# **GUIDANCE FOR THE**

# **WILLIAM F. GOODLING EVEN START**

# **FAMILY LITERACY PROGRAMS**

# PART B, SUBPART 3 OF TITLE I

# OF THE 

# ELEMENTARY AND SECONDARY EDUCATION ACT (ESEA)

![](media/image1.png){width="2.6493055555555554in"
height="2.6493055555555554in"}

**UNITED STATES DEPARTMENT OF EDUCATION**

**WASHINGTON, DC**

**SEPTEMBER 2003**

#  

**[TABLE OF CONTENTS]{.underline}**

## Introduction 

## 

## Background page 2

## 

> Purpose of the Guidance page 3

### State Administration 

State Plans page 4

#######  Committee of Practitioners page 4

*Membership*

State-Level Activities page 5

####  Administration

####  Technical Assistance

*Developing and Using Even Start Indicators of Program Quality*

Competition for Subgrants page 8

####  Review Panel

> *Selection Criteria*
>
> *Eligible Entity*

#########  Project Funding page 12

*Minimum Subgrant Amounts*

*Federal and Local Share*

*Indirect Costs*

#########  Duration of a Project page 15

####  Start-Up Period

*Continuing Eligibility*

*Insufficient Progress*

### Local Administration 

Program Elements page 17

*Identification and Recruitment of Families Most In Need of Even Start
Services*

*Screening and Preparation of Participants*

*Flexible Scheduling and Support Services*

*High-Quality, Intensive Instructional Services*

*Staff Qualifications*

*Staff Training*

*Home-Based Instructional Services*

*Year-Round Services*

*Coordination with Other Programs*

*Instructional Programs Based on Scientifically Based Reading Research*

*Attendance and Retention*

*Reading Readiness Activities Based on Scientifically Based Reading
Research*

*Continuity of Services*

*Providing Services to Families Most In Need*

*Local Independent Evaluation*

Participant Eligibility page 23

####  Parents

####  Children

*Parents or Children in Private Schools*

####  Other Family Members

####  Eligible Participants Enrolled in Other Programs

##### Migrant and Indian Families

####  Continuing Family Eligibility

#### Temporary Absence from the Project

Local Application page 27

Fiscal Issues page 27

####  Title I, Part A Collaboration

*Allowable Costs*

*Unallowable Costs*

*Maintenance of Effort*

## National Evaluation, Local Evaluation, and Indicators of Program Quality 

####  

####  National Evaluation page 32

*Classroom Literacy Interventions and Outcomes Study (CLIO)*

####  Local Evaluation page 34

###  Indicators of Program Quality page 34

### Additional Resources for Family Literacy 

Common Definition of Family Literacy page 35

Title I, Part A page 35

Early Reading First, Title I, Part B, Subpart 2 page 35

Migrant Education, Title I, Part C page 36

Head Start page 37

Adult Education page 37

Bureau of Indian Affairs page 37

Education for Homeless Children and Youth, (McKinney-Vento Act) page 38

# **GUIDANCE FOR THE WILLIAM F. GOODLING**

# **EVEN START FAMILY LITERACY PROGRAMS**

###### SEPTEMBER 29, 2003

## [INTRODUCTION]{.underline}

Even Start is an education program for the Nation's low-income families
that is designed to improve the academic achievement of parents and
their young children, especially in the area of reading. Researchers,
teachers, and administrators alike now acknowledge the vital importance
of high-quality early childhood education for all children. Young
children who have good vocabularies and who are taught early reading
skills before they start school are more likely to become good readers
and to achieve academic success throughout their school careers.
Education experts also acknowledge that parents play a critical role in
the language and intellectual development of their children. Children
who have parents who talk and play with them and who read to them have
an important advantage. And parents who themselves are competent readers
are more likely to have good jobs and be able to help their own children
in school. Even Start provides educational services for the family,
parents and children alike, so that adults and their children will be
able to take advantage of and benefit from the tremendous opportunities
available to them in this Nation. For adults and children with limited
English proficiency, Even Start helps them make progress toward
acquisition of the English language and attainment of a high level of
literacy.

The Even Start Family Literacy program was first enacted in 1988 as Part
B of Chapter 1 of Title I of the Elementary and Secondary Education Act
of 1965 (ESEA). Most recently, the program was reauthorized and amended
by the No Child Left Behind Act of 2001 (NCLB). With the enactment of
NCLB, two programs that complement Even Start are the Reading First and
Early Reading First programs. The Reading First program gives funds to
States to invest in scientifically based reading instructional programs
for the early grades; and the Early Reading First Program gives funds to
districts and other entities to support the early language, literacy,
and pre-reading development of preschool-age children.

Even Start started in FY 1989 with an initial \$14.8 million
appropriation that supported 76 projects and 2,460 families. By FY 2000,
the appropriation was \$150 million, and 860 projects served 36,000
families. In FY 2003, the \$248.4 million appropriation will fund some
1,200 projects that will serve more than 50,000 families.

From the total Even Start appropriation, the majority of the funds go to
States for State-administered subgrants. With the remaining funds set
aside at the Federal level, the following activities are conducted: (1)
migrant, Outlying Areas, and Indian tribal programs; (2) a women\'s
prison demonstration project; (3) evaluation, technical assistance,
program improvement, and replication activities; (4) research on family
literacy; and (5) Statewide family literacy initiative grants (depending
on the appropriation level).

**BACKGROUND**

Even Start offers promise for helping to break the intergenerational
cycle of poverty and low literacy in the Nation. The program integrates
early childhood education, adult literacy (adult basic and
secondary-level education and/or instruction for English language
learners), parenting education, and interactive parent and child
literacy activities into a single, unified family literacy program. The
design is based on the premise that these components build on each other
and that families need to receive high-quality instructional services in
all four areas \-- not just one or two \-- in order to bring lasting
change and effectively improve parents' and children\'s literacy
achievement. Even Start supports integrated family literacy services for
parents and children, primarily from birth through age seven, and has
three interrelated goals:

-   to help parents improve their literacy or basic educational skills;

-   to help parents become full partners in educating their children;
    and

-   to assist children in reaching their full potential as learners.

The term "family literacy services" is defined in section 9101(20) of
the ESEA as services provided to participants on a voluntary basis that
are of sufficient intensity in terms of hours, and of sufficient
duration, to make sustainable changes in a family, and that integrate
all of the following instructional activities:

(A) Interactive literacy activities between parents and their children.

(B) Training for parents regarding how to be the primary teacher for
    their children and full partners in the education of their children.

(C) Parent literacy training that leads to economic self-sufficiency.

(D) An age-appropriate education to prepare children for success in
    school and life experiences.

At minimum, a successful Even Start project should: build on
high-quality, community resources; employ qualified staff; carry out
instructional activities grounded in scientifically based reading
research; be able to document significant literacy achievement results
(for adults and children) for the majority of families served; and make
sufficient program progress as defined by the State.

We have learned from the previous national evaluations of Even Start
that:

-   The instructional focus must be on literacy and cognitive
    development.

-   Intensity of services and duration of program participation are
    correlated with participant achievement.

-   Data must be used for program improvement.

-   State and local programs must develop and implement a well-defined
    system of ongoing program monitoring and evaluation that focuses
    upon effective practices and program results.

**PURPOSE OF THIS GUIDANCE**

This Guidance for the William F. Goodling Even Start Family Literacy
Programs is written to assist States and local projects in
understanding, administering, and implementing the Even Start program.
The Guidance reflects changes made to the program by the Literacy
Involves Families Together (LIFT) Act of 2000 that are reinforced and
further strengthened by the No Child Left Behind Act of 2001. Guidance
in this document replaces all prior nonregulatory guidance for Even
Start and also addresses questions raised by State and local officials
regarding the law. States may refer to this guidance when administering
funds under the State-administered portion of the Even Start program,
and local recipients of Even Start funds may refer to this guidance when
administering or operating projects supported by subgrants awarded by
States or by direct grants from the U.S. Department of Education. This
document includes an explanation of the statutory requirements
authorized by NCLB and provides guidance for carrying out these
requirements.

Citations in the document, unless otherwise indicated, are to the ESEA.

This document does not impose any requirements beyond those in the Even
Start statute and other applicable Federal statutes and regulations.
While States may consider this guidance in developing their own
guidelines and standards, they are free to develop alternative
approaches that are consistent with applicable Federal statutes and
regulations. In other words, this document contains acceptable but not
exclusive guidance concerning Even Start. However, compliance with the
guidance in this document will be deemed by U.S Department of Education
(ED) officials, including the Inspector General, as compliance with the
applicable Federal statutes and regulations.

**[STATE ADMINISTRATION]{.underline}**

The Department awards formula grants to State educational agencies (SEAs
or States), with each State receiving funding based on the relative
proportion of funds it receives under the Part A of Title I allocation
formula. States subsequently make competitive discretionary subgrant
awards to partnerships of local educational agencies (LEAs) and other
public and private entities for Even Start Family Literacy projects.

**State Plans**

States must submit a State plan to the U.S. Department of Education for
their administration of Even Start, but may apply for Even Start funds
either through a consolidated State plan under section 9302 or through a
separate Even Start State plan. (See the Education Department General
Administrative Regulations (EDGAR), sections 76.100 -- 76.106.)

## Committee of Practitioners

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

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

***Membership***

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

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

-   administrators;

-   teachers, including vocational educators;

-   parents;

-   members of local boards of education;

-   representatives of private school children; and

-   pupil services personnel.

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

**State-Level Activities**

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

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

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

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

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

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

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

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

#### Administration

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

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

#### Technical Assistance

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

In addition, a State may use a portion of the non-administrative
State-level funds it has reserved to provide technical assistance to
Even Start projects under section 1233(a)(2), to improve those projects
and replicate those of high quality. If the State chooses to provide
technical assistance under section 1233(a)(2) to improve or replicate
Even Start projects, it must also do so through a subgrant or contract
with another entity. A State may also use a portion of the
non-administrative State-level funds it reserves to provide technical
assistance and training under section 1234(c), to assist local Even
Start projects in improving the quality of their family literacy
services (that is, to improve one or more of the Even Start core
components that make up "family literacy services"). The State must
provide this technical assistance and training through one or more
subgrants, contracts, or cooperative agreements with an entity that has
experience in offering high-quality training and technical assistance to
family literacy providers. In addition, the State must give priority to
programs of low quality as evaluated based on a State's indicators of
program quality.

For local programs that the State determines to have demonstrated
effectiveness, the State also may use technical assistance funds under
section 1234(c) to help those programs access and leverage additional
funds to expand services to families and reduce waiting lists for
services, including through using such mechanisms as requesting and
applying for non-Federal resources.

######## 

######## 

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

######## 

######## Developing and Using Even Start Indicators of Program Quality

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

Unlike the technical assistance and training that a State provides under
sections 1233(a)(2) and 1234(c), a State may provide technical
assistance and training under section 1240 to local subgrantees and
evaluators on its indicators of program quality either directly or
through a contract with another qualified entity.

**Competition for Subgrants**

The Even Start statute establishes certain required information that
each local subgrant application must contain. (Section 1237) However,
each State may develop its own application for funding and may require
additional information relevant to its own subgrant competition. (EDGAR,
section 80.37(a)) For example, a State may require applicants to address
that State's Even Start indicators of program quality, priorities for
funding that target areas that are especially underserved and in need of
Even Start services, or any other relevant criteria to obtain the most
qualified applicants. (See Local Application section.) However, any
State priorities must be consistent with the statutory competitive
priorities in section 1238(a)(2) explained below.

A State must follow certain statutory requirements in awarding
subgrants, including using statutory selection criteria and statutory
priorities and using a review panel that includes certain required
members. (Section 1238(a), and the Review Panel and Selection Criteria
sections.) However, except as required by the Even Start statute or
other Federal statutes or regulations, a State follows its own policies
and procedures when awarding subgrants and, therefore, has substantial
discretion over the competitive process for allocating funds to
high-quality local projects that can help families most in need of Even
Start services attain literacy achievement results. (EDGAR, section
80.37(a)) For example, a State's process could include such things as
on-site reviews, convening of panelists in one location for a paper
review, or a two-tiered review process (using a combination of an
on-site review and paper review).

Before issuing their instructions for a subgrant competition, the
Department encourages States to consult with their Committees of
Practitioners in developing the application review process, and any
additions to the statutory selection criteria, and priorities that are
consistent with those statutory requirements. (See Committee of
Practitioners section.)

#### Review Panel

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

***Selection Criteria***

The review panel evaluates and approves local applications in accordance
with the statutory selection criteria and priorities in section 1238(a)
of the ESEA and any additional State requirements that are consistent
with those statutory selection criteria and priorities. Those criteria
include the likelihood of success in meeting the purposes of the Even
Start program, and effectively implementing the 15 required program
elements (see the Local Administration -- Program Elements section). The
approved applications also must be representative of urban and rural
regions of the State. (Section 1238(a)(1)(G))

In addition, the applicant must demonstrate that the area to be served
has a high percentage or a large number of children and families who are
in need of Even Start services as indicated by high levels of poverty,
illiteracy, unemployment, limited English proficiency, or other
need-related indicators. (Section 1238(a)(1)(B)) Applicants must also
show how they will provide services for at least a three-year age range,
demonstrate the greatest possible cooperation and coordination between a
variety of relevant service providers, include a cost-effective budget,
demonstrate the applicant's ability to provide the local share of the
program's costs, and show the greatest promise for providing models that
may be adopted by other family literacy projects and other LEAs.
(Sections 1238(a)(1)(C)-(F) and (H))

The SEA must give priority to applications that target services to areas
of the State with a high percentage or large number of children and
families in need of Even Start services, as indicated by high levels of
poverty, illiteracy, unemployment, limited English proficiency, or other
similar need-related factors. (Section 1238(a)(2)(A)) Examples of other
similar need-related factors, as listed in section 1238(a)(1)(B), are: a
high number or percentage of children to be served by the program who
reside in a school attendance area eligible for participation in Title
I, Part A programs, a high number or percentage of parents who have been
victims of domestic violence, and a high number or percentage of parents
who are receiving "Temporary Assistance to Needy Families." In addition,
the SEA must give priority to applications for projects that are located
in areas designated as empowerment zones or enterprise communities.
(Section 1238(a)(2)(B)) To find areas in the State that have been
designated as empowerment zones or enterprise communities, contact the
Governor's office.

#### 

#### Eligible Entity

To qualify as an "eligible entity" for an Even Start subgrant, an
applicant must be a partnership between one or more LEAs
[and]{.underline} one or more nonprofit community-based organizations,
public agencies other than an LEA, institutions of higher education
(including two- and four-year institutions), or public or private
nonprofit organizations of demonstrated quality other than an LEA.
(Section 1232(e)(1))

A partnership may take a number of different forms and can designate any
partner as the fiscal agent for the subgrant or form a formal legal
entity that is a partnership to serve as the fiscal agent. However, in
each case, the partners should clearly delineate their respective roles
and functions, identify the partner(s) that will serve as the fiscal
agent, and agree in writing to any required assurances and
authorizations.

The partnership provisions in the Even Start law strengthen the
connections between schools and communities and improve a project's
ability to reach families in greatest need of services through community
outreach. The connection of a project to an LEA and a school's resources
also allows for greater ease in the continuity of family literacy
services, especially when children make the transition between an early
childhood education provider to a school.

In order to reach out to the greatest number of possible applicants, the
Secretary encourages States to inform all potentially eligible partners
of the availability of funds for an Even Start program and the process
they should follow in applying for a subgrant.

Even Start projects are cooperative projects that build on high-quality,
existing community resources to create a new range of services to serve
families\' educational needs. (Section 1231(2)(A)) In addition to the
formal partners who comprise the eligible entity applying for funding
and administering the grant, an Even Start project has a number of
collaborators who provide direct instructional or support services to
participating families and may contribute to the local project's
matching or cost share. These collaborators might include such local
agencies as: the community library, the community college, the welfare
agency, a day care program, a professional association, a faith-based
organization, or a volunteer organization. The Department encourages
projects to cultivate community investment in the program by building on
high-quality community resources or bolstering the quality of these
community resources, if necessary by supplementing those services.

**Project Funding**

***Minimum Subgrant Amounts***

The Secretary encourages States to make subgrants that are of sufficient
size, scope, and quality to be effective in meeting the purposes of Even
Start, allow projects to meet their program objectives and participant
achievement goals, and make maximum use of the resources available at
the local community level. (Section 1233(b)) SEAs are encouraged to make
continuation awards of sufficient size to ensure each project's
continuity of high-quality services and successful program outcomes and
participant achievement results. After reserving funds for
administration and technical assistance and funding continuation grants
for projects that demonstrate sufficient progress toward meeting their
individual program objectives and the State's Even Start indicators of
program quality, States must use the remaining funds to award new
subgrants. (Section 1233(b))

The minimum amount of Federal funds required for a subgrant for programs
in their first through eighth year of operation generally is \$75,000
per year. The minimum subgrant size of \$75,000 per year is reduced to
\$52,500 for recipients in their ninth and succeeding years. If less
than \$75,000 of Federal funds remain available for a fiscal year after
the State has awarded all other subgrants, the SEA may fund one subgrant
of less than \$75,000 for a project in its first through eighth year of
operation for that fiscal year, or one subgrant of less than \$52,500
for a project in its ninth or subsequent year of operation for that
fiscal year. However, each State may have only one project operating
under these conditions at any given time. (Section 1233(b)(2))

***Federal and Local Share***

An Even Start project's funding is comprised of a portion of funds
attributable to the Federal grant (Federal share) and a portion
contributed by the project (local share). The amount of the local share
in the first year of the local project's grant must be at least 10
percent of the [total cost]{.underline} of the project. In the second
year of Federal funding, the project must provide at least 20 percent of
the total cost of the second-year budget; in the third year, at least 30
percent of the third-year total budget cost; in the fourth year, at
least 40 percent of the fourth-year total budget cost; in the fifth
through eighth years, at least 50 percent of each year's total budget
cost; and in each subsequent year, at least 65 percent of each year's
total budget cost. (See Duration of a Project -- Continuing Eligibility
section.) (Section 1234(b)(1))

It is not necessary to reduce a project's grant award each year in order
to satisfy the requirements for the progressively increased local share.
Instead, a State may keep a project's grant award constant and require a
sufficient increase in the local share. Or, a State may even increase
the grant award for subsequent years, so long as there is a sufficient
local share. The important consideration is that each project receives
sufficient funds to operate a high-quality program that generates
successful participant achievement results.

A local project may provide its local share in cash or through in-kind
contributions, fairly evaluated. The project may obtain its local share
from any source, including any Federal funds other than Even Start
funds. (Section 1234(b)(1)(B)) For an explanation of how to place a
value on specific third-party in-kind contributions, see EDGAR, section
74.23 (for institutions of higher education and non-profit
organizations) and section 80.24 (for LEAs and Indian tribes).

An Even Start project may only use allowable costs to satisfy the
project's local share. (See EDGAR, section 80.24.) For example, indirect
costs are not allowable for Even Start local projects and, therefore,
may not be used to meet a project's local share. (Section 1234(b)(3))

In addition, a project may only count costs or values of third-party
in-kind contributions toward satisfying its local share for one Federal
grant or contract at a time. For example, if Head Start is a
collaborating agency with an Even Start project and counts a volunteer
teacher's time for all of the children (including the children
participating in Even Start) toward satisfying a Head Start matching
requirement, the Even Start project may not count that same teacher's
time toward meeting the Even Start local share. In the alternative, the
Head Start program and the Even Start program may agree to split the
value of the volunteer teacher's time proportionately, based on the
numbers of Head Start and Even Start children served by that teacher,
between the two programs for the purpose of each program's respective
matching requirement.

#### 

#### Indirect Costs

Under the statute, Even Start funds generally may not be used for the
indirect costs of a local Even Start project. Under certain
circumstances, the Secretary may waive this limitation for Indian tribe
or tribal organization Even Start grants from the Department. (Section
1234(b)(3))

**Duration of a Project**

A local project's grant period may not exceed four years. (Section
1238(b)(1)) The Secretary encourages SEAs to award grants for periods of
at least two years to allow projects sufficient time to implement fully
all program elements and core components and have one year of data to
use for demonstrating continuous improvement. After the end of a
project's grant period, the Even Start project may reapply and compete
for additional grants or subgrants of Even Start funds. (Section
1238(b)(5))

#### Start-Up Period

Implementing a new Even Start project presents many challenges, and
experience has shown that the average new project takes several months
to become fully operational. At an applicant's request, an SEA may
provide funds to a subgrantee for a three-to-six month start-up period
during the first year of a grant period before requiring full
implementation of the project. During this start-up period, a project
may use its Even Start funds for such activities as staff recruitment
and training, and coordination of services. (Section 1238(b)(2))

***Continuing Eligibility***

In making continuation awards from year to year during a project's grant
period, an SEA has considerable discretion over the amount of the
continuation award and may weigh a variety of factors in determining
whether a subgrantee has made sufficient progress. However, in an SEA's
review of a subgrantee's progress, it must always consider the
subgrantee's progress in meeting the objectives of its program and its
progress on the State's Even Start indicators of program quality.
(Section 1238(b)(3))

***Insufficient Progress***

An SEA may refuse to award continuation funds to a subgrantee if the SEA
determines that the program has not made sufficient progress, as
evaluated against the State's Even Start indicators of program quality.
Before discontinuing a subgrantee, a SEA must first provide technical
assistance to see if the program can improve its progress on the State
indicators of program quality and also give the subgrantee notice and an
opportunity for a formal or an informal hearing. (Section 1238(b)(4))
The hearing requirement can be satisfied by the SEA providing a formal
hearing on the record as described above under the Selection Criteria
section, or by providing an informal hearing before the denial and the
formal hearing on the record if requested by the applicant after the
final denial of funds. SEAs are encouraged to keep records describing
the technical assistance that has been given in compliance with these
requirements.

**[LOCAL ADMINISTRATION]{.underline}**

**Program Elements**

Each local Even Start program is a complex project comprised of many
different elements that when added, should equal more than the sum of
each individual element. The fifteen statutory required program elements
for Even Start projects, primarily grounded in research and national
evaluation data, are intended to ensure that projects offer high-quality
services so that all participating families can achieve their literacy
goals. (Section 1235)

It is important to note that all Even Start projects funded both before
and after the December 21, 2000 LIFT Act reauthorization are subject to
that law's new requirements and, therefore, must be implementing all
fifteen required program elements. Note that, the following program
elements (numbered by their statutory paragraph number in section 1235)
were new in 2000: #5 (staff qualifications); #10 (instructional programs
based on scientifically based reading research); #11 (attendance and
retention of families); #12 (reading readiness activities based on
scientifically based reading research); and #13 (continuity of family
literacy services). In addition, program element numbers 8 (year-round
services) and 15 (local independent evaluation) have been amended. Local
applications for continuing subgrantees should be amended to reflect
compliance with the new requirements. (Section 1237(c)(2)(B))

These program elements clarify the methods for the best implementation
of the four Even Start core requirements \-- early childhood education,
adult literacy (adult basic and secondary-level education and/or
instruction for English language learners), parenting education, and
interactive literacy activities between parents and their children \--
and the activities needed to support successful programs. Program
elements 1, 2, 11, and 14 relate to the targeting of Even Start services
to the families most in need and ready to commit to the four-component
program. Program elements 3-8 and 10 and 12 focus on the delivery of
high-quality instructional and support services so participants can
better achieve literacy gains. Program elements 9 and 13 describe
coordination with relevant programs to complement and supplement the
work of the local Even Start project. And program element 15 highlights
program accountability and linkages between program implementation and
participant outcomes. An elaboration of each program element is provided
below.

1.  ***Identification and Recruitment of Families Most In Need of Even
    Start Services***. (Section 1235(1)) Each project must identify and
    recruit families most in need of Even Start services, as indicated
    by a low level of income, a low level of adult literacy or English
    language proficiency of the eligible parent or parents, and other
    need-related indicators. It is important to note the distinction
    between families that are considered "eligible" for Even Start
    services and those actually served by a project. Even Start projects
    serve a small subset of the "eligible" population and must target
    families who are most in need of family literacy services.

2.  ***Screening and Preparation of Participants***. (Section 1235(2))
    Each project must screen and prepare parents (including teenage
    parents) and children to enable such parents and children to
    participate fully in Even Start activities and services. This
    includes testing of parents to ensure eligibility for services,
    referral to necessary counseling, other developmental and support
    services, and related services. A project should ensure that each
    member of an eligible family is fully ready to commit to the entire
    four-component Even Start program prior to considering them for
    program participation.

3.  ***Flexible Scheduling and Support Services.*** (Section 1235(3))
    Each project must be designed to accommodate participants' work
    schedules and other responsibilities. This includes providing
    support services, when such services are unavailable from other
    sources, which are necessary for full participation in the Even
    Start program. Flexibility in scheduling classes in order to
    optimize family participation and retention is especially critical
    given the demands of work participation requirements for public
    assistance, as is providing support services such as transportation,
    child care, and meals. However, the main focus of the Even Start
    program should still remain on providing high-quality instructional
    services and ensuring that participants make literacy gains.

4.  ***High-Quality, Intensive Instructional Programs***. (Section
    1235(4)) Each project must 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 core components is considered an instructional program.

***5. Staff Qualifications***. (Section 1235(5)) Each project must meet
the following staff qualification requirements for staff whose salaries
are paid in whole or in part with Even Start funds. Staff who are not
paid with Even Start funds, such as staff supported by collaborators or
partners, are not subject to the requirements of this program element.
However, whatever the funding source, the Secretary encourages a project
to make a concerted effort to use the most highly qualified staff
available.

> [Staff providing academic instruction]{.underline}
>
> Instructional staff are considered those staff members who provide
> instruction in the four core Even Start components.

*All instructional staff --* by December 21, 2004, a majority of the
individuals providing academic instruction:

1.  must have obtained an associate\'s, bachelor\'s, or graduate degree
    in a field related to (see Q11) early childhood education,
    elementary or secondary school education, or adult education; and

> 2\. if applicable, must meet qualifications established by the State
> for early childhood education, elementary or secondary school
> education, or adult education provided as part of an Even Start
> program or another family literacy program. (Section 1235(5)(A)(i))

*New instructional staff* who are hired to work in Even Start projects
must, when they are hired:

1.  have obtained an associate\'s, bachelor's, or graduate degree in a
    field related to early childhood education, elementary or secondary
    school education, or adult education; and

2.  if applicable, meet qualifications established by the State for
    early childhood education, elementary or secondary school education,
    or adult education provided as part of an Even Start program or
    another family literacy program. (Section 1235(5)(B))

[Project Director]{.underline}

Not later than December 21, 2004, the individual responsible for
administration of family literacy services must have received training
in the operation of a family literacy program. (Section 1235(5)(A)(ii))

[Paraprofessionals]{.underline}

> Not later than December 21, 2004, paraprofessionals who provide
> support for academic instruction must have a high school diploma or
> its recognized equivalent. (Section 1235(5)(A)(iii))

6.  ***Staff Training.*** (Section 1235(6)) Each project must train
    staff, including child care staff, to develop the skills necessary
    to work with parents and young children in the full range of Even
    Start instructional services offered. Effective staff professional
    development may include a set of activities that produce a
    demonstrable and measurable effect on student academic achievement,
    and may include activities such as coaching and mentoring. While not
    directly applicable to the Even Start program, you may find useful
    concepts on high-quality professional development in Part B of the
    Title II, Part A guidance (Improving Teacher Quality, State Grants),
    located at www.ed.gov/offices/OESE/SIP/TitleIIguidance2002.doc.

7.  ***Home-Based Instructional Services.*** (Section 1235(7)) Each
    project must provide and monitor integrated instructional services
    to participating parents and children through home-based services.
    Even Start projects should provide home-based services for every
    Even Start family on a regular basis. These services should be
    designed to improve the literacy skills of parents or their
    children, or both, and communicate the message that the home is a
    child's first classroom, just as the parent is a child's first
    teacher.

8.  ***Year-Round Services.*** (Section 1235(8)) Each project must
    operate on a year-round basis, including the provision of some
    program services, instructional and enrichment, during the summer
    months. This allows families to receive continuous opportunities to
    improve their learning and avoid the drop-off in achievement that
    often occurs during long breaks or vacations. Therefore, the
    families served during the summer should be the same families served
    during the school year.

9.  ***Coordination with Other Programs.*** (Section 1235(9)) Each
    project must coordinate with relevant programs, such as Title I,
    Part A, Early Reading First, Reading First, Migrant Education,
    21^st^ Century Community Learning Centers, Head Start, and volunteer
    literacy programs. Local projects must also coordinate with any
    relevant programs under the Adult Education and Family Literacy Act,
    the Individuals with Disabilities Education Act, and Title I of the
    Workforce Investment Act of 1998, and any other relevant programs.

10. ***Instructional Programs Based on Scientifically Based Reading
    Research***. (Section 1235(10)) Each project must use instructional
    programs based on scientifically based reading research (as defined
    in section 1208) for children and adults, to the extent such
    research is available. The underlying premise of basing
    instructional programs on scientifically based reading research is
    that using strategies and techniques that are demonstrated to be
    effective through the application of scientific research methods
    will give States, districts, and schools a higher probability that
    children enter school prepared to learn to read and adults
    significantly improve their literacy and help their children succeed
    in school.

11. ***Attendance and Retention.*** (Section 1235(11)) Each project must
    encourage participating families to attend regularly and to remain
    in the program a sufficient time to meet their program goals. Each
    individual program determines what is reasonable attendance for a
    family in order to achieve its educational goals and to remain as
    active participants in the program. If a family is not attending
    regularly, the project needs to work with the family to determine
    what is needed to allow them to be active participants. If such
    attempts still fail, the project should transition the family out of
    Even Start, perhaps to a more suitable program, and recruit a more
    committed family.

12. ***Reading Readiness Activities Based on Scientifically Based
    Reading Research.*** (Section 1235(12)) Each project must base its
    reading readiness activities for preschool children on
    scientifically based reading research (as defined in section 1208),
    to the extent available, to ensure children enter elementary school
    with the language, cognitive, and early reading skills necessary for
    reading success. Research shows that the most effective ways to
    reach this goal include: 1) creating classroom environments rich in
    age-appropriate print (from sources such as books, labeling, and
    posting the alphabet and children's pre-writing work); 2) teachers
    who deliver intentional, contextualized, and explicit instruction
    that supports children's age-appropriate development of oral
    language, phonological awareness, print awareness, and alphabet
    knowledge; 3) progress monitoring to determine which skills children
    are learning; and 4) intensive and ongoing professional development
    that includes mentoring and coaching in the classroom.

13. ***Continuity of Services.*** (Section 1235(13)) Each project must
    promote the continuity of family literacy, to the extent applicable,
    to ensure that individuals retain and improve their educational
    outcomes. Educational services supplementing in-school instruction
    provided through the early school years can be critical to
    sustaining gains made during the preschool years.

14. ***Providing Services to Families Most In Need.*** (Section
    1235(14)) Each project must ensure that the program will serve those
    families most in need of Even Start activities and services. This is
    related to Program Element #1.

15. ***Local Independent Evaluation.*** (Section 1235(15)) Each project
    must provide for an independent evaluation of the program that it
    will use for program improvement. The independent evaluation
    generally is conducted annually and provides critical data and
    information to the local program on the performance of each family,
    as well as on the quality of the implementation of the core
    components and program elements. The project must use the data and
    information for participant progress monitoring and continuous
    program improvement to lead to better participant outcomes. (See the
    Local Evaluation section of this guidance for further information.)

Although included as an application requirement rather than as a program
element, each project must also provide services for at least a
three-year age range of children, which may begin at birth. (Section
1238(a)(1)(C) and the State Administration -- Selection criteria
section.)

**Participant Eligibility**

To be eligible for Even Start, a family that qualifies as "most-in-need"
(Program Element section, Program Element #1) must have at least one
eligible parent and one eligible child, as described below,
participating together. (Section 1236)

#### Parents

The definition of "parent" includes, in addition to a biological or
adoptive parent, a legal guardian or other person standing "in loco
parentis." Generally, "in loco parentis" means a person acting in place
of a parent and may include a person such as a grandparent or stepparent
with whom the child lives, or a person legally responsible for the
child's welfare. (Section 9101(31))

To be eligible for Even Start, an adult must be the "parent" of an
eligible child, and either be:

(1) eligible for participation in adult education and literacy
    activities under the Adult Education and Family Literacy Act;

(2) within the State's compulsory school attendance age range, so long
    as an LEA provides or ensures the availability of the basic
    education component required under this part; or

(3) attending secondary school.

> (Section 1236(a)(1))

Eligible participants under the Adult Education and Family Literacy Act
are individuals:

(1) who have attained 16 years of age;

(2) who are not enrolled or required to be enrolled in secondary school
    under State law; and

(3) who\--

\(i\) lack sufficient mastery of basic educational skills to enable the
individuals to function effectively in society;

\(ii\) do not have a secondary school diploma or its recognized
equivalent, and have not achieved an equivalent level of education; or

\(iii\) are unable to speak, read, or write the English language.

(Section 203(1) of the Adult Education and Family Literacy Act, 20
U.S.C. 9202(1))

#### Children

Children at birth through age seven are eligible to participate in Even
Start if their parent or parents are eligible for and participating in
Even Start services. (Section 1236(a)(2))

Children over the age of seven also are eligible to participate in Even
Start with an eligible parent if the local project collaborates with a
program under Title I, Part A of ESEA, and Title I, Part A funds
contribute to the cost of providing Even Start program services to those
children. Although the participation of families with children over the
age of seven is now permissible, the focus of a local program must
continue to remain on families with young children. (See the Title I,
Part A Collaboration section of this guidance for further information.)

***Parents or Children in Private Schools***

# The equitable participation provisions, applicable to Even Start for the first time under NCLB, are found in sections 9501-9504. These provisions require recipients of Federal funds 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. The services must be provided by the eligible entity or through a contractor that is independent of any private school or religious organization.

This means that Even Start projects must consult with private school
officials to determine how to ensure that private school students
(elementary and secondary) are given the same opportunity to participate
in the Even Start project as their public school counterparts. (See the
Parents and Children sections of this guidance above for further
information on who is eligible for Even Start, whether they attend
public or private schools.) Specifically, the eligible entity must
consult with private school officials to determine how to provide
equitable Even Start services to eligible families in Even Start that
have children enrolled in private elementary schools or parents enrolled
in private secondary schools.

Consultation between public and private school officials must occur
before any decision is made that could affect the ability of private
school families to participate (that is, as the project is being
designed and before the application is submitted to the subgrant
competition) and should continue throughout the implementation and
assessment of activities. Consultation generally must include
discussions on such issues as: how the private school families' needs
will be identified; what services will be offered; how and where the
services will be offered and provided; who will provide the services;
how the services will be assessed and how the results of assessments
will be used to improve those services; the amount of funds available
for services; the size and scope of services to be provided; and how and
when the LEA/agency will make decisions about the delivery of services.
The Even Start services for eligible private school students must be
comparable to the services for their public school counterparts in terms
of quality, scope, and opportunity for participation. In addition, total
program expenditures for services and benefits for participating
elementary and secondary private school students must be equal (taking
into account the relative numbers of those private and public school
students participating in the Even Start program and their needs) to the
expenditures for participating elementary and secondary public school
students.

#### Other Family Members

Family members of eligible participants may participate in activities
and services provided by an Even Start project, when appropriate, to
serve the purposes of the program. For example, if the participation of
an older sibling would enhance learning for the participating parent and
child, then the older sibling may participate in appropriate Even Start
activities such as home-based interactive literacy activities between
parents and their children.

#### Eligible Participants Enrolled in Other Programs

So long as participating families meet the Even Start eligibility
requirements described in section 1236, and qualify as most in need of
Even Start services, they may participate in the program. Even Start is
designed to build on, rather than duplicate, already existing
high-quality community resources. Therefore, a child's enrollment in a
high-quality Head Start program or, for school-age children, enrollment
in a high-quality, regular school program, could satisfy the required
early childhood education component of Even Start. Likewise, a parent's
enrollment in a high-quality, adult basic education program could
fulfill the adult education component of the Even Start program. In both
examples, the Even Start project should provide supplemental learning
opportunities to reinforce what is being taught through its
collaborators and partners. The project\'s responsibility is to ensure
the family receives all four core components at high enough levels of
quality, either through a collaborator or directly from the project, in
order for families to make literacy achievement gains.

***Migrant and Indian Families***

Eligible migrant and Indian families in need of family literacy services
may participate like any other family in an Even Start project under the
State-administered program. Organizations serving migrant families or
Indian tribes or tribal organizations may also apply to SEAs for
subgrants in partnership with an LEA, if the organizations qualify as
one of the required entities under section 1232(e)(1)(B).

In addition, migrant and Indian families may participate in programs
funded through the Federal set-aside programs for migrant and federally
recognized Indian tribes and tribal organizations. For each fiscal year
in which the appropriation is greater than \$200 million, the Secretary
must reserve six percent of the funds appropriated for the Even Start
program (if the appropriation is \$200 million or less, five percent of
such amount) for grants to projects serving migrant families, the
outlying areas, and federally recognized Indian tribes and tribal
organizations. (Section 1232(a)(1)) However, if the same migrant or
Indian tribe or tribal organization receives both a grant from the
Secretary and a subgrant from the SEA for an Even Start project, the
funds may not be used for duplicative purposes (that is, the funds may
not be used to provide the same services to the same families). (EDGAR,
sections 75.531 and 76.760)

#### Continuing Family Eligibility

Families generally may participate in Even Start Family Literacy program
services until all family members become ineligible for participation.
In the case of families who enter the program with children ages birth
through seven, when the parent has achieved his or her educational
goals, the family continues to be eligible until all children in the
family reach age eight. In contrast, if all children in a family have
reached the age of eight and the participating parent has not achieved
his or her educational goals, the family continues to be eligible for
two more years until the youngest participating child is 10 years old or
until the parent is no longer eligible for adult education services
under the Adult Education and Family Literacy Act, whichever occurs
earlier. In both situations, if a family chooses to continue
participating in Even Start under the provisions for continuing family
eligibility, the family must participate in all remaining appropriate
Even Start services (parenting education, interactive parent and child
literacy activities, home visits) until the family exits the program.
(Section 1236(b)(2))

If the Even Start program collaborates with a Title I, Part A program
and Part A contributes to paying the cost of the Even Start program,
families are eligible and may participate in the Even Start program
until the parent reaches his or her educational goals, regardless of the
age of the child. However, the focus of the local program must continue
to remain on serving families with young children. Family ineligibility
in this situation occurs when the parent attains his or her educational
goals. (Section 1236(b)(3) and the Title I, Part A Collaboration section
of this guidance.)

#### Temporary Absence From the Project

Even Start is unique in that it is designed as a family literacy
program, in which the eligibility of parents and children is
interdependent. (Section 1236) To be eligible, at least one parent and
one or more eligible children must participate together in an Even Start
project. However, should a child or parent be temporarily absent due to
extenuating circumstances, the other eligible family members may
continue to receive Even Start services.

**Local Application**

In order to be eligible to receive a subgrant, an applicant must submit
an application to the SEA in the form and containing the information
required by the SEA. (See the Eligible Entity section of this guidance
for further information on what constitutes an eligible applicant.) At a
minimum, each application must demonstrate that the applicant has the
qualified personnel needed to develop, administer, and implement a
high-quality Even Start program and provide access to the special
training necessary to prepare staff for program implementation. (Section
1237(b)) Each application must also include a plan of operation and
continuous improvement for the program. (Section 1237(c)(1)) The plan
must include the following information, as well as any other information
required by the SEA:

(A) a description of the program objectives, strategies to meet those
    objectives, and how the objectives are consistent with the State\'s
    indicators of program quality;

(B) a description of the activities and services to be provided by the
    program, including a description of how the program will incorporate
    all of the program elements required by section 1235 (See the Local
    Administration -- Program Elements section.);

(C) a description of the population to be served and an estimate of the
    number of participants to be served;

(D) as appropriate, a description of the applicant\'s collaborative
    efforts with institutions of higher education, community-based
    organizations, the SEA, private elementary schools, or other
    eligible organizations, in carrying out the program;

(E) a statement of the methods that the project will use to: ensure that
    it will serve families most in need of Even Start activities and
    services, provide Even Start services to individuals with special
    needs such as individuals with limited English proficiency and
    individuals with disabilities, and encourage participants to remain
    in the program for a time sufficient to meet the program\'s purpose;

(F) a description of how the plan is integrated with other ESEA programs
    or other programs, as appropriate; and

(G) a description of how the plan provides for rigorous and objective
    evaluation of progress toward the program objectives described
    in (A) and for continuing use of evaluation data for program
    improvement.

Each plan submitted as part of an application is effective for the
duration of the subgrantee's participation in Even Start and may be
periodically reviewed and revised as needed. The plan may be submitted
as part of a consolidated local application. (Section 1237(d))

**Fiscal Issues**

An Even Start project must use Federal Even Start funds to support the
cost of providing family literacy services that involve parents and
children, primarily from birth through age seven, in a cooperative
effort to help parents become full partners in the education of their
children and to assist children in reaching their full potential as
learners. (Section 1234(a)) The remaining cost of the program may be
provided in cash or in kind from any source, including any Federal funds
other than Even Start. (See the Federal and Local Share and Indirect
Costs sections of this guidance for further information.)

#### Title I, Part A Collaboration

If a project collaborates with a program under Title I, Part A, and
Title I, Part A contributes to paying the cost of providing programs
under this part to children 8 years of age or older, the Even Start
project can allow the participation of families with children 8 years of
age or older. (See the Continuing Family Eligibility section of this
guidance.) However, the focus of the local program must continue to
remain on families with young children. (Section 1236(b)(5)) The intent
of this provision is not to divert substantial Even Start funds to
families with older children, but to encourage greater contribution from
the Title I, Part A program.

#### Allowable Costs

Projects may use Federal Even Start grant funds and matching resources
only for the allowable costs of those projects. (EDGAR, section 80.22)
For each type of organization, there is a separate set of Federal
principles for determining allowable costs. State-administered grants
that have LEAs as the fiscal agent, and Indian tribes and tribal
organizations, must use the cost principles in *OMB Circular A-87*.
Grantees that have institutions of higher education (IHEs) as the fiscal
agent must use the cost principles in *OMB Circular A-21*, and
non-profit organizations that are fiscal agents must use *OMB Circular
A-122*. (www.whitehouse.gov/omb/circulars/index.html)

The cost principles provide general rules for allowability, and in
addition, list alphabetically certain specific items of cost (such as
"materials cost"), indicating whether those specific cost items are
allowable, unallowable, or allowable only with the prior approval of the
awarding agency. In general, unless prohibited by the statute,
regulations, or cost principles, local projects may use Even Start funds
and matching resources for costs that are necessary and reasonable to
meet the objectives of their projects and provide each of the 15
required program elements, including the four core family literacy
service instructional components.

Following are some examples of allowable costs. Other allowable costs
are found in EDGAR and the applicable cost principles.

-   [Materials and supplies]{.underline}. Generally, a project may use
    Federal Even Start funds and matching resources to purchase
    materials and supplies related to the Even Start project. (See the
    applicable cost principles under "material costs" or "materials and
    supplies.")

-   [Equipment]{.underline}. Generally, capital expenditures for
    equipment are allowable as a direct cost when approved by the
    awarding agency. The cost principles define "equipment" as an
    article of nonexpendable, tangible personal property having a useful
    life of more than one year and an acquisition cost which equals the
    lesser of (a) the capitalization level established by the
    governmental unit for financial statement purposes, or (b) \$5,000.
    Items of equipment with an acquisition cost of less than \$5,000 are
    considered to be supplies under Circular A-87 and are allowable
    under all of the cost circulars as direct costs of Federal awards
    without requiring specific awarding agency approval. (See the
    applicable cost principles under the paragraph of selected cost
    items concerning "Equipment and other capital expenditures":
    *Circular A-87*, Attachment B, paragraph 19; *Circular A-21*,
    Section J, paragraph 16; *Circular A-122*, Attachment B, paragraph
    15.)

-   [Food and meals for project participants.]{.underline} A project may
    use Federal Even Start funds to purchase food and meals for project
    participants to the extent those expenditures are reasonable and
    necessary as a support service under section 1235(3), when
    unavailable from other sources and when necessary for a person's
    participation in the Even Start program. For example, providing food
    may be reasonable and necessary when academic instruction is
    provided in the evening and participants do not have time to eat at
    home before coming to the program, at recruitment functions, or when
    individuals otherwise would not participate in the program. However,
    entertainment costs, including meals when provided for the purpose
    of being a social activity or amusement, are unallowable under all
    of the cost principles.

-   [Minor remodeling.]{.underline} Even Start projects may use funds
    for the reasonable and necessary costs of minor remodeling, as that
    term is defined in EDGAR, section 77.1. Under that definition,
    "minor remodeling" means, in general, minor alterations to a
    previously completed building. The specific term does not include
    building maintenance and repairs, but both are allowable
    expenditures to the extent they are necessary and reasonable. The
    term excludes building construction or structural alterations to
    buildings, which are unallowable expenditures.

-   [Rental costs of buildings and equipment.]{.underline} Generally,
    reasonable rental costs are allowable under all of the OMB cost
    circulars, subject to specific requirements in each applicable OMB
    cost circular that should be reviewed before a project enters into a
    rental agreement. The rental or lease costs of buildings and
    equipment, which are owned by a partner to an Even Start grant (or
    to another entity with a less-than-arms-length relationship with any
    of the partners), generally are valued on a different basis than are
    buildings and equipment rented or leased from a third-party. (Refer
    to the applicable OMB cost circulars for more detail about
    valuation.)

-   [Transportation]{.underline}. Projects may spend Even Start funds on
    transportation for participants as a support service under section
    1235(3), when unavailable from other sources and when necessary for
    a person's participation in the Even Start program. Transportation
    costs must be reasonable and necessary. If a project wishes to
    provide this transportation through the lease or purchase of a
    vehicle, such a lease or purchase would be considered a capital
    expenditure and the applicable OMB cost circular rules for equipment
    and capital expenditures apply, including the requirement to obtain
    the approval of the awarding agency.

***Unallowable Costs***

Following are some examples of unallowable costs. Other unallowable
costs are found in EDGAR and the applicable cost principles.

-   [Indirect costs]{.underline}. Local Even Start projects may not use
    project funds (including Even Start funds and matching funds) for
    any indirect costs of a project. (Section 1234(b)(3)) The
    differences between direct and indirect costs are explained in the
    applicable cost principles described above. In general, indirect
    costs are those costs that are incurred for common or joint purposes
    among multiple cost objectives (for example, the Even Start program
    and the school district's program) and cannot be readily and
    specifically identified with a particular final cost objective
    without effort disproportionate to the results achieved (for
    example, the cost of heating and lights for a building in which
    multiple programs are located). States may use the Even Start funds
    that they reserve for State-level activities for indirect costs at
    the State level.

-   [Constructing, renovating, or acquiring real property.]{.underline}
    An Even Start project may not use Federal Even Start funds or
    matching resources to acquire real property, or for construction or
    renovation. (See EDGAR, section 75.533 for direct grantees of the
    Department, and section 76.533 for State-administered subgrants.)
    Construction includes structural alterations to buildings, but does
    not include minor remodeling (see above).

-   [Organized fundraising.]{.underline} Under *OMB Cost Circular A-87*,
    the costs of organized fundraising, including financial campaigns,
    solicitation of gifts and bequests, and similar expenses incurred to
    raise capital or obtain contributions are unallowable. However,
    expenditures of funds to obtain the statutorily required cost or
    matching share for Even Start grants are not considered to be
    unallowable fundraising.

***Maintenance of Effort***

Beginning with FY 2002, Even Start programs are subject to a
maintenance-of-effort requirement (section 9521), which is the same as
the requirement that has applied to Title I, Part A for a number of
years (section 1120(A)(a)). As applied to Even Start, the
maintenance-of-effort requirement means that an Even Start project may
receive funds only if the SEA determines that the project's LEA
partner's combined fiscal effort per student or the aggregate
expenditures of the LEA and the State with respect to the provision of
free public education by the LEA for the preceding fiscal year was not
less than 90 percent of the combined fiscal effort or aggregate
expenditures for the second preceding fiscal year. However, in cases
where a school district has failed to maintain effort in education
expenditures, ED may waive that requirement if such a waiver would be
equitable due to\-- (1) exceptional or uncontrollable circumstances such
as a natural disaster; or (2) a precipitous decline in the financial
resources of the local educational agency. For additional information on
the maintenance-of-effort requirement, you may want to talk with your
Title I State or LEA director.

**[NATIONAL EVALUATION, LOCAL EVALUATION,]{.underline}**

**[AND INDICATORS OF PROGRAM QUALITY]{.underline}**

#### National Evaluation

Since Even Start's first year, the legislation has included an
evaluation requirement at the national level. Though the legislative
mandate has changed slightly over the years, the national evaluation's
basic purposes have remained the same \-- to describe Even Start
projects and participants, to examine the performance and effectiveness
of Even Start projects, and to identify effective Even Start projects
for use in program improvement and technical assistance. There have been
three national Even Start evaluations since the inception of the
program.

The following overall findings have emerged from the three national
evaluations completed to date: 1) Even Start projects are generally able
to implement the legislatively required program elements. We cannot say
that all of the services provided by Even Start projects are of
excellent quality, but we do know that all of the legislatively required
program elements are being provided and that the letter of the law is
met by all but a very few grantees. 2) On average, Even Start
participants make gains on measures of literacy. These gains are
generally small, particularly given the very low literacy levels of
children and adults when they start the program. 3) When information has
been available from a randomly-assigned control group, Even Start
participants have made literacy gains; however, the gains are no greater
than the gains made by members of the control group.

The latest available evidence is from the third national Even Start
evaluation's Experimental Design Study (EDS). (To access a copy of the
*Third National Even Start Evaluation*, go to
www.ed.gov/rschstat/eval/disadv/evenstartthird/toc.html.) Compared with
the Even Start population, the 18 EDS projects over-represent Even Start
programs that serve ESL Hispanic families in urban areas. While such
over-representation means that care should be taken in applying the
findings to Even Start projects as a whole, almost 50 percent of the
families served by Even Start are Hispanic and about 50 percent of the
projects are in urban areas. Hence, the EDS findings apply to an
important and growing part of the Even Start population. The key
findings include:

-   While Even Start children and parents made gains on literacy
    assessments and other measures, children and parents in the 18 Even
    Start programs that participated in the EDS did not gain more than
    children and parents in the control group, about one-third of whom
    also received early childhood education or adult education services.

-   Even Start serves a very disadvantaged population. Compared with
    Head Start, Even Start parents are much less likely to have a high
    school diploma, and Even Start families have substantially lower
    annual household income.

-   Even Start children and parents made small gains on literacy
    measures and scored low compared to national norms when they left
    the program. Even Start children gained four standard score points
    on the Peabody Picture Vocabulary Test, the same gain made by
    control group children and by children in the Head Start FACES
    study.

-   Families in the program do not take full advantage of the services
    offered by Even Start projects; they participate in a small amount
    of instruction relative to their needs and program goals.

-   While the early childhood classroom experiences provided by the EDS
    projects were of overall good quality, there was not sufficient
    emphasis on language acquisition and reasoning to produce measurable
    impacts and hence to achieve legislative outcomes. Further study is
    needed to better document the quality and content of Even Start's
    instructional services.

-   The extent to which parents and children participated in literacy
    services is related to child outcomes.

Each of the national evaluations has shown that Even Start is a
complicated program that takes time to understand and implement fully.
The focus on literacy for the family as a unit is a special challenge,
as is the requirement to build on existing services to create a unified
family literacy program in a community. Maintaining a literacy focus and
ensuring that collaborators share the goals and objectives of Even Start
are critical factors, since Even Start projects are held accountable for
literacy outcomes, regardless of collaborators' objectives. By
integrating the four core instructional components, Even Start projects
seek to provide a value-added dimension to families' literacy
experiences and outcomes. These characteristics make Even Start unique
and exciting, but also difficult to evaluate.

The Department is implementing several strategies to help States and
local projects improve program performance, in part, to directly respond
to findings from the *Third National Even Start Evaluation*. ED is
working with States and local projects to strengthen the quality of each
instructional component and identify examples of local projects that are
achieving significant results in student achievement. In addition, ED
will conduct a peer review of State indicators of program quality to
ensure that all States have indicators that reflect high standards, use
appropriate assessment tools, and allow States to use their indicators
to monitor and improve local projects. Also, ED is helping to improve
the quality of State and local evaluations through development of a
revised guide to local evaluation and accompanying technical assistance.

# ***Classroom Literacy Interventions and Outcomes Study (CLIO) (2003-07)***

# 

# Research evidence from previous national Even Start evaluations has prompted an evaluation effort to identify effective family literacy models. Two experimental evaluations have shown that Even Start projects, as currently implemented, have not been effective at increasing the literacy skills of participating children and their parents over and above that of control children and their parents. The CLIO study will test the effectiveness of various enhanced family literacy interventions in promoting: (a) literacy and other school readiness skills in low-income children; (b) parent literacy; and (c) parent involvement as teachers of their own child, especially in the area of early literacy. The goal of the CLIO study is to provide information for Even Start family literacy projects on the literacy gains made by children and parents who participate in projects offering different family literacy curricula.

#### Local Evaluation

Each Even Start project is required to conduct an independent evaluation
of the program to be used for continuous program improvement. (Section
1235(15)) These evaluations are generally conducted annually and provide
local projects with critical information on individual participant
achievement results and areas of program strength and weakness. These
evaluations also provide local projects, States, the Department, and the
Congress with objective data about the activities and services provided
by the project, all the participants served, the retention rates of
those participants, and the achievement of all families in the project.
(See Local Administration -- Program Element #15 for more information.)

### Indicators of Program Quality

Section 1240 requires each State that receives Even Start funds to
develop indicators of program quality to use in monitoring, evaluating,
and improving local Even Start programs within the State.

In addition, the Department encourages States to develop performance
standards and benchmarks for each program indicator and use them for
increased local program accountability and program improvement.
Development of a complete system of accountability \-- comprised of
indicators of program quality and performance standards and benchmarks
\-- is important so that each State will have its own uniform and
workable method to measure and evaluate whether or not local programs
have made sufficient progress and improvement in participant outcomes.
This accountability system will give each State objective and explicit
data on which programs are showing gains in participant literacy, which
ones need technical assistance and in what areas, and which programs
should or should not receive continued funding.

Starting in 2003, the Department will also use it monitoring authority,
under the General Education Provisions Act: (20 USC 1232f(b), 1234(c),
and 1234(f)), to perform a peer review of States' Even Start performance
indicators. The review process will be used to ensure that all States
have indicators that reflect high standards, and use appropriate
assessment tools, and that States are able to use their indicators to
monitor and improve local Even Start programs and participant literacy
achievement results.

**[ADDITIONAL RESOURCES FOR FAMILY LITERACY]{.underline}**

Federal Even Start funds are not the only source of funding for family
literacy programs. Funding for family literacy programs or for
individual components of a family literacy program may come from a
variety of sources at the Federal, State, and local levels.

**Common Definition of Family Literacy**

# The following Federal legislation shares a generally common definition of "family literacy services":

-   Elementary and Secondary Education Act of 1965 (as amended by the No
    Child Left Behind Act of 2001)

# Head Start Act of 1998

-   Adult Education and Family Literacy Act (Workforce Investment Act)

-   Community Services Block Grant Act

**Title I, Part A**

Title I, Part A of the ESEA provides formula grants to LEAs to improve
the teaching and learning of children in high-poverty schools to enable
them to meet challenging academic content and performance standards. The
program emphasizes parental involvement and encourages each school to
provide training to help parents work with their children to improve
their school achievement.

Schools may use Title I, Part A funds to provide necessary literacy
training for parents if all reasonably available sources of funding have
been exhausted, and they are encouraged to work with communities to
provide health, nutrition, and social services that are not otherwise
available to the children being served. LEAs must reserve at least one
percent of their Title I, Part A allocations for parent involvement
activities including promoting family literacy and parenting skills,
unless the one percent is \$5,000 or less. (Section 1118(a)(3)) Title I,
Part A funds may also be used for preschool programs for educationally
disadvantaged children who reside in high-poverty areas.

In addition, section 1111(c)(14) requires SEAs to encourage LEAs and
individual schools participating in Title I, Part A programs to offer
family literacy services (using Title I, Part A funds), if the LEA or
school determines that a substantial number of disadvantaged students
have parents who do not have a high school diploma or its recognized
equivalent or have low levels of literacy. (For additional information
on Title I, Part A, go to www.ed.gov/programs/titleiparta/index.html.)

**Early Reading First, Title I, Part B, Subpart 2**

The Early Reading First program provides competitive grants to eligible
school districts and other public and private organizations located in
those school districts, to transform existing early education programs
into centers of excellence that provide high-quality, early education to
young children, especially those from low-income families. The overall
purpose of the Early Reading First program is to prepare young children
to enter kindergarten with the necessary language, cognitive, and early
reading skills to prevent reading difficulties and ensure school
success.

A variety of preschool programs located in eligible school districts,
including Even Start family literacy programs, may apply for Early
Reading First funds. All programs receiving Early Reading First grants
must demonstrate how they: provide children with a high quality
language- and literature-rich environment; provide professional
development for staff in research-based early language and reading
development; use a language and early literacy curriculum based in
scientific research; and use screening assessments to effectively
identify preschool-age children who may be at risk for reading failure.
As Even Start programs primarily serve children from ages birth through
seven, they are well equipped to ensure that there is continuity between
preschool and kindergarten educational experiences, which is a key
objective of the Early Reading First program. (For additional
information on Early Reading First, go to
http://www.ed.gov/programs/earlyreading/index.html.)

**Migrant Education, Title I, Part C**

The Migrant Education program (MEP) authorizes States to design services
that bridge gaps in a student's education caused by his or her parents'
moves to work in agriculture and other qualifying industries. Each State
designs its services by giving priority to migratory children who are
failing, or most at risk of failing, academically and whose education
has been interrupted during the regular school year. Because of the
nature of the migrant family lifestyle, migrant education programs
generally coordinate resources and integrate services using Federal
sources including Title I, Part A, State-administered Even Start, 21^st^
Century Community Learning Centers, Head Start, and Migrant and Seasonal
Head Start programs, as well as State and local education, health,
housing, and other programs. State and local migrant programs have also
developed a wide array of strategies that enable projects that serve the
same migrant students to communicate and coordinate with one another.

Family literacy activities are among the allowable strategies cited in
section 1304 to meet the unmet needs of preschool migratory children.
Migrant education funding is derived from a count of eligible children
ages 3-21. Migrant education funds may provide family literacy services
to children from birth, and to their parents as well, depending on the
State's priority for providing services to migrant students. States and
local migrant education projects, therefore, may choose family literacy
as a means to serve migrant children and their parents.

It is important to note that, for highly mobile migrant families,
progress in reaching literacy goals may require access to family
literacy services that operate across school district, State, program,
and national boundaries. Migrant Education Even Start (MEES), a
set-aside program in Title I, Part B, Subpart 3 of the ESEA, is
strengthening the capacity of its grantees to provide high-quality
intensive services on a year-round basis. With planning, collaboration,
and coordination that includes education funding, as well as
community-based and volunteer programs, migrant education programs can
leverage family literacy services no matter where migratory agricultural
families travel to work and live. (For additional information on Migrant
Education, go to
http://www.ed.gov/about/offices/list/oese/ome/index.html.)

**Head Start**

Head Start provides comprehensive early childhood, health, disabilities,
and family support services to 905,000 young children from low-income
families, including more than 55,000 infants, toddlers, and pregnant
women. Head Start\'s historic focus on serving economically
disadvantaged young children through a two-generational strategy of
early childhood and parent services meshes well with the goals and
strategies of Even Start. Many local Head Start agencies are
collaborating with Even Start programs, adult education providers, and
other family literacy organizations in providing family literacy
services. The Head Start and Even Start legislation share a common
definition of \"family literacy services". The HHS Head Start Bureau and
ED are partnering in a variety of initiatives, including national
leadership forums, a major jointly funded training and technical
assistance project with the National Center for Family Literacy, and
joint efforts to develop outcome measures for local programs.

**Adult Education**

The Adult Education and Family Literacy Act (Title II of the Workforce
Investment Act) provides important resources to fund the adult literacy
component of a family literacy program. The three most common types of
instruction that States support through adult education grants are:
adult basic education for basic literacy services for adults whose
skills are below the eighth grade level; adult secondary education for
services designed to prepare students to obtain a high school
equivalency diploma; and English literacy services for adults with
limited English proficiency. Adult education funds may also be used in
family literacy programs for support services such as child care and
transportation. (For additional information on Adult Education, go to
http://www.ed.gov/about/offices/list/ovae/index.html.)

**Bureau of Indian Affairs**

The BIA/Office of Indian Education Programs funds family literacy
programs that are similar to Even Start family literacy programs. The
Family and Child Education (FACE) program is implemented in 32
Bureau-funded schools, integrated within each school's Consolidated
School Reform Plan, and adopted as a research-based school reform model.
FACE funds are provided to Bureau-funded schools to implement unique and
culturally appropriate family literacy models.

FACE serves American Indian families with children ages birth to eight
at home and at Bureau-funded schools. The requirements for enrollment
are that families served live within the boundaries of a Bureau-funded
school to which their children attend or would be eligible to attend
upon reaching school age. FACE is a full-day program operating four days
per week with one day set aside for planning. FACE operates on a
school-year basis. Technical assistance is provided in an ongoing
commitment to all FACE staff, K-3 teachers and school administrators at
national meetings and on-site. Other non-Bureau programs such as Even
Start and Indian Head Start have participated in the technical
assistance trainings.

**Education for Homeless Children and Youth, (McKinney-Vento Act)**

Title X, Part C of the No Child Left Behind Act amended the
McKinney-Vento Homeless Assistance Act, which authorizes State formula
grants for the Education for Homeless Children and Youths program. The
McKinney-Vento Act was enacted to confront the problems of homelessness
in this nation and mandates State action to ensure that State and local
educational agencies address barriers to the enrollment, attendance, and
success in school of children and youth who are experiencing
homelessness.

The McKinney-Vento program establishes an Office for the Education of
Homeless Children and Youths in participating States and a local liaison
in all LEAs. One of the duties of the local education agency liaison is
to ensure that homeless families and pre-school-aged children receive
educational services such as Even Start family literacy programs, if
needed. LEA subgrants may be used to support developmentally appropriate
early childhood education programs, not otherwise provided through
Federal, State, or local funding, for preschool-aged homeless children.
(For additional information on Education for Homeless Children and
Youth, go to http://www.ed.gov/programs/homeless/index.html.)