Title I Funding

Using Title I Funds

• Title I, Part A Use of Funds Quick Reference Guide

Title I funds must carry out a variety of activities including, but not limited to:

• Developing and implementing plans to support and improve low-performing schools
• Providing services to homeless students
• Providing services to students in local institutions for neglected or delinquent children
• Ensuring the educational stability of students in foster care
• Developing policies and providing services to engage parents and families
• Providing services to eligible private schools
• Overseeing Title I interventions and services in Title I eligible schools

LEAs must reserve Title I, Part A funds for the following required activities:

• Services for students experiencing homelessness
• Services for children in local institutions for neglected students and delinquent students
• Parent and family engagement (required if the LEA receives $500,000 or more)
• Equitable services for eligible private school students (amounts depend on proportionate share)

Title I funds support eligible students using one of two models:

• A schoolwide model which supports high poverty schools with the flexibility to implement comprehensive school improvement strategies, not limited only to add-on services for certain students. In a schoolwide program, all students and staff may participate in Title I-funded activities. Schools may use Title I to support any reasonable activity designed to improve the school’s educational program so long as it is consistent with the school’s comprehensive needs assessment. Schoolwide programs allow a school to consolidate its federal, state, and local funds to upgrade the entire educational program.
• A targeted assistance model is available to any Title I school that does not operate a schoolwide program. In a targeted assistance school, the school uses Title I funds to provide additional support to specifically identified students struggling to meet state standards. Title I, Part A funds must be spent on supplemental activities to improve the academic achievement of eligible students.

Required program components for both schoolwide and targeted assistance models include:

• School-level needs assessment
• Evidence-based interventions
• Stakeholder consultation
• Annual evaluation

Planning to Use Title I Funds

Dependent upon the school’s needs assessment, high impact funded activities may be used to support:

• High-quality preschool, full-day kindergarten, or transition from early learning services
• Recruitment and retention of effective teachers, particularly in high-need subjects
• Increased learning time (e.g., afterschool, summer school, or extended day programs)
• Providing professional learning to teachers, principals, school leaders, and paraeducators
• Evidence-based interventions to support at-risk learning (e.g., English learners)
• Activities designed to increase access and prepare students for success in high-quality advanced coursework to earn postsecondary credit while in high school (e.g., Advanced Placement, early college high schools, and dual or concurrent enrollment programs)
• Career and technical education programs to prepare students for postsecondary education and the workforce
• Counseling, school-based mental health programs, mentoring services, and other strategies to improve students’ nonacademic skills that impact academic learning
• School climate interventions (e.g., anti-bullying strategies, positive behavior interventions)
• Equipment, materials, and training needed to compile and analyze student achievement data
• Evidence-based strategies intended to allow for early identification of students with learning or behavioral needs and to provide a tiered response based on those needs (including multi-tiered systems of support)
• High impact strategies shown to be effective at increasing family and community engagement
• Devices and software for students to access digital learning materials and collaborate with peers, and related training for educators (including accessible devices and software needed by students with disabilities)
• Programs to support improved economic, educational, health, safety, and other outcomes that address the issues of intergenerational poverty.
• District-level administration of the Title I program which is necessary and reasonable

Supplement, Not Supplant
A district shall use federal funds received under Title I only to supplement the funds that would, in the absence of such Federal funds, be made available from State and local sources for the education of students participating in Title I, and not to supplant such funds.

According to guidance under ESEA 1127(a), districts are entitled to access Title I funds for a full 15-month period (until September 30th) before a limitation on carryover funds applies. For districts with an allocation greater than $50,000, only 15% of funds can be utilized beyond the 15-month period. The North Dakota Department of Public Instruction (NDDPI) may waive the limitation once every three years under ESEA 1127(b).

The NDDPI recommends that districts obligate and expend the entire Title I allocation within each fiscal year. Districts must submit approvable claims for the 15-month period (expenses through September 30) to meet the Title I 15% limit within ten business days or by October 20, annually. If a district is not eligible for a waiver of the carryover limitation, the excess funds become available to the NDDPI to reallocate using criteria established for this process.

The percentage limitation is applied to the amount of Title I, Part A funds allocated to the district, plus any funds transferred into Title I, Part A from other ESEA programs (also known as Transfer Title I). Title I funds required to be set-aside for a specific activity (e.g., parent and family engagement, equitable services) that were not spent should be used for that specific purpose in the subsequent fiscal year.

Districts that have more than 15 % of funds remaining and are eligible to apply for a Title I waiver, will be notified by WebGrants correspondence. The district must complete the Waiver which will be in the WebGrants Status Report component, with the excess funds auto-populated.

Understanding the USED Method and Title I Funding Formula

The Title I program provides supplemental funding to help low-income schools improve the academic achievement of educationally disadvantaged students. Title I grants, formula-based funds, are allocated to districts by the US Department of Education (USED). USED uses a comprehensive approach, considering several factors when calculating Title I allocations. These factors include the U.S. Census Bureau estimates of income and poverty for all states and counties, provided in four different formulas. These estimates are derived from statistical models using census data, household survey data, population, and other poverty data records (taxes, SNAP benefits, etc.). USED’s approach aims to provide accurate estimates (not direct counts) of income and poverty for the administration of federal programs and the allocation of federal funds. The Small Area Income and Poverty Estimates (SAIPE) Program (census.gov) can be accessed for additional information.

When determining Title I allocations, the USED method directs funding to the neediest student communities. This method has always been the formula used in ND for large districts (over 20,000 population). For districts with a population of less than 20,000, the NDDPI currently uses a USED-approved alternative poverty method to allocate funds, but this method will be discontinued after the 2023-2024 school year. This method used a weighted formula (aggregate units) that includes census (15.5%), foster care (15.5%), free lunch (46%), and reduced lunch (23%) data to determine Title I eligibility and allocations for districts with a population under 20,000. Districts with 10 or more aggregate units were eligible for a Title I grant. Beginning in 2025, the USED method will be used for all eligible Title I schools with more than 10 eligible students. 

The School District Review Program (SDRP), a key tool utilized by USED in this method, plays a pivotal role in calculating Title I allocations. It does so by utilizing census data, with a specific focus on poverty from ages 5-17, not enrollment. Therefore, the SDRP's primary concern is financial responsibility, a critical aspect that guides the calculation of the poverty estimates used to determine the distribution of Title I funding. The SDRP deems a school district financially responsible when it covers the education costs of the students residing within their boundaries, ensuring a fair and equitable distribution of funds.

School Districts that only serve the elementary grade levels (i.e., Pk-8, K-5) are considered K-12 elementary school districts for the SDRP (used by USED to calculate Title I allocations). Therefore, these school districts are financially responsible for the education of K-12 students residing in their district. When a school district sends its students to schools outside its boundaries, it is represented as a K-12 Elementary School District. The Title I methodology differs from the state foundation aid because the State foundation aid formula follows where the student is being educated. Conversely, when a student attends another school outside of its boundaries, Title I funds remain where the US Census originally counted that student. 

Financial responsibility can look like the following:

Having meaningful consultations regarding student needs and supporting all student needs (regardless of where those students reside) with additional dollars through local service agreements 

Developing local processes or procedures to better serve students with Title I funds through the sharing of personnel and/or evidence-based materials across school districts 

School districts should locally determine how to best meet Title I program goals and student outcomes. In addition, the NDDPI has developed the Funding Your Plan guidance as a key resource for districts to better support sustainable efforts that are evidence-based and focused on student outcomes. This guidance should be used in tandem with other guidance documents from NDDPI on the Title I program and federal funds.

Title I Grants

There are 4 levels of Title I grants: Basic, Concentration, Targeted, and Education Finance Incentive Grants (EFIG). Each level has eligibility criteria that the school, Local Educational Agency (LEA), and/or state must meet to qualify for the grant. The Title I funds are allocated through statutory formulas that are based primarily on census poverty estimates and the cost of education in the state.

Basic Grant:

• An LEA must have at least 10 poverty children and;
• Poverty children must exceed 2 percent of the LEA's school-age population (age 5-17).

Concentration Grant:

• An LEA must have at least 10 poverty children and;
• Poverty children must be greater than 15 percent of the LEA's school-age population (ages 5-17).

Targeted Grant:

• An LEA must have at least 10 poverty children and;
• Poverty children must be at least 5 percent of the LEA's school-age population (ages 5-17).

Education Finance Incentive Grants (EFIG):

• A state must rank well in comparison to other states in its effort to provide financial support for education compared to its relative wealth as measured by its per capita income;
• A state must rank well in comparison to other states in the degree to which education expenditures among LEAs within the state are equalized;
• An LEA must have at least 10 poverty children;
• Poverty children must be at least 5 percent of the LEAs school-age population (ages 5-17) and;
• An LEA must target the Title I funds schools with the highest percentages of children from low-income families and;
• Schools must focus Title I services on children who are failing, or most at risk of failing, to meet state academic standards (unless a school is operating a schoolwide program*); and
• An LEA also must use Title I funds to provide academic enrichment services to eligible children enrolled in private schools.

*Schools in which poverty children make up at least 40% of enrollment are eligible to use Title I funds for schoolwide programs that serve all children in the school.

23-24 Title I Aggregate Units Comparison 

Annual Release of Census Data

Each year, the North Dakota Department of Public Instruction (NDDPI) determines the eligibility status for Title I funding for the subsequent school year and sends information to each district. 

The USED uses the 2022 Census data to calculate Title I allocations for the 2024-2025 school year. The data includes the count of children ages 5-17 reported below poverty on the federal census. Districts should review the North Dakota Census data and verify the accuracy of the boundary survey data on which the data are based. Districts may contact the Small Area Income and Poverty Estimates (SAIPE) Branch at the Census Bureau for further information about how to challenge census data. The challenge period for the US census data ended on March 13, 2024. See the USED memo for more details.

As the NDDPI will shift to using the USED method to calculate Title I allocations, it is important to review this information carefully.

Comparability

Title I law requires school districts with more than one school attendance area for each grade span to meet Title I comparability requirements. The schedule for reviewing comparability requirements at the state department has been moved from spring to winter so that if we encounter problems with comparability reports, there is still time to make changes before the school year ends.
 
Title I comparability requirements state that a school district may receive Title I funds only if state and local funds will be used in schools receiving Title I funds to provide services that, taken as a whole, are at least comparable to services in schools that are not receiving Title I funds. If the district is serving all schools under Title I, they may receive Title I funds only if they will use state and local funds to provide services that, taken as a whole, are substantially comparable in each school.
 
The comparability regulations include documenting compliance in the following three areas:

1. A local educational agency-wide salary schedule;
2. Ensuring equivalence among schools in teachers, administrators, and other staff; and 
3. Ensuring equivalence among schools in the provision of curriculum materials and instructional supplies.

Comparability reports are to be submitted and reviewed at the end of each school year. Meeting comparability is a prerequisite to receiving approval on your subsequent year’s consolidated application, which is processed during the summer. Demonstrating comparability is an annual requirement.
 
Previously, school districts were informed that they could develop and submit a policy to ensure that the comparability requirements were met on an annual basis. However, when the USDE released final fiscal guidance which addresses the comparability requirements and outlines new USDE expectations, the guidance states that all districts must actually perform the calculations necessary each and every year to demonstrate that all of its Title I schools are, in fact, comparable. Therefore, districts will need to submit actual documentation (not a policy) for each of the three comparability components listed above.

• Comparability and Supplement not Supplant Guidance and Reports

Supplement, not Supplant

A district may use Title I, Part A funds only to supplement the funds that would, in the absence of Title I, Part A funds, be made available from non-federal sources for the education of children participating in Title I, Part A programs. In no case may Title I, Part A funds be used to supplant, or take the place of, funds from non-federal sources. ESSA 1118(b)(2) changed the way districts demonstrate compliance with the supplement, not supplant requirement. The district must demonstrate the methodology in which state and local funds are distributed to schools. Funds must be distributed in a Title I-neutral manner; the district cannot determine the amount of state and local funds allocated to a school based on the school’s Title I allocation. The supplement, not supplant methodology must be updated annually and kept on file at the district office. 

A method of evaluation must:

• Reflect staffing allocation with real calculations and numbers to support it;
• Account for distribution of state and local funds including staff, resources, and services in a Title I-neutral manner;
• Be supported with documentation;
• Include a narrative to clarify allocation steps.

Exemptions apply for districts with only one school, a single grade span per school, or those that serve all schools with Title I allocations. In these cases, a supplement, not supplant methodology is not required.

• Title I Supplement, not Supplant Non-Regulatory Informational Document (June 19, 2019)

A district may receive Title I, Part A funds for any fiscal year only if either its combined fiscal effort per student or the aggregate expenditures of the district and the state with respect to the provision of free public education by the district for the preceding fiscal year is not less than 90% of the combined fiscal effort or aggregate expenditures for the second preceding fiscal year.

A district may transfer up to 100% of funds from other federal programs (Title II, Part A and Title IV, Part A) into Title I, Part A. A district may not transfer Title I, Part A funds into other federal programs.

A school operating a schoolwide program may use Title I funds for any activity that supports the needs of students in the school as identified through the comprehensive needs assessment and articulated in the schoolwide plan [ESSA section 1114(b)]. In designing and implementing the schoolwide plan, a school must implement strategies that: (1) provide opportunities for all children to meet challenging state academic standards; (2) use methods and instructional strategies that strengthen the academic program in the school, increase the amount and quality of learning time, and help provide an enriched and accelerated curriculum, which may include programs, activities, and courses necessary to provide a well-rounded education; and (3) address the needs of all students, but particularly those at risk of not meeting challenging state academic standards [ESSA section 1114(b)(7)(A)].

Potential Uses of Funds in a Schoolwide Program (based on a comprehensive needs assessment):

• High-quality preschool or full-day kindergarten and services to facilitate the transition from early learning to elementary education programs.
• Recruitment and retention of effective teachers, particularly in high-need subjects.
• Instructional coaches to provide high-quality, school-based professional development.
• Increased learning time (e.g., afterschool, summer school, or extended day programs).
• Providing professional learning to teachers, principals, school leaders, and paraeducators.
• Evidence-based interventions to support at-risk learning (e.g., English learners).
• Activities designed to increase access and prepare students for success in high-quality advanced coursework to earn postsecondary credit while in high school (e.g., Advanced Placement, early college high schools, and dual or concurrent enrollment programs).
• Career and technical education programs to prepare students for postsecondary education and the workforce.
• Counseling, school-based mental health programs, mentoring services, and other strategies to improve students’ nonacademic skills that impact academic learning.
• School climate interventions (e.g., anti-bullying strategies, positive behavior interventions, and supports).
• Equipment, materials, and training needed to compile and analyze student achievement data to monitor progress, alert the school to struggling students, and drive decision making.
• Evidence-based strategies intended to allow for early identification of students with learning or behavioral needs and to provide a tiered response based on those needs (including multi-tiered systems of support).
• High-impact strategies shown to be effective at increasing family and community engagement in the school, including family literacy programs.
• Devices and software for students to access digital learning materials and collaborate with peers, and related training for educators (including accessible devices and software needed by students with disabilities).
• Programs to support improved economic, educational, health, safety, and other outcomes that address the issues of intergenerational poverty.
• District-level administration of the Title I program, which is necessary and reasonable.

Each school, in conjunction with district officials, has the discretion to determine the specifics of a schoolwide plan, including which methods and instructional strategies will be used, based on the school’s identified needs in its comprehensive needs assessment.

Comingling 

A schoolwide program school has the option to “comingle” its funds, which provides for even greater funding flexibility. Comingling means that a district could choose to combine their Title I, Part A, Title II, Part A, and Title IV, Part A funds into one, Title I budget. Some advantages of comingling are described below:

• A district has the flexibility to allocate all available resources effectively and efficiently.
• A district is not required to meet most of the statutory and regulatory requirements of the specific federal programs included in the comingling, provided it meets the intent and purposes of those programs.
• A district is not required to maintain separate fiscal accounting records by federal program that identify the specific activities supported by each program’s funds.

The district must allocate funds to school attendance areas identified as eligible and selected to participate in rank order based on the percentage of low-income students. The school allocation is determined by a per-pupil amount times the total number of children from low-income families in each school. Funds are allocated for use by the school, but it remains the responsibility of the district to ensure compliance of school expenditures. For more information regarding this process, visit: Within-District Allocations Under Title I, Part A of the Elementary and Secondary Education Act of 1965, as Amended

Small districts with less than 1,000 students or only one school per grade span may use other methods to determine school allocations.

Title I, Part A, Reallocation of Funds

Section 1126 (c) of the Every Student Succeeds Act requires the State Educational Agency (SEA) to develop procedures for the reallocation of Title I, Part A funds. Funds must be reallocated to districts in a timely fashion and must be allocated in accordance with State guidelines for reallocation. The NDDPI Office of Educational Improvement and Support will reallocate Title I, Part A funds in accordance with the reallocation guidelines outlined below.

Eligibility of Funds

Title I, Part A funds eligible for reallocation are:

• Funds allocated to an eligible district that has chosen not to participate in the Title I, Part A program (method to proportionately redistribute to all districts in the current year);
• Funds returned by a district because of its failure to meet federal maintenance of effort requirements (method to proportionately redistribute to all districts in the current year);
• Funds returned by a district as a result of excess carryover (more than 15% in districts receiving more than $50,000 in Title I, Part A funds); and,
• Funds not obligated by a district and returned to the NDDPI.

(NOTE: Funds returned by the district will be available for reallocation only if they are returned during the obligation period of the grant. Funds returned after the obligation period will no longer be available for reallocation.)

Reallocation of Excess Funds

Excess funds are made available for reallocation to districts. For each program, eligible districts are those that did not have funds in excess of carryover limitations. NDDPI will reallocate excess funds to eligible districts based on the state criteria and accountability data reports for prioritization for awards and recognition.

Prioritization for Awards and Recognition

When distributing reallocated Title I, Part A funds to districts, priority will be given based on the following:

Priority 1: Distinguished Schools (same as in past years)

• This program showcases the success of two eligible schools in one of three categories:
  • Category 1: Exceptional student performance (and academic growth) for two or more consecutive years
  • Category 2: Closing the achievement gap between student groups for two or more consecutive years
  • Category 3: Excellence in serving special populations of students
• Depending on funds remaining, awards are available to allow a team of school staff to attend the National ESEA Conference to be acknowledged during the recognition events and receive quality professional learning. Remaining awarded funds not used on travel, registration, etc. for the conference may be used on any Title I allowable activity. 

Priority 2: High-Performing Title I Schools

• This recognition award supports high-performing Title I schools based on the North Dakota accountability system. 
  • Eligible Title I schools may receive this award for those ranking in the top 5%-10%
  • Equitably distribute returned funds on criteria determined by SEA
  • Award Title I schools that have raised the bar and recognize their outstanding school performance

Funds available for reallocation will be awarded in rank order to eligible schools based on these criteria.

Application, Grant Award, and Communication

The Office of Educational Improvement and Support and grants manager will work collaboratively to open the program grant award/budget period for reallocated Title I, Part A funds in November/December each year. The awarded districts will receive and must respond to accept the nomination, recognition, and award for additional funds. Once accepted, a grant award for the additional funds will be issued to the district. A memo to eligible districts will be sent with information on the recognition, criteria, and award process. Awarded districts will receive correspondence via WebGrants with information on the grant award and funding process. Awarded districts are required to follow all Title I regulations regarding the allowability of the use of funds and submit claims for the funds during the program project period of the grant. Recognition is provided in the NDDPI newsletter, social media, and website. Districts must be able to describe/justify how the receipt of these funds will help students in meeting the achievement targets. The Office of Educational Improvement and Support and grants manager will review requests for funds and determine eligibility. 

Estimated award amounts are based on the following:

• School Enrollment: 0-300 students up to $60,000
• School Enrollment: 301-800 students up to $70,000
• School Enrollment: 801+ students up to $75,000

Distribution of funds is dependent upon the amount of reallocated funds available for redistribution and funds returned; therefore, never guaranteed each year.