’s Level I decision.


4. If the parent or unaccompanied youth disagrees with the decision made at Level I and wishes to move the dispute resolution process forward to Level II, the parent or unaccompanied youth shall notify the district’s homeless liaison of their intent to proceed to Level II within ten (10) business days of receipt of notification of the Level I decision.

5. If the parent or unaccompanied youth wishes to appeal the liaison’s Level I decision, the district’s homeless liaison shall provide the parent or unaccompanied youth with an appeals package containing:

a. A copy of the parent’s or unaccompanied youth’s complaint which was filed with the district’s homeless liaison at Level I,

b. The decision rendered at Level I by the LEA liaison, andc. Any additional information from the parent, unaccompanied youth, and/or

homeless liaison.

Level II: LEA Superintendent Communication

(If the dispute remains unresolved after a Level I appeal)

1. If a parent disagrees with the decision rendered by the district’s homeless liaison at Level I, the parent or unaccompanied youth may appeal the decision to the local school district’s superintendent, or the superintendent’s designee, (the designee shall be someone other than the district’s homeless liaison) using the appeals package provided at Level I.

2. The superintendent, or superintendent’s designee, will arrange for a personal conference to be held with the parent or unaccompanied youth. The personal conference will be arranged within five (5) business days of the parent or unaccompanied youth’s notification to the district of their intent to proceed to Level II of the dispute resolution process. Once arranged, the meeting between the superintendent, or superintendent’s designee, and the parent or unaccompanied youth is to take place as expeditiously as possible.

3. The local superintendent, or superintendent’s designee, will provide a decision in writing to the parent or unaccompanied youth with supporting evidence and reasons, within five (5) business days of the superintendent’s, or superintendent's designee, personal conference with the parent or unaccompanied youth. It is the responsibility of the district to verify the parent’s or unaccompanied youth’s receipt of the written notification regarding the superintendent’s Level II decision.

4. A copy of the appeals package, along with the written decision made at Level II is to be shared with the district’s homeless liaison.

5. If the parent or unaccompanied youth disagrees with the decision made at Level II and wishes to move the dispute resolution process forward to Level III, the parent or unaccompanied youth shall notify the district’s homeless liaison of their intent to proceed to Level III within ten (10) business days of receipt of notification of the Level II decision.

6. If the dispute remains unresolved, the process then moves to Level III.

Level III: Office of Superintendent of Public Instruction (OSPI) Communication

(If the dispute remains unresolved after a Level II appeal)


1. The district superintendent shall forward all written documentation and related paperwork to the OSPI homeless education coordinator, or designee, for review, within five (5) business days of notifying the parent or unaccompanied youth of the decision rendered at Level II.

2. The entire dispute package including all documentation and related paperwork is to be submitted to OSPI in one consolidated and complete package via hard copy mail delivery. Documents submitted separately from the dispute package, documents submitted after the fact, or documents submitted outside of the dispute package in an attempt to extend the dispute timeframe or impact a pending dispute outcome may not be reviewed by OSPI. It is the responsibility of the district to ensure that dispute packages are complete and ready for review at the time they are submitted to OSPI.

3. The OSPI homeless education coordinator, or designee, along with the appropriate agency director, and/or agency assistant superintendent, shall make a final decision within fifteen (15) business days of receipt of the complaint.

4. The final decision will be forwarded to the local school district’s homeless liaison for distribution to the parent and the local superintendent.

5. The decision made by OSPI shall be the final resolution for placement of a homeless child or youth in the district.

6. The office of the school district superintendent shall maintain a record of all disputes related to the placement of homeless children and youths. These records shall include disputes resolved at Level I, Level II, and/or Level III and shall be made available to OSPI upon request.

INTER-DISTRICT DISPUTES

If a dispute arises over school selection or enrollment in a school, the child or youth shall be immediately admitted to the school in which enrollment is sought, pending resolution of the dispute. In the case of an unaccompanied youth, the homeless liaison shall ensure that the youth is immediately enrolled in school pending resolution of the dispute.

Disputes arising between school districts (LEAs) regarding the placement of a homeless child or youth in a district should be resolved between the districts at the local level in the best interest of the child and according to the law. Disputes between LEAs that remain unresolved shall be forwarded in writing by either of the disputing districts to the OSPI homeless education coordinator, or designee. A decision will be made by the OSPI homeless coordinator, or designee, along with a committee of OSPI staff within ten (10) business days of the receipt of the dispute and will be forwarded in writing to the districts' superintendents, the districts' homeless liaisons and the parent(s) of the homeless child, or the homeless youth.


The decision made by OSPI shall be the final resolution between the disputing LEAs for placement of a homeless child or youth in a district.


Appendix G.3. A Differentiated Process to Address Conflicts

G-3-1 State Coordinators’ Handbook: Dispute Resolution. Appendix G-3. A Differentiated Process to Address Conflicts

Conflict is brought to the attention of the State Coordinator

Collect initial information; contact local liaison

Determine appropriate process*

Resolve informally and document

*Ongoing fact finding may change the section of the process selected for resolution.

Can parent/LEA come to an agreement given additional info?

Yeses

No

Is enrollment or school selection challenged?

Yes Ensure enrollment in school; direct school to provide written notice

YesIs this an appeal following written notice?

Follow state level dispute resolution process

Is more information needed to determine homeless eligibility?

No

No

Yes

Provide liaison and parent/guardian/youth with explanation of determination and what procedures should be followed.

No

Appendix G-4. Information to Include in an Intake Form When a Call or Email is Received

Person completing form:

Date:

Person calling:

Relationship to students:

Location:

Phone number(s)

How did the person calling obtain the State Coordinator’s contact information:

School district(s):

School(s):

Age(s)/grade(s) of student(s):

Family situation:

Current housing situation:

Housing/homeless history:

Concerns/complaints:

Resolution desired:

If eligibility as homeless is an issue, was an eligibility checklist used? Did the liaison help the family understand why the living situation should not be considered homeless? (State Coordinator may collect information for this process.

If school selection is an issue, was a best interest determination conducted?

Follow up with liaison: (date and narrative)

Resolution:

G-4-1 State Coordinators’ Handbook: Dispute Resolution. Appendix G-4. Information to Include in an Intake Form when a Call or Email is Received

Appendix G-5. Common Disagreements

These examples are for illustrative purposes, only. Actual cases will have nuances not captured in the simplistic basic issues.

Basic Issue Steps to ResolvingThe student is seeking enrollment in the school for the current residency area. (Homeless status is not contested.)

School must enroll immediately.(State Coordinator may use a noncompliance letter if school refuses.)

The student is seeking enrollment in a school other children in the residency area may attend.

School must enroll immediately unless some other criteria are not met (for example, an arts charter school with admissions requirements related to artistic ability). If other criteria are not met, school should follow normal process for denying request. State Coordinator may use a non-MV letter template.

The student wishes to remain in a school of origin, and the school disagrees.

Ensure that the school or school district has conducted best interest determination and can provide documentation of its determination. School or school district must provide written notification and follow the dispute resolution process.

The school questions the actual residency of the student at enrollment.

If more information is needed to make a determination, school should immediately enroll pending information collection. (The school district must use care and sensitivity in the verification process.)If the student is not residing in the area to attend the school, and the school is not a school of origin, follow normal process for denying request. State Coordinator may use a non-MV letter template.

The school challenges the student’s status as homeless.

a. School must provide written notification and the school district follows dispute resolution process. (The school may use the sample determination template for parents when not MV eligible as part of the written notice.)

b. If more information is needed, or the living situation is not easily categorized, liaison

G-5-1 State Coordinators’ Handbook: Dispute Resolution. Appendix G-5. Common Disagreements

should consult with State Coordinator. State Coordinator may consult with NCHE for technical assistance. (Care and sensitivity must be used in the verification process.)

The student is seeking enrollment in a school that is not a school of origin or school of residency (including schools in which students in the attendance area may enroll).

Issue is not McKinney-Vento; provide parent, guardian, or unaccompanied youth with explanation and possible avenues to appeal outside MV.

The student does not meet the eligibility criteria to participate in a school activity, and criteria are not associated with homeless status (e.g., GPA is too low to participate in a sport).

Issue is not McKinney-Vento; provide parent, guardian, or youth with explanation and possible avenues to appeal outside MV.

The student has an IEP, and the parent is not satisfied with the special education program provided.

Special education staff will need to participate in the resolution. If specifics of the case involve homeless status, include the liaison/State Coordinator in the resolution. If the issue is not McKinney-Vento related, the parent, guardian, or youth should follow IDEA processes.

Best interest determination was conducted for child to remain in the school of origin; transportation to school of origin was not provided.

This is a compliance issue; the State Coordinator should intercede with the LEA. (See sample non-compliance template)

School of origin transportation was offered, but parent/guardian/unaccompanied youth does not accept the option offered.

State Coordinator should consider these questions before advising the school:Is the option offered safe?Does the option offered avoid stigmatizing due to homelessness?Does the option impose extraordinary inconvenience on the student (e.g., excessive transfers, unnecessary and excessively long commute time)?Does the parent/guardian/youth request exceed the requirements of the Act (e.g., door-to-door service)?


If the transportation offered is safe and does not stigmatize based on homeless status, the school has met its obligation under MV; inform the parent/guardian/unaccompanied youth.

It the option offered is unsafe or stigmatizing, the State Coordinator should work with the liaison to explore other transportation options, including the possibility of revisiting the best interest determination.


Appendix G-6. LEA Noncompliance Letter Template

[Name of Local Liaison][Name of School District][Address]

[Date]

Dear [Name of Local Liaison]

I am writing to inform you that [Name of School District] is out of compliance with the Education of Homeless and Youths Program requirements of the McKinney-Vento Homeless Assistance Act. According to Section 722(g)(2), the State is responsible for local educational agency (LEA or school district) compliance with these requirements and for the provision of technical assistance to LEAs in fulfilling these requirements.

Following are the provisions of the law with which your school district is non-compliant: [Exact wording of the law and the citation.]

[Name of the State educational agency] determined your school district’s lack of compliance based on the following actions that were brought to the attention of the State Coordinator: [Fact-finding that led to the determination of non-compliance]

We recommend that your school district conduct the following steps to resolve this issue. [Steps to follow or activities to conduct]

If you or the school district needs assistance in resolving the issue, please contact the State office for homeless education. We will be able to provide the following technical assistance. [Types of technical assistance, information, and resources available]

Please provide my office with your district’s plan of action to address this concern by [Date]. I look forward to the resolution of this matter in a timely fashion and am available to assist you.

Sincerely,

[State Coordinator’s Name, Role, Contact Information]

Cc: [Superintendent, Federal Programs Officer, School Board Chair]

G-6-1 State Coordinators’ Handbook: Dispute Resolution. Appendix G-6. LEA Noncompliance Letter Template

Appendix G-7. Template for Letter to Parents when Student is Not Considered Eligible for McKinney-Vento Services

[Name of Parent/Guardian/Unaccompanied Youth][Address][Date]

Dear [Name of Parent/Guardian/Unaccompanied Youth]

This letter is in response to your contact with my office on [date], requesting McKinney-Vento assistance for [student’s name] in the [school/school district]. Based on the information provided, [student’s name] does not meet the definition of homeless under the McKinney-Vento Education for Homeless Children and Youths (EHCY) program. General enrollment eligibility and procedures for the school in question would apply.

Under Section 725(2) of the McKinney-Vento Homeless Assistance Act, the term “homeless children and youths”—

(A) means individuals who lack a fixed, regular, and adequate nighttime residence (within the meaning of section 103(a)(1)); and

(B) includes—(i) children and youths who are sharing the housing of other persons due to loss of housing,

economic hardship, or a similar reason; are living in motels, hotels, trailer parks, or camping grounds due to the lack of alternative adequate accommodations; are living in emergency or transitional shelters; or are abandoned in hospitals;

(ii) children and youths who have a primary nighttime residence that is a public or private place not designed for or ordinarily used as a regular sleeping accommodation for human beings(within the meaning of section 103(a)(2)(C));

(iii) children and youths who are living in cars, parks, public spaces, abandoned buildings, substandard housing, bus or train stations, or similar settings; and

(iv) migratory children (as such term is defined in section 1309 of the Elementary and Secondary Education Act of 1965) who qualify as homeless for the purposes of this subtitle because the children are living in circumstances described in clauses (i) through (iii).

None of the categories above describe [student’s name]’s living situation. (Explain why, and include documentation of any vetting with national partners here or precedence the State Coordinator has on file.)

The checklist26 used to make this determination is attached. Should you have further questions, please feel free to contact my office.

Sincerely, [Your name and role]

cc: Local homeless education liaison

26 You may consider creating a checklist from the NCHE brief: Determining Eligibility for Rights and Services under the McKinney-Vento Act. Retrieved from https://nche.ed.gov/downloads/briefs/det_elig.pdf

G-7-1 State Coordinators’ Handbook: Dispute Resolution. Appendix G-7. Template for Letter to Parents when Student is Not Considered McKinney-Vento Eligible


Appendix G-8. Template for Letter for Parent when Complaint is Not a McKinney-Vento Issue

[Name of Parent/Guardian/Unaccompanied Youth][Address][Date]

Dear [Name of Parent/Guardian/Unaccompanied Youth]:

This letter is in response to your contact with my office on [Date], requesting assistance for [Student’s Name] in the [Name of the School District] under the McKinney-Vento Homeless Assistance Act (McKinney-Vento Act). You requested [Summary of the Request]. Based on the information that you provided, I have determined that this request does not fall within the requirements of the McKinney-Vento Education for Homeless Children and Youths (EHCY) program. (Provide a short explanation of why the request does not fit the McKinney-Vento program.)

I encourage you to explore other avenues that can be explored to meet your request. (Examples of details of suggestions for how the parent, guardian, or unaccompanied youth may follow up:

This appears to be a special education issue. You may wish to contact [Name of State Contact for IDEA Compliance, the State’s Parent Ombudsman, or Special Education Technical Assistance]

Your request may be appealed through the school district’s normal appeal process. Your local homeless liaison, [Name of Local Liaison], should be able to connect you with the proper central office staff.)

If after reading this letter, you still feel that your request is covered under the McKinney-Vento Act, you may ask that the school or local liaison provide you with a written notice for a dispute that will include the steps you should follow to initiate the dispute process for the EHCY program. Should you have further questions, please feel free to contact my office.

Sincerely,

[State Coordinator’s Name, Role, Contact Information]

cc: Local homeless education liaison

G-8-1

State Coordinators’ Handbook: Dispute Resolution. Appendix G-8. Template for Letter for Parent when Complaint is Not a McKinney-Vento Issue

Appendix H-1. Sample Monitoring Protocol

North Carolina Homeless Education Program (NCHEP)

LEA Monitoring

Interview Protocol27

LEA: Date of Monitoring Site Visit:

Homeless Liaison: Person Completing Report:

School representatives present during monitoring:

Documents reviewed before, during and after monitoring:

Subgrant Application

Expenditure Report for PRC026

Title I Set Aside Amounts

Dispute Policy

District Website for Homeless Education Information

District Residency Questionnaire

District Needs Assessment

Other:

Other:

Other:

27 Note that an interview protocol must be reviewed and revised each year to reflect updates in the federal and state laws, guidance, and priorities for the EHCY program.

H-1-1

State Coordinators’ Handbook: Section H. State Monitoring of Local Educational Agency McKinney-Vento Programs. Appendix H-1: Sample Monitoring Protocol

NCHEP monitor(s): Items requested during monitoring to be sent to NCHEP:

Final report sent to NCHEP by monitors if applicable:

Date NCHEP sent final report:

Other notes:

Rating Rubric

Meets Requirements Findings Recommendations Other / Not Applicable

Indicates that the status is acceptable

Out of compliance and requires a response stating actions(s) planned to correct the deficiency

Indicates a need for improvement and requires a response stating the action taken or planned to improve the situation

Interview Protocol

Interview (Liaison, Principal, Agency Representative)

Sample Evidence

1. McKinney-Vento Monitoring Area: The LEA implements procedures to address the

Enrollment/intake forms Tracking forms Notes/logs/documentation of community

H-1-2


identification of Homeless children and youth according to statutory definitions.

contacts Other

What processes and criteria have been established to locate and identify homeless families and unaccompanied youth?

Describe your community outreach and collaboration activities with service providers and other community agencies to identify homeless children and youth.

Describe any outreach activities that specifically target preschool children or unaccompanied youth.

What procedures do you use to identify doubled-up families?

How do you assess homeless students’ special needs once they are identified?

Site Notes:

Recommendations: Recommendations:

Findings: Findings:

Initial Action Needed: Initial Action Needed:


Sample Evidence

2. McKinney-Vento Monitoring Area: The LEA implements

Agendas/memos/handbooks for training sessions

H-1-3


procedures to address the immediate enrollment of homeless children and youth according to statutory requirements.

Posters/brochures/flyers

What procedures are in place to enroll homeless students?

How does the LEA document enrollment problems?

How are records (immunization or medical records, academic records, birth certificates, guardianship records, and evaluations for special services or programs) regarding each homeless child created, collected and/or maintained by the school?

What process is used for making medical, school and other records available to schools or for obtaining records in a timely manner?

What, if any, issues in the process of making records available or obtaining records have delayed the enrollment process of any homeless students?

Where are public notices of rights disseminated?

Site Notes:

H-1-4



Findings: Findings:



Sample Evidence

3. McKinney-Vento Monitoring Area: The LEA implements procedures to address the retention of homeless students.

Memos Information for parents Needs assessment documents District Board policies Tracking of transportation to school of origin

What do you do to ensure that children remain in their school of origin when feasible?

What percentage of homeless students remain in their school of origin?

How many students were transported, and how do you track this information?

How are parents, guardians, and unaccompanied youth assisted in accessing transportation services, including transportation to and from the school of origin?

What additional services/supports (Title I services, after-school, school supplies, free school meals, medical referrals, etc.) are in place to ensure the success of homeless students in school?

Are there any local district policies or procedures that remain as

Site Notes:

H-1-5


barriers to the identification, immediate enrollment, retention, or school success for homeless students?

How are parents or guardians of homeless children and youth provided with meaningful opportunities to participate in the education of their children?


Findings: Findings:



Sample Evidence

4. McKinney-Vento Monitoring Area: The LEA provides information dissemination both internally and externally to ensure appropriate implementation of the statute.

Posters/brochures in schools/agencies Agendas/memos/handbooks for training

How are information and training provided to school personnel, service providers, and advocates working with homeless families

Site Notes:

H-1-6


about the rights of homeless students and the duties of the homeless liaison?

Are homeless posters visible in each of your schools, including contact information for LEA Liaison and State Coordinator? Do you need additional posters? Brochures?

How does the LEA ensure that outside agency representatives are knowledgeable of district policies and procedures for identifying and working with homeless children and youth?

How do you inform parents or guardians of homeless children and youth of educational and related opportunities available to their children?

What efforts have been taken by the LEA to create community awareness of the needs and rights of homeless students?

H-1-7



Findings: Findings:



Sample Evidence

5. McKinney-Vento-Monitoring Area: The LEA ensures that there is coordination of programs and services to homeless students and families.

Formal/informal agreements with agencies Documentation of coordinated services

What strategies have you found successful in developing and maintaining collaborative relationships with community agencies that serve homeless children/families, including unaccompanied youth?

Describe examples of successful school-community collaboration on behalf of homeless students.

Site Notes:

H-1-8



Findings: Findings:



Sample Evidence

6. McKinney-Vento Monitoring Area: The LEA ensures that comparable Title 1, Part A services are provided to homeless students attending non-Title 1 schools.

Title I budget Expenditure reports Copy of Title I Plan Copy of Consolidated Plan Copy of Schoolwide Plans

How does the district ensure that comparable services are provided to

Site Notes:

H-1-9


homeless students attending non-Title I schools?

Does the Title I Plan have a description of services the LEA will provide to homeless students?

What amount of Title 1 Part A funds were reserved for the previous and current school years?

What process is used to reserve funds? Do you coordinate this with your Title I office?

What supplementary activities are provided with Title I reserved funds?

Who makes decisions about such services?

Do you have budget information that documents how reserved Part A funds are spent?

Note: If LEA states that they are exempt from this requirement because all schools are Title I Schoolwide schools, then monitor should ask to see the Schoolwide plan and document that such plan includes a description of how the needs of homeless students are being addressed.


Findings: Findings:


H-1-10



Sample Evidence

7. McKinney-Vento Monitoring Area: The LEA has a system for ensuring prompt resolution of disputes.

Dispute resolution policy Dispute resolution log

How does the district ensure that disputes are being addressed, investigated, and resolved in a timely manner? Do you have a written Dispute Resolution process?

What documentation do you use when a parent or youth contacts you about enrollment problems or other issues? Do you have a log of contacts?

How does the liaison assist with dispute resolution? Who makes the final decision on school disputes?

Site Notes:

H-1-11



Findings: Findings:



Sample Evidence

8. Optional: Complete if the LEA receives a McKinney-Vento Subgrant

McKinney-Vento budget Expenditure reports Program evaluation data, reports

How has the LEA expanded or improved services for homeless students through the McKinney-Vento subgrant? Describe services provided with subgrant funds.

Describe the process you use to verify that subgrant funds are spent only for approved project activities. What budget documentation can you provide as evidence of accountability for the use of subgrant funds?

Are grant expenditures on schedule? If

Site Notes:

H-1-12


no, why not? Describe how the implementation of

the subgrant addresses the academic needs of homeless students?

What data are you collecting to evaluate your program?

Have you submitted an evaluation report to the state?

Are there any specific challenges to successful implementation of your grant project?

Additional questions should be asked in reference to specifics of proposed project.


Findings: Findings:


H-1-13


H-2. LEA Monitoring Scenarios

The following scenarios describe four SEA approaches to the monitoring of LEAs for compliance with the McKinney-Vento Act. These scenarios feature a hybrid of components of monitoring programs gathered from interviews with State Coordinators and grouped by different sizes and characteristics of the states.

Scenario 1: Large State (in Geographic Size and Population)

The State has established a comprehensive review process, with each LEA

undergoing a full review every five years. As with other Federally-funded programs,

questions specific to the legislative requirements of McKinney-Vento and related

LEA responsibilities are included in the overall State monitoring process. The State

Coordinator works closely with the Title I Director to develop questions that can be

addressed by members of the review team, with probe questions noted if the

interviewer needs clarification or if responses are not clear. These questions are

revisited at the beginning of each year to reflect any changes in the legislation or in

guidance from the U.S. Department of Education. Results of these site visits are

forwarded to the State Coordinator as part of the after action reporting process,

serving as a broad screening device to determine next steps for that LEA. Next steps

could include any combination of (1) more in-depth monitoring, including a follow-

up site visit by the State Coordinator; (2) follow-up monitoring via phone, fax,

and/or email to further explore compliance issues or other items of interest; (3)

technical assistance to address issues in program implementation; and/or (4)

routine communication and exchange of information for support upon request.

In some states, the State Coordinator requires all LEAs, with and without

subgrants, to complete a self-assessment (in some cases, this can be as brief as a

short online survey with questions that address broad areas of compliance). The

State Coordinator uses this information to determine the LEAs’ progress in

McKinney-Vento implementation. Most State Coordinators require end-of-year

reports from their subgrantees.

H-2-1

State Coordinators’ Handbook: Section H. State Monitoring of Local Educational Agency McKinney-Vento Programs. Appendix H-2. LEA Monitoring Scenarios

The State Coordinator reviews assessment data from the LEAs and

determines what steps among the four listed above are appropriate for each LEA,

prioritizes the LEAs to be monitored, and develops a schedule. Those LEAs that need

more in-depth monitoring are notified that a site visit will take place in the coming

year.

While the above process includes all LEAs, the State conducts additional on-

site reviews of all LEAs receiving McKinney-Vento subgrants at least once during the

grant period. These reviews cover all components of the funded program as well as

the basic requirements of the McKinney-Vento Act. The on-site review, along with

the year-end report, allows the State Coordinator to see first-hand how the program

is being implemented, how the grant funds are being used, and what services are

being supported with other resources. In particular, the review identifies the extent

to which the homeless children and youth in the LEA are being served and provides

a measure of the quality of those services.

Scenario 2: Small State (Few Urban Areas, Many Small LEAs)

This State’s monitoring of LEAs is a combination of on-site reviews, desk

reviews, telephone conferencing, and regional meetings. A significant first step in

the process is the LEA self- assessment required of all LEAs, whether they receive

McKinney-Vento subgrants or not. Information from the self-assessment guides

decisions about the LEAs’ needs for on-site monitoring, continued desk review,

and/or technical assistance. Program issues, in terms of both compliance and

quality, are often apparent from the self-assessment, and in many cases, are already

being addressed as a result of their own self-study. Other issues might arise during

telephone conferencing, regional meetings, or review of documents, leading to more

intensive review. In many of these cases, technical assistance is often provided along

with more focused compliance monitoring as needed. On-site reviews are automatic

H-2-2


for subgrantees, with annual site visits by the State Coordinator, but also occur for

those LEAs for which the desk review is not sufficient.

In some states, the State Coordinator collaborates routinely with Title I

program staff, including a homeless review as part of the monitoring protocol.

Regional meetings are also conducted in collaboration with Title I for purposes of

exchanging information about legislative requirements and offering professional

development activities related to the implementation of quality programs. The State

is fortunate to have very positive and productive working relationships across

Federal programs at the State level, and encourages local LEAs to work toward a

collaborative approach, as well. In a small State, collaboration is imperative for

maximizing personnel and other resources, and the impact on programs when

people combine their strengths toward common goals is significant.

The State Coordinator always sends monitoring protocols in advance so that

there are no surprises during the interviews, and so that the LEAs can be prepared

with adequate documentation. If sufficient evidence is not available during the site

visits, the monitor probes for further information, sometimes requesting that the

LEA provide additional documentation related to compliance issues.

The State Coordinator sends follow-up reports after each monitoring visit to

share observations, strengths, and weaknesses, and to notify LEAs of any corrective

action needed. The State Coordinator confers by phone to agree on a timeline for

corrective action and discuss any need for technical assistance to address

compliance issues.

Scenario 3: Large State (Some Urban LEAs, Many LEAs in Rural Communities)

The State monitors approximately one-third of its LEA EHCY programs every

year. After determining which LEAs will be monitored, the State Coordinator begins

preliminary desk monitoring for the selected LEAs. The State Coordinator then

determines whether compliance issues exist and notes if the LEA is receiving

H-2-3


McKinney-Vento funds. Next, the State Coordinator meets with members of the SEA

monitoring team to provide a homeless education program interview protocol to be

included in the SEA consolidated federal programs monitoring process. Since this is

a large State covering long distances, the SEA often contracts with local individuals

who are trained to assist SEA Federal program personnel with the required

monitoring. In some communities, the SEA has developed a pool of individuals from

local colleges and community agencies, retired educators, volunteer tutors, etc., who

are trained to assist with monitoring activities. As these contractors are trained

regarding EHCY program requirements, they are sometimes employed to assist with

the monitoring of additional LEAs with a focus on McKinney-Vento compliance. This

is especially helpful in rural areas, reducing travel costs associated with on-site

monitoring.

This three-year cycle provides the safety net for monitoring, with each LEA

having an on-site monitoring visit at least once during the cycle. Additional

McKinney-Vento monitoring activities include the following:

• All McKinney-Vento subgrantees are desk reviewed annually through expenditure

reports, year-end data collection, and the narrative report required by their grant. If

there are issues requiring attention, the State Coordinator schedules telephone

conferencing or site visits, as needed.

• Video conferences are scheduled every other month for grantees to discuss

problems or issues with implementation of their grants and share successes. This

allows the State Coordinator to monitor general progress and identify any specific

areas of concern in a particular LEA.

• At the conclusion of each on-site monitoring visit, the LEA receives a report from the

State Coordinator that details the results of the visit and any compliance issues that

need to be addressed. Observations are also noted regarding the quality of program

implementation, areas that are not necessarily compliance issues but need to be

strengthened, and information about technical assistance and other available

H-2-4


resources.

Scenario 4: Medium State (Mostly Rural)

Every LEA in the State that receives Title I funds is monitored on-site at least

once every three years. The State Coordinator conducts McKinney-Vento reviews as

part of that process. The State Coordinator provides a monitoring protocol for use

by the State team, with additional questions for LEAs with McKinney-Vento

subgrants. All LEAs are visited during this three-year cycle, with follow-up visits

from the State Coordinator, as needed, especially if compliance issues arise during

the state monitoring.

In addition to the three-year cycle of State monitoring of all Federal

programs, the State Coordinator reviews annual data submitted to ED for the

Consolidated State Performance Report. Some State Coordinators also conduct an

annual online survey of all LEAs, including those with and without subgrants. The

online survey enables the State Coordinator to identify LEAs that need immediate

assistance and brings attention to “red flags” or LEAs of potential concern, in terms

of both compliance and program quality.

The State Coordinator encourages the local liaisons in all LEAs to work

closely with community agencies to determine the extent to which homeless

families are being identified and children are being enrolled. This requires a

commitment to go beyond school-based data collection in reporting to the state.

The State Coordinator sends each local liaison a report after each site visit

with the results of monitoring activities and any corrective action needed.

H-2-5


H-3. Problems and Suggested Solutions in LEA Monitoring

The following table represents problems, obstacles, and issues State Coordinators encounter in monitoring LEAs. The table also provides suggested strategies and solutions offered by State Coordinators and others with monitoring experience.

Problem Suggested Solutions

Large number of LEAs; cannot visit all

SEA conducts only desk monitoring

State Coordinator wears many hats and is assigned to McKinney- Vento for a small percentage of time

1. Develop a tiered system, conducting on-site visits for those with the least evidence of a quality program or those where the liaison has changed since the last monitoring; use desk monitoring for those with established programs; and develop a survey instrument to help determine which LEAs might require a site visit.

2. Rotate site visits over a series of years.3. Collaborate with Title I program staff to include McKinney-

Vento questions in their monitoring schedule; follow up with phone calls or e-mail with further questions as needed.

4. Train colleagues in the field to conduct on-site visits, with phone/e-mail follow-up as needed.

5. Use interactive video conferencing to replace site visits for LEAs with video capacity.

Lack of monetary incentive to comply for LEAs without subgrants

Resistance on the part of LEAs to go beyond minimal compliance with legislation

Minimal approach at State level to monitoring activities

1. Require consolidated planning, where possible, so that all Federal programs are accountable for McKinney-Vento requirements.

2. Send official communication to LEA superintendents and school board chairpersons.

3. Offer on-site training to educate school officials and school personnel.

4. Develop a barrier-tracking instrument (for liaisons) that includes the collection of specific information from community agencies, comparing the number reported homeless with the number enrolled.

5. Work with Title I State personnel to add language to the Title I, Part A application to describe coordination with the homeless education program.

6. Provide joint training with Title I for coordination between McKinney-Vento and Title I programs, including determining the Title I, Part A homeless set aside based on needs assessment data.

High turnover of local 1. Remind LEA superintendents and Federal programs

H-3-1 State Coordinators’ Handbook: Section H. State Monitoring of Local Educational Agency McKinney-Vento Programs. Appendix H-3. Problems and Suggested Solutions in LEA Monitoring

Problem Suggested Solutions

liaisons administrators on an annual basis to inform you immediately when a new liaison is appointed, maintain an updated list of liaisons, and remind them that high liaison turnover is a risk factor for compliance when prioritizing LEAs for monitoring.

2. Communicate with new liaisons to orient them to their position and support them in carrying out their duties, develop a “care package” to send to new local liaisons who arrive after training events are completed, and connect them with a “mentor” liaison.

3. Establish a routine schedule for e-mail communication (perhaps monthly) with local liaisons for discussion of updates and emerging issues.

Poor attendance at trainings

1. Identify trainings as “compliance trainings” and send notification of trainings to the local liaison, Federal programs administrator, and superintendent requiring the attendance of the local liaison.

2. Include a question regarding local liaison training participation in the monitoring protocol, and reinforce this expectation in routine communication with liaisons.

3. Provide a link to NCHE webinars to new liaisons and request that they provide you with a certificate of their attendance within three months of their appointment.

4. Pay for travel expenses for local liaisons to attend trainings; suggest the use of Title I homeless set-asides or other professional development funds to support travel costs associated with training events.

5. Conduct regional trainings to minimize travel time for liaisons; target areas with limited participation in training, and request the assistance of non-participants in identifying a location for the training.

H-3-2 State Coordinators’ Handbook: Section H. State Monitoring of Local Educational Agency McKinney-Vento Programs. Appendix H-3. Problems and Suggested Solutions in LEA Monitoring

Appendix I-1. McKinney-Vento Subgrants Authorized Activities

(d) AUTHORIZED ACTIVITIES - A local educational agency may use funds awarded under this section for activities that carry out the purpose of this part, including the following:

(1) The provision of tutoring, supplemental instruction, and enriched educational services that are linked to the achievement of the same challenging State academic standards as the State establishes for other children and youths.

(2) The provision of expedited evaluations of the strengths and needs of homeless children and youths, including needs and eligibility for programs and services (such as educational programs for gifted and talented students, children with disabilities, and English learners, services provided under title I of the Elementary and Secondary Education Act of 1965 [20 U.S.C. 6301 et seq.] or similar State or local programs, programs in career and technical education, and school nutrition programs).

(3) Professional development and other activities for educators and specialized instructional support personnel that are designed to heighten the understanding and sensitivity of such personnel to the needs of homeless children and youths, the rights of such children and youths under this part, and the specific educational needs of runaway and homeless youths.

(4) The provision of referral services to homeless children and youths for medical, dental, mental, and other health services.

(5) The provision of assistance to defray the excess cost of transportation for students under section 11432(g)(4)(A) of this title, not otherwise provided through Federal, State, or local funding, where necessary to enable students to attend the school selected under section 11432(g)(3) of this title.

(6) The provision of developmentally appropriate early childhood education programs, not otherwise provided through Federal, State, or local funding, for preschool-aged homeless children.

(7) The provision of services and assistance to attract, engage, and retain homeless children and youths, particularly homeless children and youths who are not enrolled in school, in public school programs and services provided to nonhomeless children and youths.

(8) The provision for homeless children and youths of before- and after-school, mentoring, and summer programs in which a teacher or other qualified individual provides tutoring, homework assistance, and supervision of educational activities.

I-1-1 State Coordinators’ Handbook: Appendix F-1. McKinney-Vento Subgrants Allowable Activities

(9) If necessary, the payment of fees and other costs associated with tracking, obtaining, and transferring records necessary to enroll homeless children and youths in school, including birth certificates, immunization or other required health records, academic records, guardianship records, and evaluations for special programs or services.

(10) The provision of education and training to the parents and guardians of homeless children and youths about the rights of, and resources available to, such children and youths, and other activities designed to increase the meaningful involvement of parents and guardians of homeless children or youths in the education of such children or youths.

(11) The development of coordination between schools and agencies providing services to homeless children and youths, as described in section 11432(g)(5) of this title.

(12) The provision of specialized instructional support services (including violence prevention counseling) and referrals for such services.

(13) Activities to address the particular needs of homeless children and youths that may arise from domestic violence and parental mental health or substance abuse problems.

(14) The adaptation of space and purchase of supplies for any nonschool facilities made available under subsection (a)(2) to provide services under this subsection.

(15) The provision of school supplies, including those supplies to be distributed at shelters or temporary housing facilities, or other appropriate locations.

(16) The provision of other extraordinary or emergency assistance needed to enable homeless children and youths to attend school and participate fully in school activities.

I-1-2 State Coordinators’ Handbook: Appendix F-1. McKinney-Vento Subgrants Allowable Activities

Appendix I-2. Sample Timeline for the McKinney-Vento Subgrant Process.

Deadline Activity NotesJanuary Notify SEA administrators, grants

coordinators, and the budget office of the upcoming McKinney-Vento subgrant competition; provide them with a description of the requirements in the law, a description of the previous cycle’s subgrant process, and a timeline of events related to the subgrant process.

Request that all who receive the notification review the current process and provide feedback to you on needed changes and on state procedures you must follow.

Begin notification process for local liaisons.

Post an announcement on the state homeless education website; announce the competition in trainings and other communications with local liaisons.

August Review and revise the subgrant process and request for proposals as needed; get approval from SEA administrators, as needed.

Discuss the subgrant process with NCHE staff and review subgrant materials from other states on the subgrants page of NCHE’s Resources by Topics web page: http://center.serve.org/nche/ibt/sc_subgrants.php.

November Develop a rubric for subgrant proposal reviewers (or revise the existing rubric).

December Identify reviewers and schedule a reviewer training in early March.

January 5 Post the RFP and supporting materials; sent notification to local liaisons, superintendents, federal programs officers, and budget offices in each LEA (and to charter schools, if considered LEAs).

Request announcement recipients to review the RFP and materials and submit questions that will be addressed in a frequently asked questions document to be posted on a web page and in training events.

January 20 Conduct a webinar on developing a strong McKinney-Vento subgrant proposal.

Record the webinar and post it on line.

February 28

Deadline for proposal submission.

March 7 Conduct reviewer training and review of one or two proposals

I-2-1 State Coordinators’ Handbook: The McKinney-Vento Subgrant ProcessAppendix I-2. Sample Timeline for the McKinney-Vento Subgrant Process.

http://center.serve.org/nche/ibt/sc_subgrants.php

http://center.serve.org/nche/ibt/sc_subgrants.php

utilizing the rubric to establish inter-rater reliability. Provide reviewers with proposals.

April 1 Deadline for reviewer feedback.April 15 Make recommendations for awards;

follow SEA protocols for internal approval and subgrantee budgets. Review data for LEA risk-assessment for managing a federal grant.

May 20 State Coordinator sends award notifications and instructions on next steps.

Request acknowledgement of the award.

July 31 SEA disburses subgrantee award funds to LEAs after ED provides McKinney-Vento funding to the SEAs.

August 1 First year of subgrant cycle begins.

I-2-2 State Coordinators’ Handbook: The McKinney-Vento Subgrant ProcessAppendix I-2. Sample Timeline for the McKinney-Vento Subgrant Process.

Appendix J-1. Guiding Questions for Use of Subgrant Funds

Foundation Questions

McKinney-

Vento Act1. Does the expense meet the intent of the law? That is, does the expense

facilitate the identification, enrollment, attendance, and success in

school of homeless children and youth? Moreover, is it critical to

improving identification and/or maintaining the enrollment,

attendance, and success of homeless students or even just one

homeless child or youth?

2. Does the expense fit in with one of 16 authorized activities in Section

723 of the law?

3. Does this expense cover services that apply only to the homeless

education program and are connected to the educational needs

specifically of homeless children and youth? (The exception would be

for services provided on school grounds; these services may include a

small percentage of other at-risk students.)

Uniform

Guidance1. Is this expense necessary to the administration and performance of

the grant?

2. Is it reasonable, in that it does not exceed that which would be

incurred by a prudent person under the circumstances prevailing at

the time the decision was made to incur the cost?

3. Is it allocable, that is incurred specifically for the benefit of homeless

children and youth?

4. Is it allowable under Federal, State, and local laws?

5. Can it be documented in a clear and transparent way?

J-1-1 State Coordinators’ Handbook: Appendix J-1. Guiding Questions for Use of Subgrant Funds

Foundation Questions

The

Subgrant

Proposal

1. Does the expense fit within goals articulated, and approved, in the

subgrant proposal?

2. Does the expense meet a need that was identified as a priority need

based on a needs assessment?

3. Was the expense included, and approved, in the subgrant budget?

4. Is the expense necessary for efficient operation of the homeless

education program?

Is there reasonability in proportion to the rest of the program budget

and how much is being spent per student? Or, if this is an expense for

one student, is it proportional to other program or students’ needs?

Coordination 1. Is this expense for supplemental services and not for services that

should be paid for by the LEA as part of the regular academic

program?

2. Are there comparable services that the LEA provides to non-homeless

students and should provide to homeless students?

3. Is there evidence of coordination with Title I for use of the Title I, Part

A homeless set aside?

4. Has an effort been made to obtain this service from another source,

such as business partners and service agencies?

5. Is this expense beyond the scope of the McKinney-Vento program and

would be more appropriately covered by a community service agency?

J-1-2 State Coordinators’ Handbook: Appendix J-1. Guiding Questions for Use of Subgrant Funds

Appendix K-1. Tips for Preparing for EHCY Monitoring

Appendix K-1 provides practical tips State Coordinators (and their teams) can use to approach the Federal monitoring review process efficiently and effectively and meet the compliance requirements for the EHCY program. Following these suggestions will enable State Coordinators to plan activities that should be completed before a review is scheduled, once the review is scheduled, during the review, and after the review.

Prior to a Scheduled Review

States often think that the pre-review process begins with a call from the

Federal EHCY program office regarding the upcoming review. However, it is

important to think ahead, even before getting that call. By starting earlier, you will

have time to understand the current monitoring indicators, assess your state’s

compliance with those indicators, and adjust policies and practices as necessary.

Even if a review is not scheduled, you should become familiar with the current EHCY

monitoring protocol and have a process in place to periodically organize and review

documents. The following list identifies steps that you can take in advance.

Familiarize yourself with each monitoring indicator in the current protocol and

implement activities to address any areas of needed improvement. (Consider

incorporating needed changes into your annual activity plan.)

Check the risk factors for monitoring (see Section K.3. Preparing for Federal

Monitoring of the State Education for Homeless Children and Youth Program) to

identify areas of needed program improvement.

Review the State’s most recent Federal EHCY program monitoring report and any

corrective action materials, identify any findings that your SEA received during the

last review, and ensure that they have been addressed. (For a copy of your last

monitoring report, go to the ED’s Title I Program Monitoring webpage or contact the

Federal coordinator. For a copy of the required written response to any corrective

action sent to ED after your SEA received the monitoring report, contact your Title I

director.)

K-1-1 State Coordinators’ Handbook: Appendix K-1. Tips for Preparing for EHCY Monitoring

http://www.ed.gov/admins/lead/account/monitoring/index.html

Locate the materials that the Federal office will usually request at least two months

in advance of your review and make sure these are available electronically. These

materials will include

o a copy of your SEA’s McKinney-Vento State Plan, including dispute policy;

o logs of calls and emails related to educational barriers experienced by homeless

students in the State and dispute documents;

o fiscal records for the State EHCY grant;

o list of local liaisons and their LEAs;

o Title I homeless set aside amounts for each LEA;

o LEA data on identification of homeless students;

o subgrant applications, list of all current LEA subgrantees, award amounts, and

budgets;

o copies of any updated guidance and technical assistance materials that you have

provided to LEAs since your last review;

o participant lists and agendas for LEA trainings;

o LEA monitoring protocol, schedule of past and upcoming visits, and records of

follow-up to any corrective actions required; and

o any collaborative agreements or memoranda of understanding or agreement

with other programs or agencies.

Assess your State’s compliance with each indicator of the current protocol and

identify evidence to support the assessment.

Once the Review is Scheduled

Identify the EHCY program’s monitoring team at each level. (Include other SEA staff

with duties administering the EHCY program and the local liaisons who will be

interviewed by the ED team. Include people who are knowledgeable about each

indicator and can speak to the requirements, for example, EDFacts or CSPR

coordinators, the Title I coordinator, and fiscal administrators. Let them know when


the monitoring visit will take place and what their responsibilities are for

preparation and during the interviews.)

Review all ED communication regarding your tasks in arranging the review,

whether on site or via video-conferencing; share communication with the interview

team; and provide agendas with dates and times for interviews.

Upload all required documents to NCHE’s Extranet. Request assistance from NCHE

as needed. (Note: Creating subfiles on the Extranet for each indicator will ensure

that the monitor knows what evidence supports each indicator; the Extranet

includes a tagging feature so that one document can be included for multiple

indicators, rather than having to upload the same document several times. As a

word of caution, do not share individual student records. If you want to show an

example of a student record, be sure to conceal personally identifiable information.)

Provide the Federal monitor with a list of names, phone numbers, and email

addresses for all SEA and LEA staff involved in the interviews or with whom he or

she may need to speak while monitoring.

Provide the Federal monitor with appropriate logistical information. (For example,

for on-site reviews, provide a detailed agenda that includes where interviews will

take place and directions and travel logistics. For remote reviews, ensure the

monitor knows with whom he or she will speak, when, and through what medium.)

Send reminders to all SEA and LEA staff involved the week before the review.

Ensure all logistics are in place (e.g., meeting rooms are arranged if on site and

technology is functional if remote).

Prepare all interviewees for what to expect from the monitoring review, but do not

encourage them to hide areas of need or noncompliance. When areas of

noncompliance are brought to the attention of a Federal review, the result is often

increased awareness on the part of SEA administrators and technical assistance that

will ultimately improve services and educational outcomes for homeless children

and youth.


During the Review

Assemble all documents and records for easy access in supporting responses to

questions.

Be thorough, honest, and relaxed in your responses, and encourage your colleagues

to do the same. Feature both positive aspects of the program as well as the

challenges.

Notify all administrators to be present for the Federal team’s exit interview or

debrief, if one is scheduled. This would apply for both on site and remote reviews.

After the Review

Clarify with the Federal program coordinator when the SEA will receive the

monitoring report and to whom it will be sent; follow up if the report is not sent by

the designated date.

Schedule a time to debrief the report with SEA administrators; take this opportunity

to reflect on the State EHCY program and determine ways to strengthen it and make

it more compliant. Also, take this opportunity to reflect on the process of preparing

for the monitoring review to inform subsequent monitoring of the EHCY program

and other programs.

Debrief the monitoring visit with those outside of the SEA, including LEA staff

involved in the interviews and community service providers, if involved.

Determine what type of response is needed and by what date.

Incorporate strategies for addressing monitoring findings in the annual action plan

for the State EHCY program.

Keep the monitoring report on file for easy access to review progress on a yearly

basis.


Appendix K-2: Summary of EHCY Performance Management Pilot Monitoring, FY 2015-18

Appendix K-2 provides a review of U.S. Department of Education (ED) monitoring results for the Performance Management Pilot Monitoring Protocol. This protocol was instituted in FY 2015 as a result of the Government Accountability Office study of the Education of Homeless Children and Youth (EHCY) program, which recommended, based on a risk assessment of SEAs, that ED conduct more regular monitoring.

Background

Section K of the National Center for Homeless Education (NCHE) SEA Coordinator’s Handbook (Handbook) provides guidance to SEA educational agency (SEA) staff to assist in preparing for Federal monitoring of SEA administration and implementation of McKinney-Vento Act requirements applicable to SEAs and local Educational Agencies (LEAs). This summary replaces the ED monitoring summary from prior versions of the Handbook, and has been updated to reflect the amendments to the Education for Homeless Children and Youth (EHCY) program made by the Every Student Succeeds Act and a new monitoring protocol that was aligned with them. (Note: There was a period of two years when no SEA monitoring was conducted.)

In 2014, the EHCY program moved to the Office of Safe and Healthy Students (OSHS) and revised its monitoring protocol to pilot several performance management features. Among the main changes to the protocol were:

The development of a more comprehensive performance risk assessment of SEAs, and A greater focus on using LEA-level performance data relative to other LEAs within

monitored SEAs to select LEA subgrantees for interview, particularly given the increase in remote reviews.

Ultimately, a new performance management indicator was added in FY 2017. This indicator included requirements for data quality review, data analysis, and use of program data at the SEA and LEA subgrantee-levels to set baseline goals and annual targets. In addition, while under OSHS, monitoring reports began to include commendations of promising emerging practices observed at the LEA or SEA level. For an emerging practice to be commended in a monitoring report, it must be judged that the practice could be replicated by EHCY programs in other SEAs.

Finally, if there is a compliance finding in the draft report, an SEA is provided with an opportunity to resolve the issue. If the finding can be resolved within the 30 business day

K-2-1 State Coordinators’ Handbook: Appendix K-2. Summary of EHCY Performance Management Pilot Monitoring, FY 2015-18

technical review period, that finding is removed from the report. Beginning with FY 2017, SEAs have also had the opportunity to respond to monitoring recommendations in reports published by OSHS on the EHCY program website.

What follows is a summary of the main findings, recommendations for improvement, and commendations of emerging practices for the 18 SEAs monitored from FY 2015-18. The items are organized by indicator. Some adjustments to the federal comments were made to reflect the following several changes made to the indicators in FY 2017. These adjustments moved performance management recommendations that were under indicator 1.1 to the new performance management indicator 1.2. Findings and recommendations regarding the Title I, Part A LEA homeless set-aside were moved from indicator 2.1 (policy and coordination) to fiduciary indicator 3.3 for all four years of this summary.

The findings and recommendations in this document have been abbreviated for length. If you wish to review the full text of a finding or recommendation beyond the simple content summary, please click on the SEA hyperlink to go directly to the full ED report. The emerging practices are summarized and listed by indicator, in chronological order. Although they were not tied directly to indicators in the published reports, they were informed by them.

Table 1. Summary of EHCY Findings and Recommendations by Indicator and SEA (FY 2015-18)

Indicator Finding Recommendation Comment1.1 CT (2015)1.2 AL, IN, MN, SC, WV,

(2016); TN, (2017); AK, KY, ND, OH, VA (2018)

Analyze EHCY performance data, create workplans with

measurable goals2.12.2 IN (2016); TN (2017); AK

(2018)Provide more SEAwide PD

and track new liaison training3.1 CT, MD (2015); WV

(2016); TN(2017); AK, KY (2018)

Provide TA to subgrantee LEAs on evaluating

performance; award grants on time; use multiple reviewers

3.23.3 CT, MN (2015);

IN (2016); ND (2018)

PA (2015) Lack of systematic coordination between EHCY

and Title I, Part A at SEA level resulting in missing or

inconsistent set-asides


https://www2.ed.gov/programs/titleipartd/pa-oshsmonitoringreport-final.pdf

https://www2.ed.gov/programs/homeless/nd-ehcy-finalmonitoringreport.pdf

https://www2.ed.gov/programs/homeless/in-ehcy-finalmonitoringreport.pdf

https://www2.ed.gov/programs/homeless/mn-ehcy-finalmonitoringreport.pdf

https://www2.ed.gov/programs/titleipartd/ct-oshsmonitoringreport-final.pdf

https://www2.ed.gov/programs/homeless/ky-ehcy-finalmonitoringreport.pdf

https://www2.ed.gov/programs/homeless/ak-ehcy-finalmonitoringreport.pdf

https://www2.ed.gov/programs/homeless/tn-ehcy-finalmonitoringreport.pdf

https://www2.ed.gov/programs/homeless/wv-ehcy-finalmonitoringreport.pdf

https://www2.ed.gov/programs/titleipartd/md-oshsmonitoringreport-final.pdf





https://www2.ed.gov/programs/homeless/va-ehcy-finalmonitoringreport.pdf

https://www2.ed.gov/programs/homeless/oh-ehcy-finalmonitoringreport.pdf

https://www2.ed.gov/programs/homeless/nd-ehcy-finalmonitoringreport.pdf





https://www2.ed.gov/programs/homeless/sc-ehcy-finalmonitoringreport.pdf



https://www2.ed.gov/programs/homeless/al-ehcy-finalmonitoringreport.pdf


Emerging Practices for the EHCY Program Observed by ED in SEAs and LEAs Commended in ED Monitoring Reports, FY 2015-18 (26 in Total)

Indicator 1.1: Monitoring Practices

1. Monitoring

a. Maryland (April 2015) The SEA has a system for monitoring LEAs and all subgrantee LEAs every 2 years.

b. Arizona (March 2015) The SEA has a system for monitoring all LEAs for both desk-reviews and on-site reviews for subgrantees throughout a 3-year period.

c. Arizona (March 2015)The SEA has a tool, called the Arizona LEA Tracker (ALEAT), to follow up on Corrective Actions.

Indicator 1.2: Performance Management Practices

2. LEA Data Analysis and Use to Improve Data Quality or Performance

a. Maryland (April 2015)The SEA requires grantees to reflect on progress toward past years’ goals and what could be improved.

b. Pennsylvania (June 2015)The SEA has state-level EHCY coordination to improve the quality of data reported by all regional offices and LEAs.

c. Connecticut (September 2015)Connecticut has statewide efforts to get more accurate counts of homeless youth, especially unaccompanied homeless youth.

d. Utah (February 2016)The Utah Department of Workforce Services issued a Comprehensive Report on Homelessness, SEA of Utah 2015, which includes ED’s EHCY data and


https://www2.ed.gov/programs/homeless/ut-ehcy-finalmonitoringreport.pdf


https://www2.ed.gov/programs/titleipartd/pa-oshsmonitoringreport-final.pdf


https://www2.ed.gov/programs/titleipartd/az-oshsmonitorinigreport-final.pdf

https://www2.ed.gov/programs/titleipartd/az-oshsmonitorinigreport-final.pdf


compares them with US Department of Housing and Urban Development (HUD) grantee data.

e. Ohio (September 2018)In line with SEA goals to reduce chronic absenteeism among all public school students with annual percentage reductions, ODE has set annual goals to reduce chronic absenteeism among homeless students from SY 2015-16 to SY 2025-26. Analysis of lower levels of proficiency in reading, math, and science and higher levels of chronic absenteeism from ODE’s SY 2016-17 data by the National Center for Homeless Education showed a strong negative correlation between test scores and rates of chronic absenteeism.

3. Risk Assessment

a. Minnesota (December 2015)The SEA assesses all LEAs for potential under-identification and underserving of homeless children and youth and uses this risk assessment to target its monitoring of, and technical assistance to, LEAs. The SEA also tracks all inquiries and complaints received annually and uses these two data points to determine a LEA risk rating.

Indicator 2.1: Policy and Coordination

4. State Plan

a. Tennessee (September 2017)TDOE stated in its State plan that it has a Tennessee Advisory Council on the Education of Homeless Children and Youth, which started in April 2016. It is intended to continuously review policies and barriers to identification, enrollment, retention, and achievement of students experiencing homelessness. The first quarterly meeting of subgrantee liaisons was scheduled for October 2017.

5. Identification of Homeless Youth

a. Nevada (May 2015)The SEA practices district-wide planning and coordination across multiple programs, funding streams, and community resources for identifying and serving homeless children and youth.

6. Interagency Housing Initiatives


https://www2.ed.gov/programs/titleipartd/nv-oshsmonitoringreport-final.pdf




a. Washington (June 2015)The SEA has collaboration with housing programs in local communities to provide housing and community resources.

b. Alabama (January 2016)LEA homeless education staff have proactively participated in and collaborated with their Continuum of Care (CoC) and Homeless Management Information System (HMIS), funded by HUD, to develop a coordinated entry system for HUD-eligible families, children, and youth experiencing homelessness.

c. South Carolina (March 2016)The SEA Coordinator is on the Board of Directors of the South Carolina Coalition for the Homeless (SCCH) and serves as a SEA advocate and coordinator on four regional CoCs, which has improved local coordination between education, human services, and housing agencies.

d. West Virginia (April 2016)The SEA actively participates in SEA and regional interagency coordination to reduce and end family and youth homelessness. West Virginia convened an Interagency Council on Homelessness, which issued a report in December 2015 entitled Opening Doors in West Virginia. The report outlines a plan to prevent and end homelessness in West Virginia by 2020.

7. Early Childhood

a. Connecticut (September 2015)The SEA early childhood education program and homeless services sector coordinate comprehensively. There is also a Governor-appointed Children’s Cabinet, which has an early childhood homeless committee that is developing its own action plan and involves the EHCY State Coordinator and Head Start Collaborator.

b. Minnesota (December 2015)Coordination on early childhood education has been advanced by the Race to the Top Early Learning Challenge grant, which was publicly funded so that more early childhood providers are aware of the EHCY definition of homelessness and the less visible population of homeless young children.





https://www2.ed.gov/programs/homeless/sc-ehcy-finalmonitoringreport.pdf


https://www2.ed.gov/programs/titleipartd/wa-oshsmonitoringreport-final.pdf

8. Child Welfare and Juvenile Justice

a. Virginia (June 2018)The State Coordinator participated in a training with the Juvenile and Domestic Relations District Court Judges in May 2018, which is convened through a Federal Court Improvement Project grant awarded by the U.S. Department of Health and Human Services to the Office of the Executive Secretary, Supreme Court of Virginia. The grant program focuses on improving the ability of the court system to manage and resolve cases of child abuse, neglect and foster care. The specific training focused on the intersections and parallel issues for children and youth in foster care or experiencing homelessness, including chronic absenteeism and truancy that impact on-time graduation rates, and on which SEAs and LEAs must now report for students who were either homeless or in foster care in high school as required by section 1111(h)(1)(C)(ii) of the Elementary and Secondary Education Act of 1965, as amended by the Every Student Succeeds Act.

Indicator 2.2: Professional Development and Technical Assistance

9. Training

a. Tennessee (September 2017)The SEA had a statewide training plan for the 2017-18 grant year that included several McKinney-Vento regional trainings. Furthermore, of its eight technical assistance regions, coordinators submitted draft plans in three regions that included specific McKinney-Vento training needs.

b. Kentucky (April 2018)The SEA recently issued a regulation that requires all designated local liaisons to receive annual department approved training to cover at least the following topic areas: the rights and services provided for homeless children and unaccompanied youth; identification of homeless children and unaccompanied youth; the SEA dispute resolution process; data utilization, monitoring and reporting requirements under this regulation; and best practices to serve homeless children and unaccompanied youth.

c. Ohio (September 2018)LEAs can subscribe to two portals called “Public Works” and “Safe Schools” that include training modules on McKinney-Vento. ODE staff may request to view a report of the district staff who have participated in this training, and how well





https://www2.ed.gov/programs/homeless/va-ehcy-finalmonitoringreport.pdf

participants performed on a post-test. This is one way SEAs and LEAs can satisfy the EHCY requirement that SEAs provide professional development opportunities for LEA personnel and the LEA liaison to assist such personnel in identifying and meeting the needs of homeless children and youths, and provide training on the definitions of terms related to homelessness.

Indicator 3.1: Subgrant Management

10. Subgrant Projects

a. Alabama (January 2016)The SEA offers a range of program options geared towards helping homeless and highly mobile high school students to graduate, including a virtual school that also has classes in a building, and an evening school for students who must work or care for children during the day.

b. Indiana (May 2016)Using its McKinney-Vento subgrant funds, the MSD Warren Township’s Academic Growth and Recovery program provides an array of services to homeless children and youth in all grade levels, including academic tutoring with one or more teachers, truancy intervention, social and anger management skills, and breakfast and lunch on Saturdays.

c. Alaska (May 2018)The Anchorage School District (ASD) Child in Transition program is a primary source of referral for early intervention and dropout prevention services to identify young people and families who are, or who are at risk of being, homeless. The State of Alaska Divisions of Juvenile Justice and Behavioral Health and the Office of Children’s Services administer programs that provide family counseling, remediation, and reunification. ASD, the United Way of Anchorage, public benefit agencies, and childcare facilities are points of early intervention to address the rising number of youth entering foster care, entering the juvenile justice system, and experiencing homelessness.

d. Ohio (September 2018)CCS’ Project Connect provides targeted outreach, counseling, and mentoring for all unaccompanied homeless youth and other homeless youth who are juniors and seniors to support their on-time graduation from high school and applications to and enrollment in postsecondary education programs.






With some grant funding and collaboration with the Cincinnati Youth Collaborative (CYC), CCS is also supporting 10 recent high school graduates who were homeless while they are enrolled in institutions of higher education in the metropolitan area. They are given computers and incentives to participate in regular college counseling and mentoring. Project Connect and CYC plan to expand this cohort by 10 students every year and follow them until they graduate from their institutions of higher education.

Indicator 3.2: SEA Set-Aside for State Level Coordination Activities

Not applicable.

Indicator 3.3: Title I, Part A LEA Homeless Set-Aside (in FY 2015-16, Dispute Resolution Procedures)

11. Title I, Part A Set-Aside Use

a. Tennessee (September 2017)Rutherford County LEA explained how it supported two staff funded through the Title I, Part A set-aside who worked intensively in providing support services to middle and high school students experiencing homelessness, liaising with staff including graduation coaches in high schools, resulting in an 89% graduation rate for students experiencing homelessness in grades 9-12.



Appendix L-1

Needs Assessment

McKinney-Vento Services to American Indian and Alaska Native Students

State Educational Agency (SEA) Program Assessment

McKinney-Vento Coordinator (Name, email, and phone number)

Indian Education or Title VI Coordinator (Name, email, and phone number)

Title III/EL Coordinator (Name, email, and phone number)

Additional staff supporting American Indian students: (Name, contact information, title, and brief description of duties)

1. 2.

3. 4.

*Many terms are used to identify Tribal people in general, such as Native, Indian, American Indian, and Indigenous. In this document we will use

the term American Indians. Whenever possible be Tribal specific.

L-1-1 State Coordinators’ Handbook: Appendix L-1. Needs Assessment: McKinney-Vento Services to American Indian and Alaska Native Students

To find your State Indian Education contact see the list here: https://www2.ed.gov/about/offices/list/oese/oie/statecontacts.html

Questions to Consider:

1. Is there a “program” within my SEA that addresses Indian Education issues?

2. What information is available on the SEA website about this program?

3. Is there a committee or group in my agency that is addressing the needs of American Indian/Alaska Native students? If not, consider

convening such a group. For an example see: https://opi.mt.gov/Educators/Teaching-Learning/Indian-Education

4. What supports does my Title III/EL program provide to American Indian/Alaska Native students who speak their American Indian language?

5. How does my State support the teaching of American Indian/Alaska Native cultures and languages in public schools?

6. How can the McKinney-Vento grant application incorporate the inclusion of programs or services to specifically support the unique needs

of American Indian students and families?

7. Which schools serving large numbers of American Indian/Alaska Native students has the SEA identified for additional support as either a

comprehensive or targeted support school as defined by ESSA (additional information here)?

Tribal Assessment

List all federally recognized Tribes located within

the State.

List the names of Tribal reservations in the State and

if several members of other Tribes are living on them,

put the names of those Tribes in parentheses.

List the Tribal Education Director (Name and contact info)


https://www2.ed.gov/policy/elsec/leg/essa/essacctchart1127.pdf

https://opi.mt.gov/Educators/Teaching-Learning/Indian-Education

https://www2.ed.gov/about/offices/list/oese/oie/statecontacts.html

1.

2.

3.

4.

5.

6.

7.

1.

2.

3.

4.

5.

6.

7.

1.

2.

3.

4.

5.

6.

7.

List any additional Tribes recognized by the State, not recognized by the Federal government (include Education contacts if available).

List additional reservations and Tribes on another sheet as necessary.



8. What is my awareness of the history of American Indian/Alaskan Native education, nationwide and in my State?

9. Where can I obtain professional development about best practices regarding American Indian/Alaskan Native education?

10. What networking opportunities should I consider pursuing in support of American Indian students experiencing homelessness or high

mobility?

11. Are there any joint training opportunities between the SEA, LEAs, and the BIE, or Tribal Education Directors that would be of mutual

benefit regarding the implementation of McKinney-Vento in communities with high numbers of American Indian students?

12. Are there any Tribal Education Agencies (TEAs) in my State? If so, what is the current level of communication and collaboration between

the TEAs and SEA? (Example: “Met with several TEAs and have a monthly phone call.” Or “Have provided professional development at the

Tribal Education Conference.”)

American Indian/Alaska Native Student Assessment

Total number of American

Indian/Alaska Native children in my

State

Total school age

(PK-12)

Total in public school Total in charter schools Total in BIE schools Total in Tribally operated

schools


Public school Enrollment Only Head Start/Tribal Head

Start

Elementary (PK-5) Middle School (6-8) High School (9-12)

Total All American Indian/Alaska Native

Children

Total American Indian Enrollment on

Reservation

Total American Indian Enrollment off

Reservation

Total American Indian/Alaska Native and

Homeless


SPED


EL


Migrant

Coordinators should contact their data analyst to obtain a detailed data analysis of American Indian/Alaska Native students enrolled in each

public school district. The following categories of information should be considered: District of enrollment, School of enrollment, Grade


level, Gender, Ethnicity/Tribal Enrollment, Graduation/Dropout information, State Assessment scores, participation in other Federal

programs (Title III/EL, migrant, foster care, Title IV/21st Century programs, CTE/Perkins programs, etc.)

Districts should be sorted by the reservation in which they are located. Districts located off of reservations that have American Indian

students enrolled should be included in this spreadsheet. The coordinator should contact the district to determine which Tribes or

reservations are represented in their student populations.

Obtain a list of schools served by Educational Talent Search, GearUp, or other programs aimed at supporting high school graduation and

college attendance.


13. If I have BIE schools in my State, where are they located, and what type of school are they?

14. Is my state the site for an Education Program Administrator (EPA) supported by BIE? If so, what communication exists between SEA and

EPA? Between EPA and LEAs?

15. Are there any State-level data on key indicators regarding child well-being and American Indian students? What are the specific issues,

current and ongoing, of the American Indian American communities affecting these students in my State (e.g., poverty, suicide,

unemployment)? http://www.aecf.org/m/resourcedoc/aecf-2018kidscountdatabook-2018.pdf

https://www.cdc.gov/violenceprevention/pdf/suicide-datasheet-a.pdf https://www.cdc.gov/healthyyouth/data/yrbs/results.htm

http://opi.mt.gov/Portals/182/Page%20Files/YRBS/17NativeAmericanTrendData.pdf (The last one is a specific example from Montana.)


http://opi.mt.gov/Portals/182/Page%20Files/YRBS/17NativeAmericanTrendData.pdf

https://www.cdc.gov/healthyyouth/data/yrbs/results.htm

https://www.cdc.gov/violenceprevention/pdf/suicide-datasheet-a.pdf

http://www.aecf.org/m/resourcedoc/aecf-2018kidscountdatabook-2018.pdf

16. What information is shared between Tribal foster care agencies and the SEA?

17. What types of statewide or local agencies in my State provide services to American Indian/Alaska Native students and/or their families?

What opportunities exist for increased coordination between and among agencies as families move between public schools, BIE schools,

and/or Tribal/reservation schools?

18. Is educational support provided through BIE or Tribal governments for students attending public schools? The Elementary and Secondary

Education Act of 1965 (ESEA) requires that schools conduct Tribal consultation with American Indian Tribes when 50% or more of the

student population is American Indian, or the LEA received $40,000 or more in Title VI Formula Grant funding prior to submitting a plan

or application for covered programs. http://www.niea.org/wp-content/uploads/2016/02/NIEA-Evaluation-Bklt-FINAL-1.pdf

19. How can the data that I am gathering be used to provide technical assistance and training to help LEAs meet the unique needs of American

Indian/Alaska Native students, and who should be involved in these trainings?

20. Is there a statewide Indian Education Advisory Council, or similar group, whether established by law or by communities coming together

around common goals? Most States have established Commissions or Committees on Indian Affairs. The following link provides

information and further links to specific legislative or executive initiatives http://www.ncsl.org/research/state-tribal-institute/state-tribal-

relations-committees-and-commissions.aspx. http://www.niea.org/


http://www.niea.org/

http://www.ncsl.org/research/state-tribal-institute/state-tribal-relations-committees-and-commissions.aspx

http://www.ncsl.org/research/state-tribal-institute/state-tribal-relations-committees-and-commissions.aspx

http://www.niea.org/wp-content/uploads/2016/02/NIEA-Evaluation-Bklt-FINAL-1.pdf

Higher Education Assessment

List all in-State Tribal Colleges (Name and address) Dual Enrollment? TRiO program? Tutoring? Subjects? Student Housing?

1.

2.

3.

4.

5.


6.

7.

List any other in-State schools offering specific programs to support American

Indian students.

1.

2.

3.

Add additional sheets as necessary.


21. Are there colleges, universities, or community colleges in my state that may be involved in education initiatives for American Indian/Alaska

Native students? (Further information on the USDE 2018 Indian Education Professional Development Grant is available at

https://www2.ed.gov/programs/indianprofdev/applicant.html.

22. Does my State have an Higher Education State Point of Contact?


https://www2.ed.gov/programs/indianprofdev/applicant.html

23. Have school counselors received training on how to assist American Indian students in accessing educational benefits based on their Tribal

enrollment status or ethnicity? What types of training do they need? (The ESEA requires that school counselors be able to assist and advise

students in planning and preparing for college.)

24. Are there any federal grant projects being implemented in my State, either statewide or local, involving higher education or K-12 (e.g.,

STEP Awards, demonstrations grants, etc.)? Are there any reports, proceedings, or other documents available that describe the work of

the project?

State and Community Assessment – Questions to Consider

25. What types of services are available to Indian children experiencing homelessness that go beyond State and local community services (e.g.,

The Indian Health Act)? What supports are lacking?


26. Has my State legislature enacted any specific laws that impact the education of American Indian/Alaska Native students? What do these

laws require? (Note: The Native American Rights Fund has compiled the education laws of 39 States in their document, Compilation of

State Indian Education Laws, available at http://www.narf.org/wordpress/wp-content/uploads/2015/01/blue.pdf ) .

27. What projects, initiatives, coalitions, or collaborative efforts have resulted from these laws in my State?

28. Are there any statewide, regional or local coalitions, projects, or other efforts that would offer an opportunity to bring McKinney-Vento

into the discussion and build a more collaborative network to serve American Indian students experiencing homelessness? If not, consider

facilitating the creation of one in your State.



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