St. Louis Park Schools Title Services for Nonpublic Students and Schools: Setting the Context
St. Louis Park School District will ensure timely and meaningful consultation with each nonpublic school about the use of Title I, Title II and Title III to meet the nonpublic school’s specific needs. 34 CFR 200.63, §200.64(b)(4); §1120(b)(5) and §9501(b)-(c) [to be replaced by ESSA §1117(b); §8501(c)]
- For more about required consultation topics, read the Affirmation of Consultation form available on the Nonpublic Participation page on the MDE web site.
- To provide services to eligible nonpublic students, the district must employ a licensed teacher or procure a contractor. Services may not be provided entirely by paraprofessionals.
- Title II is intended to improve academic achievement of all students while Title I is for improving achievement of students in need of Title I services.
*(Per MDE Equitable Participation of Nonpublic Schools Requirement, Guidance and Clarification)
St. Louis Park School District Title Services to Nonpublic students and schools are provided in the context of:
I. Laws and community standards regarding use of public funds;
II. Federal statutes, regulations and guidance; and
III. St. Louis Park Schools’ (SLP) policy and procedures.
I. Laws and community standards regarding use of public funds
As a public entity, SLP must not only obey numerous state and federal laws, but must also behave as a responsible steward of public resources. Our behaviors, including our financial practices, are subject to public scrutiny.
Two key principles come up frequently as we work with nonpublic students and schools:
a. No public money for private use: SLP is required to provide title services to nonpublic students and schools. SLP is also required to maintain control of all public funds, including Title funds, to assure that they are not put to private use.
b. The Establishment Clause of the constitution of the United States: The first amendment of the Constitution prohibits the federal government from declaring and financially supporting a national religion. This is the reason that Title funds can only support non-religious, non-secular activities.
II. Federal statutes, regulations and guidance
Statutes, regulations, OMB circular A-87, and federal guidance govern the use of funds from the U.S. Department of Education to school districts.
Statutes include both the specific law that establishes a program (e.g., NCLB/ESEA) and the General Education Provisions Act (GEPA). Since the Elementary and Secondary Education Act (ESEA) was first passed in 1965 it has contained provisions for services for nonpublic students and schools. These provisions have evolved with each reauthorization and through court cases, regulations and guidance.
Regulations and guidance include both specific program regulation & guidance (e.g. Title I, Title II, and Title III) and the Education Department General Administrative Regulations (EDGAR).
All of these, combined with the district’s annual application for a specific grant, including entitlement grants such as NCLB/ESEA, must be taken into account when determining whether a grant can pay for a particular expenditure.
III. St. Louis Park Schools (SLP) policy and procedures
District policy, procedures and practices are designed to assure that the district and all of its employees fulfill our legal obligations, act as responsible stewards of public funds and meet the test of public scrutiny. Sometimes district policy is more restrictive than grant (i.e., Title fund) guidelines. For example, a grant might be able to pay for good for staff or for families at a district sponsored event. However, because SLP has strict guidelines about when funds may be used to pay for food, there may be times when funds cannot be used to pay for food. As a general rule of thumb district staff must follow whichever guidelines are most restrictive.
For more information, please visit: MN Dept of Education Nonpublic Participation