001Good morning. We will give everybody just a couple more minutes to finish uh being able to get in. Uh um There was uh slightly different update, I think, and was not exactly what we were expecting to see in terms of uh being able to start, but uh we'll be getting started shortly. Good morning. Uh thank you for joining us today. We are here for the uh session on blueprint for compliance for navigating the Title I Part A monitoring and self-check essentials. Uh we hope to share with you um information especially about uh uh documentation requirements uh concerning uh the items that we have been uh validating uh during our program monitoring validation process this year uh so that it will um I hope help you uh in terms of being better prepared for next time
002um and for uh ensuring that you're in compliance with uh program requirements as you are implementing your Title 1 Part A program. Um my name is Vivian Smirl, and I am program director for Title 1 Part A in the Federal Program Compliance Division at the Texas Education Agency. Um and so let me go ahead and uh get started with a couple of things here. Um we have a presentation check-in survey. Um if you would be so kind as to uh complete that survey, you can either uh use the QR code that is on your screen or uh I have or I am about to put the link to the survey in the chat so that you can access that. Um I thought that the presentation slides were already posted. If they are not, here let
003me take a uh second and go ahead and uh put a copy of the slides in the chat so that you can access those. You know, just a second. Let me navigate to them. Okay, and I believe that I have put the uh slides in the chat so that you can um access a copy of those. Um so if as you are completing the check-in, uh if you could select from the drop-down the event name um is for the April 30th date for Blueprint for Compliance Navigating Title 1 Part A Monitoring and Self-Check Essentials. Um that will help us uh keep track of the number of LEAs that we are able to reach through our statewide trainings, um and help us with our compliance metrics. All right. So, while you're taking care of that, um
004I also want to go through a couple of our standard legal disclaimers. Um this particular presentation is intended for information and guidance purposes only. The content reflects our current understanding of statute and the applicable federal guidance, and it is subject to change depending on uh future guidance of or uh the uh the future guidance from the US Department of Education. Um So, it is subject to change. The presentation doesn't constitute legal advice. Um and you are advised to consult with your own legal counsel before taking action based on this information and guidance. Um the presentation is copyrighted by TEA, um and the um rules related to the use, copying, reproduction, and sharing of that information, um you can uh access uh through uh the information available from [email protected]. Additionally, um TEA prohibits recordings of any
005of our grants-related trainings. Uh we also prohibit uh the use of AI technologies in uh training uh using our presentations to train AI technologies. So, if you are using any kind of a um AI bot or whatever for note-taking, um you will have that uh kicked out of the presentation. Uh just it it because we can't we can't we can't use those uh technologies. All right. So, today what I'd like to go through um is some of the self-check essentials. Um but I my primary focus today is going to be on documentation, sort of a documentation 101 kind of session. Um as we have gone through our program monitoring validation process this year, we have tried to collect uh the um examples of uh documentation that works well for um the various requirements and documentation
006that maybe was not working quite so well. So, we're trying to to give you examples of of documentation that that doesn't really work and documentation that is better um to help you understand what it is we're looking for um as we are doing our reviews. So, we'll be covering documentation for meetings um in general. Uh we'll be covering documentation related to the LEA program plan descriptions, uh to the Title I Part A student selection criteria, uh to LEA and campus PFE policies, campus allocations, and for the SNS methodology. Um I'll also try to leave time for questions and answers. So, if you have a question as we go along, if you'll go ahead and put that in the Q&A section, um uh that would be great. Um I see people who have come in late
007may not have gotten the slides, so hang on just a second. I will try to add those one more time cuz I know that you don't get to go backwards when Okay, I think I put that in one more time. Um, I'm also going to drop the survey attendance, oops, in one more time. I'm going to try. So that uh you can provide us that information as well. Hey. So I think I have put the slides in again. We'll try one more time. It claims that I've done it. So I hope so. Okay, so we'll we'll move on. Um All right. So the self-check guide that is posted currently on the website is version 8.2. Um, we did try to uh Well, we did we did have one last update based on uh guidance that
008we got from the US Department of Education. There was a section that we had neglected to copy and paste, and so the program uh self-check guide now has the complete section in it. Uh it didn't really change a whole lot. It just uh has the the the complete uh text of statute reflected. Um those of you who are having difficulty downloading the slides, you might have to to go up uh to uh the little folder on the upper right corner where after you download it, I know it disappears, but if you look in the upper right corner, there's a little folder that if you click on, it will show you uh the the file in your download folder. The section of 8.2 that is new um is the uh basis for admission or exclusion line,
009which basically says that a student shall not be admitted to or excluded from any federally assisted education program on the basis of surname or language minority status. I mean, I that's sort of a no-brainer. I mean, I'm sure that that everybody is is uh not excluding people on the basis of their surname or their language minority status, but but the the the statutory requirement uh does need to be in our self-check guide um because it is part of it is part of the requirement. Okay, let's try that one other way. I was trying to give you a link to a document. Uh so, let me see here. Let me go to the program monitoring valid No, it's on uh sorry. It's not that part. It is compliance reports. And what I want to get is
010this link right here. I'll copy the address. And we will put it here. Maybe that'll be better. Okay, that goes directly to the website. So, that maybe that'll be easier for you to get rather than the actual files that I was trying to put in. Okay, hopefully that worked. Um So, that's that's the language that was added to the self-tech guide for um version 8.2. Um and what I'd like to spend the bulk of our time on today is uh the documentation because I feel like that that that is uh that that is the uh uh area that will will help districts um more in terms of understanding what it is we're what what kind of documentation we receive um or what we're looking for um and what we get. So, let's talk first about
011the meeting documentation that we ask for. So, when when we talk about meeting documentation, um basically we're looking at three things. We're looking at a meeting agenda, meeting notes and minutes, and sign-in sheets. And you know, when we when we tell uh districts that we're we're we're wanting documentation for a particular meeting, you know, these are the three elements that we're we're we're expecting to get. But we haven't in the past given you a whole lot more detail than that. And so, what I'd like to do is to talk about each one of these things um to be sure that people understand what it is we're we're we're actually looking at. So, when when we when we ask for an agenda, okay, there are a lot of different ways you could do an agenda. I
012mean, you know, like agenda could be kind of a generic like a what do I want to talk about at my meeting that I'm about to to have just like for my personal notes of so that I don't forget to say something or it could be you know something that I'm sharing with staff so that they know what to expect from the particular meeting. It also could be for documentation for my auditor so that they see what got discussed. And if those those are those are very different audiences. There's very different purposes for having the agenda. And and in order to meet each of those needs you might need to be more intentional about what you're having your agenda look like. So for example, what you have on your screen here is is sort of
013a representation of some of the documentation that we received recently about agendas. So here's an agenda that says that the comprehensive needs assessment is on it. The campus improvement plan's on it. We've got training related to a new math curriculum and the calendar. What you don't see here is a date. You don't see the name of an LEA. You don't see a campus that might be involved. You don't have a whole lot of description about what's going to be discussed in terms of the comprehensive needs assessment. Is this supposed to be a meeting where the comprehensive needs assessment is being conducted? Is this supposed to be a comprehensive needs assessment where results are presented? This particular version of an agenda doesn't help me a lot in terms of knowing what this meeting actually is about.
014Okay, similarly for the comprehensive for the campus improvement plan. I don't know what campus. I don't know what school year this is associated with. I don't know whether this is reviewing it for uh is this a like we're approving a plan? Are we reviewing a plan for it to be revised for the coming year? There's really just not a whole lot of information here for me to be able to um associate this agenda with a particular activity in terms of uh whether this is is going to be compliant. So, let's turn to what might make it more descriptive of and and make it actually more useful for uh documentation for a meeting. So, now this particular example, we are talking about a site-based decision-making committee for example Elementary. And it's being conducted on May 21st
015of 2026 from 4:30 to 5:00 in the afternoon. Um the comprehensive needs assessment has a list of things that are going to be included in that discussion. Um it's clear that we're looking at data from 2022-23 through 24-25. Uh there's more description, in other words, about what this agenda is actually uh for. Um for the campus improvement plan section, we are looking at we're reviewing the 24-25 CIP for camp for example Elementary, and we're making revisions for the 26-27 school year. Which sort of matches up with the date that we're talking about. If this meeting is being held in May, in late May of 2026, it makes sense that we're reviewing the 25-26, the current year CIP, but then we're reviewing it to make revisions for the upcoming, the 26-27 school year. So, that that's
016not like a whole lot more information, but it's enough more information that I can place the example of the agenda. I can I can place the agenda better than just the one that we looked at previously where it just had, you know, like a short list of something that I might have, you know, tossed off a bit like, I want to be sure to discuss the comprehensive needs assessment, the campus improvement plan, you know, okay, I know what I'm going to talk about. But if that was like just for me, for documentation for an auditor, that doesn't quite do enough. So, you you can see that the additional detail is something that that I should be able to add at the time, okay? So, it's contemporaneous with the meeting. Um it's something that I can
017as easily put in a file to pull out later to show what was discussed at the meeting um or what was going to be discussed at the meeting. Um so you can see that it's it's got more uh more detail so that it can be a better representation of what happened or what's going to happen at this particular meeting. Now, the agenda's just one piece, okay? So, once you have the agenda, which that's what's going to happen, then you want the meeting notes or minutes to show what actually was discussed as an additional piece of documentation for this particular meeting. So, uh let me back up just for a second. So, the meeting agenda, you wanted it to be able to be tell from the agenda what was going to be discussed. You wanted to
018be sure that the school year that's being reflected is clearly noted. Um, you want to be sure that there's a reasonable amount of time for the meeting. Now, I just want to point out here on this particular meeting, we were meeting in this time frame for this particular agenda from 4:30 to 5:00 in the evening. Okay, that's a 30-minute meeting. If this is the only time that the district is meeting for discussing the comprehensive needs and reviewing the CIP for the following year, 30 minutes is not a lot of time. Okay, so you'd be hard-pressed to to to say that if this is the only time this is that that people are gathering to conduct these activities, it would be difficult to to convey that this was sufficient amount of time. Now, if this particular
019meeting is one of a series of meetings where, you know, you might have been meeting, you know, like in in March and April and May and you've got another one in June or whatever. And so that you've got a uh you you you've been you've been meeting, you know, like in subcommittees going along and and that's part of your planning process that you have documented, then this could be a piece of that and 30 minutes might be, you know, what this meeting entailed, okay? But it's part of a larger process. It's not trying to represent that the district did its comprehensive needs assessment and its campus improvement planning revisions in half an hour. Okay? So, you want to be sure that if uh if if if there if it's part of a larger process, you
020have a way of documenting that in your notes, also. So, like you might when we get to the to the meeting notes, we may we'll talk about a way that you could incorporate that description into the meeting notes for that meeting. Um the other thing that we're going to be looking at as we go through these descriptions is that there is an alignment between the agenda and the meeting notes and the sign-in sheet that there's a date connecting them. That's that there's there's title of a meeting connecting them so that you're you're you're seeing them as part of a set. Okay? So like this meeting had an agenda that's dated and and got a name and this meeting notes that are dated similarly with a name and the assign-in sheet that's dated with the name
021so that they are clearly a set of documentation for this particular meeting. Okay, so let's let's move on to the meeting notes. So we have seen meeting notes that are as simple as this where, you know, okay, the first thing we discussed was a comprehensive needs assessment. And as part of that staff reviewed the student performance data and made recommendations. And that may be the only notes that's there. Campus Improvement Plan. Staff suggested additional activities to improve student performance. Maybe that's all that's there. But you'll note on this particular example that there is no date. Okay? There is no title of the meeting. So I have no way of knowing which agenda it went with, which uh which which which meeting it's supposed to represent, what date of the meeting it was for. Um so
022so in terms of trying to be uh documentation for for example um school-wide stakeholders for the school-wide program plan, I'd have difficulty accepting this because I don't know when it was for. I don't know what school year it's attached to. I don't know what campus improvement plan it was supposed to be representing. So, there the the lack of a date and the lack of specificity within the meeting notes is a problem in terms of being able to look at the documentation and tell what it is supposed to be documentation for. Okay, what is it documenting? So, an improved example of the meeting notes would be where you had the name of the meeting. We had this is a site-based decision-making committee for example elementary for May 21st, 2026 from 4:30 to 5:00 p.m. Okay, so
023this would be enough to clearly link this set of meeting notes with the improved example of the agenda, okay? So, that it's clear that it is this date, this meeting for this elementary school. Okay. So, also what you see within the meeting notes is that in the description of what about what was discussed for the comprehensive needs assessment it specifies that it is for the 2026-2027 school year. So, it's it's the it's the needs assessment that's being conducted for the school year that's coming. Um it says that stakeholders reviewed the student performance and school climate data and made the following recommendations concerning the prioritization of needs and it lists their recommendations. Now, if we go back to the prior example this said staff reviewed student performance data." If I was trying to take this particular
024example as documentation for a meeting where the appropriate stakeholders were involved, I'd have a hard time accepting where it just said staff. Because school-wide stakeholders involves more than staff. Okay? It involves different kinds of staff, teachers, principals, paraprofessionals if they're there, um pupil services personnel. I mean, if staff is unspecific in terms of which staff is actually involved, and it's also exclusive of the parents and community members who would also be required stakeholders. So, the fact that it the first example just said staff was already limiting and also non-specific in terms of being an appropriate set of documentation. Um under the campus improvement plan section, uh we have a description here. Subcommittee groups, made up of required stakeholders, submitted reports to the site-based decision-making committee suggesting the following revisions to the campuses uh campus improvement
025plan for the 2026-2027 school year. So, what this statement does is it already suggests that there is a larger process involved, okay? Aside from the meeting that is being documented here, it's already mentioning that there were subcommittee groups, okay? Who presented reports or who's contributed reports that were considered at this meeting. So, it's it's providing um additional information, additional documentation concerning this particular LEA's planning process to show that there that this this 4:30 to 5:00 meeting was not the only process involved in the the LEA's uh review and revision process for its campus improvement plan or for its school-wide program plan. So, being a little bit more intentional about the the the specificity in that's listed on the agenda and the specificity that is included in the meeting notes, okay? You can see how that
026strengthens the documentation for this particular LEA's process and this particular LEA's inclusion of stakeholders in its review and revision process. So, um it's it's it's uh a level of specificity that is relatively easy to achieve at the time if the LEA is doing it on purpose, you know, being intentional about, "Hey, this is what I'm needing to document. This is what I need to say. This is the level of specificity that I need to achieve in in order to have good documentation and to give myself credit for the good work that we're doing at the LEA um so that when I pull out this documentation next year to give to TEA, they will be able to see what our process was and what we were able to document as we went. But, this is the
027kind of thing that needs to happen at the time that you're doing it. This This is what gets lost when uh if if that level of detail has not been accounted for at the time that you're documenting it. Next year, when you're pulling the files, you know, one, nobody remembers, okay? Two, you know, you're not supposed to recreate documentation after the fact. You're not supposed to say, "Oh, well, this this is not specific enough. We need to go back and put it in more detail." You needed to do it at the time of the meeting. So, it's it's more of being aware of understanding the the implications of why you're having the meeting in the first place, okay? Who your audiences are for that meeting, okay? It's not just the person conducting the meeting being
028sure that they say everything. It's not just the people who are coming to the meeting who understand what it is that we're going to be talking about. Those two are very important things, but it's also, when we finish this meeting, and this is going to be the documentation that I pull later, have have we said enough about what we did at this meeting that it's going to reflect compliance with the requirements that we're trying to be in compliance with. Okay. Um So, kind of of of of questions that you can look at your documentation for the for for last year and and see whether it would have passed muster, um cuz we only looked at like 170 school districts this year. And for the meeting documentation, it may only have included uh those LEAs that
029we looked at for um school-wide program plan stakeholders, okay? Or for PFE uh requirements or PFE policy revisions, stake uh the the the people who were involved in that process. You know, we may only have looked at 80 LEAs total um between those two um uh requirements for this last year. So, look at your requirements and ask yourself if you can tell from the meeting notes what was really discussed. Okay? Can you tell what school year it was associated with? Can you tell um who was involved in the discussion? Can you tell what recommendations were made? Is it clear that stakeholders actually had a genuine opportunity to have input into the review and revision of the policy uh the or the or the campus improvement plan. Um so you want to be sure that the
030school year is that's being reviewed is clearly noted so that you can say, "Okay, we're reviewing 24-25 with that I toward revising it for 26-27 or reviewing 25-26 with an I toward revising it for 26-27." You want to be sure that that is actually stated. Um was there a reasonable amount of time? So, is it clear if this is part of a larger process? Did we like say somewhere that this is part of a larger process? Did you if you if you're looking at um uh reports from previous, you know, subcommittees, did you say that in the meeting notes? Because that that can be documentation of the district's uh review and revision process. Um and it can supplement the Okay, if if if it only says this meeting is an hour is is a is
031a half hour long, but it's it's obvious from the meeting notes that this is part of a larger process, then we're We're looking at the meeting notes going, "You did your entire comprehensive needs assessment and revising your policy in half an hour." Because that wouldn't really be a reasonable thing to to expect. Um did the meeting notes show that the stakeholders had a genuine opportunity to provide input? Um if you had input from other um areas, whether it's it's the subcommittee reports or if you did a a survey of other stakeholders like you did a professional development survey from teachers or a needs assessment for the professional development for teachers or if you had a parent involvement surveys, um if that was part of the process, your meeting notes should reflect that, you know, this
032material was collected previously and that it was part of our review and revision process. And again, the the the headings of the meeting notes should have the date and the title of the meeting so that it can be tied to the agenda and tied to the sign-in sheet so that the three elements, the the agenda, the meeting notes, and the sign-in sheet are part of the documentation for this one meeting. It's it's documenting different aspects, but it's it's part of a whole. Okay, so let's talk about sign-in sheets for a second. So here on this example aside from figuring out that I can't write with a mouse okay? Um this has a couple of things wrong with it for a sign-in sheet, all right? So there's no date. There's no indication of what meeting this
033is for. There are no roles assigned to each of these people. So, although, you know, uh 2 4 6 8 10 people signed into this meeting, I, as an auditor, I don't have a clue who they are. Um I don't know whether they're principals or teachers or parents or community members. I don't know who they are. Um and so, in terms of determining whether the required stakeholders were actually in attendance at this meeting, I don't have a clue. Um I also wouldn't be able probably to take this list and look at a list of, you know, site-based decision-making committee members, I which might have a role associated with them, but I might not necessarily be able to read uh this admittedly lousy handwriting. Um and and you can't always on this. So, so being expecting
034an auditor to be able to compare this to a list um is not really something that uh would be able to do. So, in terms of making this compliant, you again would want to have the date for the sign-in sheet. Um you'd have the title of the meeting. You'd have a printed version of the name. Now, this could either like be preprinted if you knew who was going to be there, or it could be the person who is in attendance actually printing their name before they scrawled their signature. Okay? Um it's a whole lot easier to read somebody's printing than it is to decipher their handwriting. So, um it also has the roles listed so that you can see who the principal is, who the parent is, um who the teachers are, uh which one's
035the para- paraprofessional. Um and also please note that the parents are not school district employees. They are not teachers doing double duty or paraprofessionals doing double duty. The state law, the Texas Education Code, prohibits parent representatives from also being school district employees, or maybe I should say that the other way around. It prohibits school district employees from being parent representatives. Okay? And the reason for that is that it's a potential conflict of interest. Okay? Parent representatives need to be able to represent parent perspective and parent needs independent of concerns about what their employer might be thinking about it. So, you don't want your parent representatives to be to to have a conflict of interest, um having to like go against what, you know, their employer is is is trying to do. You want there to
036be a uh you want parent representatives to be able to represent the parent perspectives, um without influence from the district. Okay. So, as you're looking at your sign-in sheets, can you tell from the sign-in sheet or participant roster who attended the meeting? So, if it's an in-person meeting, you should have a sign-in sheet. There should be like a physical sign-in sheet. If it's a virtual meeting, we do accept participant rosters. Um it could be uh like uh an an electronic sign-in. Um it could be uh some some sort of like timestamped thing about, you know, this person signed in at this time. Um it could be like a chat where you have uh either everybody, you know, type in their name and their role. Um it could be something where you have like what we
037did at the beginning of this particular meeting where you have an attendance survey where the people, you know, they they click on the link and they they type in their name and they select their role and, you know, that that could be a produce a participant roster that would be an acceptable um attendance survey. Um the Texas Education Code uh citation where the parent representatives cannot be LEA employees is Texas Education Code chapter 11 uh section 251. Um I also want to point out that if this particular meeting that we're trying to document is supposed to be where the parent and family engagement policies were reviewed and revised, then the majority of the group doing the review of the uh review and revision of the parent uh PFE policy needs to be parents. The majority
038of the group doing the revision review of the parent family engagement policy needs to be parents for that relevant campus. Okay, if it's the district, it can be represented parent representatives from all the district all the campuses that are involved, but if it's the campus policy, it needs to be parents at that particular Title 1 Part A campus. Um this could be a subcommittee of a larger group so that the subcommittee, the majority of the people on that subcommittee were the parents doing the review and revision of the policy, or it could be a parent advisory council that had a majority parents. And please note that I did not say that 51% of the parents in the district had to be involved. Okay? That's not what I said. All right? It's 51% of the group
039that's reviewing the parent family engagement policy need to be parents. All right. Um and does for for this participant sign-in sheet or or participant roster, does the date of the roster align with the meeting notes and the agenda so that it's all part of a piece. I mean, we have uh templates out there for districts to use. Um it's a little bit frustrating on our end where uh we have um where we have uh uh templates out there available and they might be used, but when you get to the part about where the the date of the meeting, it's left blank. So, there's a blank available for it on the template, but it didn't get filled out. Yeah, so so if you're using the templates, fill out all the blanks. And and that'll be um
040that'll put you in better stead for your documentation. But um we get the feeling sometimes that uh especially if if if it's a situation where the district is wanting to to show, oh, we had a lot of parents involved in this particular meeting. So, they go pull whatever sign-in sheets they had related to meet the teacher night. Okay, because we had, you know, 150 parents come to meet the teacher night, which is great. But it's probably is not super likely that that's the event where you actually had opportunities for parents to participate in the review and revision of the policy for PFE. It's more likely that that was a distribution opportunity for the finished product. And so, that's where uh you want to be sure that the meeting that you're using for your documentation is
041matching up with what the in what what meeting you're what what activity you're actually trying to document. So, if it's the meeting where parents had the opportunity to review and revise the policy, that's what you want your agenda to show. That's what you want your meeting notes to show that parents had that opportunity. That's what you want the uh sign-in sheet to be for parents who were involved in that process, not necessarily the meet the teacher night where that's where you had 150 students or 150 parents attend. I know, when I was a teacher, and I did meet the teacher night, uh the 14 minutes that I had parents in my class, while they were running around doing their student schedule, I had my syllabus to go through. I had, you know, other other stuff
042that we were talking We weren't reviewing and revising the parent and family engagement policy in my classroom. And yet, that's what the people who signed in for uh Ms. Smalls' classroom, that's that's what they were signing in for. They weren't signing in to document that they had a opportunity to review and revise the policy. So, just be sure that the documentation that you are presenting as documentation for a particular activity is really representative of that activity. Okay. Um let's move on to the LEA plan descriptions. Uh this is talking about the 13 required descriptions for and that that related to Title I Part A that need to be in the Title I Part A program plan. So, frequently what we see is here's an example where the requirement for the description says that the LEA
043shall describe how the LEA will ensure that all children receive a high-quality education and close the achievement gap between children meeting the challenging state academic standards and those children who are not meeting such standards. That's the requirement. Okay? In the LEA plan description, we may see the LEA will ensure that all children receive a high-quality education and close the achievement gap between children meeting the challenging state academic standards and those children who are not meeting such standards. Okay. If the requirement is that the LEA describe how this description doesn't do that. This descript description just says that the LEA will do this. It doesn't say how, and that's what the requirement is is that the plan is supposed to describe how. So, to turn this example this non-compliant example into a better example, the LEA
044could just add we'll do this by doing the following and then say bullet bullet bullet. These are the activities that we're going to do to be sure that this particular activity or this particular uh requirement is met. So, you see the difference between those two. Okay, so we have like uh Okay, I understand that the slides somehow are not able to be posted. I will find out why because I thought they were posted on the website where you registered for um the uh seminar. Um I've tried to put them in the chat. I will follow up to see why they're not there. But, I can't do that while I'm doing the presentation. Um So, you see you see how uh you see the difference between a non-descriptive description where you just turn around the the
045basically the requirement as opposed to how the LEA is going to meet the particular requirement. The other thing I'd like to say about the LEA plan descriptions, um there are some LEAs who have created like a template basically where they have the the 13 descriptions that are required the requirements on the left-hand side, on the right-hand side they've listed how what the LEA is going to do to meet those particular requirements. So, they've said here's the requirement, here's how we're meeting it. Okay? That does two things, actually three things. It it keeps it all in one place so that it's easy to find, it's easy for the LEA to find it, it's easy for the auditors to see it. Um it has the advantage of letting of of of providing the LEA a visual, okay?
046So, like when they're reviewing their plan for the following year, if they look at the right-hand side and they say, "Mm, we're not doing that anymore. Let's delete this." If they delete the description of what they're doing, they're left with a blank, okay? So, there's a visual reminder of, okay, if I took this off, I need to put something else there, okay? I need to describe what we are doing as opposed to just taking out what we didn't do or we aren't doing anymore. Um if the LEA has just embedded these in their plan, which some LEAs do, okay? And it's not that that's necessarily wrong, it just presents a different set of challenges because one, the LEA doesn't necessarily remember from one year to the next, from one set of personnel to the next.
047Your new programs director may not understand the significance of a particular description embedded in the plan. If that got taken out, there's no prompt necessarily to replace it with something, okay? So, the the the new people coming in who don't have maybe the history about why something got written in a certain way, they come in, they say, "Okay, well, we're not doing this activity anymore." It gets taken out, so now there's nothing in the plan to reflect what the LEA is doing for this particular description requirement. So, it it it it can benefit the LEA to have this all in one place both in terms of ease of finding, okay? Both for the LEA and for the auditor, but it also is a check for the LEA where the uh uh the description is there
048then the if if changes are made to it or if if if if perhaps this year maybe a particular one of these are descriptions wasn't applicable. For example, uh maybe I didn't have any schools in school improvement, so I didn't have to have a description of what I was doing with my title funds title one funds to to assist those LEAs. But next year I have campuses are in school improvement, so I need a description. I may not realize that I need to do that unless I'm going through a set where say oh I said that wasn't applicable, but now this year it is. Um I had uh someone tell me in the chat that if they open the webinar chat to a full window that they are then able to download and save the
049slides. So if you're not looking at the chat in a full window, maybe you don't see the opportunity to be able to download them. So that could be a possibility. Thank you for that, Heather. All right, let's move on to targeted assistance student selection criteria. I know that there are very few school districts um maybe as few as 60 in the entire state out of a hundred of 1200, so 60 out of 1200 who are operating a targeted assistance program. If you are offering a targeted assistance program there's a requirement that the LEA plan describe what the multiple educationally related objective criteria are for selecting students to be served in the targeted assistance program. Okay, those of you who have schoolwide programs, you're able to serve all of the schoolwide programs. All of all of
050the students at the school-wide program. All students on a school-wide program are eligible for Title I services. On a targeted assistance program, it is only those students who meet the educationally related objective criteria that the district has set who are eligible to receive Title I services. Now, when when the district describes what these multiple educationally related objective criteria are, the district also needs to say what the cut point is, okay? And also, they need to be able to They don't have to put this in their plan, but they need to be able to produce a single list of students who are identified as most at risk. So, basically, that sort of involves like a matrix, okay? So, like you would have if if my objective criteria, my multiple criteria are um passing level on STAR
051Reading. So, anybody who's below passing level on STAR Reading, anybody who's below passing level on STAR Math. That's two criteria, okay? Um you'd create a a a a a matrix so that you could put your STAR Reading and your STAR Math results, and you would score them for each student so that you could come up with one set of criteria that would have one list of students. So, that you would be able to say um here are the the 50 students who are most in need, or the 75 students who are most in need at this particular targeted assistance campus. And then if you if if, you know, the next quarter the list changes, you know which students you need to to to to serve. Or if you get reallocation money, you're able to serve
052more students, you don't have to create a new list, you can just go further down it. Um so, let's talk a little bit about specific things. Um, some of the issues that we found during the uh validations, um, some of the issues that we found during the validations were that um the criteria doesn't have a cut score. That's a possibility. Um, they might have one or more criteria that's not educationally related. Um, one that comes to mind is that we had a district that listed um COVID. COVID is not an educationally related objective criteria. Okay? COVID could have had an impact on student performance and student performance on whatever assessment could be an educationally related objective criteria, but COVID itself has nothing to do with it, okay, in terms of um, you you can't say,
053well, you know, 10 students got COVID and they missed however many days, that's not an educationally related objective criteria in and of itself. Um, the district also can't say, well, we're going to serve all the students in grade two because they're to to to help them get ready for the grade three star test. You can't serve an entire grade with a targeted assistance campus, okay? Because that's not serving the students who are most at risk of failing. The entire grade two is not most at risk of failing the grade three star test. Okay. Um, let's see. So, here's an example. Um, so like you could have for your pre-K students, you could have like uh your assessment might be you've got a a a rapid naming letter test. You've got rapid vocabulary. You've got phonological
054awareness assessments. And if you have students who have three out of the three domains in red, that means that they're at risk. Okay, so you've defined that criteria. Um if you have map quizzes or map map scores for kindergarten through grade two, um you've you've said uh what the cut score is. So, like if you've got a map score below 115, you're going to put those kids on uh the list. So, um that's an example of kinds of assessments that you could have on your educationally related objective criteria and what kind of cut score you would need to define so that your district was applying it uniformly. Okay. So, let's move on now to um LEA and campus PFE policies. So, when we've been reviewing the campus and LEA PFE policies, um we are looking
055at the LEA PFE policy for Title I Part A, and we also selected at the same time a campus, a Title I campus, so that within the district so that we could look at their campus PFE policy for Title I. Um most districts who have multiple campuses are going to have two separate documents. Okay? Um if it is a single campus LEA, it is possible to have one document, but you want to be sure that both the LEA requirements and the campus requirements are addressed in the policy document. If the LEA has more more one campus, the LEA should have a district policy and a separate campus policy. Because it can get really dicey in terms of ensuring that the appropriate campus or parents associated with each campus have input into the campus level policy
056if it's all mashed up together in one document. So, um it it's it's easier to document, it's easier to keep clean if the LEA has an LEA policy document and a campus policy document unless it's a single campus LEA. So, some of the common issues that we found related to campus PFE policies are that the old statute is cited. And that could have been No Child Left Behind. It could even have been Improving America's Schools Act. Okay? I And I'm sorry. The ESSA statute has been the law since 2015. We're now in 2026, about to start the 2026-2027 school year. 11 years is enough, guys. I mean, like it's way past time that we should have outdated statutory references in our policies. Okay? So, so we shouldn't be seeing references to No Child Left Behind
057or Improving America's Schools Act. Now, No Child Left Behind could be referenced not only by the words No Child Left Behind, that's sort of an obvious one, and I do still see those. It could also be the actual citation of the statute. So, it's easy enough to tell when I'm looking at old statutory references because No Child Left Behind was section 1118. Under ESSA, section 1118 talks about supplement not supplant. Okay? So, if it's talking about 1118, I know it's outdated. The way to fix it is not to replace 1118 with 1116. Okay? The way to replace it is to take the whole policy document and review it against uh the current st- uh template for the current statutory requirements, so that you're ensuring that um the the new statu- the newer statutory requirements are
058being addressed by the policy. The other thing that we sometimes see is under No Child Left Behind, the requirement related to the percentage that had to be distributed to campuses. So, like the if if a district gets more than $500,000 in Title I Part A money, they're required to reserve 1% of that at the district level for PFE. 95% of that under NCLB was required to be distributed to campuses. Under ESSA, it's only 90% that's required to be distributed to campuses. Now, it's not wrong for a district to reserve 95%, but it's is more restrictive than current statute. So, if the district has 95% still in its uh district PFE policy, the district's going to be held to 95% to be allocated to campuses. Okay? The district can't come back and say, "Oh, well, the
059current statute says 90." Yeah, it does, but if your district policy says 95, that's more restrictive and that's what the district is going to be held to. So, if you're doing 95, that's fine. Just be sure you're doing it on purpose, not because it's a holdover from No Child Left Behind. Um one of the other things that we noticed is that in the district and campus PFE policy, that there isn't any indication that the PFE policy or the PFE program are being evaluated and that those evaluation results are being used to review and revise next year's policy. That's a requirement. Um there's also in some cases no mention of the capacity building activities. Those should be reflected in both the district and the campus policy. Now, they could be addressed in different ways. It may
060be that the district is supporting the capacity building requirements in certain ways and the campus is supporting those activities in other ways. And so, they just need to reflect what the district and or the campus is actually doing to support those uh capacity building requirements. Um we talked a little bit earlier about not enough parents participating in the review and revision of the PFE policy. Anytime you have a review and revision of parent and family engagement anything, okay? It needs to be done by a group that is majority parents. All right? So, you wouldn't have your review and revision of the PFE policy being done by your site-based decision-making committee as a whole, because that's likely only to going to have, you know, two parents on it as opposed to, you know, the 10 or
06112 or however many other district or campus people who are on that committee, okay? So, it needs to be either like a subcommittee of that group that is majority parents, or it needs to be a uh parent advisory committee that is majority parents that are reviewing and revising those documents that have to do with parent and family engagement. Um we mentioned earlier that uh LEA employees cannot be parent representatives. Um So, uh the other thing could be uh it could be related to the wrong school year. Okay, so whatever policy the the policy needs to be reviewed and revised every year, okay? And so, there needs to be a date associated with every iteration of the PFE policy. So, if we're looking at the one for 26-27, we're looking it should be dated that way.
062If we're looking at the one for 25-26, it should be dated that way. Um we talked earlier about the meeting documentation. I've seen a lot of mismatched supporting documentation related to meetings. So, that there isn't necessarily the agenda that's dated the same way as the meeting notes that's dated the same way as the uh sign-in sheet. And then the other thing is that what's submitted is quite frankly not a policy. Um I know that for the last several years we've been giving the example of, you know, we we we have a uh a commercial version of uh a draft or a template that can be used for um student handbook. Okay, it's fine for a student handbook, but you can't copy what's in there and say, "Hey, this is my parent policy." It's a wish
063list for how districts would want parents to behave. It has nothing to do with what the district or what the campus is doing to meet the Title I Part A parent and family engagement requirements. So, um keep in mind that just because something is called, you know, this is this is you know, a parent involvement section, okay, that doesn't necessarily make it a policy and it doesn't necessarily make it something that is compliant with the Title 1 Part A parent and family engagement requirements. Okay. Um I think I've got a couple more sections I want to get to before we we we stop. So, this one is about uh Title 1 Part A campus allocation documentation. So, when when you're documenting how the district determines what it's Title 1 Part A campus allocations are, the
064district should have a spreadsheet, okay, that lists all of its Title 1 Part A campuses, the enrollment, the low-income numbers, uh the per pupil amount and what the calculation actually is for the Title 1 Part A allocation. So, however the district came up with its per pupil amount, it should be listed the the the amount that that per pupil amount should be listed on the spreadsheet. You should be able to multiply that out that per pupil amount times the number of low-income students and you should get the campus allocation. This is a budget activity, okay? This should not be done after the fact using campus expenditures and figuring out what your actual per pupil amount is for your Title 1 Part A campuses for fund code 211. That is totally backwards. You should be doing
065this on the front end to let dis to let campuses know what their Title 1 Part A allocation is for the coming year, okay? One way that we are able to tell that districts do this backwards is that we get things that talk about okay, I'm my per pupil amount is $427.19. I'm sorry. I'm going to call BS on that one because nobody uses $427.19 as a per pupil amount. Okay, I mean that that's that's a reverse engineered number. If you're going to do this as a budget activity, take a whole number for one thing, okay? So you should be dealing in whole numbers because your your your per pupil amount should be a whole number. Your number of student low-income students should be a whole number, okay? We don't have partial students in Texas,
066okay? You got a whole student. Um so you should be able to multiply a whole number times a whole number and get a whole number. Okay, we shouldn't be dealing in cents in terms of what your campus allocations are for Title 1 Part A. Right? Um so when then we look at your general ledger, your general ledger is going to have a column likely on whatever report that you print that's going to say, this is the budget for the campus, okay? That number should match what's on your spreadsheet so that we can see that the calculation that was done to determine campus allocations translated to an amount that was budgeted for the campuses in the general ledger. Okay, so I think I've got an an example here. Oh, okay, some of this I said, sorry.
067It's a budget process, not a review of expenditure data. You need all the stuff all the the relevant data amounts in the in the spreadsheet because when we're reviewing this, we need to be able to reproduce your calculation. There needs to be enough information in the spreadsheet for us to say x * y = your campus allocation. Okay, we should be able to reproduce that. Now, you can also double-check yourself to be sure that you haven't like got embedded [clears throat] rounding things in if you accidentally used a a decimal, which you shouldn't be using because it's supposed to be a whole number. But, if you take your allocation and you divide it by the number of low-income students, you should get the per pupil amount. So, like 5 * 3 is 15, you should
068be able to say 15 / 3 is 5. If you've got different numbers, something's weird about your spreadsheet. Okay. Um the campus list, the enrollment, and the low-income data should match what is on your SC5000. Because the law says the statute says that campus eligibility, which is what is determined on the SC5000, should be based on the same data. The same data should be used to determine campus allocations. So, you determine campus eligibility and campus allocations based on the same data set. Okay, I think I've got an example. Okay, yeah, I do. Okay, so here, for example, you've got uh Title I allocations here. You've got per pupil amounts here. You've got low-income numbers of students. Okay, so I've got whole numbers here on the Title I campus allocations, but I've got weird cents, okay,
069on the per pupil amounts. So, this is telling me that probably this district figured out what these per pupil amounts were based on what actual expenditures happened because I promise you nobody picks $210.57 as their per pupil amount. And that's not how budgeting works, okay? I mean like you're going to pick a whole number. Um there could be other things wrong with this too because uh if you look here, you've got uh a campus at 77.26% getting $205.38 per kid or per low-income kid. And then you have a campus at a lower poverty percentage at 70 getting a higher per pupil amount. And that's not right. You're not supposed to be able to give a higher per pupil amount to a lower poverty school. Okay? So, I'm just saying there there there are other things
070besides just the weird cents involved in this particular non-compliant example. Um as you are reviewing your allocations, if you have a question or you want to talk about it, email me. I'm happy to talk about it. I won't I promise I will not look at your LEA name. I will I will not remember from one year to the next. I'm happy to talk about it like off the books, you know, what would we what would we be seeing here? You know, I I I I don't have to have my monitoring hat on while we talk about um questions that you may have about how to do campus allocations. I promise I will not hold it over for the next year. So, some of the issues that we've seen campuses may not be being served in
071rank order when it's required to be served in rank order. Um we might have higher poverty campus receiving a lower poverty a lower per pupil amount. Um we've seen where there doesn't seem to be any correlation whatsoever between the amounts that got calculated in the spreadsheet and the amounts that are being shown as budgeted on the general ledger. There should be a correlation between those two things. I mean, that's why you calculate the spreadsheet is so that you know how much to budget. Um we also have um a few indications where the Title I there was a Title I campus listed as being served on the SE 5000, but it might not have received an allocation. And And that that uh that could be that they that there was a a mismatch, that maybe it
072shouldn't have been served on the SE 5000, or it may also have been that the district didn't quite understand that if they had trans used it fun funding transferability and moved like Title II funds or Title IV funds into Title I, that they could have or should have included fund code 211 for that campus or fund code 289 for that campus so that we could see, in addition to fund code 211, um how those got um allocated to campuses. Um also sometimes the the ledger reports uh and it may just be a function of of not not understanding how how the reporting functions on your particular uh accountability software work, um but you should be able to produce a report that's sorted and totaled by campus, not just by a well, this is fund code
073211 and, you know, you've got uh campus 101 and 103 and 041 all jumbled up in in the list. Um we're not going to go try to sort them out and um do our own calculations for that. You need to have the reports done by sorted by campus so that we can see a total amount of Title I funds or inclusive of funding transferability funds totaled by campus. Okay. Okay, last topic I think is the SNS methodology. Every district in the state should have either a methodology for allocating state and local dollars to its campuses or it should have a statement of exemption. So, everybody's got one or the other of those documents if they take Title I Part A funds. Common issues are that the methodology is not Title I neutral. That is the
074primary requirement of the methodology, that the district allocate state and local dollars to its campuses without paying any attention whatsoever to the Title I status of its campuses. Okay? You don't want to be in a position where you're giving more state and local dollars to non-Title I campuses because, well, they don't get Title I money, so they need more state and local. No. That is like the definition of not being Title I neutral. So, so you want to be sure that however you're distributing your Title I money, sorry, however you're distributing your state and local money, you want to be doing it without paying attention to whether the campus is Title I or not. We had some examples where the LEA stated in its methodology that it was applying the presumptions of supplanting to Title
075I Part A. And that's wrong. They should not be asking whether an activity is a state requirement when it comes to Title I Part A. Okay? So, so Title 1 Part A is establishing compliance with supplement not supplant by having a methodology for distributing its state and local dollars. It does not then also apply the presumptions of supplanting. Um we had spreadsheets submitted that didn't contain enough information for us to be able to replicate the calculations. So, for example, if if the the LEA was going to do uh a weighted per pupil amount and say, "Okay, I was going to do, you know, $41 for every kid who was in, you know, performing arts or whatever." You don't have to get that level of detail, but some people do. If you're going to give that
076level of detail, then the spreadsheet needs to have the $41 and also the number of students that that $41 would apply to. So, like we have to be able to replicate all of the pieces, not just the number of students enrolled in the campus. Okay? So, if if you're doing just a straight per pupil, then the num that the enrollment and the amount per pupil would be enough. But, if you've got little bitty buckets of money that that you're trying to to, you know, uh uh be more detailed uh more complicated about your methodology, then in order to be able to replicate that, we would need the additional data to be able to replicate your uh to be able to replicate your calculations. Um the general ledger pages that you're trying to match up, so
077like once the the the spreadsheet gets your amount per campus for state and local dollars, your general ledger pages that are submitted should be for fund code 199 if you're a regular school district or should be for 420 if you're a charter school. We shouldn't be getting fund code 211 for your SNS methodology because we're looking at state and local dollars for this. Yes, it's a title one requirement, but we're looking at state and local distributions to campuses. Um some of the general ledger pages just didn't even provide a budget for the campuses. So, you you want to be sure that what what ledger pages that you're submitting in support of your SNS methodology show the campus number, the campus name, and the amount, the total amount of state and local dollars distributed at our
078campus. Now, I say the total amount. If your LEA has done uh a methodology that has like personnel costs that you're justifying based on a staffing pattern, then you need to submit your staffing pattern. So that we can see that each campus got the staff that they were supposed to get based on the staffing pattern. We're not looking at dollars when we look at staffing pattern. We're looking at numbers of personnel, okay? Um the non-personnel costs would be the 6200 through 6600, and we would be able to we should be able to tie the amount of state and local funds that were budgeted for 62 and 6600 to the ledger totals per campus for 62 and 6600, but that should be a report that the district is able to generate with totals by campus. Now,
079it may be that the report that you generate is part of uh that is part of the expenditure report. Okay, just know that when we're looking at this for SNS methodology, we're looking at the total budgeted. I'm not paying attention to line item expenditures on that report for this particular thing. I'm looking at campus name, campus number, total state and local dollars allocated to the campus or that that that the non-personnel costs allocated to that campus if the LEA has done staffing patterns for personnel. Okay. Let's see. Uh yeah, so I think I talked about that. So let's generally talk about lessons learned. Um So just having an agenda and the meeting notes in the sign-in sheet doesn't necessarily document compliance. It's going to depend on what the content of those things is. Um and
080it's going to depend on whether they they match up based on date and title. Um it's going to depend on uh whether the documentation that the LEA created at the time, whether they did it on purpose, whether it was intentional. Did they document what they intended to document with that meeting? Were they aware that that's what the meeting was being held for? Um it and it it's important for the LEA to be aware of what they're trying to document as they're creating the agenda and as they're creating the meeting notes so that they are recording the correct things that's going to give them credit for the good work that they do because I have a feeling that a lot of these issues is because it it it's it's it's insufficient documentation more than it's lack
081of doing the requirement. Okay, but but in terms of auditing, in terms of monitoring, if the documentation isn't there to support what happened, then it didn't happen. Okay? I mean, that we we don't have any we don't have any proof, and auditors like live proof. So, you have to be sure that that's uh what's there. And if you've got subcommittee processes, be sure that they are submitting stuff in writing, and that you're able to document in your meeting notes that, "Hey, we had sub- subcommittee reports submitted in writing, and this is part of the material that we reviewed as part of our meeting." And that will help. Um be sure that your descriptions include how, and not just what. Um that your spreadsheets have the data that's necessary to replicate the calculations, and that the
082reports from your ledger um include totals by campus for the applicable fund codes and the applicable um class object codes that are involved in your particular uh uh methodology. Okay, so I know that that was a lot of material. Um I'm going to run back through and see if there's any things that I need to see. Yes, I'll repost the slides. Um that seems to be the main thing. Okay. So, right? Um I will uh be happy to um take questions, or if you have follow-up that you want to do, please feel free to to to email me. Um and also, if you wouldn't mind uh doing the uh survey or the evaluation, that will help us improve um the information the type of information that we um provide to you as part of these
083trainings. I am also trying with minimal success. Um I have put the evaluation survey link into the chat, um so that uh you can use that to uh access the the survey. Um please be sure that you check or or pick the right part of the drop-down box. I think it's the third one that's showing um for the 4 30 2026 blue plan for compliance for Title I, Part A. Um that will be extremely helpful for us in terms of uh being able to provide you with trainings that are beneficial to you. We do take uh the comments that you provide um very seriously and we use them to try to improve our trainings. So, we would greatly appreciate that. Um a video of this presentation will be posted shortly. Um I will uh try
084to see uh where or why uh slides maybe not were uh accessible in advance because I really thought that they were. Um Thank you very much for joining us today and uh have a good rest of your week.