Its OK for Moyer to fail but not DEDOE: Check out this USDOE report

Scope of Review: A team from the U.S. Department of Education’s (ED) Student Achievement and School Accountability Programs (SASA) office monitored the Delaware Department of Education (DEDOE) the week of December 14-18, 2009.  This was a comprehensive review of the DEDOE’s administration of the following programs authorized by the Elementary and Secondary Education Act of 1965 (ESEA), as amended: Title I, Part A; and Title I, Part D.  Also reviewed was Title VII-B of the McKinney-Vento Homeless Assistance Act (also known as the McKinney-Vento Homeless Education Assistance Improvements Act of 2001). 

Monitoring Area 1, Title I, Part A: Standards, Assessments and Accountability

Accountability Workbook 

Finding:    The DEDOE did not ensure that its decision-appeal procedures and its method for calculating participation rates in the State assessment system complied with the State’s approved Accountability Workbook procedures.  The procedures used in adequate yearly progress (AYP) determinations did not require the inclusion of all students in the accountability decisions. permission for the students’ scores to be removed and excluded from AYP determinations.

In one LEA, the superintendent requested a change in AYP determinations for schools with students that were absent for ten or more days during the year.  Students (who were identified) in five schools that did not meet AYP were enrolled for a full academic year (FAY) and took the Delaware Student Testing Program (DSTP).  The DEDOE granted.

Further action required:  The DEDOE must provide ED with the names of all schools that were granted permission to remove scores of students that were absent for ten or more days but met the FAY requirement.

The DEDOE must provide ED with the names of all schools that met AYP based on the appeals process identified in the above paragraph and the schools’ current school improvement status.

SEA annual report card

Finding:  The DEDOE did not ensure that it included the required information on its report card.  The percentage of students not tested by subject, disaggregated by subgroup, was not included in the public website for the SEA and LEA profiles but was included in the school profile on the SEA website.  The number of recently arrived limited English proficient (LEP) students who are not assessed on the State’s reading /language arts assessment were not included on the SEA, LEA, or school profile.

The State data from the National Association of Educational Progress (NAEP) is on the State profile on the website, but not on the LEA or school profile.

Citation:  Section 1111(h)(1)(c)(i) of the ESEA requires the SEA to include the number of recently arrived LEP students who are not assessed on the State’s reading/language arts assessment.  

Further action required: The DEDOE must submit disaggregated participation rates, and the number of recently arrived LEP students not assessed on the reading/language arts LEA and school report cards to ED.   The DEDOE must ensure that State NAEP data are reflected on the LEA and school report card.

LEA annual report cards

FindingThe DEDOE did not ensure that its LEA report cards have the required elements.  Data regarding the percentage of students not tested by subject, disaggregated by subgroup, were not included in the public website for the SEA and LEA profiles but were included in the school profile on the SEA website.  The number of recently arrived LEP students who are not assessed on the State’s reading/language arts test were not included on the SEA, LEA, or school profile.  The State data from the NAEP are on the State profile on the website, but not on the LEA or school profile.

Further action required:   The DEDOE must submit disaggregated participation rates by subject; LEP reading/language arts assessment data for LEA and school report cards; and State NAEP data on the LEA and school report cards to ED. 

Monitoring Area 2, Title I, Part A: Instructional Support

Finding:  The DEDOE has not fully ensured that all instructional paraprofessionals in all Title I schools are highly qualified. The DEDOE does not have a process in place to annually collect, review and verify information from all its LEAs to determine if all instructional paraprofessionals in Title I schools meet the hiring requirements. 

Citation:  Section 1119(c)(1) of the ESEA requires that new paraprofessionals hired after the date of enactment of the No Child Left Behind (NCLB) and working in a program supported with Title I funds shall have:  a) completed at least 2 years of study at an institution of higher education; b) obtained an associate’s (or higher) degree; c) met a rigorous standard of quality and can demonstrate, through a formal State or local academic assessment, knowledge of, and the ability to assist in instructing, reading, writing and mathematics; or d) knowledge of and the ability to assist in instructing, reading readiness, writing readiness, and mathematics readiness as appropriate.  Section 1119(d) of the ESEA requires that all paraprofessionals hired before the date of enactment of the NCLB and working in a program supported with Title I funds shall, not later than four years after the date of enactment, satisfy the requirements of subsection (c) listed above.  Through a policy announcement from the Deputy Secretary, ED informed States that they would have until the last day of the 2005-2006 school year to comply with these requirements.

Further action required:  The DEDOE must submit a written explanation, including timelines, that details how the DEDOE has addressed (or will address) the following actions in a manner that ensures the LEAs are annually hiring and retaining qualified instructional paraprofessionals (ED noted a similar finding during its previous Title I monitoring visit in September 2008):

  1. Review the status of instructional paraprofessionals in all LEAs that are working in programs supported by Title I funds during SY 2009-2010 and report to ED the total number of paraprofessionals who were required to meet the qualification requirements but did not do so; 

  2. Establish a process and timeline to collect annually from all LEAs at the beginning of each school year evidence that all paraprofessionals are highly qualified; and

  3. Define specific corrective actions, with timelines, that the DEDOE will take to ensure full compliance in cases where actions taken by LEAs do not meet statutory requirements.  

The DEDOE must take these additional actions to ensure that all instructional paraprofessionals in Title I schools meet qualification requirements prior to the beginning of the 2010-2011 school year, and in subsequent years.

Schoolwide Programs

Finding:  The DEDOE has not ensured that its Title I schoolwide schools develop a plan based on the requirements for a schoolwide program.  The DEDOE has implemented the Education Success Planning and Evaluation System web-based tool that LEAs and schools use to prepare improvement plans that align State and Federal programs and funding into a single, comprehensive plan.  Title I schools are required to use this tool to complete a single Success Plan that addresses the requirements for schoolwide programs, school improvement, and school improvement grants.  The ED team noted a lack of specificity in the school plans, and it was unable to determine what specific actions were being taken or how the strategies included in the plans related to the objectives.  As a result, it was not clear how the plans were used to guide and govern changes in teaching and learning to improve student achievement or how the schoolwide program could be annually evaluated as required to determine its effectiveness in increasing student achievement and making changes as necessary based on the results of the evaluation. This finding was also identified by the ED team during the September 2008 monitoring visit. 

Further action required:  The DEDOE must provide ED with a written explanation, including timelines, that details how the SEA has addressed, or will address, each of the actions noted to resolve this finding in a manner that ensures the LEAs and schools are implementing Success Plans that address the required components of schoolwide programs and schools in improvement. 

Because ED noted a similar finding during its previous Title I monitoring visit in September 2008, the DEDOE must take the following additional actions to ensure that the goals, strategies, and activities described in the school Success Plans, including any supporting documentation, adequately address the individual needs of each school and also meet State and Federal requirements:

Revise, as appropriate, DEDOE’s written guidance for the Education Success Planning and Evaluation System web-based tool to include (a) information specific to the requirements for schoolwide programs and schools in improvement and (b) examples or samples of strategies that are aligned with program goals and objectives for both schoolwide programs and schools in improvement. 

  1. Revise, as appropriate, DEDOE’s Success Planning review instrument and process to ensure that the school plans address the Title I schoowide program and school improvement requirements and that the review examines the quality of plans to determine that the goals and strategies directly address the academic achievement problems of the school and are of the nature to effectively meet the student progress goals described in the plans. 

  2. Provide technical assistance to LEA and SEA staff to improve the Success Plan review process as one method to improve the quality of plans and the alignment of program goals and strategies related to schoolwide programs, school improvement requirements, and school improvement grants.  This technical assistance must be designed to help LEAs document that a peer review process has taken place and necessary adjustments have been made to the school Success Plan as a result of the peer review prior to submitting the plan to the DEDOE. 

Recommendation:  The ED team recommends that the DEDOE provide additional guidance and technical assistance regarding the purpose, nature, and requirements involved in implementing a schoolwide program to its LEAs.  Based on the interviews with principals in schoolwide program schools, it appears that principals, especially new principals, may not be clear about the purpose of a schoolwide program or how schoolwide programs contribute to and intersect with their school improvement efforts.  The ED team encourages the DEDOE to provide additional technical assistance and support to staff in schoolwide program schools to ensure that principals and staff in these schools are fully aware of the requirements of schoolwide programs.  Additionally, the DEDOE should consider working with the Mid-Atlantic Comprehensive Center to develop training materials on schoolwide program requirements for use by DEDOE Title I staff and members of the State technical assistance teams. 

Because ED noted a similar finding during its previous Title I monitoring visit in September 2008, the DEDOE must take the following additional actions to ensure that the goals, strategies, and activities described in the school Success Plans, including any supporting documentation, adequately address the individual needs of each school and also meet State and Federal requirements:

 

1.      Revise, as appropriate, DEDOE’s written guidance for the Education Success Planning and Evaluation System web-based tool to include (a) information specific to the requirements for schoolwide programs and schools in improvement and (b) examples or samples of strategies that are aligned with program goals and objectives for both schoolwide programs and schools in improvement. 

2.      Revise, as appropriate, DEDOE’s Success Planning review instrument and process to ensure that the school plans address the Title I schoowide program and school improvement requirements and that the review examines the quality of plans to determine that the goals and strategies directly address the academic achievement problems of the school and are of the nature to effectively meet the student progress goals described in the plans. 

3.     Provide technical assistance to LEA and SEA staff to improve the Success Plan review process as one method to improve the quality of plans and the alignment of program goals and strategies related to schoolwide programs, school improvement requirements, and school improvement grants.  This technical assistance must be designed to help LEAs document that a peer review process has taken place and necessary adjustments have been made to the school Success Plan as a result of the peer review prior to submitting the plan to the DEDOE.   

 

 

RecommendationThe ED team recommends that the DEDOE provide additional guidance and technical assistance regarding the purpose, nature, and requirements involved in implementing a schoolwide program to its LEAs.  Based on the interviews with principals in schoolwide program schools, it appears that principals, especially new principals, may not be clear about the purpose of a schoolwide program or how schoolwide programs contribute to and intersect with their school improvement efforts.  The ED team encourages the DEDOE to provide additional technical assistance and support to staff in schoolwide program schools to ensure that principals and staff in these schools are fully aware of the requirements of schoolwide programs.  Additionally, the DEDOE should consider working with the Mid-Atlantic Comprehensive Center to develop training materials on schoolwide program requirements for use by DEDOE Title I staff and members of the State technical assistance teams. 

 

 

Within District Allocation Procedures.

 Finding (1)The DEDOE did not ensure that its LEAs follow the statutory requirements for “skipping” (or not serving) a school that has a poverty percentage of 75% and above.  In RCCSD, AIMS Middle school had a poverty percentage of 77% and the school was skipped with permission granted “over the phone” (from a DEDOE representative).  RCCSD staff did not provide any documentation or justification to “skip” this school as required by the ESEA

Further Action Required: The DEDOE must provide ED with documentation showing that LEA officials in RCCSD have submitted adequate justification for not serving schools in rank order or not serving schools with poverty percentages of 75% and above. 

Finding (2)The DEDOE did not ensure that its LEAs correctly calculate the Title I, Part A funds used in central reservations to provide the equitable share for services to private school children.  RCCSD did not calculate an equitable share of funds for services to private school children from the funds supporting the summer school program and two professional development central reservations.  This finding was also an issue during the September 2008 monitoring visit. 

Citation: Section 200.64(a)(2)(i) of the Title I regulations requires LEAs to calculate the equitable share of Title I funds reserved for instructional activities for public elementary and secondary school students at the district level.  The amount of funds available to provide equitable services must be proportionate to the number of private school children from low-income families residing in participating public school attendance areas. 

Further Action RequiredThe DEDOE must provide ED with evidence that RCCSD officials have correctly calculated the equitable amount of funds, including Title I, Part A funds, supporting the central reservations it made for district-wide instructional related activities for public elementary or secondary school students.  The DEDOE must ensure that RCCSD and all other LEAs serving private school children calculate the equitable amount of funds from central reservations that they reserve for district-wide instructional activities not related to program improvement.   The DEDOE must provide ED with evidence that it has informed its LEAs serving private school children of this requirement to provide an equitable share of funds reserved under section 200.77 of the Title I regulations for instructional and related activities for services to eligible private school students and that its LEAs are aware of the legal definition of “improvement” vs. the general strategies that Title I funds support to “improve” student achievement

Fiscal Requirements: Maintenance of Effort, Comparability, Supplement not Supplant, and Internal Controls

Finding:   The DEDOE did not ensure that its LEAs used their Title I funds in an allowable manner to pay for the single A-133 audits.  During a review of the CSD and RCCSD LEA plans and interviews with LEA staff, ED discovered that the LEAs were using Title I, Part A funds to pay for the single A-133 audits (required) for several Federal programs rather than Title I funds being used to pay for its proportionate share of the audit. 

Finding (2) The DEDOE did not ensure that its LEAs correctly calculate the Title I, Part A funds used in central reservations to provide the equitable share for services to private school children.  RCCSD did not calculate an equitable share of funds for services to private school children from the funds supporting the summer school program and two professional development central reservations.  This finding was also an issue during the September 2008 monitoring visit. 

 

Citation: Section 200.64(a)(2)(i) of the Title I regulations requires LEAs to calculate the equitable share of Title I funds reserved for instructional activities for public elementary and secondary school students at the district level.  The amount of funds available to provide equitable services must be proportionate to the number of private school children from low-income families residing in participating public school attendance areas. 

 

Further Action RequiredThe DEDOE must provide ED with evidence that RCCSD officials have correctly calculated the equitable amount of funds, including Title I, Part A funds, supporting the central reservations it made for district-wide instructional related activities for public elementary or secondary school students.  The DEDOE must ensure that RCCSD and all other LEAs serving private school children calculate the equitable amount of funds from central reservations that they reserve for district-wide instructional activities not related to program improvement.   The DEDOE must provide ED with evidence that it has informed its LEAs serving private school children of this requirement to provide an equitable share of funds reserved under section 200.77 of the Title I regulations for instructional and related activities for services to eligible private school students and that its LEAs are aware of the legal definition of “improvement” vs. the general strategies that Title I funds support to “improve” student achievement

Services to Eligible Private School Children.  Finding:  The DEDOE did not ensure that its LEAs provided oversight of the Title I program to eligible private school children attending private schools.  During the onsite review, ED observed the DEDOE making progress towards full compliance in this area (since this issue was a major issue during the 2008 visit); however, the oversight of the program had not been fully implemented at the time of the monitoring visit.  ED was working with the DEDOE to help with the oversight of the third party contractors in delivering the program, LEA oversight of the program, and evaluation of the program

Further action required:  The DEDOE must require all its LEAs serving private school children to maintain control of the Title I program including materials, equipment, and property purchased with Title I funds.  The DEDOE must provide ED with evidence that it has implemented its plan to oversee the Title I program in the private schools in CSD, RCCSD and all LEAs serving private school students. 

Education Department General Administrative Regulations (EDGAR) requires that a control system be developed by recipients of Federal funds to ensure that there are adequate safeguards to prevent loss, damage, or theft of the property.  Section 200.66 of the Title I regulations requires that all materials and equipment purchased with Title I funds must only be used to meet the educational needs of participating private school children.Further action required:  The DEDOE must require all its LEAs serving private school children to maintain control of the Title I program including materials, equipment, and property purchased with Title I funds.  The DEDOE must provide ED with evidence that it has implemented its plan to oversee the Title I program in the private schools in CSD, RCCSD and all LEAs serving private school students.

3 responses to “Its OK for Moyer to fail but not DEDOE: Check out this USDOE report

  1. nativebluehen

    What an embarrasment.
    Yet DOE Dan will stay put until he jumps ship to Red Clay.

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    • kilroysdelaware

      Come 2012 there will be a major house cleaning. Governor Lavelle will let me hand deliver the pink slips

      Like

  2. This is disgusting. UNREAL.

    Like