Wisconsin Department of Public Instruction

**April 21 -- 25 2008**

**Scope of Review:** A team from the U.S. Department of Education's (ED)
Student Achievement and School Accountability Programs (SASA) office
monitored the Wisconsin Department of Public Instruction (WDPI) the week
of April 21, 2008. This was a comprehensive review of the WDPI's
administration of the following programs authorized by the Elementary
and Secondary Education Act of 1965 (ESEA), as amended by the No Child
Left Behind Act (NCLB): Title I, Part A; Title I, Part B, Subpart 3; and
Title I, Part D. Also reviewed was Title VII, Subtitle B of the
McKinney-Vento Homeless Assistance Act (Education for Homeless Children
and Youth) as amended by 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 of the
State educational agency (SEA). During the week, the ED team visited two
LEAs, Milwaukee Public Schools (MPS) and Madison Metropolitan School
District (MMSD), interviewed administrative staff, met with officials
from three schools in MPS that have been identified for improvement, and
conducted two parent meetings. The ED team then interviewed personnel to
confirm data collected in each of the three monitoring indicator areas.

In its review of the Title I, Part B, Subpart 3 Even Start program, the
ED team examined the State's request for proposals, State Even Start
guidance, State indicators of program quality, and the most recent
applications and local evaluations for two local projects located in
Beloit and Janesville School Districts. During the onsite review, the ED
team visited these local projects and interviewed administrative and
instructional staff. The ED team also interviewed the Even Start State
coordinator to confirm information obtained at the local sites and to
discuss State administration issues.

In its review of the Title I, Part D program, the ED team examined the
State application for funding, procedures and guidance for State Agency
(SA) applications under Subpart 1 and LEA applications under Subpart 2,
technical assistance provided to SAs and LEAs, the State oversight and
monitoring plans and activities, SA and LEA subgrant plans and local
evaluations for projects in the Wisconsin Department of Corrections and
the Wauwatosa School District. The ED team interviewed administrative,
program and teaching staff. The ED team also interviewed the WDPI's
Title I, Pa**r**t D coordinator to confirm information obtained at the
local sites and discuss administration of the program.

In its review of the Education for Homeless Children and Youth program,
the ED team examined the State's procedures and guidance for the
identification, enrollment and retention of homeless students, technical
assistance provided to LEAs with and without subgrants, the State's
McKinney-Vento application, and LEA applications for subgrants and local
evaluations for programs in Milwaukee and Middleton-Cross Plains School
Districts, as well as the homeless liaisons from two LEAs without
subgrants, West Allis and Verona School Districts. The ED team also
interviewed the WDPI's McKinney-Vento coordinator to confirm information
obtained at the local site and discuss administration of the program.

**Previous Audit Findings:** None

**Previous Monitoring Findings:** None

**[Overarching Requirement -- SEA Monitoring]{.underline}**

A State's ability to fully and effectively implement the requirements of
NCLB is directly related to the extent to which it is able to regularly
monitor its LEAs and provide quality technical assistance based on
identified needs. This principle applies across all Federal programs
under NCLB.

Federal law does not specify the particular method or frequency with
which States must monitor their grantees, and States have a great deal
of flexibility in designing their monitoring systems. Whatever process
is used, it is expected that States have mechanisms in place sufficient
to ensure that they are able to collect and review critical
implementation data with the frequency and intensity required to ensure
effective (and fully compliant) programs under NCLB. Such a process
should promote quality instruction and lead to achievement of the
proficient or advanced level on State standards by all students.

Status: Met requirement

**Title I, Part A**

**Summary of Monitoring Indicators**

+------------+-------------------------------------+-------------+----+
| **         |                                     |             |    |
| Monitoring |                                     |             |    |
| Area 1,    |                                     |             |    |
| Title I,   |                                     |             |    |
| Part A:    |                                     |             |    |
| Accoun     |                                     |             |    |
| tability** |                                     |             |    |
+------------+-------------------------------------+-------------+----+
| *          | **Description**                     | **Status**  | #  |
| *Indicator |                                     |             | Pa |
| Number**   |                                     |             | ge |
+------------+-------------------------------------+-------------+----+
| 1.1        | SEA has approved system of academic | Met         | N  |
|            | content standards, academic         | Requirement | /A |
|            | achievement standards and           |             |    |
|            | assessments (including alternate    |             |    |
|            | assessments) for all required       |             |    |
|            | subjects and grades, or has an      |             |    |
|            | approved timeline for developing    |             |    |
|            | them.                               |             |    |
+------------+-------------------------------------+-------------+----+
| 1.2        | The SEA has implemented all         | Met         | N  |
|            | required components as identified   | Requirement | /A |
|            | in its accountability workbook.     |             |    |
+------------+-------------------------------------+-------------+----+
| 1.3        | The SEA has published an annual     | Rec         | 4  |
|            | report card as required and an      | ommendation |    |
|            | Annual Report to the Secretary.     |             |    |
+------------+-------------------------------------+-------------+----+
| 1.4        | The SEA has ensured that LEAs have  | Rec         | 4  |
|            | published annual report cards as    | ommendation |    |
|            | required.                           |             |    |
+------------+-------------------------------------+-------------+----+
| 1.5        | The SEA indicates how funds         | Met         | N  |
|            | received under Grants for State     | Requirement | /A |
|            | Assessments and related activities  |             |    |
|            | (section 6111) will be or have been |             |    |
|            | used to meet the 2005-06 and        |             |    |
|            | 2007-08 assessment requirements of  |             |    |
|            | NCLB.                               |             |    |
+------------+-------------------------------------+-------------+----+
| 1.6        | The SEA ensures that LEAs meet all  | Met         | N  |
|            | requirements for identifying and    | Requirement | /A |
|            | assessing the academic achievement  |             |    |
|            | of limited English proficient       |             |    |
|            | students.                           |             |    |
+------------+-------------------------------------+-------------+----+

#### **Title I, Part A**

#### **Monitoring Area 1: Accountability**

**1.3 -- The SEA has published an annual report card as required and an
Annual Report to the Secretary.**

**1.4 - The SEA has ensured that LEAs have published annual report cards
as required.**

**[Recommendation:]{.underline}** All items required for the SEA and LEA
report cards are posted on WDPI's website, but they are difficult to
locate. ED recommends that the WDPI consider listing in one place on its
website all information related to State and local report cards so that
the public can easily access this information.

+------------+-------------------------------------+------------+-----+
| ##         |                                     |            |     |
|  Monitorin |                                     |            |     |
| g Area 2,  |                                     |            |     |
| Title I, P |                                     |            |     |
| art A: Pro |                                     |            |     |
| gram Impro |                                     |            |     |
| vement, Pa |                                     |            |     |
| rental Inv |                                     |            |     |
| olvement a |                                     |            |     |
| nd Options |                                     |            |     |
+------------+-------------------------------------+------------+-----+
| **I        | ## Description                      | ## Status  | #   |
| ndicator** |                                     |            | # P |
|            | ##                                  |            | age |
| **Number** |                                     |            |     |
+------------+-------------------------------------+------------+-----+
| 2.1        | The SEA has developed procedures to | Finding    | 5   |
|            | ensure the hiring and retention of  |            |     |
|            | qualified paraprofessionals.        |            |     |
+------------+-------------------------------------+------------+-----+
| 2.2        | The SEA has established a statewide | Met        | N/A |
|            | system of support that provides, or | R          |     |
|            | provides for, technical assistance  | equirement |     |
|            | to LEAs and schools as required.    |            |     |
+------------+-------------------------------------+------------+-----+
| 2.3        | The SEA ensures that LEAs and       | Findings   | 6   |
|            | schools meet parental involvement   |            |     |
|            | requirements.                       |            |     |
+------------+-------------------------------------+------------+-----+
| 2.4        | The SEA ensures that LEAs and       | Met        | N/A |
|            | schools identified for improvement, | R          |     |
|            | corrective action, or restructuring | equirement |     |
|            | have met the requirements of being  |            |     |
|            | so identified.                      |            |     |
+------------+-------------------------------------+------------+-----+
| 2.5        | The SEA ensures that requirements   | Met        | N/A |
|            | for public school choice are met.   | R          |     |
|            |                                     | equirement |     |
+------------+-------------------------------------+------------+-----+
| 2.6        | The SEA ensures that requirements   | Met        | N/A |
|            | for the provision of supplemental   | R          |     |
|            | educational services (SES) are met. | equirement |     |
+------------+-------------------------------------+------------+-----+
| 2.7        | The SEA ensures that LEAs and       | Finding    | 7   |
|            | schools develop schoolwide programs |            |     |
|            | that use the flexibility provided   |            |     |
|            | to them by the statute to improve   |            |     |
|            | the academic achievement of all     |            |     |
|            | students in the school.             |            |     |
+------------+-------------------------------------+------------+-----+
| 2.8        | The SEA ensures that LEA targeted   | Finding    | 8   |
|            | assistance programs meet all        |            |     |
|            | requirements.                       |            |     |
+------------+-------------------------------------+------------+-----+

#### **Title I, Part A**

#### **Monitoring Area 2: Program Improvement, Parental Involvement and Options**

Indicator 2.1 - The SEA has developed procedures to ensure the hiring
and retention of qualified paraprofessionals.

[Finding]{.underline}: The WDPI has not ensured that all
paraprofessionals hired to work in programs supported with Title I funds
met qualification requirements as appropriate. Based on information
provided by the WDPI, there are paraprofessionals in MPS Title I schools
who have not met the statutory qualification requirements. Additionally,
MPS staff members did not provide evidence that they had a process for
ensuring that their paraprofessionals work under the direct supervision
of highly qualified teachers.

[Citation]{.underline}: Section 1119(c)(1) of the ESEA requires that new
paraprofessionals hired [after]{.underline} the date of enactment of the
ESEA as amended by 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; or (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 either reading, writing and
mathematics; or reading readiness, writing readiness, and mathematics
readiness, as appropriate. All paraprofessionals hired
[before]{.underline} the date of January 2002 and working in a program
supported with Title I funds shall meet the requirements of section
1119(c)(1) not later than 4 years after the date of enactment. 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. Section 200.59(c)(1) of the Title I
regulation states that a paraprofessional may not provide instructional
support to a student unless the paraprofessional is working under the
direct supervision of a teacher who meets the qualification requirements
in section 200.56 of the Title I regulations.

[Further action required:]{.underline} The WDPI must provide ED with a
detailed plan, including timelines, of the steps it will take to ensure
that all paraprofessionals hired by MPS to work in programs supported
with Title I funds meet qualification requirements prior to the
beginning of the 2008-2009 school year, and annually thereafter. This
documentation must also provide information on any corrective actions
that the WDPI will take to ensure full LEA compliance in cases where an
LEA has not taken the necessary actions to meet the statutory
requirements. The WDPI must also provide ED with copies of written
guidance or examples of other technical assistance it is providing to
all its LEAs to ensure they are familiar with and implementing the
requirement that paraprofessionals must work under the direct
supervision of highly qualified teachers.

**Indicator 2.3 - The SEA ensures that LEAs and schools meet parental
involvement requirements.**

**[Finding (1)]{.underline}:** The WDPI has not ensured that all its
LEAs met the parental involvement requirements. At the time of the
onsite review, MMSD had not evaluated annually the effectiveness of its
LEA parental involvement policy. The MMSD LEA parental involvement
policy had not been reviewed or updated in three years. Additionally,
the MMSD officials were unable to provide copies of Title I schools'
parental involvement policies or parent compacts. The parent compact
checklist that the MMSD provided its schools was inadequate. In MPS, the
parent compact, which was included in the school parental involvement
policies, did not meet Title I requirements.

[Citation:]{.underline} Section 1118(a)(2) of the ESEA states that each
local educational agency that receives Title I funds shall develop
jointly with, agree on with, and distribute to, parents of participating
children a written parental involvement policy. Section 1118(a)(2)(E) of
the ESEA requires that the LEA conduct, with the involvement of parents,
an annual evaluation of the content and effectiveness of the parental
involvement policy. Section 1118(b)(1) of the ESEA requires that each
school receiving Title I funds shall jointly develop with, and
distribute to, parents of participating children a written parental
involvement policy and parent compact.

Further action required: The WDPI must provide ED with documentation of
the process and procedures it will use, including technical assistance,
as appropriate, to ensure that MMSD, MPS, and all its other LEAs have
parental involvement policies and parent compacts for Title I schools
that meet the Title I requirements under section 1118 of the ESEA,
including planning, reviewing, and revising of LEA and school parental
involvement policies and compacts**.** The WDPI must provide ED with
copies of the procedures it will use to monitor the implementation of
this requirement.

[Finding (2):]{.underline} The WDPI has not ensured that its LEAs
consistently included all necessary information in its notification to
parents of school improvement status. In MPS, the parent notification
did not include all the required components.

[Citation:]{.underline} Section 1116(6)(a) of the ESEA requires that the
notice include an explanation of what the identification means, and how
the school compares in terms of academic achievement to other elementary
schools or secondary schools served by the local educational agency and
the State educational agency involved. Section 1116(6)(d) of the ESEA
requires that the notice include an explanation of what the local
educational agency or State educational agency is doing to help the
school address the achievement problem. Section 1116(6) of the ESEA
requires that the notice include an explanation of what the school
identified for school improvement is doing to address the problem of low
achievement.

[Further action required:]{.underline} The WDPI must provide ED with
documentation of the process and procedures it will use, including
technical assistance, as appropriate, to ensure that all its LEAs with
Title I schools that have been identified for improvement know the
parental notification requirements for such schools. Also the WDPI must
provide ED with documentation of the procedures it will use to monitor
the implementation of this requirement.

Indicator 2.7 - The SEA ensures that LEAs and schools develop schoolwide
programs that use the flexibility provided to them by the statute to
improve the academic achievement of all students in the school.

**[Finding]{.underline}:** The WDPI has not ensured that all its LEAs
with schools operating Title I schoolwide programs have schoolwide plans
that address all the required components. In MPS and MMSD, the
schoolwide plans reviewed by the team were missing required components.

[Citation:]{.underline} Section 1114 (b) of the ESEA requires schoolwide
programs to include strategies to attract highly qualified teachers to
high-need schools; to include strategies to increase parental
involvement in accordance with section 1118 of the ESEA, such as family
literacy services; and to include plans for assisting preschool children
in the transition from early childhood programs, such as Head Start,
Even Start, Early Reading First, or a State-run preschool program, to
local elementary school programs.

[Further action required:]{.underline} The WDPI must provide ED with
documentation of the process and procedures it will use, including
technical assistance, as appropriate, to ensure that all its LEAs with
Title I schools operating schoolwide programs know the required
components that must be in schoolwide plans. In addition the WDPI must
provide ED with documentation of the procedures it will use to monitor
LEAs to ensure that schoolwide plans contain all the required
components.

**Indicator 2.8 - The SEA ensures that LEA targeted assistance programs
meet all requirements.**

**[Finding]{.underline}**: The WDPI has not ensured that its LEAs
consistently operate targeted assistance programs in compliance with the
ESEA. MPS did not provide sufficient evidence that multiple,
educationally related, objective criteria were used to select Title I
participants in schools operating targeted assistance programs.

[Citation]{.underline}: Section 1115(b) of the ESEA requires that a
school operating a targeted assistance program to select eligible
children identified by the school as failing, or most at risk of
failing, to meet the State's challenging student academic achievement
standards on the basis of multiple, educationally related, objective
criteria established by the local educational agency and supplemented by
the school.

**[Further action required]{.underline}:** The WDPI must provide ED with
a plan and timeline for how it will provide technical assistance to all
its LEAs regarding the requirement that schools operating targeted
assistance programs must use multiple, educationally related, objective
criteria to select students for targeted assistance programs and
evidence that the plan is being implemented. The WDPI must also provide
ED with documentation of the procedures it will use to monitor the
implementation of this requirement.

+---------+----------------------------------------+-------------+----+
| **Mon   |                                        |             |    |
| itoring |                                        |             |    |
| Area 3, |                                        |             |    |
| Title   |                                        |             |    |
| I, Part |                                        |             |    |
| A:      |                                        |             |    |
| Fi      |                                        |             |    |
| duciary |                                        |             |    |
| Resp    |                                        |             |    |
| onsibil |                                        |             |    |
| ities** |                                        |             |    |
+---------+----------------------------------------+-------------+----+
| **In    | # Description                          | **Status**  | ** |
| dicator |                                        |             | Pa |
| N       |                                        |             | ge |
| umber** |                                        |             | ** |
+---------+----------------------------------------+-------------+----+
| 3.1     | SEA complies with---                   | Finding     | #  |
|         |                                        |             | ## |
|         | -   The procedures for adjusting       |             | ## |
|         |     ED-determined allocations outlined |             | ## |
|         |     in sections 200.70 -- 200.75 of    |             | #  |
|         |     the regulations.                   |             |    |
|         |                                        |             | 10 |
|         | -   The procedures for reserving funds |             |    |
|         |     for school improvement, State      |             |    |
|         |     administration, and (where         |             |    |
|         |     applicable) the State Academic     |             |    |
|         |     Achievement Awards program.        |             |    |
|         |                                        |             |    |
|         | -   The reallocation and carryover     |             |    |
|         |     provisions in section 1126(c) and  |             |    |
|         |     1127 of Title I statute.           |             |    |
+---------+----------------------------------------+-------------+----+
| 3.2     | SEA ensures that its LEAs comply with  | Met         | #  |
|         | the provision for submitting an annual | Requirement | ## |
|         | application to the SEA and revising    |             | ## |
|         | LEA plans as necessary to reflect      |             | ## |
|         | substantial changes in the direction   |             | #  |
|         | of the program.                        |             |    |
|         |                                        |             | N  |
|         |                                        |             | /A |
+---------+----------------------------------------+-------------+----+
| 3.3     | SEA ensures that all its LEAs comply   | Finding     | #  |
|         | with the requirements in section 1113  |             | ## |
|         | of the Title I statute and sections    | (See        | ## |
|         | 200.77 and 200.78 of the regulations   | Indicator   | ## |
|         | with regard to (1) Reserving funds for | 3.1)        | #  |
|         | the various set-asides either required |             |    |
|         | or allowed under the statute, and (2)  |             | 10 |
|         | Allocating funds to eligible school    |             |    |
|         | attendance areas or schools in rank    |             |    |
|         | order of poverty based on the number   |             |    |
|         | of children from low-income families   |             |    |
|         | who reside in an eligible attendance   |             |    |
|         | area.                                  |             |    |
+---------+----------------------------------------+-------------+----+
| 3.4     | -   SEA complies with the maintenance  | Finding     | #  |
|         |     of effort (MOE) provisions of      |             | ## |
|         |     Title I.                           |             | ## |
|         |                                        |             | ## |
|         | -   SEA ensures that its LEAs comply   |             | #  |
|         |     with the comparability provisions  |             |    |
|         |     of Title I.                        |             | 11 |
|         |                                        |             |    |
|         | -   SEA ensures that Title I funds are |             |    |
|         |     used only to supplement or         |             |    |
|         |     increase non-Federal sources used  |             |    |
|         |     for the education of participating |             |    |
|         |     children and do not supplant funds |             |    |
|         |     from non-Federal sources.          |             |    |
+---------+----------------------------------------+-------------+----+
| 3.5     | SEA ensures that its LEAs comply with  | Met         | N  |
|         | all the auditee responsibilities       | Requirement | /A |
|         | specified in Subpart C, section 300(a) |             |    |
|         | through (f) of OMB Circular A-133.     |             |    |
+---------+----------------------------------------+-------------+----+
| 3.6     | SEA ensures that its LEAs comply with  | Met         | #  |
|         | requirements regarding services to     | Requirement | ## |
|         | eligible private school children,      |             | ## |
|         | their teachers and families.           |             | ## |
|         |                                        |             | #  |
|         |                                        |             |    |
|         |                                        |             | N  |
|         |                                        |             | /A |
+---------+----------------------------------------+-------------+----+
| 3.7     | SEA complies with the requirement for  | Finding     | #  |
|         | implementing a system for ensuring     |             | ## |
|         | prompt resolution of complaints.       | Rec         | ## |
|         |                                        | ommendation | ## |
|         |                                        |             | #  |
|         |                                        |             |    |
|         |                                        |             | 12 |
+---------+----------------------------------------+-------------+----+
| 3.8     | SEA complies with the requirement to   | Finding     | #  |
|         | establish a Committee of Practitioners |             | ## |
|         | and involves the committee in          |             | ## |
|         | decision-making as required.           |             | ## |
|         |                                        |             | #  |
|         |                                        |             |    |
|         |                                        |             | 13 |
+---------+----------------------------------------+-------------+----+

Title I, Part A

# Monitoring Area 3: Fiduciary Responsibilities

Indicator 3.1 -- SEA complies with the procedures for adjusting
ED-determined allocations outlined in sections 200.70 -- 200.75 of the
regulations, the procedures for reserving funds for school improvement,
State administration, and (where applicable) the State Academic
Achievement Awards program, and the reallocation and carryover
provisions in sections 1126(c) and 1127 of Title I statute; and

Indicator 3.3 -- SEA ensures that all its LEAs comply with the
requirements in section 1113 of the Title I statute and sections 200.77
and 200.78 of the regulations with regard to (1) Reserving funds for the
various set-asides either required or allowed under the statute, and (2)
Allocating funds to eligible school attendance areas or schools in rank
order of poverty based on the number of children from low-income
families who reside in an eligible attendance area.

**[Finding:]{.underline}** The WDPI transfers funds from MPS' Title I,
Part A allocation to neighboring LEAs to reimburse these LEAs for
providing Title I services to approximately 850 children who reside in
MPS but attend school in these neighboring LEAs. The WDPI indicated that
the process it uses to transfer these funds was based on guidance it
received from ED staff many years ago that it could use the authority
under section 1126(b)(2) of the ESEA to act as a fiscal agent for MPS in
this matter. However, the amount of funds currently withheld from MPS'
total Title I, Part A allocation and used to reimburse the neighboring
LEAs that serve MPS' children was not calculated in accordance with
current law. The WDPI based the amount of the reimbursement on the cost
of the Title I services provided rather than on the number of Census
poverty children who transferred from MPS to neighboring LEAs. In
addition, because the LEAs receiving Title I funds that were transferred
from MPS did not include these funds as part of their total Title I
allocation, they did not properly meet the reservation of funds,
within-district ranking and allocation, and equitable service
requirements of Title I. Based on the process that WDPI used, children
who transferred from MPS to another LEA may have received Title I
services from an LEA that was not eligible to receive Title I funds or
in the case where the LEA was eligible for Title I funds, those children
may have attended non-Title I schools in the receiving LEA and received
Title I services.

[Citation]{.underline}: Section 1126(b)(2) of the ESEA gives the WDPI
the authority to adjust ED-determined Title I, Part A LEA allocations to
account for LEAs that provide a free public education to children who
reside in other Title I-eligible LEAs across the State. Section 1124(c)
of the ESEA requires ED to determine LEA allocations based primarily on
data from the U.S. Census Bureau on the number of children ages 5
through 17 from low-income families. Therefore, any adjustments to LEA
allocations made under section 1126(b)(2) of the ESEA must reflect the
number of Census poverty children that transfer from one LEA to another.
Funds that transfer from MPS into another LEA under section 1126(b)(2)
of the ESEA become part of the receiving LEA's total Title I allocation,
and are subject to the within-district ranking, allocation, and
reservation requirements of section 1113 of the ESEA and sections 200.77
and 200.78 of the Title I regulations. As a basic rule, MPS children who
transfer into an LEA that is not eligible to receive Title I funds may
not receive Title I services. With the exception of homeless children,
those MPS students who transfer into a Title I eligible LEA but do not
attend a Title I school in the receiving LEA are not eligible for Title
I services. Additionally, because these funds are part of the receiving
LEA's Title I, Part A allocation, the LEA must also ensure that it
provides equitable services to private school children as required under
section 1120 of the ESEA.

[Further action required:]{.underline} If the WDPI transfers funds from
MPS to neighboring Title I eligible LEAs under the authority in section
1126(b)(2) of the ESEA, the WDPI must provide ED with evidence that the
amount of MPS' school year 2008-2009 Title I, Part A allocation
transferred to other LEAs under section 1126(b)(2) of the ESEA is based
on the number of Census poverty children who transferred from MPS. The
WDPI may use another poverty measure (from a previous year if that is
the best data available) to derive a Census poverty count of children
who transfer from MPS to other LEAs. An example of how to do this
calculation can be found in Appendix A at the end of this report. The
WDPI must not transfer any Title I funds to LEAs not eligible to receive
Title I funds and children who transfer to a Title I-eligible LEA but
attend non-Title I schools may not receive Title I services.

However, if the WDPI does not want to use the authority under section
1126 of the ESEA, MPS may contract separately with each neighboring LEA
(which must be eligible to receive Title I funds) to provide Title I
services to their children who transferred from MPS. Under this option,
MPS must first reserve funds from its total Title I allocation in
accordance with section 200.77 of the Title I regulations. From the
amount available for distribution to schools after reserving funds under
section 200.77, MPS must then calculate how much is needed to provide
equitable services for private school children. (Because of its open
enrollment policy, MPS calculates the amount needed to provide equitable
services for private school children by dividing the number of children
from low-income families attending private school by the total number of
poverty children in MPS who attend both public and private schools and
applying that percentage to the total amount available for distribution
to its schools.) The amount of funds available for each MPS contract
with a neighboring LEA is the amount of funds generated by children from
low-income families who attend MPS' Title I public schools, transfer to
a neighboring LEA, and attend a Title I school in that LEA. This becomes
the amount of funds available to each neighboring LEA to serve eligible
MPS children in the neighboring LEAs' Title I schools. MPS children who
transfer to a neighboring LEA but attend a non-Title I school may not
receive Title I services.

**Indicator 3.4 -- SEA ensures that LEAs comply with Title I
requirements related to maintenance of effort; comparability
requirements; and supplement not supplant so that Title I funds
supplement or increase non-Federal sources used for the education of
participating children and do not supplant funds from non-Federal
sources.**

**[Finding]{.underline}**: The WDPI has not ensured that MPS properly
complied with the comparability requirement so that each Title I school,
including charter schools, are substantially comparable. In school year
(SY) 2006-2007, MPS calculated comparability based on the per pupil
amount of State and local funds that a school uses to purchase
instructional staff and materials. In reviewing the SY 2006-2007 MPS'
comparability calculations in a March 2007 report, the ED team found
that MPS had created six grade spans (high schools, middle schools, K-8
schools, elementary schools, instrumentality charter schools (K-12) and
non-instrumentality charter schools (K-12)). MPS treated its
instrumentality and non-instrumentality charter schools as two separate
grade-span groupings and compared the charter schools within each
grouping to each other rather than to the non-charter schools operated
directly by MPS in the other grade-span groupings. In addition, MPS
included non-instructional expenses, such as transportation, in its
comparability calculations. Because charter schools were not included in
the appropriate grade span groupings and non-instructional funds were
included in the comparability calculations, MPS did not properly
determine whether its charter schools and non-charter schools were in
fact comparable.

[Citation]{.underline}: Section 1120A of the ESEA provides that an LEA
may receive Title I, Part A funds only if it uses State and local funds
to provide services in each Title I school that are at least comparable
to services that, taken as a whole, an LEA provides to schools not
receiving Title I funds. (Or, if all schools in an LEA are Title I
schools, each school must be substantially comparable to each other.)
The purpose of this requirement is to ensure that each Title I school
receives an equitable share of State and locally supported resources
that would otherwise flow to it in the absence of Title I. Although
section 1120A(c)(1)(B) of the ESEA provides flexibility by allowing an
LEA to meet the comparability requirement on a grade-span basis, the
grade-span breakout must be one that results in each Title I school
receiving the amount of State and local resources to which it is
entitled. Separating instrumentality and non-instrumentality charter
schools into their own grade-span groupings and comparing only the
charter schools to other charter schools within that grouping rather
than comparing them with other non-charter schools for the appropriate
grade span does not produce a valid comparison that meets the intent and
purpose of section 1120(A)(c).

[Further action required]{.underline}: The WDPI must provide
documentation that in meeting the comparability requirements (1) MPS
includes all of its schools, including instrumentality and
non-instrumentality charter schools, in the correct grade span when
using grade-span groupings, (2) MPS includes only State and local funds
that a school uses to purchase instructional staff and materials, and
(3) the schools, including charter schools, that MPS lists in each
grade-span grouping are in fact comparable.

The WDPI must also ensure that its other LEAs with instrumentality and
non-instrumentality charter schools follow the same guidelines for
calculating comparability.

**Indicator 3.7 - SEA complies with the requirement for implementing a
system for ensuring prompt resolution of complaints.**

**[Finding:]{.underline}** The MMSD and MPS complaint procedures do not
contain any information or directions on how and with whom private
school officials are to file their complaints. None of the complaint
procedures required in sections 1120 and 9503 of the ESEA were in these
LEAs' complaint procedures or policies**.** The statute has specific
requirements for private school officials to follow when filing a
complaint of noncompliance by the LEA: the private school official
provides the basis of the noncompliance by the LEA to the SEA, not the
LEA. The LEA's only responsibility is to forward the appropriate
documentation to the SEA, which makes the final decision on the
complaint. In addition, LEAs serving private school children must
provide private school officials with these specific procedures.

[Citations:]{.underline} Sections 1120(b)(5) and (c)(2) and section 9503
of the ESEA describe the complaint process and procedures that private
school officials must use to file a complaint against an LEA for such
issues as lack of timely and meaningful consultation by the LEA, no
consideration given by the LEA to the views of the private school
officials, or a dispute regarding low-income data. Sections 299.10 and
299.11 of the Code of Federal Regulations require (1) SEAs to adopt
written complaint procedures and (2) LEAs to disseminate information
about complaint processes to ... appropriate private school officials.

[Further action required]{.underline}: The WDPI must ensure that MMSD,
MPS, and its other LEAs serving private school children have complaint
procedures that describe how and to whom a private school official files
a complaint in accordance with sections 1120(b)(5) and (c)(2) and
section 9503 of the ESEA. The WDPI must provide ED with the amended
pages of the revised complaint procedures for the MMSD and MPS with the
changes highlighted.

**[Recommendation:]{.underline}** ED recommends that the WDPI add to its
complaint policies the procedures that a private school official must
use to file a complaint against an LEA for such issues as lack of timely
and meaningful consultation by the LEA, no consideration given by the
LEA to the views of the private school officials, or a dispute regarding
low-income data.

Indicator 3.8 - SEA complies with the requirement to establish a
Committee of Practitioners and involves the committee in decision-making
as required.

**[Finding:]{.underline}** The WDPI's Committee of Practitioners (COP)
does not include representatives of private school children as required.

[Citation]{.underline}: Section 1903(b)(2) of the ESEA requires that the
COP shall include as a majority of its members, representatives from
LEAs; administrators, including the administrators of programs described
in other parts of this title; teachers, including vocational educators;
parents; members of local school board; representatives of private
school children; and pupil services personnel.

[Further action required:]{.underline} The WDPI must appoint at least
two representatives of private school children to serve on the COP. The
WDPI must provide ED with a revised list of COP members that meets that
statutory requirement, including the membership category each member
represents.

**Summary of Title I, Part B, Subpart 3 (Even Start)**

**Monitoring Indicators**

# 

+-----------+-------------------------------------+-------------+-----+
| # Monitor |                                     |             |     |
| ing Area  |                                     |             |     |
| 1, Title  |                                     |             |     |
| I, Part B |                                     |             |     |
| , Subpart |                                     |             |     |
|  3: Accou |                                     |             |     |
| ntability |                                     |             |     |
+-----------+-------------------------------------+-------------+-----+
| **        | # Description                       | # Status    | #   |
| Indicator |                                     |             |  Pa |
| Number**  |                                     |             | ge  |
+-----------+-------------------------------------+-------------+-----+
| 1.1       | The SEA complies with the subgrant  | Met         | N/A |
|           | award requirements.                 | Requirement |     |
+-----------+-------------------------------------+-------------+-----+
| 1.2       | The SEA requires applicants to      | Finding     | 14  |
|           | submit applications for subgrants   |             |     |
|           | with the necessary documentation.   |             |     |
+-----------+-------------------------------------+-------------+-----+
| 1.3       | In making non-competitive           | Met         | N/A |
|           | continuation awards, the SEA        | Requirement |     |
|           | reviews the progress of each        |             |     |
|           | subgrantee in meeting the           |             |     |
|           | objectives of the program and       |             |     |
|           | evaluates the program based on the  |             |     |
|           | indicators of program quality, and  |             |     |
|           | refuses to award subgrant funds to  |             |     |
|           | an eligible entity if the agency    |             |     |
|           | finds that the entity has not       |             |     |
|           | sufficiently improved the           |             |     |
|           | performance of the program.         |             |     |
+-----------+-------------------------------------+-------------+-----+
| 1.4       | The SEA develops indicators of      | Rec         | 15  |
|           | program quality for Even Start      | ommendation |     |
|           | programs, and uses the indicators   |             |     |
|           | to monitor, evaluate, and improve   |             |     |
|           | projects within the State.          |             |     |
+-----------+-------------------------------------+-------------+-----+
| 1.5       | The SEA ensures that projects       | Met         | N/A |
|           | provide for an independent local    | Requirement |     |
|           | evaluation of the program that is   |             |     |
|           | used for program improvement.       |             |     |
+-----------+-------------------------------------+-------------+-----+
| 1.6       | The SEA reports to ED in a timely   | Met         | N/A |
|           | manner using the required           | Requirement |     |
|           | performance measures and ensures    |             |     |
|           | that local projects are assessing   |             |     |
|           | the progress of their participants  |             |     |
|           | using those measures.               |             |     |
+-----------+-------------------------------------+-------------+-----+
| 1.7       | The SEA ensures compliance with all | Rec         | 15  |
|           | Even Start program requirements.    | ommendation |     |
+-----------+-------------------------------------+-------------+-----+

**Title I, Part B, Subpart 3**

**Monitoring Area: Accountability**

**Indicator 1.2 - The SEA requires applicants to submit applications for
subgrants with the necessary documentation**.

**[Finding]{.underline}:** The request for proposals (RFPs) issued by
the WDPI did not include the statutory requirement that an applicant
submit the required documentation.

[Citation]{.underline}: Section 1237 of the ESEA states that to be
eligible to receive a subgrant under Even Start, an LEA shall submit an
application to the State educational agency that includes the required
documentation.

[Further action required]{.underline}: Although the WDPI has a uniform
template for all RFPs, the WDPI must integrate the omitted requirement
into its application and submit a revised copy of the application to ED
for review.

**Indicator 1.4 - The SEA develops indicators of program quality for
Even Start programs and uses the indicators to monitor, evaluate, and
improve projects within the State.**

[Recommendation:]{.underline} ED recommends that the WDPI revise its
indicators of program quality to ensure that standards are appropriately
challenging and that all projects are continuously striving to reach the
highest standards. The current benchmarks do not reflect high
expectations for children or adults and most Even Start programs are not
only meeting but are exceeding the current indicators.

**Indicator 1.7 - The SEA ensures compliance with all Even Start program
requirements.**

[Recommendation:]{.underline} ED recommends that the WDPI provide
feedback to local programs on areas of deficiency as identified in their
monitoring reports. Currently, the WDPI conducts onsite visits to
one-third of the Even Start programs each year. Staff at the local
projects indicated that no action is required by the WDPI in response to
areas of deficiency.

+-----------+-------------------------------------+-------------+----+
| ##        |                                     |             |    |
|  Monitori |                                     |             |    |
| ng Area 2 |                                     |             |    |
| , Title I |                                     |             |    |
| , Part B, |                                     |             |    |
|  Subpart  |                                     |             |    |
| 3: Progra |                                     |             |    |
| m Support |                                     |             |    |
+===========+=====================================+=============+====+
| **        | # Description                       | ### Status  | #  |
| Indicator |                                     |             | #  |
| Number**  |                                     |             | Pa |
|           |                                     |             | ge |
+-----------+-------------------------------------+-------------+----+
| 2.1       | The SEA uses funds to provide       | Met         | N  |
|           | technical assistance to local       | Requirement | /A |
|           | projects to improve the quality of  |             |    |
|           | Even Start family literacy services |             |    |
|           | and comply with State indicators of |             |    |
|           | program quality.                    |             |    |
+-----------+-------------------------------------+-------------+----+
| 2.2       | Each program assisted shall include | Met         | N  |
|           | the identification and recruitment  | Requirement | /A |
|           | of eligible families.               |             |    |
+-----------+-------------------------------------+-------------+----+
| 2.3       | Each program assisted shall         | Finding     | 16 |
|           | implement all 15-program elements.  |             |    |
|           |                                     | Rec         |    |
|           |                                     | ommendation |    |
+-----------+-------------------------------------+-------------+----+
| 2.4       | The SEA ensures that all families   | Met         | N  |
|           | receiving services participate in   | Requirement | /A |
|           | all four core instructional         |             |    |
|           | services.                           |             |    |
+-----------+-------------------------------------+-------------+----+
| 2.5       | The local programs shall use        | Met         | N  |
|           | high-quality instructional programs | Requirement | /A |
|           | based on scientifically based       |             |    |
|           | reading research (SBRR) for         |             |    |
|           | children and adults.                |             |    |
+-----------+-------------------------------------+-------------+----+

**Title I, Part B, Subpart 3**

#### **Monitoring Area: Program Support**

**Indicator 2.3 -- Each program assisted shall implement all 15-program
elements.**

**Element #4: Intensity of Instructional Services**

**[Finding]{.underline}:** The number of hours offered in each of the
four instructional components falls below ED's minimum recommendation.
The Even Start projects observed are not offering a sufficient number of
hours to make sustainable changes in a family. The average number of
hours offered in adult education and early childhood education in the
programs visited was 36 hours per month.

[Citation]{.underline}: Section 1235(4) of the ESEA requires that each
project provide high-quality, *intensive* instructional programs that
promote adult literacy and empower parents to support the educational
growth of their children, developmentally appropriate early childhood
services, and preparation of children for success in regular school
programs. Each of the four components is considered an instructional
component.

[Further action required]{.underline}: The WDPI must develop, submit to
ED, and implement an action plan to ensure that local projects provide
high-quality and intensive instructional programs that promote adult
literacy and empower parents to support the educational growth of their
children, and to prepare children for success in regular school
programs. The recommended minimum intensities for the four core
components are:

Adult Education - 60 hours per month

> Early Childhood Education (birth-3) - 60 hours per month
>
> Early Childhood Education (3-4) - 65 hours per month
>
> Parenting Education and Interactive Literacy Activities between
> Parents
>
> and Children - 20 hours per month

The WDPI must submit to ED a copy of the guidance it will provide to
local programs regarding the recommended minimum intensities for the
four core instructional components of the Even Start program.

#  

**[Element #7 -- Home-based Instruction:]{.underline}**

[Recommendation:]{.underline} ED recommends that the WDPI develop and
implement a plan to ensure that local projects receive at least one home
visit per month. The current minimum requirement of three home visits
per year is not sufficient to provide adequate support to families on a
regular basis.

+-----------+-------------------------------------+-------------+------+
| # Moni    |                                     |             |      |
| toring Ar |                                     |             |      |
| ea 3, Tit |                                     |             |      |
| le I Part |                                     |             |      |
|  B, Subpa |                                     |             |      |
| rt 3: SEA |                                     |             |      |
|  Fiduciar |                                     |             |      |
| y Respons |                                     |             |      |
| ibilities |                                     |             |      |
+-----------+-------------------------------------+-------------+------+
| **        | # Description                       | ### Status  | ##   |
| Indicator |                                     |             | Page |
| Number**  |                                     |             |      |
+-----------+-------------------------------------+-------------+------+
| 3.1       | The SEA complies with the           | Met         | N/A  |
|           | allocation requirements for State   | Requirement |      |
|           | administration and technical        |             |      |
|           | assistance and award of subgrants.  |             |      |
+-----------+-------------------------------------+-------------+------+
| 3.2       | The SEA ensures that subgrantees    | Rec         | 18   |
|           | comply with statutory and           | ommendation |      |
|           | regulatory requirements on uses of  |             |      |
|           | funds and matching.                 |             |      |
+-----------+-------------------------------------+-------------+------+
| 3.3       | The SEA complies with the           | Met         | N/A  |
|           | cross-cutting maintenance of effort | Requirement |      |
|           | provisions.                         |             |      |
+-----------+-------------------------------------+-------------+------+
| 3.4       | The SEA ensures that grantees       | Met         | N/A  |
|           | comply with requirements with       | Requirement |      |
|           | regard to services for eligible     |             |      |
|           | private school children, their      |             |      |
|           | teachers, and their families.       |             |      |
+-----------+-------------------------------------+-------------+------+
| 3.5       | The SEA has a system for ensuring   | Met         | N/A  |
|           | fair and prompt resolution of       | Requirement |      |
|           | complaints and appropriate hearing  |             |      |
|           | procedures.                         |             |      |
+-----------+-------------------------------------+-------------+------+

Title I, Part B, Subpart 3

Monitoring Area: SEA Fiduciary Responsibilities

**Indicator 3.2 - The SEA ensures that grantees comply with requirements
with regard to services to eligible private school children, their
teachers and their families**

[Recommendation:]{.underline} ED recommends that the WDPI encourage its
LEAs, which conduct consultation meetings with private school officials
that cover requirements for many Federal programs, to include the Even
Start program in these consultation meetings.

# Title I, Part D

#  Summary of Monitoring Indicators

+------------+-----------------------------------+-------------+------+
| # Neglec   |                                   |             |      |
| ted, Delin |                                   |             |      |
| quent or A |                                   |             |      |
| t-Risk of  |                                   |             |      |
| Dropping-O |                                   |             |      |
| ut Program |                                   |             |      |
+------------+-----------------------------------+-------------+------+
| **I        | # Description                     | ### Status  | ##   |
| ndicator** |                                   |             | Page |
|            |                                   |             |      |
| **Number** |                                   |             |      |
+------------+-----------------------------------+-------------+------+
| 1.1        | The SEA has implemented all       | Met         | >    |
|            | required components as identified | Requirement |  N/A |
|            | in its Title I, Part D (N/D)      |             |      |
|            | plan.                             |             |      |
+------------+-----------------------------------+-------------+------+
| 1.2        | The SEA ensures that State agency | Met         | >    |
|            | (SA) plans for services to        | Requirement |  N/A |
|            | eligible N/D students meet all    |             |      |
|            | requirements.                     |             |      |
+------------+-----------------------------------+-------------+------+
| 1.3        | The SEA ensures that local        | Met         | >    |
|            | educational agency (LEA) plans    | Requirement |  N/A |
|            | for services to eligible N/D      |             |      |
|            | students meet all requirements.   |             |      |
+------------+-----------------------------------+-------------+------+
| 2.1        | The SEA ensures that              | Met         | >    |
|            | institutionwide programs          | Requirement |  N/A |
|            | developed by the SA under Subpart |             |      |
|            | 1 use the flexibility provided to |             |      |
|            | them by law to improve the        |             |      |
|            | academic achievement of all       |             |      |
|            | students in the school.           |             |      |
+------------+-----------------------------------+-------------+------+
| 3.1        | The SEA ensures each SA has       | Met         | >    |
|            | reserved not less than 15 percent | Requirement |  N/A |
|            | and not more than 30 percent of   |             |      |
|            | the amount it receives under      |             |      |
|            | Subpart 1 for transition          |             |      |
|            | services.                         |             |      |
+------------+-----------------------------------+-------------+------+
| 3.2        | The SEA conducts monitoring of    | Met         | >    |
|            | its subgrantees sufficient to     | Requirement |  N/A |
|            | ensure compliance with Title I,   |             |      |
|            | Part D program requirements.      |             |      |
+------------+-----------------------------------+-------------+------+

**McKinney-Vento Homeless Education Program**

**Summary of Monitoring Indicators**

+------------+------------------------------------+------------+------+
| # M        |                                    |            |      |
| cKinney-Ve |                                    |            |      |
| nto Homele |                                    |            |      |
| ss Educati |                                    |            |      |
| on Program |                                    |            |      |
+------------+------------------------------------+------------+------+
| *          | # Description                      | ### Status | ##   |
| *Indicator |                                    |            | Page |
| Number**   |                                    |            |      |
+------------+------------------------------------+------------+------+
| Indicator  | The SEA collects and reports to ED | Met        | >    |
| 1.1        | assessment data from LEAs on the   | R          |  N/A |
|            | educational needs of homeless      | equirement |      |
|            | children and youth.                |            |      |
+------------+------------------------------------+------------+------+
| Indicator  | The SEA implements procedures to   | Met        | >    |
| 2.1        | address the identification,        | R          |  N/A |
|            | enrollment and retention of        | equirement |      |
|            | homeless students.                 |            |      |
+------------+------------------------------------+------------+------+
| Indicator  | The SEA provides, or provides for, | Met        | >    |
| 2.2        | technical assistance for LEAs to   | R          |  N/A |
|            | ensure appropriate implementation  | equirement |      |
|            | of the statute.                    |            |      |
+------------+------------------------------------+------------+------+
| Indicator  | The SEA ensures that LEA subgrant  | Met        | >    |
| 3.1        | plans for services to eligible     | R          |  N/A |
|            | homeless students meet all         | equirement |      |
|            | requirements.                      |            |      |
+------------+------------------------------------+------------+------+
| Indicator  | The SEA ensures that the LEA       | Met        | > 20 |
| 3.2        | complies with providing comparable | R          |      |
|            | Title I, Part A services to        | equirement |      |
|            | homeless students attending        |            |      |
|            | non-Title I schools.               | Reco       |      |
|            |                                    | mmendation |      |
+------------+------------------------------------+------------+------+
| Indicator  | The SEA has a system for ensuring  | Met        | >    |
| 3.3        | the prompt resolution of disputes. | R          |  N/A |
|            |                                    | equirement |      |
+------------+------------------------------------+------------+------+
| Indicator  | The SEA conducts monitoring of     | Met        | > 20 |
| 3.4        | LEAs with and without subgrants,   | R          |      |
|            | sufficient to ensure compliance    | equirement |      |
|            | with McKinney-Vento program        |            |      |
|            | requirements.                      | Reco       |      |
|            |                                    | mmendation |      |
+------------+------------------------------------+------------+------+

**Indicator 3.2 - The SEA ensures that the LEA complies with providing
comparable Title I, Part A services to homeless children attending
non-Title I schools.**

[Recommendation:]{.underline} ED recommends that the Office of the State
Coordinator for the Education of Homeless Children and Youth Programs
and staff from the Title I Office at the WDPI work together to ensure a
methodical review of homeless student enrollment data to determine a
suitable proportional reservation of funds under section 200.77(a) of
the Title I regulations for comparable Title I services. A review of
Title I, Part A reservations for several districts with subgrants with
significant populations of homeless students found either no reservation
or just a minimal reservation of funds.

Indicator 3.4 - The SEA conducts monitoring of LEAs with and without
subgrants, sufficient to ensure compliance with McKinney-Vento program
requirements

[Recommendation:]{.underline} ED recommends that the WDPI's Title I and
McKinney-Vento staff develop an expanded protocol with indicators
specific to the McKinney-Vento grant programs for monitoring LEAs with
subgrants. ED also recommends that the WDPI monitor LEAs with subgrants
through one formal onsite review at least once during their grant
periods.

**APPENDIX A**

##### 

##### CALCULATION EXAMPLE

**ADJUSTMENTS TO ACCOUNT FOR Free and Reduce Price Lunch (fr/pl)
CHILDREN TRANSFERRING OUT OF MILWAUKEE**

  ---- ------------------------------------------------ -------------- --------------
                                                                       

                                                        2007-08        2008-09

                                                                       

  1    Milwaukee Public Enrollment                      80,043         80,043

  2    Public FR/PL count in Milwaukee                  62,497         62,497

  3    \% FR/PL (Line 2/Line 1)                         78.08%         78.08%

  4    Children transferring                            850            850

  5    FR/PL transferring (Line 4 \* Line 3)            664            664

  6    \% FR/PL children transferring (Line 5/Line 2)   1.06%          1.06%

  7    Census poor                                      43,411         38,785

  8    \% Census poor transferring (Line 6)             1.06%          1.06%

  9    Census poor transferring (Line 7 X Line 8)       461            412

  10   Federal Title I, Part A allocation for Milwaukee \$87,105,186   \$87,874,737

  11   Federal formula count                            44,754         40,128

  12   Amount per formula child (Line10/Line 11)        \$1,946.31     \$2,189.86

  13   Title I amount transferring from Milwaukee (Line \$897,249      \$902,222
       9 X Line 12)                                                    

                                                                       

  \-   Milwaukee\'s FR/PL rate is 78.08 percent. (Line                 
       2/Line 1)                                                       

  \-   Therefore, 78.08 percent of all children                        
       transferring to other LEAs are FR/PL children.                  

  \-   Of the total number of FR/PL children in                        
       Milwaukee, 1.06 percent of those children                       
       transfer to other LEAs. (Line 5/Line 2)                         

  \-   Apply the 1.06 percent (the percent of FR/PL                    
       children in Milwaukee transferring to other                     
       LEAs) to Milwaukee\'s number of Census poor                     
       children to determine the number of Census poor                 
       children who are transferring. (See Line 9)                     

  \-   Divide the Federal Title I allocation by the                    
       total Federal formula count to determine an                     
       amount allocated per formula child. (See Line                   
       12)                                                             

  \-   Multiply the amount allocated per formula child                 
       by the derived number of Census poor children                   
       transferring to determine that amount of Title I                
       funds that Milwaukee would transfer to other                    
       LEAs.                                                           
  ---- ------------------------------------------------ -------------- --------------