The Dept. of Ed’s Advice on Using Title I Funds for Preschool

School districts have always been allowed to use federal Title I funds to establish preschool programs for disadvantaged children, and in fact they can use these dollars to support children beginning at birth.  But because Title I is part of the Elementary and Secondary Education Act ( ESEA), currently known as No Child Left Behind, it is most often used to fund K-12 programs. Some school district leaders may not even know that these funds can be used for programs before kindergarten or may be unsure about what is and is not allowed.

Earlier this month, the Department of Education released new documents – known among policy wonks as “non-regulatory guidance” – on the use of Title I funds for preschool programs to help clear up confusion among school district leaders and principals. (“Preschool” is defined as from a child’s birth to the age that the school district provides a free public elementary education.)

The department has issued similar guidance before, most recently in 2004. The confusion has persisted, and it appears that very few districts use their Title I funds in this way. For example, researchers at the Center for Law and Social Policy several years ago estimated that about 3 percent of Title I funds are used to serve children before they enter kindergarten. But because districts are not required to report the allocation of Title I funds by age, it’s difficult to know for certain how these funds are being used.

The new guidance issued by the department differs little from the guidance issued in 2004. But here are a few notable changes:

1)     In 2004, the department defined Title I “preschool programs” as educational services focused on raising the academic achievement of children once they enter school age. This is still true, but the department broadened the definition to include other important aspects of a child’s development, such as improved cognitive, health and social-emotional outcomes.

2)    In 2004, the guidance featured information on the benefits of high-quality preschool experiences and the components of high-quality preschool programs. These sections do not appear in the 2012 document, presumably because the department did not think it was needed given the Obama Administration’s frequent references about the importance of high-quality early learning programs.

3)    The new document tweaks the language of “parental involvement” to include “family engagement” as well. And it includes new information on using Title I funds to support parent involvement in a Title I preschool program.

4)     The department has also included a section on the use of School Improvement Grant funds to operate a preschool program as part of a school intervention model and on how a Title I preschool program can benefit from the Race to the Top – Early Learning Challenge program.

5)    The department also notes that some children are automatically eligible to participate in a Title I preschool program, including children who have participated in a Head Start; migrant preschool-aged children; homeless preschool-aged children; and children who are in a program for neglected or delinquent children.

Here are a few other important reminders for districts and school leaders about Title I and how it can be used to support young children from high-need families:

• There are three ways a school district can use Title I funds to support a preschool program:
• A Title I School can use all or part of its Title I funds to operate either a school wide (40 percent of its students are from low-income families) or a targeted preschool program for eligible children.
• A school district can reserve a portion of its Title I funds to operate a preschool program for eligible children in the whole district (if all of the schools in the district are Title I Schools) or in a portion of the district.
• A school district can use Title I funds to coordinate with and support eligible children enrolled in other publicly funded preschool programs.

• Title I funds are allowed to be used to provide professional development for any teacher or paraprofessional who works in a Title I preschool program supported, in whole or in part, with Title funds even if his or her salary is not paid for with Title I dollars. Title I funds may also be used for professional development for non-Title I preschool teachers working in programs such as Head Start if the children served are likely to be attending a Title I elementary school when they enter kindergarten.

• School districts can use Title I funds to complement or extend other publicly funded preschool programs for high-need children. For instance, funds may be used to extend the hours or number of days a Head Start program operates. Districts can also use Title I funds to supplement or expand other existing early learning programs, including state-funded preschool, child care and community-based early learning programs for Title I eligible children. Importantly, if Title I funds are used to support other publicly funded preschool programs, then they are considered to be Title I programs and all Title I requirements apply.

• Districts can open Title I preschool programs in just about any location, including public schools public libraries, community centers and privately owned facilities.

• Title I funds can be used to provide comprehensive services for eligible children such as health, nutrition and other social services.

In 2010, CLASP produced an analysis of the 2004 guidance, and since there are not significant changes it applies to the updated guidance as well.

One use of Title I funds not covered in this guidance is how these might be used for full-day kindergarten. Since kindergarten is considered part of K-12 education, one would think that districts are less likely to be confused about whether Title I can be used for kindergarten expansions. And yet there is little information available on whether districts or schools are using Title I to fund full-day kindergarten. This is something school districts should consider if they aren’t doing it already.

Having access data on how Title I funds are spent aggregated by children’s age would be of great benefit to the education community. Again, districts are not currently required to report this level of detail.

This new Title I guidance provides clarity on how funds can be used to support and implement preschool programs for high-need children. But we’d like to see the department do more than just provide guidance.  Using competitive grant programs and other policy guidance, it should actively encourage states, school districts and schools to use a portion of their Title I funds to support early learning. There is a significant learning gap between children from middle-income and low-income families, but reams of research show that high-quality preschool programs can help to narrow it.