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Title I, Part A (Title I) schools charging tuition for preschool

We know that many of you have questions concerning charging tuition for your preschool students. We hope the following guidance will help in your decision making process.

With respect to your questions about a Title I, Part A (Title I) schools charging tuition for preschool, as you know, the supplement not supplant considerations would be different for targeted assistance schools (TAS) than schoolwide program schools (SWP). Please see below for details.

TAS

A TAS school may use Title I funds only for preschool services that supplement those that would be available for Title I students from non-Federal funds in the absence of the Title I funds (ESEA section 1120A(b)). With respect to the question of charging tuition, one way that the school could use Title I funds for preschool in a supplemental manner would be to pay for preschool for the children selected as Title I students and charge the parents of other students. In this situation, the difference is that the parents of the non-Title I students pay tuition and the parents of the Title I students do not. If a school takes this approach, it must make sure that it follows all Title I requirements, including how it identifies the Title I children (i.e., the children whose parents would not pay tuition).

In terms of identification, preschool-age children residing in the attendance area of a TAS school who are identified as most at risk of failing to meet the State’s academic achievement standards are eligible to participate in a Title I preschool program (ESEA section 1115(b)(1)(B)). To identify eligible preschool children in a targeted assistance school, the school must use multiple, educationally related, objective criteria, such as teacher judgment, interviews with parents, and developmentally appropriate measures of child development. The use of family income as one factor in determining eligibility is allowable, but children should not be identified for a Title I preschool program solely on the basis of family income. In addition, certain children are “automatically eligible” to participate in a Title I preschool program (ESEA section 1115(b)(2)), including children who—
• participated in Head Start or a Title I preschool program at any time in the prior two years;
• received services under Part C of Title I (migrant education) in the prior two years;
• are homeless preschool-age children; and
• are in a local institution for neglected or delinquent children and youth or attending a community-day program for these children.

Finally, it’s possible that the amount of Title I funds available may not permit a TAS school to serve all eligible preschool children by paying their tuition. In that case, consistent with ESEA section 1115, from the universe of eligible children, the school would select those children who have the greatest need for special assistance to participate in the Title I preschool program by having their tuition paid.

SWP
If a SWP school operates a preschool program, in order to meet the SWP supplement not supplant requirement, the LEA must ensure that the school receives all of the non-Federal funds it would otherwise have received if it were not a Title I school, including those funds necessary to provide services required by law (ESEA section 1114(a)(2)(B)). Assuming that a SWP meets this requirement and its comprehensive needs assessment supports the need for preschool, the SWP could use Title I funds to pay for preschool services to children who reside in its attendance zone.

However, if a SWP school does not have enough Title I funds to pay for all preschool-age children residing in the school attendance area and wants to use Title I funds to pay for some children’s preschool tuition, it must establish and apply selection criteria to ensure that those children who are most at risk of failing to meet the State’s academic achievement standards are selected. In this situation, the school must use multiple, educationally related, objective criteria, such as teacher judgment, interviews with parents, and developmentally appropriate measures of child development, to determine those preschool children most in need. The use of family income is one factor that may inform whether a preschool child is most in need, but children should not be identified for services in a Title I preschool program solely on the basis of family income. Related to the specific issue of charging tuition in a SWP preschool, I am attaching a 2008 response to a question about whether a SWP, when it lacked enough Title I funds to provide preschool for all children who lived in its attendance zone, could charge some parents for preschool and not others.

We hope this guidance is helpful, but as always if you have further questions please don’t hesitate to contact us.

Have a great month and best regards,
Dr. Kristine Harms, EdD.
State Title I Director


DIRECTORS NOTE:
Spring 2012