Title II, Part A Equitable Services

The teachers and principals of non-profit, private schools approved by Washington State Board of Education may be eligible for services provided through Title II, Part A of the Elementary and Secondary Education Act (ESEA) federal education program. On this page, Local Educational Agencies (LEAs) can find guidance on how to offer services to eligible private schools, and help private schools understand how to use these funds.

Additional information regarding how private schools can participate in federal programs can be found at Private School Participation in Federal Programs. 

Determining Allowability

The Title II, Part A Private School Allowable Uses document provides sponsoring LEAs and private schools information on their responsibilities and how Title II, Part A funds can be used.

LEAs are required to spend an equitable share of their awarded funds on behalf of qualifying private schools. The LEA is responsible for meaningfully consulting with the private schools to determine whether an activity is allowed.

• Funds may not be used to pay or subsidize any portion of a private school teacher’s salary or benefits.
• Private schools cannot be reimbursed for professional development.
• Services must be provided by the LEA or through a contract between the LEA and a third-party provider.
• The LEA must administer and retain control over the funds.
• Federal funds may not be awarded or paid to private schools directly.
• Private schools are held to the same standards for professional learning as LEAs.

Professional Learning

Professional learning funded by Title II, Part A, including professional learning provided to private schools, must be:

• Ongoing (not just one-day or short-term workshops) thorough, team-based, integrated into daily work, data-driven, and focused on the classroom.
• High quality, evidence-based, and aimed at improving teaching and student learning and achievement.

Evidence-based means that it has been proven to have a positive impact on students through a well-designed study or is supported by high-quality research findings.

Conferences 

Many conferences are short-term or stand-alone and do not meet the professional learning requirements. LEAs and SEAs address this issue by having a comprehensive professional development plan integrating conferences with ongoing, job-embedded activities. 

• Private schools should show the LEA that attendance at a short-term conference is part of an ongoing professional development plan for specified teachers that meets Title II, Part A requirements.
• Title II, Part A does not need to fund the entire professional development plan, instead the funds can supplement an existing professional development plan. 

Supplement not Supplant

Funding for eligible private schools and LEAs is limited to supplementing or expanding existing professional development activities. 

• Title II, Part A Supplement Not Supplant
• Consider asking yourself, If I didn't have federal funds available to conduct this activity/service, would I still conduct it with state or local funds anyway? If the answer is yes, you are most likely supplanting because it is no longer a supplementary activity. You must be able to demonstrate that you could not conduct the activity if it weren't for the federal funds.

Secular, Neutral, and Non-Ideological

• Title II, Part A funded professional learning, educational services, or other resources (including materials and equipment) must be secular, neutral, and nonideological. In some situations, conferences and other professional learning may include both religious and secular content.
• When professional learning is a mix of religious and secular, funds may only be spent on the portion of the professional learning that is secular, neutral, and nonideological.
  • To determine what funds may be used, the private school needs to provide the LEA enough information to determine the sessions of the conference that provide secular, neutral, and nonideological professional development.
  • This should include a description of each session the private school teacher will attend, along with documentation proving the teacher's participation in those sessions.
• Title II, Part A funds may not be used for professional development subscriptions with any religious content.

Equitable Services Carryover

• A private school is eligible for equitable services carryover for one additional year unless they inform the LEA that they have no unmet needs. 
• LEAs should send a certified letter with a 10-day response deadline after multiple documented attempts to contact a private school. If a complaint is filed, LEAs will need to provide this documentation.
• The district’s business manager needs to sub-code the funds to become part of the general pool of funds eligible to the district and participating private schools. This process should also be used when a private school responds to the district that they intend to utilize funds but fails to provide specific details on how the funds will be spent.