Honorable. Linda McCulloch

Superintendent of Public Instruction

Montana Office of Public Instruction

1227 11th Avenue

Helena, Montana 59620-2501

Dear Superintendent McCulloch:

During the week of May 24-27, 2004, a team from the U.S. Department of
Education's (ED) Student Achievement and School Accountability (SASA)
Programs reviewed the Montana Office of Public Instruction's (OPI)
administration of the Title I, Part A and Part B programs under the
authority of the Elementary and Secondary Education Act of 1965 (ESEA),
as amended by the No Child Left Behind Act of 2001 (NCLB). Enclosed is a
report based upon that review.

The reauthorization of ESEA under NCLB brought a major shift in emphasis
and priorities for education in this country. With increased emphasis on
accountability for [all]{.underline} students, and a focus on States'
responsibilities to work with districts and schools to improve
instruction and boost student achievement, SASA is committed to working
closely with States to define those responsibilities. SASA has developed
a monitoring process that is aligned to these changes brought about by
NCLB. Monitoring for the

Title I, Part A and Part B, Subpart 3 (Even Start) programs is conducted
in three broad areas -- accountability, instructional support and
compliance with fiduciary responsibilities. Prior to and during the
onsite monitoring review, the ED team conducted a number of activities
(described in detail in the enclosed report) to verify compliance with
critical monitoring indicators in each of the three broad areas for both
programs.

The enclosed report contains a listing of the critical monitoring
elements in each of the areas, a description of the scope of the
monitoring review, and the findings, recommendations and commendations
that the ED team cited as a result of the review. Within thirty days of
the date of this letter, please provide us with a detailed description
of the actions your office has taken or will take regarding any findings
noted in this report.

The ED team would like to thank BJ Granberry and her staff for their
hard work and the assistance they provided prior to and during the
review in gathering materials and providing access to information in a
timely manner. The ED team was impressed with

Page 2 -- Honorable Linda McCulloch

the efforts of your State's staff to implement the many requirements of
Part A and Part B of Title I of the ESEA.

We look forward to working further with your staff members on any follow
up activities in Montana.

Sincerely,

Jacquelyn C. Jackson, Ed.D.

Director

Student Achievement and

> School Accountability Programs

Enclosure

cc: BJ Granberry

Montana Office of Public Instruction (OPI)

**May 24 -- 27, 2004**

**Scope of Review:** The Student Achievement and School Accountability
Programs (SASA) from the U.S. Department of Education (ED) monitored the
OPI the week of May 24 -- 27, 2004. This was a comprehensive review of
the OPI's administration of Title I, Part A and Part B funds, as
required by the Elementary and Secondary Education Act of 1965 (ESEA),
as amended by the No Child Left Behind Act (NCLB).

In conducting this comprehensive review, the ED team carried out a
number of major activities. In reviewing the Part A program, the ED team
conducted an analysis of State assessments and State Accountability
System Plans, reviewed the effectiveness of the instructional
improvement and instructional support measures established by the State
to benefit local educational agencies (LEAs) and schools, and reviewed
compliance with fiscal and administrative oversight requirements
required of the State educational agency (SEA). During the onsite week,
the ED team visited two LEAs -- Billings School District (BSD) and
Helena School District (HSD), interviewed administrative staff, visited
four schools in the LEAs (one of which had been identified for
improvement and one private school) and conducted a district parent
meeting and a district teacher meeting in HSD. The ED team then
interviewed OPI personnel to obtain State-level information for each of
the three monitoring indicator areas. The ED team conducted conference
calls to three additional LEAs (Great Falls, Browning and Harlem School
Districts) upon its return to Washington, DC to confirm information
gathered onsite in the LEAs and in the OPI.

In reviewing Part B of Title I (Even Start), the ED team examined the
State request for proposals, State Even Start guidance, State indicators
of program quality, and the most recent applications, local evaluations,
and expenditure reports from the Even Start programs in Missoula and
Butte. During the onsite review, the ED team visited these two local
Even Start programs and interviewed administrative and instructional
staff. Finally, the team interviewed the OPI's Even Start State
coordinator to confirm data collected at the two local sites and to
discuss State administration issues.

**Previous Audit Findings:** None to report.

**Previous Monitoring Findings:** ED last reviewed Title I, Part A
programs under ESEA in Montana in November of 1997 as part of a Federal
integrated review initiative. The OPI subsequently addressed all issues
raised in that review. ED has not previously conducted a comprehensive
review of the Even Start program in Montana.

Title I Part A

Summary of Monitoring Indicators

+---------+--------------------------------+-------------------+------+
| # Monit |                                |                   |      |
| oring A |                                |                   |      |
| rea 1:  |                                |                   |      |
| Account |                                |                   |      |
| ability |                                |                   |      |
+---------+--------------------------------+-------------------+------+
| **      | **Description**                | # Status          | #    |
| Element |                                |                   | Page |
| N       |                                |                   |      |
| umber** |                                |                   |      |
+---------+--------------------------------+-------------------+------+
| C       | The SEA has approved academic  | Met requirements  | N/A  |
| ritical | content standards for all      |                   |      |
| element | required subjects or an        |                   |      |
| 1.1     | approved timeline for          |                   |      |
|         | developing them.               |                   |      |
+---------+--------------------------------+-------------------+------+
| C       | The SEA has approved academic  | Met requirements  | N/A  |
| ritical | achievement standards and      |                   |      |
| element | alternate academic achievement |                   |      |
| 1.2     | standards in required subject  |                   |      |
|         | areas and grades or an         |                   |      |
|         | approved timeline to create    |                   |      |
|         | them.                          |                   |      |
+---------+--------------------------------+-------------------+------+
| C       | The SEA has approved           | Met requirements  | N/A  |
| ritical | assessments and alternate      |                   |      |
| element | assessments in required        |                   |      |
| 1.3     | subject areas and grades or an |                   |      |
|         | approved timeline to create    |                   |      |
|         | them.                          |                   |      |
+---------+--------------------------------+-------------------+------+
| C       | The SEA has implemented all    | > Recommendation  | > 5  |
| ritical | required components as         |                   |      |
| element | identified in its              |                   |      |
| 1.4     | accountability workbook. N.B.  |                   |      |
|         | Report card requirements are   |                   |      |
|         | addressed separately (1.5)     |                   |      |
+---------+--------------------------------+-------------------+------+
| C       | The SEA has published its      | > Met             | > 6  |
| ritical | annual report card and ensured | > requirements    |      |
| element | that LEAs have published       |                   |      |
| 1.5     | annual report cards as         |                   |      |
|         | required.                      |                   |      |
+---------+--------------------------------+-------------------+------+
| C       | SEA indicates how funds        | Met requirements  | N/A  |
| ritical | received under Grants for      |                   |      |
| element | State Assessments and related  |                   |      |
| 1.6     | activities (§6111) will be or  |                   |      |
|         | have been used to meet the     |                   |      |
|         | 2005-06 and 2007-08 assessment |                   |      |
|         | requirements of NCLB.          |                   |      |
+---------+--------------------------------+-------------------+------+
| C       | SEA ensures that LEAs meet all | Met requirements  | N/A  |
| ritical | requirements for identifying   |                   |      |
| element | and assessing the academic     |                   |      |
| 1.7     | achievement of limited English |                   |      |
|         | proficient students.           |                   |      |
+---------+--------------------------------+-------------------+------+

+---------+---------------------------------+------------------+------+
| # Monit |                                 |                  |      |
| oring A |                                 |                  |      |
| rea 2:  |                                 |                  |      |
| Instruc |                                 |                  |      |
| tional  |                                 |                  |      |
| Support |                                 |                  |      |
+---------+---------------------------------+------------------+------+
| **      | # Description                   | ### Status       | ##   |
| Element |                                 |                  | Page |
| N       |                                 |                  |      |
| umber** |                                 |                  |      |
+---------+---------------------------------+------------------+------+
| C       | The SEA designs and implements  | Met requirements | N/A  |
| ritical | policies and procedures that    |                  |      |
| element | ensure the hiring and retention |                  |      |
| 2.1     | of highly qualified staff.      |                  |      |
+---------+---------------------------------+------------------+------+
| C       | The SEA provides, or provides   | Commendation     | 6    |
| ritical | for, technical assistance for   |                  |      |
| element | LEAs and schools as required.   | Recommendation   |      |
| 2.2     |                                 |                  |      |
+---------+---------------------------------+------------------+------+
| C       | The SEA establishes a Committee | Met Requirements | N/A  |
| ritical | of Practitioners (COP) and      |                  |      |
| element | involves the committee in       |                  |      |
| 2.3     | decision making as required.    |                  |      |
+---------+---------------------------------+------------------+------+
| C       | The SEA ensures that the LEA    | Finding          | 6    |
| ritical | and schools meet parental       |                  |      |
| element | involvement requirements.       | Recommendations  |      |
| 2.4     |                                 |                  |      |
+---------+---------------------------------+------------------+------+
| C       | The SEA ensures that schools    | Recommendations  | 8    |
| ritical | and LEAs are identified for     |                  |      |
| element | improvement, corrective action, |                  |      |
| 2.5     | or restructuring as required    |                  |      |
|         | and that subsequent, required   |                  |      |
|         | steps are taken.                |                  |      |
+---------+---------------------------------+------------------+------+
| C       | The SEA ensures that            | > Met            | N/A  |
| ritical | requirements for public school  | > Requirements   |      |
| element | choice are met.                 |                  |      |
| 2.6     |                                 |                  |      |
+---------+---------------------------------+------------------+------+
| C       | The SEA ensures that the        | > Recommendation | 8    |
| ritical | statutory requirements for the  |                  |      |
| element | provision of supplemental       |                  |      |
| 2.7     | educational services (SES) are  |                  |      |
|         | met.                            |                  |      |
+---------+---------------------------------+------------------+------+
| C       | The SEA ensures that LEAs and   | Recommendation   | 8    |
| ritical | schools develop schoolwide      |                  |      |
| element | programs that use the           |                  |      |
| 2.8     | flexibility provided to them by |                  |      |
|         | law to improve the academic     |                  |      |
|         | achievement of all students in  |                  |      |
|         | the school.                     |                  |      |
+---------+---------------------------------+------------------+------+
| C       | The SEA ensures that LEAs and   | Met requirements | N/A  |
| ritical | schools develop and maintain    |                  |      |
| element | targeted assistance programs    |                  |      |
| 2.9     | that meet all required          |                  |      |
|         | components.                     |                  |      |
+---------+---------------------------------+------------------+------+

+---------+---------------------------------+------------------+------+
| #       |                                 |                  |      |
| Monitor |                                 |                  |      |
| ing Are |                                 |                  |      |
| a 3: SE |                                 |                  |      |
| A Fiduc |                                 |                  |      |
| iary re |                                 |                  |      |
| sponsib |                                 |                  |      |
| ilities |                                 |                  |      |
+---------+---------------------------------+------------------+------+
| **      | # Description                   | ### Status       | ##   |
| Element |                                 |                  | Page |
| N       |                                 |                  |      |
| umber** |                                 |                  |      |
+---------+---------------------------------+------------------+------+
| C       | The SEA ensures that its        | Met requirements | 9    |
| ritical | component LEAs are audited      |                  |      |
| element | annually, if required, and that | Commendation     |      |
| 3.1     | all corrective actions required |                  |      |
|         | through this process are fully  |                  |      |
|         | implemented.                    |                  |      |
+---------+---------------------------------+------------------+------+
| C       | The SEA complies with the       | Met requirements | N/A  |
| ritical | allocation, reallocation, and   |                  |      |
| element | carryover provisions of         |                  |      |
| 3.2     |                                 |                  |      |
|         | Title I.                        |                  |      |
+---------+---------------------------------+------------------+------+
| C       | The SEA complies with the       | Met requirements | N/A  |
| ritical | maintenance of effort           |                  |      |
| element | provisions of Title I.          |                  |      |
| 3.3     |                                 |                  |      |
+---------+---------------------------------+------------------+------+
| C       | The SEA ensures that the LEA    | Finding          | 9    |
| ritical | complies with the comparability |                  |      |
| element | provisions of Title I.          |                  |      |
| 3.4     |                                 |                  |      |
+---------+---------------------------------+------------------+------+
| C       | The SEA ensures that LEAs       | Finding          | 9    |
| ritical | provide Title I services to     |                  |      |
| element | eligible children attending     |                  |      |
| 3.5     | private schools.                |                  |      |
+---------+---------------------------------+------------------+------+
| C       | The SEA has a system for        | Met requirements | N/A  |
| ritical | ensuring and maximizing the     |                  |      |
| element | quality, objectivity, utility,  |                  |      |
| 3.6     | and integrity of information    |                  |      |
|         | disseminated by the agency.     |                  |      |
+---------+---------------------------------+------------------+------+
| C       | The SEA has an accounting       | Met requirements | N/A  |
| ritical | system for administrative funds |                  |      |
| element | that includes (1) State         |                  |      |
| 3.7     | administration, (2)             |                  |      |
|         | reallocation, and (3)           |                  |      |
|         | reservation of funds for school |                  |      |
|         | improvement.                    |                  |      |
+---------+---------------------------------+------------------+------+
| C       | The SEA has a system for        | Met requirements | N/A  |
| ritical | ensuring fair and prompt        |                  |      |
| element | resolution of complaints.       |                  |      |
| 3.8     |                                 |                  |      |
+---------+---------------------------------+------------------+------+
| C       | The SEA ensures that the LEA    | Met requirements | N/A  |
| ritical | complies with the rank order    |                  |      |
| element | procedures for the eligible     |                  |      |
| 3.9     | school attendance area.         |                  |      |
+---------+---------------------------------+------------------+------+
| C       | The SEA conducts monitoring of  | Met requirements | 10   |
| ritical | its subgrantees sufficient to   |                  |      |
| element | ensure compliance with Title I  | Recommendation   |      |
| 3.10    | program requirements.           |                  |      |
+---------+---------------------------------+------------------+------+
| C       | The LEA complies with the       | Met requirements | N/A  |
| ritical | provision for submitting an     |                  |      |
| element | annual plan to the SEA.         |                  |      |
| 3.11    |                                 |                  |      |
+---------+---------------------------------+------------------+------+
| C       | The SEA and LEA comply with     | Met requirements | N/A  |
| ritical | requirements regarding the      |                  |      |
| element | reservation of administrative   |                  |      |
| 3.12    | funds.                          |                  |      |
+---------+---------------------------------+------------------+------+
| C       | The SEA ensures that Title I    | Met requirements | N/A  |
| ritical | funds are used only to          |                  |      |
| element | supplement or increase          |                  |      |
| 3.13    | non-Federal sources used for    |                  |      |
|         | the education of participating  |                  |      |
|         | children and not to supplant    |                  |      |
|         | funds from non-Federal sources. |                  |      |
+---------+---------------------------------+------------------+------+

#### Area: Accountability[^1]

## Indicator 1.4: The SEA has implemented all required components as identified in its accountability workbook

**[Finding:]{.underline}** The OPI did not make timely adequate yearly
progress (AYP) determinations. Since the OPI is required to apply a more
labor intensive and time consuming process for small school
accountability (as more than half the schools in Montana have an
enrollment of less than 100 students) ED has allowed some flexibility in
the timeliness with which assessment results are provided to districts
and schools for the 2003-04 school year. The OPI has notified ED of
impending delays, specifically that it will not be able to make final
AYP determinations until January of 2005.

[Citation:]{.underline} 20 U.S.C 6316 §1116(a)(2) requires that
assessment results be provided to LEAs prior to the beginning of the
school year. The OPI must also allow enough time for schools and LEAs to
appeal AYP determinations and to notify parents of public school choice
and supplemental educational services options.

[Further Action Required:]{.underline} The OPI must make every effort to
provide assessment data, finalize the appeals process, and allow parents
reasonable time to decide on public school choice and supplemental
educational services options. The OPI might consider implementing an
earlier testing window, accelerating the reviews for small schools,
improving quality control procedures, and/or streamlining the appeals
process as possible actions to improve the timeliness of AYP
determination.

ED understands that because of the standards setting process for the new
assessments, a delay is anticipated for the 2004-05 school year. A
correct and timely process is expected for the 2005-06 school year.

**[Recommendation]{.underline}**: The OPI's process for schools and LEAs
to appeal AYP determinations revealed that quality control issues were
the cause for many appeals. ED recommends that the OPI carefully review
the assessment contractor's report on quality control issues encountered
in 2003-04 and develop procedures to correct the most common lapses.
LEAs should be informed and trained on implementing the procedures.

## Indicator 1.5: The SEA has published its annual report card and ensured that LEAs have published annual report cards as required.

[Recommendation:]{.underline} The ED team recommends that the OPI inform
LEAs of the required elements of the school and district report card.
The LEAs visited by the ED team issued a local community annual report
that included some of the required elements under NCLB. The OPI provides
all the required data through their website for both district and school
levels. The ED team recommends that the OPI advise LEAs that the extant
data on the website may be included in their community reports. The
community report can then serve as the district/school report card,
which would allow greater access to the general public, particularly to
households without Internet access. These reports should also be
translated to native/home languages where practicable.

**Area: Instructional Support**

**Indicator 2.2: The SEA provides technical assistance to LEAs and
schools as required.**

**[Commendation]{.underline}**: The ED team commends the OPI for its
team approach to providing technical assistance to LEAs; specifically,
the practice of assigning staff as single points of contact for LEAs,
which supports delivery of technical assistance.

**[Recommendation]{.underline}**: The ED team recommends that, due to
the geographical diversity and breadth of the State, the OPI make
greater use of technology through its website, and populate the Title I
section with multiple examples or templates for LEAs to use in
implementing and overseeing school programs. Additionally, the OPI may
wish to share information with its LEAs from the ED's Title I listserve,
including information offered through web-casts and audio-telecasts.

**Indicator 2.4: The SEA ensures that the LEA and schools meet parental
involvement requirements.**

**[Finding:]{.underline}** School plans reviewed by the ED team did not
address some of the parent involvement requirements, including
supporting parents' capacity to be involved in schools as meaningful
partners or stakeholders. The following required elements were missing
in one or more of the school plans reviewed by the ED team:

-   Evidence that the LEA/school involves parents in the joint
    development, review and revision of district or school plans,
    including parent involvement plans.

-   Evidence that the LEA conducts with the involvement of parents an
    annual evaluation of the parent involvement policy;

-   Evidence that the LEA involves parents in decisions on use of funds
    reserved for parent involvement activities;

-   Evidence that the school, as part of the school-level parent
    involvement policy, ensures parents read and acknowledge the
    components of the school-parent compact;

-   Evidence that the SEA reviews LEA parent involvement policies and
    practices to determine if requirements have been met.

LEAs were notified by the OPI that each LEA is required to jointly
develop a parent involvement policy to be incorporated as a part of the
LEA Consolidated Subgrant application. Materials distributed at the
OPI's Title I Directors/Coordinators Meeting in March 2004 and posted on
the OPI's website reference the parent involvement policy requirements.
These references include activities and procedures that involve parents
in meaningful consultation for planning and implementation, including
requirements for School-Parent Compacts. The documents list all of the
Title I statutory requirements; however, it appears that this written
guidance has not resulted in the collaborative development of parent
involvement policies that meet all of the statutory requirements.

[Citation]{.underline}: 20 U.S.C. 6316 §1116(a)(1)(D) states that LEAs
shall review the effectiveness of the actions of schools with respect to
parent involvement. 20 U.S.C. 6318 §1118 states that LEAs must implement
programs, activities and procedures for the involvement of parents
including, but not limited to:

-   Involving parents in the joint development of the plan under §1112,
    and the process of school review and improvement under §1116;

-   Conducting, with the involvement of parents, an annual evaluation of
    the content and effectiveness of the parental involvement policy in
    improving the academic quality of the schools;

-   Involving parents of children receiving services under Title I, Part
    A in the decisions regarding how funds are allotted for parental
    involvement activities;

-   Requiring each school served under this part to jointly develop
    with, and distribute to, parents of participating children a written
    parental involvement policy, agreed on by such parents;

-   Involving parents, in an organized, ongoing, and timely way, in the
    planning, review, and improvement of Title I programs, including the
    planning, review, and improvement of the school parental involvement
    policy and the joint development of the schoolwide program plan;

[Further action required]{.underline}: The OPI must review LEA and local
school parent involvement policies to ensure that parents are involved
as meaningful partners in providing input for the development and
implementation of district and school planning activities as well as
parent involvement policies, as identified in §1116 and §1118. Further,
the OPI must review the guidance it provides to LEAs and schools
regarding parent involvement to determine if further refinement or
clarification is needed. The ED team requests a copy of the revised
documents from both BSD and HSD.

[**Recommendation**:]{.underline} The ED team recommends that the OPI
clarify for LEAs and schools that the primary purpose of parental
involvement is to improve student academic achievement and school
performance. It is the obligation of the LEA and each school to ensure
the effective involvement of parents by building their capacity for
involvement (20 U.S.C. 6318 §1118(e)). Many parental involvement
activities detailed in LEA and school plans reviewed by the SASA team
did not address this crucial area of parental involvement.

**Indicator 2.5: The SEA ensures that schools and LEAs are identified
for improvement, corrective action, or restructuring as required and
that subsequent, required steps are taken.**

[**Recommendation**:]{.underline} The ED team recommends that the OPI
carefully review the five-year plans of LEAs and schools in improvement
status to assure that they contain all

Title I requirements for school improvement plans, including the
specific reasons why schools have been identified for improvement, and
the steps the schools are taking to address these issues. The purpose of
the five-year plans is to consolidate multiple school-reform planning
efforts. Several of the five-year plans reviewed by the ED team were
vague in identifying their schools as in need of improvement under Title
I, Part A.

[**Recommendation**:]{.underline} The OPI should ensure that parent
notification for all schools identified as in need of improvement
explicitly state the reasons why the school was identified and the
specific actions that the school and LEA are taking as a result of this
designation. The school in BSD in corrective action status sent notices
to parents that were unclear as to the reasons for offering choice and
supplemental educational services.

Indicator 2.7: The SEA ensures that the statutory requirements for the
provision of supplemental educational services (SES) are met.

**Recommendation:** The OPI should work with BSD to increase the pool of
available SES providers and is strongly encouraged to engage and assist
qualified schools and LEAs not in improvement status to become SES
providers in order to broaden the options for parents in choosing SES
providers. The ED team was informed that the school in BSD that had been
identified for corrective action has only one SES provider available to
work with eligible children. This provider is not accessible for a
majority of the eligible students and is therefore underutilized.

Indicator 2.8: The SEA ensures that LEAs and schools develop schoolwide
programs that use the flexibility provided to them by law to improve the
academic achievement of all students in the school.

**Recommendation:** The ED team was informed that the five-year school
planning process has consolidated other reform planning efforts,
including schoolwide planning. The OPI should closely monitor LEAs to
ensure that five-year school plans include all of the ten required
elements in the schoolwide planning process. The ED team reviewed the
five-year plans for the schools visited in HSD and BSD, and found
several of the ten required schoolwide planning components located in
documents that were ancillary to the five-year plans. These components
should all be included in one 'core' document. In order to demonstrate
positive practices and outcomes, it is important for schools that have
chosen to become schoolwide programs to maintain the integrity and
philosophy behind schoolwide planning and implementation.

Area: Fiduciary Responsibilities

# Indicator 3.1: The SEA ensures that its component LEAs are audited annually, if required, and that all corrective actions required through this process are fully implemented.

[Commendation]{.underline}: The OPI has established a process for
annually tracking audit findings that ensures that all corrective
actions are developed as required. The OPI also follows up with each
district to verify that corrective actions have been implemented.

# Indicator 3.4: The SEA ensures that the LEA complies with the comparability provisions of Title I. 

[Finding]{.underline}: The ED team found in HSD that calculations to
determine comparability between Title I and non-Title I schools had not
been completed for the 2003-2004 school year.

[Citation]{.underline}: 20 U.S.C. 6321 §1120A(c), "Fiscal Requirements,"
states that an LEA may receive Title I funds only if State and local
funds will be used in schools served to provide services that, taken as
a whole, are at least comparable to services in schools that are not
receiving Title I funds.

[Further Action Required]{.underline}: The OPI must ensure that all LEAs
in the State conduct comparability calculations annually in order to
ensure that an eligible LEA receive Title I funds only if it can verify
that State and local funds are used in schools to ensure that its Title
I schools are comparable to non-Title I schools.

Indicator 3.5: The SEA ensures that LEAs provide Title I services to
eligible children attending private schools.

**[Finding]{.underline}**: The Title I director in BSD informed the ED
team that the Title I program

for eligible private school children in the LEA was implemented by a
teacher in the employ of the private school. BSD officials provide the
private school with instructional materials and supplies equal to the
amount generated by children from low-income families, and a teacher
employed by the private school provides direct services to the students.
BSD officials further explained that they consult with the private
school in the design of the program to be provided to eligible students;
however, BSD does not participate in the evaluation of the program, as
required.

[Citation]{.underline}: U.S.C. 6320 §1120(d)(2) requires the provider of
Title I services to eligible private school children to be an employee
of the LEA or an employee of a contractor hired by the LEA. The Title I
services must be provided by either an employee of the LEA or through a
contract by the LEA with an individual, association, agency or
organization. These employees, individuals, associations, agencies or
organizations must be independent of the private school and any
religious organization in the provision of those services, and such
employment or contract must be under the control or supervision of the
LEA.

[Further action required]{.underline}: The OPI must ensure that BSD and
all its LEAs design, after consultation with appropriate private school
officials, a Title I program that meets the needs of the private school
participants. LEAs may not delegate this responsibility to the private
schools or their officials. In addition, LEAs, in consultation with
private school officials, must determine what challenging content and
student achievement standards will apply and how the LEA will annually
assess the progress of the Title I program toward meeting the
agreed-upon standards.

Indicator 3.10: The SEA conducts monitoring of its subgrantees
sufficient to ensure compliance with Title I program requirements.

**[Recommendation]{.underline}**: The OPI has developed procedures for
conducting desk reviews of LEAs that are outlined in its *State and
Federal Grants Handbook*; however, it has no established process for
conducting onsite monitoring of LEAs. The ED team strongly recommends
that the OPI establish a mechanism for monitoring LEAs onsite, as
necessary. This process could supplement OPI's desk review procedures
used to determine 'risk,' as defined in Section 600-5 of the handbook.

Title I, Part B Monitoring

**Summary of Critical Monitoring Elements**

+--------------+---------------------------------+--------------+----+
| # Monitorin  |                                 |              |    |
| g Area 1: Ac |                                 |              |    |
| countability |                                 |              |    |
+--------------+---------------------------------+--------------+----+
| **Element    | **Description**                 | # Status     | #  |
| Number**     |                                 |              | Pa |
|              |                                 |              | ge |
+--------------+---------------------------------+--------------+----+
| Critical     | SEA complies with the subgrant  | Re           | 15 |
| element 1.1  | award requirements.             | commendation |    |
+--------------+---------------------------------+--------------+----+
| Critical     | The SEA requires applicants to  | Met          | >  |
| element 1.2  | submit applications for         | requirements |  N |
|              | subgrants with the necessary    |              | /A |
|              | documentation.                  |              |    |
+--------------+---------------------------------+--------------+----+
| Critical     | In making non-competitive       | Met          | >  |
| element 1.3  | continuation awards, the SEA    | requirements |  N |
|              | reviews the progress of each    |              | /A |
|              | subgrantee in meeting the       |              |    |
|              | objectives of the program and   |              |    |
|              | evaluates the program based on  |              |    |
|              | the indicators of program       |              |    |
|              | quality.                        |              |    |
+--------------+---------------------------------+--------------+----+
| Critical     | The SEA refuses to award        | Met          | >  |
| element 1.4  | subgrant funds to an eligible   | requirements |  N |
|              | entity if the agency finds that |              | /A |
|              | the entity has not sufficiently |              |    |
|              | improved the performance of the |              |    |
|              | program, as evaluated, based on |              |    |
|              | the indicators of program       |              |    |
|              | quality.                        |              |    |
+--------------+---------------------------------+--------------+----+
| Critical     | The SEA develops, based on the  | Met          | >  |
| element 1.5  | best available research and     | requirements |  N |
|              | evaluation data, indicators of  |              | /A |
|              | program quality for Even Start  |              |    |
|              | programs.                       |              |    |
+--------------+---------------------------------+--------------+----+
| Critical     | The SEA uses the Indicators of  | Met          | >  |
| element 1.6  | Program Quality to monitor,     | requirements | 15 |
|              | evaluate, and improve local     |              |    |
|              | programs within the State.      |              |    |
+--------------+---------------------------------+--------------+----+
| Critical     | The SEA conducts monitoring of  | Re           | >  |
| element 1.7  | its subgrantees sufficient to   | commendation | 15 |
|              | ensure compliance with Even     |              |    |
|              | Start program requirements.     |              |    |
+--------------+---------------------------------+--------------+----+
| Critical     | The SEA ensures that projects   | Met          | >  |
| element 1.8  | provide for an independent      | requirements |  N |
|              | local evaluation of the program |              | /A |
|              | that is used for program        |              |    |
|              | improvement.                    |              |    |
+--------------+---------------------------------+--------------+----+

+--------------+----------------------------------+------------+------+
| # Moni       |                                  |            |      |
| toring Area  |                                  |            |      |
| 2: Instructi |                                  |            |      |
| onal Support |                                  |            |      |
+--------------+----------------------------------+------------+------+
| **Element**  | # Description                    | ### Status | ##   |
|              |                                  |            |  Pg. |
+--------------+----------------------------------+------------+------+
| Critical     | The SEA uses funds to provide    | Reco       | 16   |
| element 2.1  | technical assistance to LEAs to  | mmendation |      |
|              | improve the quality of Even      |            |      |
|              | Start family literacy services   |            |      |
|              | or comply with State indicators  |            |      |
|              | of program quality.              |            |      |
+--------------+----------------------------------+------------+------+
| Critical     | Each program assisted shall      | Met        | N/A  |
| element 2.2  | include the identification and   | re         |      |
|              | recruitment of families most in  | quirements |      |
|              | need and serve those families.   |            |      |
+--------------+----------------------------------+------------+------+
| Critical     | Each program shall include       | Met        | N/A  |
| element 2.3  | screening and preparation of     | re         |      |
|              | parents and enable those parents | quirements |      |
|              | and children to participate      |            |      |
|              | fully in the activities and      |            |      |
|              | services provided.               |            |      |
+--------------+----------------------------------+------------+------+
| Critical     | SEA ensures that all families    | Met        | N/A  |
| element 2.4  | receiving services participate   | re         |      |
|              | in all four core instructional   | quirements |      |
|              | services.                        |            |      |
+--------------+----------------------------------+------------+------+
| Critical     | Each program shall be designed   | Met        | N/A  |
| element 2.5  | to accommodate the participants' | re         |      |
|              | work schedule and other          | quirements |      |
|              | responsibilities, including the  |            |      |
|              | provision of support services,   |            |      |
|              | when those services are          |            |      |
|              | unavailable from other sources.  |            |      |
+--------------+----------------------------------+------------+------+
| Critical     | Each program shall include       | Met        | N/A  |
| element 2.6  | high-quality, intensive          | re         |      |
|              | instructional programs that      | quirements |      |
|              | promote adult literacy and       |            |      |
|              | empower parents to support the   |            |      |
|              | educational growth of their      |            |      |
|              | children, and in preparation of  |            |      |
|              | children for success in regular  |            |      |
|              | school programs.                 |            |      |
+--------------+----------------------------------+------------+------+
| Critical     | Each instructional staff of the  | Met        | N/A  |
| element 2.7  | program hired after January 8,   | re         |      |
|              | 2002 of whose salary is paid in  | quirements |      |
|              | whole or in part with Even Start |            |      |
|              | funds, meets the Even Start      |            |      |
|              | staff qualifications.            |            |      |
+--------------+----------------------------------+------------+------+
| Critical     | **By December 21, 2004,** a      | Met        | N/A  |
| element 2.8  | majority of the individuals      | re         |      |
|              | providing academic instruction   | quirements |      |
|              | shall have obtained an           |            |      |
|              | associate's, bachelor's, or      |            |      |
|              | graduate degree in a field       |            |      |
|              | related to early childhood       |            |      |
|              | education, elementary school or  |            |      |
|              | secondary school education, or   |            |      |
|              | adult education.                 |            |      |
+--------------+----------------------------------+------------+------+
| Critical     | **By December 21, 2004, if       | Met        | N/A  |
| element 2.9  | applicable,** a majority of the  | re         |      |
|              | individuals providing academic   | quirements |      |
|              | instruction shall meet the       |            |      |
|              | qualifications established by    |            |      |
|              | the [State]{.underline} for      |            |      |
|              | early childhood education,       |            |      |
|              | elementary or secondary          |            |      |
|              | education, or adult education    |            |      |
|              | provided as part of an Even      |            |      |
|              | Start program or another family  |            |      |
|              | literacy program.                |            |      |
+--------------+----------------------------------+------------+------+
| Critical     | **By December 21, 2004,** the    | Met        | N/A  |
| element 2.10 | person responsible for           | re         |      |
|              | administration of family         | quirements |      |
|              | literacy services has received   |            |      |
|              | training in the operation of a   |            |      |
|              | family literacy program.         |            |      |
+--------------+----------------------------------+------------+------+
| Critical     | **By December 21, 2004**,        | Met        | N/A  |
| element 2.11 | paraprofessionals who provide    | re         |      |
|              | support for academic instruction | quirements |      |
|              | will have a secondary school     |            |      |
|              | diploma or its recognized        |            |      |
|              | equivalent.                      |            |      |
+--------------+----------------------------------+------------+------+
| Critical     | The local programs shall include | Reco       | 16   |
| element 2.12 | special training of staff,       | mmendation |      |
|              | including child-care workers, to |            |      |
|              | develop the necessary skills to  |            |      |
|              | work with parents and young      |            |      |
|              | children.                        |            |      |
+--------------+----------------------------------+------------+------+
| Critical     | The local programs shall provide | Met        | N/A  |
| element 2.13 | and monitor integrated           | re         |      |
|              | instructional services to        | quirements |      |
|              | participating parents and        |            |      |
|              | children through home-based      |            |      |
|              | programs.                        |            |      |
+--------------+----------------------------------+------------+------+
| Critical     | The local programs shall operate | Met        | N/A  |
| element 2.14 | on a year-round basis, including | re         |      |
|              | the provisions of some program   | quirements |      |
|              | services, including              |            |      |
|              | instructional and enrichment     |            |      |
|              | services, during the summer      |            |      |
|              | months.                          |            |      |
+--------------+----------------------------------+------------+------+
| Critical     | The local program shall be       | Met        | N/A  |
| element 2.15 | coordinated with other relevant  | re         |      |
|              | programs under the Adult         | quirements |      |
|              | Education and Family Literacy    |            |      |
|              | Act, the Individuals with        |            |      |
|              | Disabilities Act, and Title I of |            |      |
|              | the Workforce Investment Act of  |            |      |
|              | 1988 and the Head Start program, |            |      |
|              | volunteer literacy programs, and |            |      |
|              | other relevant programs.         |            |      |
+--------------+----------------------------------+------------+------+
| Critical     | The local programs shall use     | Met        | N/A  |
| element 2.16 | instructional programs based on  | re         |      |
|              | scientifically based reading     | quirements |      |
|              | research for children and        |            |      |
|              | adults.                          |            |      |
+--------------+----------------------------------+------------+------+
| Critical     | The local program shall          | Met        | N/A  |
| element 2.17 | encourage participating families | re         |      |
|              | to attend regularly and to       | quirements |      |
|              | remain in the program a          |            |      |
|              | sufficient time to meet their    |            |      |
|              | program goals.                   |            |      |
+--------------+----------------------------------+------------+------+
| Critical     | The local programs shall use     | Met        | N/A  |
| element 2.18 | reading-readiness activities for | re         |      |
|              | preschool children based on      | quirements |      |
|              | scientifically based reading     |            |      |
|              | research.                        |            |      |
+--------------+----------------------------------+------------+------+
| Critical     | The local program shall, if      | Met        | N/A  |
| element 2.19 | applicable, promote the          | re         |      |
|              | continuity of family literacy to | quirements |      |
|              | ensure that individuals retain   |            |      |
|              | and improve their educational    |            |      |
|              | outcomes.                        |            |      |
+--------------+----------------------------------+------------+------+

+--------------+-----------------------------------+------------+-----+
| # M          |                                   |            |     |
| onitoring Ar |                                   |            |     |
| ea 3: SEA Fi |                                   |            |     |
| duciary resp |                                   |            |     |
| onsibilities |                                   |            |     |
+--------------+-----------------------------------+------------+-----+
| **Element    | # Description                     | ### Status | #   |
| Number**     |                                   |            | # P |
|              |                                   |            | age |
+--------------+-----------------------------------+------------+-----+
| Critical     | The SEA complies with the         | Met        | N/A |
| element 3.1  | allocation requirements for State | re         |     |
|              | administration and technical      | quirements |     |
|              | assistance, and award of          |            |     |
|              | subgrants.                        |            |     |
+--------------+-----------------------------------+------------+-----+
| Critical     | The SEA ensures that subgrantees  | Met        | N/A |
| element 3.2  | comply with statutory and         | re         |     |
|              | regulatory requirements on uses   | quirements |     |
|              | of funds and matching.            |            |     |
+--------------+-----------------------------------+------------+-----+
| Critical     | The SEA complies with the         | Met        | N/A |
| element 3.3  | cross-cutting maintenance of      | re         |     |
|              | effort provisions.                | quirements |     |
+--------------+-----------------------------------+------------+-----+
| Critical     | The SEA ensures timely and        | Reco       | 16  |
| element 3.4  | meaningful consultation with      | mmendation |     |
|              | private school officials on how   |            |     |
|              | to provide Even Start services    |            |     |
|              | and benefits to eligible          |            |     |
|              | elementary school students        |            |     |
|              | attending non-public schools and  |            |     |
|              | their teachers or other           |            |     |
|              | personnel, and local programs     |            |     |
|              | provide an appropriate amount of  |            |     |
|              | those services and benefits       |            |     |
|              | through an eligible provider.     |            |     |
+--------------+-----------------------------------+------------+-----+
| Critical     | The SEA has a system for ensuring | Met        | N/A |
| element 3.5  | fair and prompt resolution of     | re         |     |
|              | complaints.                       | quirements |     |
+--------------+-----------------------------------+------------+-----+

Title I Part B -- Even Start

**Area: Accountability**

**Indicator 1.1: SEA complies with the subgrant award requirements**

**[Recommendation:]{.underline}** Incorrect statutory references,
including those regarding staff qualifications, and unclear language in
the RFP and application should be revised. State Even Start Coordinator
will be sent a list of specific recommended changes.

Indicator 1.6: The SEA uses the indicators of program quality to
monitor, evaluate, and improve local programs within the State.

**[Recommendation]{.underline}**: A section should be added to the
mid-year report template to allow for brief narrative explanations of
why local projects did not meet indicators. The current template allows
projects to identify only those indicators that were not met but does
not elaborate [why]{.underline}. Identifying why indicators were not met
will assist projects in focusing on inadequate services, thus allowing
them to strengthen those services.

**Indicator 1.7: The SEA conducts monitoring of its subgrantees
sufficient to ensure compliance with Even Start program requirements.**

**[Recommendation]{.underline}:** Monitoring reports will assist local
project staff in making needed improvements if the State included more
analysis and guidance for the projects visited, and less reiteration of
what is occurring in the program. Also, the State is encouraged to
explore options for performing advanced statistical analysis, such as
regression, so that local programs can better understand the
relationship of project services to participant outcomes. Such analysis
may be attainable using the extensive electronic data collection system
that the State uses for all its Even Start programs.

[**Commendation**:]{.underline} Overall, ED observed a consistent
monitoring presence through documents and interviews with the OPI and
local program staff. The State Coordinator is closely monitoring the
project in Harden, and tries to ensure that projects serve the number of
families they proposed in their application. ED has requested an update
on the progress of the Harden program as technical assistance from the
OPI continues. The coordinator had also encouraged the Butte program to
serve the full age range of birth to seven years, which should help
sustain long-term service, thus increasing participant benefits.

##### 

##### 

##### Area: Instructional Support

**Indicator 2.1: The SEA uses funds to provide technical assistance to
local programs to improve the quality of Even Start family literacy
services.**

**Indicator 2.12: The local programs shall include special training of
staff, including child-care workers, to develop the necessary skills to
work with parents and young children.**

[**Recommendation**:]{.underline} The OPI should consider offering
professional development to local project staff that will enable them to
apply various data analysis techniques to information received from
mid-year and annual evaluation reports. This analysis will enable the
local projects to use data more effectively in making the needed
improvements to program design and services.

##### Area: Fiduciary

**Indicator 3.4: The SEA ensures timely and meaningful consultation with
private school officials on how to provide Even Start services and
benefits to eligible elementary and secondary school students attending
non-public schools and their teachers or other instructional personnel,
and local programs provide an appropriate amount of those services and
benefits through an eligible provider**.

**[Recommendation]{.underline}**: The OPI should consider inserting
language in the application that references equitable participation
requirements (these requirements are referenced in the State's *State
and Federal Grants Handbook,* and could be copied from there). The OPI
should also ensure that all Even Start projects meaningfully consult
with private school officials in order to provide Even Start services
and benefits to eligible private school students and their teachers or
other educational personnel on an equitable basis under §§9501 and 9504
of ESEA recipients of Federal funds are required to provide eligible
school-age children who are enrolled in private elementary and secondary
schools, and their teachers or other educational personnel, educational
services and benefits under those programs on an equitable basis.
Eligible entities must provide the equitable services after timely and
meaningful consultation with the appropriate private school officials.

[^1]: The OPI has entered into a Compliance Agreement with ED in order
    to comply with the requirement under IASA to have Statewide
    assessments that are aligned with the State academic content and
    achievement standards. The OPI is developing these assessments and
    field-tested them in April of 2004. In January of 2005, OPI will
    have established cut scores for their assessments and will have
    completed the standards setting process. By April 2005 the
    Compliance Agreement will expire and the OPI should have completed
    all the requirements to comply with NCLB requirements. Because of
    this agreement, the OPI is protected from findings on Indicators 1.2
    and 1.3.