Neglected and Delinquent Services: From Compliance to

Quality

2008 Annual GCEL ConferenceFebruary 10 – 13, 2008Kathy Cox,State Superintendent of Schools

Neglected and Delinquent Services: From Compliance to

Quality

Presented by:

Eric McGheeGrants Program Consultant Programs for Neglected and Delinquent Children

Agenda The Basics

NCLB, Population, Senate Bill 618, Title IA Services, Title ID Services

LEA Compliance At-Risk Population, Identification, Consultation,

LEA Plan, Survey, SIS, Evaluation, Monitoring Observations

SB618, Facilities, Children, Monitoring Future Vision

Expectations Quality

Services, Identification, Year Round, Instruction, Special Education, Consultation, Parent Involvement, Fiscal, Verification

THE BASICSNCLB, Population, Senate Bill 618, Title IA Services, Title ID

Services

No Child Left Behind and N/D Children Sec. 1001(2) – One of the purposes of Title I is to

address the needs of N/D children. Sec. 1112(b)(1)(E)(ii) – LEAs are required to develop a

district plan that addresses the educational needs of N/D children. The plan should include details about the coordination of services from various stakeholders and/or programs.

Sec. 1113(C)(1)(a)(b)(3) –LEAs are required to: Allocate resources to eligible Title I schools based on rank

order. Rank Order is determined by the poverty percentages in a given school

attendance area.

Reserve a set-aside for N/D children in residential facilities located in the district’s school attendance area.

No Child Left Behind and N/D Children Sec. 1401 – Title I, Part D

Requires SEAs and LEAs to provide services needed to make successful transitions to further schooling and to prevent students from dropping out of the education process.

SEAs and LEAs must prioritize the education of children returning from correctional facilities in an effort to ensure their ability to compete with their non-institutionalized peers.

At-Risk PopulationTitle I, Part A and Part D, subparts 1 and 2, serve the same population; namely, school aged individuals:

At-risk of academic failure Drug or alcohol problem Pregnant or is a parent Contact with the juvenile justice system in the past At least 1 year behind expected grade level for age Limited English proficiency Gang member Dropped out of school in the past High absenteeism rate at school

Neglected and Delinquent Children

Neglected = Children and youth who are in need of care due to abandonment, neglect, or death of their parents or guardians.

Delinquent = Children who have been adjudicated to be delinquent or in need of supervision.

Grantees and Population Title I, Part A

Provides financial assistance to LEAs and schools with high numbers or high percentages of poor children to help ensure that all children meet challenging state academic standards.

Title I, Part D Subpart 1 - Provides financial assistance to educational

programs for youth in state-operated facilities or community day programs.

Subpart 2 - Provides financial assistance to support eligible LEA programs involving collaboration with locally operated correctional facilities.

Senate Bill 618 Some N/D residential facilities were previously

under the direct supervision of DJJ; however, DJJ moved away from directly supervising privately run facilities. These facilities were in danger of operating without oversight.

In the summer of 2006, the Georgia Legislature passed Senate Bill 618 transferring the education responsibility for children in State custody who reside in the school district to Local Education Agencies (LEAs).

Senate Bill 618 As a result of Senate Bill 618 (SB618), all

students residing in SB618 residential facilities are eligible for enrollment in the educational programs of that local school district.

Because students are eligible for enrollment in the educational programs of that local school district, students can transition to LEA schools without interruption to the educational program.

Types of Residential Facilities There are two types of residential facilities

that LEAs will serve: N/D Facilities which are licensed under DHR;

thus, considered “Neglected” for reporting purposes.

Primarily, children is these facilities receive their “regular” educational program in an LEA school; however, supplementary educational services may be provided on-site.

N/D Facilities which fall under Senate Bill 618. Primarily, these facilities provide the “regular”

educational program on-site; however, in a few cases, some children may attend the LEA schools.

Services for N/D Children In general, the same allowable services

provided under Title I are the same type of services provided to N/D residential facilities and children.

Resources provided to N/D residential facilities and children should supplement, and not supplant, the “regular” school program.

Services may include before and after school tutorial, summer school, credit recovery, educational materials and supplies, and more.

Title I, Part A Set Aside Funding

All N/D residential facilities qualify to receive support from the Title I, Part A set aside.

LEAs must describe N/D services for residential facilities derived from Title I, Part A funding in the “Set Aside” section on the Consolidated Application in the Coordination page.

Title I, Part A Set Aside Funding The U.S. ED determines the LEA Title I, Part A N/D

set aside amount based on the N/D child count derived from the N/D Annual Survey.

LEAs must use the entire Title I, Part A N/D Set Aside for N/D children, unless the LEA has written verification that the residential facilities do not need the entire amount – the unclaimed amount reverts back to Title I, Part A.

LEAs are required to consult with all N/D facilities located in the district’s school attendance area to determine needs.

Title I, Part A Set Aside Funding

Title I, Part A Additional Support The LEA may choose to use additional Title I, Part A

funds to support N/D children. (This is not required!) To do this, LEAs may

Create a “Custom Set Aside” in the consolidated application with the proposed budget and activities

OR Include the additional funds in the N/D Set Aside

LEA should delineate between the required N/D Set Aside amount and the additional funds).

The CLIP (coordination page) should fully explain in detail the needs analysis that determined this use of funds and how the resources will be used.

SB618 Residential Facility Funding SB618 residential facilities are eligible to

receive funding from 4 sources: Title I, Part A Set Aside (See previous slides.) FTE (Full Time Equivalent) resources for eligible

N/D residential facilities operating as schools under Senate Bill 618 in the LEA’s allotment sheet.

Title I, Part A resources, if they rank in the funding range for schools in the district.

Title I, Part D, Subpart 2 resources, for eligible residential facilities located in a district that ranks above the median based on the number of N/D children.

Title I, Part D FundingTitle I, Part D is another program available to serve N/D

children.Goals: Improve educational services in local and state

facilities in order for students to meet the challenging state academic content standards and state student academic achievement standards.

Provide students with services to successfully transition from institutionalization to “regular” schools in the LEA, further schooling, or employment.

Prevent at-risk youth from dropping out of school, and to provide dropouts and youth returning from correctional facilities with a support system to ensure their continued education.

Title I, Part D Subpart 1

Provides assistance for State Agencies Dept. of Juvenile Justice Dept. of Corrections Dept. of Human Resources

Subpart 2 Provides assistance for LEAs

Working in collaboration with local residential correctional facilities (In Georgia, SB618 facilities MAY be eligible)

Title I, Part D, Subpart 1 State Agency Programs

State agencies responsible for the care children and youth: In institutions for N/D children and youth. Attending community day programs for N/D

children and youth. In adult correctional institutions.

Title I, Part D, Subpart 2 Local Education Agency ProgramsPurpose To support operation of LEA programs that

involve collaboration with locally operated correctional facilities to — Carry out high quality education programs to prepare

children and youth for secondary school completion, training, employment, or further education.

Provide activities to facilitate the transition from correctional programs to further education or employment.

Operate programs in local schools for children and youth returning from correctional facilities and programs which may serve at-risk children and youth.

Title I, Part D, Subpart 2 Grants to LEAs LEAs with high numbers or percentages of

children and youth residing in locally operated (including county operated) correctional facilities including facilities involved in community day programs.

Note: In the 2008-2009 school year, some LEAs with SB618 residential facilities MAY be eligible for funding.

Title I, Part D, Subpart 2 Funding LEAs who have a N/D children count above

the State median as reported in the 2007 Annual N/D Survey may be eligible for Title I, Part D, Subpart 2 funding.

PPA allocation is calculated by only counting the N/D number for those LEAs whose N/D number is above the median for Georgia. For example, if the median is 44, LEAs with a

count of 45 and higher would be eligible for funding.

Title I, Part D, Subpart 2Uses of Funds Carry out high-quality education programs.

Assist in the transition of children and youth returning to the local “regular” school environment from correctional facilities and help them remain in school to complete their education.

Provide dropout prevention programs to serve at-risk children and youth.

Title I, Part D, Subpart 2Uses of Funds Coordinate health and social services for N/D

children, if the provision of such services will improve the likelihood children completing their education.

Provide special programs to meet unique academic needs of N/D children.

Provide mentoring and peer mediation.

LEA COMPLIANCEAt-Risk Population,

Identification, Consultation, LEA Plan, Survey, SIS, Evaluation, Monitoring

LEA Compliance DutiesLEAs are required to:

Define at-risk population Identify N/D Facilities Consult (face to face) Review Title I, Part A LEA plan Conduct Annual N/D Survey Code N/D children in SIS Complete Annual LEA N/D Evaluation Monitor

LEA Compliance DutiesAt-Risk Population:

LEAs are required to define their at-risk populations.

N/D children must be among the identified groups if N/D residential facilities are located in the school attendance area.

In this effort, LEAs can confer with service agencies, school personnel, including pupil services, and alternative education staff in the district and coordinate efforts to meet the needs of the N/D population within the LEA.

LEA Compliance DutiesIdentification:

LEAs are required to locate and consult with the N/D facilities in their school attendance area. LEAs can do a search for “Child Caring

Institutions” by reviewing the Department of Human Resources’ (DHR) Office of Regulatory Services’ (ORS) Web site: http://www.ors.dhr.state.ga.us/

LEAs can search for facilities by county, city, zip code, or facility name.

Residential Facility Search

Residential Facility Search

Identify SB618 Facilities

LEAs can find the current Senate Bill 618 facilities by accessing the Title Programs Web page http://www.gadoe.org/tss_title.aspx in the box entitled “Resources.”

Title Programs Web Page

LEA Compliance DutiesConsultation: LEAs are required to consult with local residential

N/D facilities . Review educational needs as determined by needs

assessment of the N/D facilities. Develop strategies with N/D facilities to address educational

support to residential facilities. Implement mutually agreed upon services in residential

facilities. Consultation is a face to face meeting with all N/D

facilities to determine student needs, develop strategies to serve these children, and provide technical assistance for the Annual N/D Survey.

LEA Compliance DutiesLEA Plan:

LEAs are required to review Title I, Part A LEA plan to ensure that needs determined are included and adequately explained.

Detail all services provided from the N/D Set Aside in the CLIP on the Coordination Page.

LEA Compliance DutiesSurvey:

Conduct Annual N/D Survey Verify data during consultation with residential

facility. Submit compiled data for all residential facilities in

LEA to GaDOE.

N/D Annual Survey Submission The N/D Annual Survey is conducted each Fall.

The survey generates resources from the U.S Department of Education for the following fiscal year. LEAs select a 30-day window to conduct the survey – 1

day must be in October. The student count includes the total caseload of a given

facility during the 30 days. LEAs should include all children residing in the facility.

No one is excluded. Children only need to be enrolled 1 day in October

during the 30-day window to be included - they are not required to be there for 30 days.

N/D Annual Survey Submission

The survey is part of the electronic LEA Consolidated Application Survey found under the “Data Collection” tab. Look for “Title I-A Delinquent Project.” Supporting documentation and student list(s)

are kept on file at LEA for monitoring purposes.

Annual Survey Electronic Submission

LEA Compliance DutiesSIS Coding:

Verify the N/D students (i.e. The students listed on the Annual N/D Survey) are properly coded in the Student Information System (SIS).

Report student record data for N/D students through the LEA SIS Coordinators.

SIS Data Collection ENVIRONMENT CODE indicates the type of residential

environment in which a student resides or the type of school the student attended at anytime during the school year at a school. For students where codes do not apply, leave blank.

(Note: Used to apply only to Title I students – now applies to ALL students)

Data Element ID: STU045 Layout ID: C045

Environment Code Description

1 Resides in a local institution for neglected

2 Resides in a local institution for delinquent

3 Homeless

Blank Not applicable

LEA Compliance DutiesAnnual Evaluation:

LEAs and N/D facilities are required to… Evaluate the educational program and

services, disaggregating data on participation by Gender, Race/ethnicity, and Age

Evaluate in order to determine the effect on the ability of participants to maintain and improve educational achievement.

Annual EvaluationLEAs and N/D facilities are required to:

Assess the accrual of “regular” school credits that meet State requirements for grade promotion and secondary school graduation.

Use multiple and appropriate measures of student progress.

Facilitate and maintain records of the transition to a regular program or other education program operated by an LEA; complete secondary school

Annual EvaluationLEAs are required to:

Use the results of evaluations to plan and improve subsequent programs for participating children and youth.

Use student achievement data to determine AYP status.

Use student achievement data to complete school report cards.

(Note: When children receive educational services at an LEA school, AYP and student data on school report cards will be maintained by the students’ home schools.)

LEA Compliance DutiesLEA Monitoring:

The LEA must monitor the N/D program.

In addition to any district specific requirements, the LEA should include the indicators of quality that correspond to the monitoring components that GaDOE uses to monitor the LEA (See the following SEA Monitoring Slides).

SEA Monitoring - Services

The LEA describes the services provided for neglected and delinquent children. Copy of Comprehensive LEA Improvement Plan

(CLIP). Copy of the Consolidated Application Coordination page.

Discuss the process for the development of the LEA’s plan for serving neglected or delinquent children including technical assistance provided on the process.

SEA Monitoring - Identification

The LEA identifies children in local institutions for neglected and delinquent children. Copy of Annual Survey of Institutions for

Neglected Children for previous and current year with student list from each facility.

Describe the process for identifying neglected or delinquent children.

SEA Monitoring - Year Round

The LEA describes Title I services and educational programs that are year round. Class schedules and calendar confirming that

Title I services and educational program are year round.

Describe the process for establishing reservations/set asides for serving neglected or delinquent children.

Describe the educational program that occurs during the summer.

SEA Monitoring - Quality Instruction

The LEA provides high quality instruction based on scientifically based research. Sample curriculum plan based on scientifically

based research for a school serving an institution.

Describe how instruction incorporates scientifically based research.

Describe how the LEA ensures that the same academic standards required by all students and schools in the LEA are being provided to children residing in neglected or delinquent institutions.

SEA Monitoring - Special Education

The LEA provides SPED services, as needed. Number of students receiving special

education services and a sample copy of an IEP from a student residing in an institution. (For privacy rights consideration, the LEA may remove personal identifying information from the sample IEP.)

Describe services provide to special education population residing in institutions.

SEA Monitoring - Consultation

The LEA consults with institutions regarding educational plans and budget. Collaborative planning agendas.

Describe the consultation process with Neglected and Delinquent institutions.

SEA Monitoring - Parent Involvement

The LEA ensures that institutions implement parental involvement plan in order to increase student achievement and, if appropriate, decrease delinquent behavior. Parent involvement correspondence and

parent involvement plan.

SEA Monitoring - Parent Involvement

Describe the parent involvement plan. If the Neglected and Delinquent institutions send

their youth to the LEA school, then the school would need to address the N/D population in its plan – the institution is not responsible for maintaining a parent involvement plan.

If the Neglected and Delinquent institutions educate their youth on-site, then the institutions is responsible for maintaining a parent involvement plan. (Section 1118 of ESEA)

SEA Monitoring - Fiscal Control

The LEA utilizes financial procedures that ensure fiscal control. Purchase orders for materials and equipment

as well as real property and equipment inventory documentation.

Describe the purchasing process and how fiscal control is maintained by the LEA.

SEA Monitoring - Verification

The LEA verifies the authenticity of neglected facilities in the district. Copy of an (a) up-to-date facility license and

the (b) articles of incorporation. Describe the procedure for acquiring and maintaining

documents that verify the operational status of the Neglected and Delinquent institutions.

OBSERVATIONSSB618, Facilities, Children,

Monitoring

Senate Bill 618

Currently, there are 22 LEAs that have Senate Bill 618 facilities.

Currently, there are a total of 29 SB618 facilities in Georgia.

Identified Facilities

In the fall of 2006, LEAs in Georgia identified about 120 residential facilities.

In the fall of 2007, LEAs identified 303 residential facilities. 29 = SB618 facilities 274 = Neglected facilities

Identified Children

In the fall of 2006, LEAs identified 2402 neglected children

In the fall of 2007, LEAs identified 3063 neglected children

Monitoring

In FY07, GaDOE required LEAs to adhere to 3 monitoring indicators of compliance for the Neglected & Delinquent Program.

In FY08, GaDOE requires LEAs to adhere to 9 monitoring indicators of compliance for the Neglected & Delinquent Program.

FUTURE VISIONExpectations

It is the Right Thing to Do N/D children are among the most vulnerable in our

society and they have a right to a free and appropriate public education.

The cost of one high school dropout is expected to be over $200k in his/her lifetime. – Joan Helibrunn and Ken Seely, 2002

The cost of allowing one youth to leave school for a life of crime and drug abuse is $1,700,000 - $2,300,000 annually – Title II of the Reauthorization of the JJDP Act of 2002.

What we Know…

“We can, whenever and wherever we choose, successfully teach all children whose schooling is of interest to us.” – Ron Edmunds, Pioneer Educator

“Education is the only equalizer for these kids.” (Anonymous)

Expectations - LEAs LEAs will provide to all children educational

services that are based on Georgia Performance Standards (GPS) that lead to a high school diploma.

LEAs in Georgia will identify all at-risk children in the Consolidated LEA Improvement Plan (CLIP), including Neglected and Delinquent children.

LEAs will have a written plan in the CLIP to address the needs of all at-risk populations in their school attendance area.

Expectations – At-Risk Population In a reasonable amount of time, all at-risk

children receiving supplementary services will demonstrate meaningful learning gains.

Children receiving supplementary services will achieve learning gains at an accelerated rate.

In a reasonable amount of time, all at-risk children receiving supplementary services will rate proficient or above on all GPS standards.

Expectations – N/D Population Neglected and Delinquent children leaving

residential facilities will have a streamlined transition to LEA schools.

In a reasonable amount of time, all Neglected and Delinquent children receiving supplementary services will be on or above grade level.

All Neglected and Delinquent children will maintain the credits necessary to graduate with a high school diploma on time.

QUALITYServices, Identification, Year Round, Instruction, Special Education, Consultation,

Parent Involvement, Fiscal, Verification

Services In order to go beyond compliance, LEAs

should reflect on the following: Does the CLIP adequately describe all of the

services that the LEA provides to N/D children? Can someone unfamiliar with Title I read the

CLIP and know exactly what actions to take in order to service N/D children?

Did N/D stakeholders assist the LEA in developing the CLIP?

Are the objectives for N/D children described in the CLIP measurable?

Identification In order to go beyond compliance, LEAs

should reflect on the following: Is it possible that any N/D facilities were not included

on the annual N/D survey? Did the LEA use all available resources to identify N/D

children? Can someone unfamiliar with Title I read the LEA plan

for identifying N/D children and properly identify all N/D facilities and children?

Can an outside auditor look at the LEAs list of N/D children for the annual survey and match it to properly coded children in the Student Information System (SIS)?

Year Round In order to go beyond compliance, LEAs

should reflect on the following: When LEA schools are not in session (i.e.

summer), do all N/D children still have access to educational services?

On-site at the facility? LEA summer school? Learning field experiences?

Are summer services to N/D children considered when set-aside resources are agreed upon by the LEA and the N/D facility?

Instruction In order to go beyond compliance, LEAs

should reflect on the following: If N/D children are being educated at the residential

facility, how does the LEA know if the education being provided is based on Georgia Performance Standards?

If N/D children are being educated at the residential facility, are they receiving school credit that can transfer to the LEA school and leads to a high school diploma?

If N/D children are being educated at the residential facility, what is the likelihood that these children will graduate on time?

Special Education In order to go beyond compliance, LEAs

should reflect on the following: How does the LEA identify all N/D children that

need special education services? Can any parent, child advocate, or auditor

have any reason to believe that the LEA is not providing special education services to any given N/D child?

What documentation does the LEA have that proves that special education services are being provided to all eligible N/D children?

Consultation In order to go beyond compliance, LEAs

should reflect on the following: Is the LEA truly collaborating with N/D facilities

or is the LEA just dictating what services will be provided?

Is the consultation face to face? How often does the LEA meet with the N/D

facilities? In the fall for the Annual survey? At the end of the school year to evaluate the previous year

and plan for the next fiscal year? During mutually beneficial staff and teacher trainings?

Parent Involvement In order to go beyond compliance, LEAs

should reflect on the following: Is the LEA aware of the “proxy” parent(s) for N/D

children that cannot, for whatever reason, have their biological parents serve as educational advocates?

In LEA schools where N/D children attend, do schools encourage a facility representative to serve on the Parent Advisory Council (PAC)?

If N/D children are being educated at the residential facility, did the LEA offer to assist the facility in developing a parent involvement policy?

Fiscal Control In order to go beyond compliance, LEAs

should reflect on the following: Can someone unfamiliar with Title I read the

LEAs fiscal procedures and know that the LEA must:

Have written procedure that prohibits the transfer of money to the N/D facilities?

Have instructors paid with Title I funds that are highly qualified?

Only purchase materials and supplies on behalf of the N/D facilities that are related to instruction and will assist students to increase their results on Georgia Performance Standards?

Verification In order to go beyond compliance, LEAs

should reflect on the following: Can someone unfamiliar with Title I read the CLIP

and know exactly what actions to take in order to: Contact the Office of Regulatory Services regarding the

validity and operational status of the residential facilities in the LEA’s school attendance area?

Maintain documentation that proves that services are only being provided to licensed child caring facilities?

Collect documentation that proves that services are only supplementing instruction based on Georgia Performance Standards?

Based on what you learned or confirmed…

Who needs to weigh-in on potential conflicts?

What further questions remain?

What current procedures must change?

What procedures will remain?

Final Thoughts

“Every time you stop a school, you will have to build a jail. What you gain at one end you lose at the other. It's like feeding a dog on his own tail. It won't fatten the dog. ” Mark Twain, 1900

Contact Information

Eric McGheeGrants Program Consultant

Programs for Neglected or Delinquent Children

Education Support and ImprovementTelephone: (404) 651-7555

Fax: (404) 651-9111Email: emcghee@doe.k12.ga.us