Guidance for the william f. Goodling even start family literacy programs



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Committee of Practitioners

Each State must form a Committee of Practitioners to advise the State in carrying out its responsibilities under Even Start and other programs under Title I of the ESEA. The Committee of Practitioners reviews, prior to publication, any proposed or final State rules or regulations issued concerning the program. (Section 1903(b))


The Committee of Practitioners must also be substantially involved in the development of the separate or consolidated State plan and continue to be involved in the monitoring of the plan’s implementation by the State. For example, the Committee reviews portions of the State plan describing the Even Start subgrant competition process.


Example: The Committee reviews a State’s Even Start indicators of program quality to ensure that they are of high quality and coordinated with other related State-administered programs.



Membership
At a minimum, the Committee of Practitioners must include the following:


  • representatives of LEAs, as a majority of its members;

  • administrators;

  • teachers, including vocational educators;

  • parents;

  • members of local boards of education;

  • representatives of private school children; and

  • pupil services personnel.

A State may also include additional members, such as family literacy experts or other individuals, who are familiar with Even Start. If no family literacy experts or individuals familiar with Even Start are formally on the Committee of Practitioners, a State is encouraged to invite such persons to participate in Committee of Practitioners meetings if Even Start or family literacy policies are on the agenda for discussion.




Example: A Committee of Practitioners for a State is composed of: 20 urban and rural school administrators, two non-public school representatives, five parents, two pupil personnel services representatives, six teachers, one local school board member, and three liaisons from the State Education Department.

State-Level Activities
A State may reserve up to 6 percent of its Even Start grant for the following State-level activities:


  • administration (Section 1233(a)(1));

  • technical assistance under section 1233(a)(2), provided to Even Start subgrantees for program improvement and replication through one or more subgrants or contracts with third parties;

  • technical assistance under section 1234(c), provided to Even Start subgrantees to improve the quality of Even Start family literacy services (early childhood education, adult literacy (adult basic and secondary-level education and instruction for English language learners), parenting education, and interactive parent and child literacy activities) through a subgrant, contract, or cooperative agreement with a qualified entity;

  • technical assistance under section 1234(c) to help local programs raise additional funds, provided through a subcontract, contract, or cooperative agreement with a qualified entity; and

  • activities to develop, implement, and use the State’s Even Start indicators of program quality under section 1240.

As explained in more detail below, in order to support the high quality implementation of local projects, a State has significant flexibility under these various functions in how it divides State-level activities. The Secretary encourages States to specify in their accounting records how, and under what authority, the State is using its State-level funds. However, of the total that the State reserves for these State-level activities, the State may use no more than one-half of the total amount for administrative activities. (Section 1233(a))



Q1: If a State reserves a total of 4 percent from its Even Start grant for administration and technical assistance, what percentage can the State use for administration?
A1: The State can use no more than 2 percent, because the statute states that the costs for administration may not exceed half of the total amount reserved for both administration and technical assistance. In other words, a State may take up to half of the amount reserved, and not half of 6 percent.


After determining the amount of funds to be used for State-level activities (up to 6 percent of the State’s total grant amount) and identifying the portion of those funds to be used for activities that it categorizes as administrative (up to one half of the total amount reserved), the State may use the balance of its State-level funds as described below to provide technical assistance and to carry out the State’s indicators of program quality. The technical assistance should be designed to improve local programs and support the replication of successful programs, help local programs raise additional funds and improve the quality of Even Start family literacy services, and develop, implement, and use the State’s indicators of program quality.




Administration

As explained above, a State may use up to one half of the total amount it reserves for State-level administrative activities. The State may use its administrative funds for indirect and direct administration costs, and to provide technical assistance and training to local Even Start projects to improve participant achievement results.




Q2: What indirect cost rate applies to the funds that a State reserves for State-level activities?
A2: The State may use its unrestricted indirect cost rate for Even Start funds that the State reserves for State-level activities because Even Start is not subject to a supplement-not-supplant requirement. (EDGAR, sections 76.560 – 76.580.)

Under section 9201, a State may consolidate its Even Start administrative funds with State administrative funds from some of the programs under the ESEA if the SEA is able to demonstrate that the majority of the agency’s resources come from non-Federal sources. Eligible programs under section 9201 include any ESEA program in which funds are authorized to be used for administration, and any other programs that the Secretary designates.



Technical Assistance

A State may provide training and technical assistance for local subgrantees in several ways. Different statutory requirements apply depending upon the type of training and technical assistance that the State chooses to provide. States may provide these activities directly, as part of the State’s administrative function discussed above or as a part of its implementation of the State’s Even Start indicators of program quality discussed below.


In addition, a State may use a portion of the non-administrative State-level funds it has reserved to provide technical assistance to Even Start projects under section 1233(a)(2), to improve those projects and replicate those of high quality. If the State chooses to provide technical assistance under section 1233(a)(2) to improve or replicate Even Start projects, it must also do so through a subgrant or contract with another entity. A State may also use a portion of the non-administrative State-level funds it reserves to provide technical assistance and training under section 1234(c), to assist local Even Start projects in improving the quality of their family literacy services (that is, to improve one or more of the Even Start core components that make up “family literacy services”). The State must provide this technical assistance and training through one or more subgrants, contracts, or cooperative agreements with an entity that has experience in offering high-quality training and technical assistance to family literacy providers. In addition, the State must give priority to programs of low quality as evaluated based on a State’s indicators of program quality.
For local programs that the State determines to have demonstrated effectiveness, the State also may use technical assistance funds under section 1234(c) to help those programs access and leverage additional funds to expand services to families and reduce waiting lists for services, including through using such mechanisms as requesting and applying for non-Federal resources.


Q3: How can a State provide technical assistance to help a local project in accessing and leveraging additional funds?
A3: A State may use some of the funds it reserves for State-level activities to provide technical assistance to help local projects, that have demonstrated their effectiveness in helping families make educational gains, to access and leverage additional funds in order to expand or sustain services to eligible families. Such technical assistance may include activities such as providing a grant writing or oral presentation workshop, assisting a local project in initiating a local campaign to attract greater community investment in the local project, or compiling a directory of available funding resources.

The State’s use of funds for technical assistance and training in improving family literacy services under section 1234(c) may not result in a decrease from the level of activities and services that subgrantees provided to program participants in the previous year (section 1234(c)(1)). In other words, a State’s reservation of funds for technical assistance and training under section 1234(c) cannot negatively affect the quality and intensity of services that can be provided by subgrantees to their program participants.



Developing and Using Even Start Indicators of Program Quality
A State may also use funds it reserves for technical assistance to develop and use its State indicators of program quality, as described in section 1240, to monitor, evaluate, and improve local projects within the State. These technical assistance activities, for example, may include training local project staff and evaluators on the following: how to improve the content of local evaluations so that they are aligned with State indicators of program quality; how to better use local evaluations for continuous program improvement; how to identify high quality professional development activities for local Even Start staff; and strategies to improve participant retention and literacy achievement results. (See National Evaluation, Local Evaluation, and Indicators of Program Quality -- Indicators of Program Quality section.) In addition, a State could use those funds to provide the technical assistance required under section 1233(a)(3) to improve local projects that have made insufficient progress on the State’s indicators of program quality before the State discontinues those projects for insufficient progress.
Unlike the technical assistance and training that a State provides under sections 1233(a)(2) and 1234(c), a State may provide technical assistance and training under section 1240 to local subgrantees and evaluators on its indicators of program quality either directly or through a contract with another qualified entity.


Q4: When can a State provide technical assistance and training directly?
A4: A State can directly provide technical assistance for activities related to the development and use (such as through monitoring, evaluation, and program improvement) of State indicators of program quality. For all other technical assistance and training, including helping local programs of demonstrated effectiveness to access and leverage additional funds for the purpose of expanding services and reducing waiting lists, a State must use an outside entity. (Sections 1233(a)(2) and 1234(c)(4))


Competition for Subgrants
The Even Start statute establishes certain required information that each local subgrant application must contain. (Section 1237) However, each State may develop its own application for funding and may require additional information relevant to its own subgrant competition. (EDGAR, section 80.37(a)) For example, a State may require applicants to address that State’s Even Start indicators of program quality, priorities for funding that target areas that are especially underserved and in need of Even Start services, or any other relevant criteria to obtain the most qualified applicants. (See Local Application section.) However, any State priorities must be consistent with the statutory competitive priorities in section 1238(a)(2) explained below.
A State must follow certain statutory requirements in awarding subgrants, including using statutory selection criteria and statutory priorities and using a review panel that includes certain required members. (Section 1238(a), and the Review Panel and Selection Criteria sections.) However, except as required by the Even Start statute or other Federal statutes or regulations, a State follows its own policies and procedures when awarding subgrants and, therefore, has substantial discretion over the competitive process for allocating funds to high-quality local projects that can help families most in need of Even Start services attain literacy achievement results. (EDGAR, section 80.37(a)) For example, a State’s process could include such things as on-site reviews, convening of panelists in one location for a paper review, or a two-tiered review process (using a combination of an on-site review and paper review).
Before issuing their instructions for a subgrant competition, the Department encourages States to consult with their Committees of Practitioners in developing the application review process, and any additions to the statutory selection criteria, and priorities that are consistent with those statutory requirements. (See Committee of Practitioners section.)

Review Panel

The SEA must establish a review panel to review and approve local subgrant applications. The review panel must consist of at least three members, including one early childhood professional, one adult education professional, and one individual with expertise in family literacy. Additional members may include one or more of the following: a representative of a parent-child education organization, a representative of a community-based literacy organization, a member of a local board of education, a representative of business and industry with a commitment to education, or an individual who has been involved in the implementation of the State’s Title I programs, which include Reading First and Early Reading First. (Section 1238(a)(3)) In order to ensure a fair and objective evaluation of applications, an SEA must follow State conflict-of-interest requirements or policies that it may have with respect to the review of subgrant applications.





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