USED Releases Guidance for Title I Supplement-Supplant Compliance

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USED released guidance on the ‘supplement not supplant’ portion of the Title I formula in ESEA. ‘Supplement not supplant’ is a long-standing provision in Title I requiring that education funding from the federal government be in addition to—not in place of—funding that would otherwise be available from state and local funds. Center for American Progress and American Enterprise Institute released a pretty good primer on supplement/supplant in 2012. How the Supplement-Not-Supplant Requirements Can Work Against the Policy Goals of Title I reviews the origins of the provision and shares examples of how the rule impacts Title I program implementation. Current statute can substantially limit how LEAs may spend their Title I funds and the ways that Title I funding can support at-risk students. Compliance with supplement/supplant comes with administrative burden. While LEAs can operate school-wide Title I programs, the field continues to have some confusion about what can and cannot be done with Title I funds as it relates to running a school-wide program and being compliant with the supplement/supplant provision. The latest guidance seeks to clarify the confusion.

The guidance is a clarification for current law, though in our read it also aligns with proposed changes to ESEA. In a nutshell, the guidance highlights a compliance test that can be used in running a school wide program. Current law measures compliance with a cost-by-cost basis, meaning LEAs have to demonstrate that each cost is aligned with an activity they would not have administered with state or local funds.  This test doesn’t fit in a school-wide model, and the guidance clarifies the compliance tests that can/should be used in that instance. For someone managing dollars (like a school system leader) this emphasis on the use of school-wide programs is more flexibility. For someone who is a program coordinator (Think: Title I program coordinator) this could be an increased burden. No longer looking at specific costs or services within Title I, this clarification gives more room to innovate; it makes it easier to try something new, and to step away from the status quo. Pages 4-6 offer good examples of misconceptions about running school-wide programs, and pages 9-10 offer concrete examples of ways to calculate supplement/supplant in a school wide system. 

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