Title III Funding Guidelines
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Title III Funds
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Must be used to supplement the level of
Federal, State and local funds that, in the
absence of Title III funds, would have
been expended for programs for LEP
students and immigrant children and
youth.
(Section 3115 (g))
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The USDE assumes supplanting exists if –
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A local educational agency (LEA) uses
Title III funds to provide services that the
LEA is required to make available under
State or local laws, or other Federal laws
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The Department assumes supplanting
exists if –
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An LEA uses Title III funds to provide
services that it provided in the prior year
with State, local, or other Federal funds.
(This assumption may be rebutted)
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1. What is the instructional program/service provided to all
students?
2. What does the LEA do to meet
Lau requirements?
3. What services is the LEA required by other Federal,
State, and local laws or regulations to provide?
4. Was the program/service previously provided with State,
local, and Federal funds?
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Would the proposed funds be used to
provide an instructional program/service
that is in addition to or supplemental to an
instructional program/service that would
otherwise be provided to LEP students in
the absence of a Title III grant?
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T3 funds are supplemental to existing
bilingual-bicultural programs (state-aid).
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Reasonable lunch for participants in a
professional development activity, if there
is no other opportunity to eat, and the
activity is all day
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Reasonable snacks for students for Title III
funded summer or after-school programs,
and transportation for these programs, if
needed and not provided by the district
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Tickets and transportation for educational
field trips, if part of high-quality language
instructional educational program
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Reasonable refreshments for parent
outreach activities
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Core Instructional services/programs
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Coordinating
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Administration
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Clerical
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(above and beyond current positions &
require different job descriptions)
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Consultant
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PD provider
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Instructional coach
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Mentor
Explore the guidelines for using Title III funds to supplement programs for LEP students and immigrant children. Learn about the tests for supplanting, allowable expenses, and essential questions to ask. Ensure compliance with federal, state, and local laws to maximize the impact of Title III grants.
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Presentation Transcript
Title III Supplemental Guidance & Allowable Expenses Jacqueline A. Iribarren, Ph.D. Title III Consultant Fall 2013
Title III Funds Must be used to supplement the level of Federal, State and local funds that, in the absence of Title III funds, would have been expended for programs for LEP students and immigrant children and youth. (Section 3115 (g))
The First Test of Supplanting: Required by Law The USDE assumes supplanting exists if A local educational agency (LEA) uses Title III funds to provide services that the LEA is required to make available under State or local laws, or other Federal laws
The Second Test of Supplanting: Prior Year The Department assumes supplanting exists if An LEA uses Title III funds to provide services that it provided in the prior year with State, local, or other Federal funds. (This assumption may be rebutted)
Questions to Ask regarding the Supplement not Supplant Requirement: 1. What is the instructional program/service provided to all students? 2. What does the LEA do to meet Lau requirements? 3. What services is the LEA required by other Federal, State, and local laws or regulations to provide? 4. Was the program/service previously provided with State, local, and Federal funds?
Bottom Line: Would the proposed funds be used to provide an instructional program/service that is in addition to or supplemental to an instructional program/service that would otherwise be provided to LEP students in the absence of a Title III grant?
Allowable Expenditures & Activities
Costs of Activities must be: The federal criteria Reasonable Allocable Allowable
Points to Consider if your district receives Bilingual/Bicultural State-aid T3 funds are supplemental to existing bilingual-bicultural programs (state-aid).
What is? Reasonable: Activity 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 co
What is? Allocable: A cost is allocable to a cost objective if the goods or services involved are chargeable or assignable to the cost objective in accordance with the relative benefits received.
What is? Allowable: A cost is allowable if it is necessary and reasonable for proper and efficient performance of the award and allocable to the award.
MAY be allowable costs: Reasonable lunch for participants in a professional development activity, if there is no other opportunity to eat, and the activity is all day Reasonable snacks for students for Title III funded summer or after-school programs, and transportation for these programs, if needed and not provided by the district
MAY be allowable costs: Tickets and transportation for educational field trips, if part of high-quality language instructional educational program Reasonable refreshments for parent outreach activities
How about Salaries/Positions? Not Allowed Core Instructional services/programs Coordinating Administration Clerical
How about Salaries/Positions? Allowed (above and beyond current positions & require different job descriptions) Consultant PD provider Instructional coach Mentor
