| To: | Coordinators, Even Start Family Literacy Partnerships | Date: January 29, 2003 |
| From: | Susan C. Henry State Even Start Coordinator |
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| Subject: | Participation by Private School Children in Even Start |
The No Child Left Behind Act included a new requirement that made Even Start subject to the cross-cutting provisions in Title IX of the ESEA. One of these provisions is the equitable participation for private school children. The impact of the equitable participation provision on continuation programs is the same as on new programs. Even Start was not previously defined as a "covered program," but now is [see Title I, Section 9101(13)]. The two provisions that appear to have the most applicability are the maintenance of effort provision (section 9521) and the equitable participation provisions (section 9501). I do not expect the applicability of the maintenance of effort provision to affect most Even Start programs differently than it already does. It has been applicable to local districts receiving Title I funds for years, and most local education agencies in Even Start projects receive Title I funds. The following is a series of questions and answers designed to help answer some of the questions regarding equitable participation. These provisions are effective July 1, 2002.
What do the “equitable participation” provisions require?
This provision requires that programs, after timely and meaningful consultation with private school officials, provide special educational services or other benefits to children and their teachers on an equitable basis. These educational services must be equitable in relation to the services and other benefits for public school children participating in the program.
What is “meaningful consultation”?
Meaningful consultation must occur before the partnership makes any decision that affects the opportunities of eligible private school children, teachers, or other personnel to participate in Even Start programs, and should continue throughout the implementation and assessment of the project. This consultation should provide a forum for parents, private school personnel and administrators to have input in to the design and implementation of Even Start programs and services. The following specific issues must be addressed:
- how the children/family’s needs will be identified
- what services will be offered
- how, where and by whom the services will be provided
- how the services will be assessed and how the results of the assessment will be used to improve services
- the size and scope of the services to be provided to private school children, teachers and other educational personnel
- the amount of funds available for such services
- how and when the partnership will make decisions about the delivery of services
How do the new NCLB requirements that are applicable to the Even Start Family Literacy Program, apply to current Even Start programs (continuation grants)?
A partnership may receive an Even Start continuation award on or after July 1, 2002 only if it complies with the requirements in the new NCLB legislation. Therefore, before funds for FY03 can be released the Partnership must demonstrate that it has provided an opportunity for meaningful consultation with the private school.
Example: A partnership is currently in the second year of the four-year cycle. It has previously received two years of Even Start funding under the previous legislation. The partnership may receive its third year of funding -- under the new Even Start Family Literacy Program -- only if it complies with the new NCLB legislative requirements. The continuation program decides to call a meeting with the private school providers, and parents whose children attend private school, to determine if Even Start services can be offered or need to be adjusted to meet the needs of eligible families.
How do the new NCLB requirements that are applicable to the Even Start Family Literacy Program apply to new Even Start programs?
Since the program year begins September 1 for all new eligible entities, the partnership must comply with the new NCLB requirements before new money is released to the partnership. Although the Request for Proposals was released
Example: A partnership is at the end of its four-year cycle and is reapplying for a second four-year cycle as a new eligible entity. Since there are only two providers in the area to be served, the partnership decides to meet individually with the private school providers and parents and draft memoranda of agreement with each one.
What kind of documentation must be submitted?
The partnership is required to provide written affirmation, signed by officials of each private school, that the consultation required has occurred.
How should this be submitted to the Department?
A copy of the written affirmation documenting that meaningful consultation has occurred must be submitted as soon as is practicable, but no later than September 1, 2002 to ensure the release of funds in a timely manner. Even Start Family Literacy Partnerships should also submit documentation that supports any needed changes in the original proposal regarding need, implementation and/or evaluation.