Office of Accountability

Frequently Asked Questions (FAQs):
2009-10 Technical Assistance Teleconferences for the Consolidated Application Update


Academic Intervention Services

Q: Since there is no "Math" certification for elementary, is it reasonable to assume that Elementary Certification is acceptable for providing Math AIS services?
A: Yes.

Q: If someone is providing AIS services in grade 7 for only 1 period a day, and is certified in K-6, would that be acceptable, as 1 period outside of their area?
A: NYSED regulations allow up to 5 hours per week of "incidental teaching", see Subpart 80.5-3 at, and item A-12 of the NCLB NYS Field Memo at  If such a teacher were providing CORE subject instruction according to the schedule described in your question, they could become highly qualified to do so by demonstrating their content knowledge through use of the HOUSSE, or other allowable methods (both are described in other sections of the NCLB NYS Field Memo cited above).  However, since AIS services are not considered core instructional activities, no such demonstration of content knowledge is needed to meet NCLB and IDEA "highly qualified" requirements, or NYSED regulations related to incidental teaching.  
For information regarding what is required under Academic Intervention Services (AIS), see:


Q: Please detail the accountability statuses for the district and schools in my district.
A: Current accountability reports for 2008-09 assessments are available on nySTART for each LEA.  Reports are updated weekly and only available to LEAs for verification and correction until final release in August.  Prior year reports are available online:
You may also consult your SED liaison @ (518) 474-5923.

Q: If the accountability status lists aren't available prior to August 31, should we assume the 2008-09 status for each building and include SES and School Choice in our budget? 
A: If you assume the 2008-09 status for each building, you will probably be required to revise your application shortly after submission.  LEAs will have access to their preliminary Accountability Overview Reports in early August and should use that information for the 2009-10 Consolidated Application if at all possible. 
Changes in federal rules (Part 200 of the Regulations of the U.S. Department of Education) now require New York State to report on the accountability status of schools and districts no later than 14 days prior to the start of the school year.
For the 2009-10 school year, all accountability status determinations must be reported publicly by the State Education Department no later than August 26, 2009.

Highly Qualified  Teachers

Q: Regarding Title I, 5% professional development set-aside because there was less than 100% highly qualified teachers: What items can be included in the 5%? 
A: The 5% professional development set-aside is not for general professional development (PD).  It is to be used to ensure all teachers and paraprofessionals are highly qualified and/or certified per NCLB Section 1119 legislation.  Title I funds can be used to complete certification filing requirements (ex. Fingerprinting, exams, etc.) and college-level coursework completion.  The 5% set-aside is in addition to the 10% building PD set-aside requirement for SINI, Corrective Action buildings and the 10% PD set-aside for Districts In Need of Improvement (DINI). If an LEA can assure (describe how) that they can get all core academic teachers and paraprofessionals to be highly qualified and/or certified by using less than the 5% amount they may do so.  As an example, if several teachers need to go through the fingerprinting process or Child Abuse training in order for all core academic subject teachers to meet Section 1119 requirements, the LEA could justify an amount less than the required 5% set-aside.

Q: When we look at our staff relative to being "highly qualified", are we looking for CORE areas only?
A: Yes.  The NCLB definition of "highly qualified" pertains only to core subject areas.  Core academic subjects for the NCLB and IDEA are English, reading, language arts, mathematics, science, history, geography, economics, civics and government, foreign languages and the arts.  In New York State, the arts include the visual arts, dance, music, theater - including public speaking - and drama.

Q: What content area does the State look for with our AIS teachers?  For example, is Elementary Certification acceptable for someone providing AIS in K-6, or would the State be looking for Literacy Certification?  (It is a bit difficult sometimes, since certification areas and tenure areas do not align.)
A: This is a confusing area.  In general, a teacher with elementary certification meets the NCLB definition of "highly qualified" for all core subjects, including developmental reading and English Language Arts.  NYSED certification regulations require a Literacy or Reading certification for the teaching of 'remedial reading', and so only a teacher with this certification would be considered "highly qualified" under the NCLB and IDEA for the teaching of remedial reading as a core subject.  However, in general, remedial reading is not considered by the LEA to be a core subject, and is usually offered as supplemental instruction.  When it is offered as an AIS service, it is by definition "not core", and in this case the NCLB definition of "highly qualified" does not apply.  See item A-5 in the most recent NCLB NYS Field Memo at

Q: For the required set-aside for non-highly qualified Teachers:
What procedures do we follow if we reported on one teacher who was not highly qualified last year and that teacher is still not highly qualified during the 09-10 school year?
A: Identification as failing to meet the 100% HQT benchmark in 2007-08 is what generates the requirement to complete a teacher quality plan.  The district should use the HQ/C report provided by NYSED’s Office of Information and Reporting Services  (the BEDS office) for that year as its primary source for determining why it failed to meet the 100% target.  If the HQ/C report confirms that the gap remains as only the 1 teacher, the 2009-10 Teacher Quality Plan should address district progress or failure in getting that one teacher to HQ status, and indicate any new strategies that will be employed.  The set-aside requirement remains, but may be released following approval of a viable plan.

Q: When and where do we find the highly qualified 2008-09 numbers?
A: 2007-08 teacher quality data is at teacher quality data has not yet been finalized or released.

Q: Do we base whether we need to set- aside Professional Development funds for HQ based on the 2008-09 numbers or the number projected for 2009-10?
A: Highly qualified teacher data for the 2007-08 school year determines whether or not the LEA met the benchmark of 100% HQ.  Districts that did not, must include responses to the Teacher Quality Plan, Section A, in their Consolidated Application.  Districts that also failed to meet AYP in the past three consecutive years must also complete Section B. 
In both cases, the Title I 5% set-aside must be reserved.  An approvable plan might include district knowledge of 2008-09 teacher quality issues in the district, or even projections for 2009-10, but neither is required.  If the Teacher Quality Plan accurately assesses district HQ data and gaps in the 2007-08 school year, proposes reasonable strategies to achieve the 100% target as soon as possible in the future, and proposes use of Title IIA or other funds to meet this goal, the 5% set-aside in the Title I budget may be released.

Private Schools

Q: How is the Title I private school student set-aside calculated and what are the uses for the funds?
A: The Title I, Part A calculation is always based on multiplying the number of poverty children, living in a Title I attendance area in the LEA, times the calculated Supplement Form, Per Pupil Amount (PPA) (whether or not your students are attending a private school inside or outside the district).  For students attending the private school from outlying Local Educational Agency (LEAs) their PPA is multiplied by the number of poverty children, living in a Title I attendance area in that LEA.  An LEA could conceivably have varying PPAs because of students from other LEAs, or even varying PPAs within the LEA of residence (where the private school is located).  In the rare instances where there is only one poverty student from another LEA attending the private school, that student must also be in academic need in order to generate funds for services.  Title I funds may be used in private schools the same way it is used in public schools. Supplement/Supplant rules apply to private schools.
A good source for information on the uses of Title I funds for private schools is the “Title IX, Part E Uniform Provisions Subpart 1-Private Schools – Non-Regulatory Guidance”, dated August 2005.   Also, the October 17, 2003 – Title I Services to Eligible Private School Children – Non-Regulatory Guidance is helpful in this area. These guidance documents can be downloaded from the USDOE web site at:
Federal guidance suggests the following strategies to use when a private school’s set-aside amount is too small for instructional services: Pool (i.e. private school consortium) set-asides from several private schools to provide instructional services, take-home computer programs, individual tutoring programs/sessions, professional development activities for private school teachers with Title I students, parent involvement activities, and counseling (for students who are failing or at risk of failing).

Q: Please clarify funding to private schools.
A: The question is too general for a specific answer since there are many issues related to equitable services to eligible private school children (the children receive the services, not the private school).
A good source for information on the uses of Title I funds for private schools is the “Title IX, Part E Uniform provisions Subpart 1-Private Schools – Non-Regulatory Guidance”, dated August 2005.  Also, the October 17, 2003 – Title I Services to Eligible Private School Children – Non-Regulatory Guidance is helpful in this area. These guidance documents can be downloaded from the USDOE web site at:
In general, eligible students, parents, and teachers attending a private school are to be provided equitable services as those offered in a public Title I school.  Title I funding amounts are calculated as noted above, by multiplying the number of poverty students who live in a district’s Title I attendance area (i.e. They would be enrolled in a district Title I school if they were not attending the private school) by the calculated Per pupil Amount from the online Title I Supplement Form.  Things that can affect a private school’s allocation include:
(1) Whether the district calculates a 125% PPA, or whether set-asides are taken out before a PPA is calculated.
(2) An allocation over or under $500,000.00 can affect a private school’s set-aside.  
(3) If only one student from the district is attending a private school outside the district, certain criteria must be met before a set-aside can be determined.
Should you have questions about your own unique private school issues, please call our office at (518) 473-0295.

Q: In consulting with our non-public schools, what are their options when they do not receive enough funding to support a Title I teacher?  If they receive funds from outside districts and do not know their allocation prior to submitting the grant, how do they report it on their participation form?
A: Title I funds cannot be used solely to purchase supplies and materials.  If supplies & materials are purchased they must be secular, neutral and related to academic intervention services.  The LEA is responsible for overseeing the use of those materials in the proper manner.  Federal guidance suggests the following strategies to use when a private school’s set-aside amount is too small for instructional services:
(1) Pool (i.e. private school consortium) set-asides from several private schools to provide instructional services, take-home computer programs, individual tutoring programs/sessions, professional development activities for private school teachers with Title I students, parent involvement activities, and counseling (for students who are failing or at risk of failing). (2) If after making and documenting their best efforts at trying to obtain the student counts, a private school should estimate the number of private students from other districts, based on past experience when filling out the Private School Participation Form of the 2009-10 Consolidated Application Update.  Remember, that calculation does not affect the district of residence’s private school set-aside, nor does Title I funds from other LEAs show up on the district’s FS-10.


Q: Is there a posted webinar for the ’09-‘10 Consolidated Application?  We can only locate the webinar for ’08-’09.
A: Since there are no significant changes to the 2009-10 Application, it is helpful for LEA staff to review their 2008-09 Application and the posted webinars from 2008-09.  A 2009-10 Webinar is being planned to address the common errors in Application submission.  Periodically check the link (below) for any postings.

Parental Involvement

Q: Do we submit the Parental Involvement Policy if no changes have occurred for the 2009-10 school year? 
A: Yes, all LEAs are required to submit their Parent Involvement Policies (PIP) whether or not there have been any changes to it.  LEAs should look to see when the PIP was last reviewed.  LEAs are required to annually evaluate the content and effectiveness of their PIPs.

Q: Does the sample letter for the Parent's Right (Title I-A) To Know need to be submitted again?  Since I took over this task last year, I have not been able to find this letter in the files. Can you explain what is required to be stated in this letter?
A: If there have been no significant changes to the letter’s content it does not have to be re-submitted.  If you cannot find the letter you must create a new one.  Since you have nothing to compare to, you should submit a new one. The best guidance can be found in NCLB Section 1111 legislation.  At a minimum, the letter should contain information that parents may request regarding the professional qualifications of the student’s classroom teachers including:
(i) Whether the teacher has met State qualification and licensing criteria for the grade levels and subject areas in which the teacher provides instruction.
(ii) Whether the teacher is teaching under emergency or other provisional status through which State qualification or licensing criteria have been waived.
(iii) The baccalaureate degree major of the teacher and any other graduate certification or degree held by the teacher, and the field of discipline of the certification or degree.
(iv) Whether the child is provided services by paraprofessionals and, if so, their qualifications.
There are additional suggested (not required) pieces of information which are included in NCLB Section 1111 legislation.

Neglected and Delinquent

Q: Is there a separate list of allowable and unallowable expenses for Institutions with Delinquent students (Title ID) allocations, as opposed to the Title IA allocations?
A: As with Title I A funds, Title I D funds are supplemental to the core program operating at the facility.  The following web link has a description regarding the use of Title I D funds you may find useful.

Q: What special provisions are there for Special Act School Districts? 
A: Special Acts must follow all the requirements for Title I D as every other school district.  The funds must be used to supplement the core educational program at the facility.

Q: How should I handle left over funds from 2008-09 from the Catholic schools and juvenile facilities? They haven’t spent all of their funds. How long do I carry these funds?
A: Funds remaining for the private schools must be indicated on the new application and budget as carryover.  The funds must be utilized by the Catholic schools and not by the district.  Funds remaining for the juvenile facilities must also be indicated on the new application and budget as carryover.  The funds must be utilized by the juvenile facilities and not by the district.
The funds can be carried over for 27 months from the date of the initial allocation.

Q: Can you please explain the amount set-aside for neglected students?
A: The neglected set-aside is calculated by multiplying the child count listed for the facility by the Title I per pupil calculated for the district.

Title II A

Q: Regarding Title IIA, please provide an explanation of the class size reduction positions as well as coaching or mentoring positions.
A: Title II, Part A allows LEAs to spend funds on a variety of strategies to improve teacher and principal quality, recruit and retain highly qualified teachers and principals, ensure the equitable distribution of highly qualified teachers, and provide high quality professional development.  Mentoring and coaching positions can arguably support any of these goals, as can professional development provider positions.  The Title also allows the district to hire highly qualified teachers to meet class size reduction purposes.  In both cases, the proposed positions should be supported by the district’s prioritized needs assessment, and meet all other requirements of Title II A, including supplement-not-supplant requirements.  See NCLB sections 2122 and 2123 at:, also see Title II A Guidance, and particularly related to class size reduction, items E-1, 8 and E13-E16 at:

Q: Can Title II-A funds be carried over from the ‘08-‘09 year to ‘09-‘10?
A: Yes.  100% of Title II A funds may be carried over for one year.

Title III

Q: Will the Consolidated Application include Title III-A Immigrant allocations?
A: When available, the Title III allocations will appear with the Consolidated Application information at:

Q: For school districts who submitted the two year AMAO (Annual Measurable Achievement Objectives) mprovement Plan, what are the procedures for the 2009-10 school year for completing the Title III?
A: If the LEA or Consortium met the AMAOs for the 2007-08 school year and has met AMAOs for two (2) or more consecutive years, your LEA/Consortium is deemed in good standing and does not have to submit any reports.
If it has been determined that your LEA or Consortium has failed to make progress toward meeting the AMAO objectives for two (2) consecutive years (2006-07 and 2007-08), you are required to submit an Improvement Plan.  The Plan is a two-year plan and must be developed and implemented during the 2009-2010 and 2010-2011 school years and should include the following:

  • A description of well-researched and scientifically-based professional development strategies and activities that an LEA or Consortium could use to meet the AMAO objectives; and
  • A description of well-researched and scientifically-based strategies and methodologies that will serve to improve specific programs, curricula, or method(s) of instruction provided to LEP/ELL students.

If your LEA or Consortium submitted an AMAO two-year Improvement Plan last year, together with your NCLB 2008-09 NCLB Consolidated Application Update, you do not have to submit one this year, unless changes have been made to the initial plan that was previously approved.

If the LEA or Consortium has not met its AMAOs for four (4) consecutive years, you are required to submit a Corrective Action Plan (CAP).  These plans must be submitted together with your district’s NCLB 2009-2010 Consolidated Application Update which is due on August 31, 2009.  The Corrective Action Plan must be completed by LEAs or Consortia that did not meet AMAOs for four (4) consecutive school years (i.e. 2004-05, 2005-06, 2006-07, and 2007-08).  The CAP is a two-year plan that will be developed and implemented during the 2009-10 and 2010-11 school years, and must address the objectives/activities of your Comprehensive Plan, as well as the following objectives:

  • Make adequate yearly progress (AYP) in the English language proficiency among LEP/ELL students;
  • Modify curricula, programs and method(s) of instruction to best address the needs of LEP/ELLs; and
  • Evaluate, and, if necessary, replace educational personnel critical to the success of LEP/ELL students making progress in developing their English language proficiency and academic achievement.  The CAP must address the factors which prevented the LEA or Consortium from meeting the objectives outlined in its Improvement Plan and to indicate actions and strategies to be taken in order to meet the AMAO objectives.

Note:  Those LEAs or Consortia without an approved AMAO Corrective Action Plan (CAP), will not receive final approval of their 2009-2010 Title III LEP and Immigrant allocations.

Those LEAs or Consortia that have not met their Title III AMAOs for three (3) consecutive years are not required to submit a plan at this time.  However, it is highly recommended that these LEAs or Consortia critically review and evaluate the educational programs that are currently in place for LEP/ELL students to avoid being designated as a Title III Corrective Action LEA or Consortium.

Title III of the NCLB Act also requires LEAs and Consortia that have failed to make progress on their AMAOs, for either two or four consecutive years, to inform parents of such failure no later than 30 days after the LEAs and Consortia have been notified.  The information included in the letter to parents/guardians must be easily understandable, uniform, free of technical jargon, with additional explanations if necessary, and to the extent practicable, in a language that the parents/guardians can read and understand.

Information about your LEA or Consortium AMAO status can be found at the following NYSED OBE-FLS website:

Title IV

Q: Will there be Title IV funds?
A: Funds have been appropriated for 2009-10.  However, as of now, there is a proposal for the elimination of Title IV funds for the 2010-2011 funding year.  Please be advised that this is a proposal, and Congress will ultimately decide what the actual legislation would be.

Title V

Q: Do we complete the Title V- Innovative Programs this year (’09-‘10)?
A: No.  All Title V, Part A components will be eliminated from the 2009-10 Consolidated Application Update.  Funding for Title V, Part A has not been appropriated since 2007-08.  In 2008-09, LEAs were able to use carryover funds that remained from unexpended 2007-08 appropriations.  This opportunity expires effective August 31, 2009; any carryover funds remaining must be returned to USDOE.

Q: Will districts be able to utilize transferability to Title V in 2009-2010?
A: No.  There are no funds accounts under Title V, Part A for 2009-10.

McKinney-Vento, Homeless

Q: What are the requirements for homeless student allocations?
A: If the LEA has non-Title I schools, a reserve/set-aside must be identified in the Title I, FS-10 budget for the services for homeless students who attend non-Title I Schools, although it may be used for homeless students who attend Title I Schools as well.  Even if no homeless children or unaccompanied youth are currently identified, a reserve must be included for homeless children who may enroll during the school year.
The Title I director must coordinate the set-aside amount and its uses with the district’s homeless liaison. See the following website for allowable services: The plan for homeless students, in the Consolidated application, must articulate clearly how the district’s homeless liaison will ensure that Homeless children and youth and their families receive educational services for which they are eligible, including Head Start, Even Start, and preschool programs administered by the LEA, and referrals to health, mental health, dental, and other appropriate services;
To calculate the set-aside for homeless a district needs to identify who is homeless.  All districts receiving Title I funds are required to use an enrollment form at registration that asks nighttime residence that will identify who is homeless.  Please see the following website for the enrollment form:
Four methods you might be able to use to determine your set-aside for homeless students:

1. Review needs and costs involved in serving homeless students in the current year and use those figures to project for the following year.
2. Multiply the number of homeless students by the Title I Part A per pupil allocation.
3. For districts with subgrants, reserve an amount greater than or equal to the McKinney-Vento subgrant funding request.
4. Reserve a percentage based on the district’s poverty level or total Title I Part A allocation.

For more information: Homeless children and youth are entitled to receive all of the services that are provided to their non-homeless counterparts and in the same setting as their non-homeless peers.  These include: before-school, after-school, and/or summer programs; counseling services; outreach efforts to identify children and youth living in homeless situations and help them access school programs; basic needs such as clothing, uniforms, school supplies, and health-related needs; transportation once the student is permanently housed; the work of the liaison; tutoring services; parental involvement programs that make a special effort to reach out to parents in homeless situations; research-based programs that benefit highly mobile students; data collection to assess the needs and progress of homeless and other highly mobile students; and other services that are not ordinarily provided to permanently housed Title I students and are not available from other sources.

Maintenance of Effort (MOE)
Q: Please explain MOE.
A: MOE, or Maintenance of Effort, like Supplement Not Supplant, is a mechanism to ensure that federal funds support additional services to improve education rather than just paying for existing, or required, ones.  An LEA maintains its effort when it continues to contribute at least 90% of the amount of local and state funds that it contributed in the preceding year.  When we speak about MOE, we are generally looking at 3 years - the year under consideration for funding, e.g., 2009-10, which we’ll call year 3; the year prior to that (2008-09 in this case), which we’ll call year 2, and the preceding year (2007-08), which we’ll call Year 1.  In order to receive its full federal allocation in Year 3, the LEA must have, in year 2, contributed at least 90% of what it had contributed in state and local funds during Year 1.  Barring exceptional circumstances, such as a disaster or drastic cut in state and local funds, an LEA that failed to maintain that 90% effort will have its Year 3 allocation cut accordingly.

Title I Supplement

Q: When will the Title I Application Supplement be available?
A: The Title I Supplement is also in the revision stages and not yet ready for release.  We are trying to put it in the same format as the Comparability report was last year (easy-to-produce, retrievable data, etc.)

Q: Can we use last year’s Consolidated Application and the Title I supplement and fill them out?
A: Some of last year’s forms (consultation/collaboration, private school part) require only that the dates be changed. The 2009-10 Supplement will be different.

Q: I would like to know the last day that changes in the Title I Allocations can occur after approval of the FS-10's.
A: Allocations are always vulnerable to changes if USDE says to change them.  The routine posting of “final” Title I allocations usually takes place in Dec. /Jan., after the final data are received from the Charter School LEAs.  There are no scheduled changes to the other Titles after the initial posting.

2009-10 Consolidated Application Update

Q: Please list any commonly missed areas or common errors.
A: Common errors include missing required forms & signatures:

  • Signed Assurances and Certifications – (pages 9-22) Assurances & certifications must be attached to signature page.
  • Consultation/Collaboration Documentation Form 2009-10 (boxes not checked, required group not represented, IIA paraprofessional, IV student, parents)
  • Title I, Part A, Services for Homeless Students, LEA Plan – item 2 (enrollment form) and item 3
  • Title I, Part A, item 11 – Coordination of Services
  • Title I, Part A, LEA Plan – item 13 – Parent Involvement narrative response and copy of Title I LEA Parent Involvement Policy.  We need to see it every year.
  • Title II, Part A, narrative response to question #1
  • Title II, Part D, on line Technology Plan Checklist, and current Technology Plan website address
  • Title IV, Part A, Safe and Drug Free Schools (item 7) and the typology table.
  • Private School Participation Form(s) (if applicable) Include allocations, check accepting or declining and description of programs attached.
  • Title I, Part D, Participation of Facilities with Children Who are Neglected, Delinquent, or At-Risk of Dropping Out of School Form (if applicable)
  • Budget Narrative for each program.

Q: Can you provide websites and contact information for technical assistance?
A: Technical assistance for the Consolidated Application Update can be found at:

Q: How different will the page numbers on the 2009-10 Consolidated Application Update be from last year? 
A: They will be similar to last year’s application.  There are 91 pages in the document under review.

Q: Will the application still be available at the NCLB web site or must we download it from SEDDAS?
A: The Application and guidance will be posted at:

Q: We would appreciate a general overview of the process.  In addition, can you provide information on any training sessions for Title I, IIa, IId, III, IV and UPK coordinators?
A: Preparation of the Consolidated Application is an important part of school improvement planning and its components reflect steps in that process.
A general overview of the process is provided by the Webinars on our Technical Assistance page.


Q: What changes have been made in the application process?
A: Title V was deleted.  Schools newly identified in August/September 2009 are required to offer SES in the first year of improvement (Differentiated Accountability).  The submission instructions require one original application with 2 copies in word format on CDs.  In addition to the original signed application, you must also submit 1 hard copy of all appropriate signature pages as follows:

  1. Consultation/ Collaboration Form;
  2. Private School Participation Form; and
  3. Title I, Part D Neglected and Delinquent Form

Budgets still require an original and two hard copies.  Only one budget narrative is required for each budget code.

Q: Can you give examples of outstanding budget narratives?
A: The budget narrative should briefly explain the line item expenditures in the budget so that the reviewer can determine that the expenditure is allowable.

Q: I need to verify that the correct BEDS Codes are being used across each Title Award.
A: Go to the following link to verify your schools’ BEDS code:
You can also contact the BEDS office at (518)-474-7965.

Q: How is the application different for a school identified as a "School in Need of Improvement" Year One?
A: Applications for LEAs with Title I schools in improvement must use the Group 1 checklist and complete the applicable sections for School Improvement, Public School Choice and SES (if the school does not make AYP for 2008-09 and becomes a School in Improvement – Year 2).The budget would have to include any required set-asides for professional development in the identified building.  The supplement would have to show the required 20% reserve for Choice/SES, and the budget would have to show the Title I funds that are being used for the 20% Choice/SES reserve.

Q: How is poverty calculated for funding purposes?
A: See the Eligible Child Count tables on our Web site at

Q: My allocation has been decreasing dramatically for the past three years. Is this happening to everyone and why?
A: Title I funds are allocated based on the size of the State allocation, the eligible child count, and an LEA’s relative position vis-à-vis the other LEAs in the State.

Q: Regarding the Title I Supplement: What is the best method for determining cost per pupil?
A: Follow the instructions on the Supplement form.  It depends if your LEA has a 125% requirement, and how many attendance areas are Title I-eligible.  The bottom line is that each LEA needs to sub-allocate all of its available funds (the figure at the end of Section 6 of the Supplement) among its Title I-eligible attendance areas.  An LEA can take that figure and divide by the total number of poverty pupils in Title I attendance areas and come up with a good Per Pupil Amount (PPA).

Q: If an LEA is no longer eligible for Title I, Part A, can we use Transferability of the use of funds from other Titles for I-A purposes?
A: Yes.  An LEA in Good Standing can transfer the use of 50 percent of the base current year allocation of Titles II-A, II-D and IV-A for purposes in any one of those three Titles or Title I-A/D.  An LEA in Improvement Status is limited to 30 percent of the base allocation, and LEAs in Corrective Action cannot use Transferability.  The lack of a base allocation amount for the Title in which the proposed usage is being contemplated does not preclude Transferability.  For the 2008-09 project year, LEAs were allowed to use Transferability for Title V-A purposes, even though there was no 2008-09 allocation for that Title.

Q: How long are we required to keep the old Consolidated Applications on file?
A: LEAs are required to keep the old Consolidated Application for seven years.  After the seventh year, LEAs may discard the application.

Q: Our Tech Plan has been approved until 2012 pursuant to the requirements of the FCC's e-rate.  Will that acceptance count for Title II?
A: A tech plan for E-Rate application will not count for Title II Part D.  LEAs are required to create or update its long term education technology plan as a part of its education improvement plan with focus on integrating technology into teaching and learning and improving students' academic performance.

Q: How can I fund someone to serve as an attendance officer at the middle level?
A: Attendance Officers are generally locally funded.  The position of Attendance Officer, as it’s usually conceived, isn’t one that can be funded by Title I.  It’s usually a district level position with reporting responsibilities that are not limited strictly to removing barriers to academic performance for participating children.  However, the fact that you mention only the middle level suggests that you may be conceiving of this position differently.  As with many Title I issues, additional details are needed to answer your question.  They include, among others, the functions to be performed; eligibility for services of the students to be served; and whether or not any similar positions have been, or will be supported by other funds.
First, whom will the attendance officer serve?  All students in all middle schools?  If so, are all of your schools Title I Schoolwide Programs and have their needs assessments identified poor attendance as a significant barrier to improving the school’s performance?  If your schools are Targeted Assistance, will the attendance person work only with identified students and their families?  If the position will serve any students within the district who do not either meet the Title I academic eligibility criteria or attend a Title I Schoolwide program, or if the LEA is supporting, or intends to support similar positions with local funds, it will no longer be supplementary in the sense of being above and beyond what any other students would receive and what the district would otherwise support.
Will the purpose of the attendance officer’s funded work be exclusively devoted to removing barriers to academic performance caused by poor attendance (or to other allowable activities)? To the extent that it’s not, Title I can’t be used to fund it.
If the position meets the criteria above, has it ever been paid for through local funds or a different existing federal grant?
Essentially, barring any special circumstances, you can only fund this position with Title I funds if
a) the attendance officer will serve only students who are Title I eligible for whom poor attendance is presenting a barrier to their academic achievement or students in schoolwide program schools that have identified poor attendance in their needs assessment and funding this position as part of the schoolwide plan.
b) this will be the  position’s sole function (with the exception of other allowable Title I activities) and no similar positions have been or will be supported by other funds within the LEA.
Such a position would really be more like that of a social worker or student/family attendance advocate, rather than an attendance officer, which implies a number of non-allowable functions, so it should be named differently to prevent it from slipping into some of those non-allowable activities associated with attendance officers down the road.

Q: When will the application materials be available on-line for the consolidated grants?
A: The 2009-10 Consolidated Application Update is presently going through the Department’s approval process.  As soon as this process is completed, it will be released for posting.  Since there will be no significant changes, staff can be guided by their 2008-09 application.  The Application and guidance will be posted at:

Q: Can we obtain an audio recording of the workshop?
A: An audio recording will not be available, however, the Questions and Answers document is intended to provide the same end.

Q: When will allocations be available?
A: Preliminary allocations are currently posted on the Consolidated Application website at.

Q: What are the requirements (re: allocations/transportation costs/etc.) for schools required to offer School Choice?
A: Schools required to offer School Choice must set-aside an amount equivalent to 20% of their Title I allocation if they are not required to offer Supplemental Educational Services (SES).  Funds for transportation costs related to school choice can come from other federal, state or local sources.  If an LEA can demonstrate that a lesser amount is needed they may allocate that lesser amount. Justification should be included in the School Choice Plan in the application and in the Title I FS-10 Budget Narrative.  If funds are going to come from a Non-Title I Source make sure you indicate it in the online Supplement Form.

Q: As someone new to the Consolidated Application, will there be additional training or support in Albany this summer?
A: Additional support can be found by viewing the following webinars which are presently available on our website at

Please check our website periodically for the following Webinar updates that will be coming soon:

  • NCLB 2009-10 Consolidated Application Update: Application and Budget Reminders
  • School Choice/Supplemental Educational Services
  • Neglected and Delinquent
  • Safe and Drug Free Schools
  • Parent Involvement

The Title I staff is also available to assist.  Please call (518) 473-0295 with any additional questions you may have.

Q: Our district is looking for specific guidelines on allowable professional salaries and professional development; also specific guidelines on supplement/supplant.
A: Guidance can be found by clicking on the Allowable/Unallowable Expenses link on the Title I Technical Assistance page for the Consolidated Application.  The Supplement, Not Supplant restriction is the basis for most of what is or is not allowable in professional salaries.  General principles to keep in mind that describe which positions are not allowable and explain supplement versus supplanting in the process are:

  1. Positions required by statute or regulation are not allowable.  They are not supplemental (above and beyond what’s required and/or what’s supported by other funds for non-eligible students or would be supported by other funds in the absence of Title I funds) so using Title I funds for them, e.g., to teach required core courses, would be supplanting a required LEA expenditure.  One exception to this is AIS positions.
  2. As an example, guidance counselors are required by Commissioner’s Regulations at the secondary level but not at the elementary level so a counselor at the elementary level could be supplementary while one of the required positions at the secondary level would not be; funding the latter would be supplanting and would not be allowable.
  3. District wide positions are not allowable because they perform district functions in addition to serving eligible students and may even serve non-eligible students within the LEA.  For example, a deputy superintendent could not be funded by Title I.
  4. Any position is not allowable to the extent that it doesn’t perform supplementary Title I functions for eligible Title I students.
  5. Title I coordinators can, as a last resort, be paid with Title I funds for the proportion of their salary appropriately devoted to Title I functions.
  6. Required administrators, such as principals, may NOT be paid with Title I funds for ANY activities that take place within their regular work day.
In terms of professional development, any professional development that is designed to address identified student needs (not, for example for stress management or education law for teachers) provided to teachers serving eligible Title I students in some capacity (particularly important in Targeted Assistance schools) in core subject areas is allowable.  Teachers can be paid salaries to provide professional development to others or stipends to participate in professional development IF the PD is held at a time outside their regular work hours.  Refreshments for PD may not be funded unless they’re being provided in lieu of salary outside the regular work day. Substitutes may be hired to release faculty for appropriate PD.
Last Updated: March 20, 2014