> ![](media/image1.png){width="0.9in"
> height="0.8604166666666667in"}**UNITED STATES DEPARTMENT OF
> EDUCATION**

OFFICE OF INSPECTOR GENERAL

Audit Services

Chicago/Kansas City Audit Region

March 15, 2007

> **Control Number ED-OIG/A05G0034**

Dr. Suellen Reed

State Superintendent of Public Instruction

Indiana Department of Education

Room 229, State House

Indianapolis, IN 46204-2798

Dear Dr. Reed:

This **Final Audit Report**, titled *Indiana Schools' Implementation of
Schoolwide Plans Under the No Child Left Behind Act of 2001*, presents
the results of our audit. Our audit objectives were to determine whether
(1) the Indiana Department of Education (IDE) and local educational
agencies (LEAs)[^1] had adequate processes in place to ensure that
schoolwide schools had schoolwide plans that included all required
elements and that these schools implemented their schoolwide plans, (2)
schoolwide plans for selected schools included all required elements,
and (3) the selected schools implemented the elements included in their
schoolwide plans. Our audit covered the 2005-06 school year (July 1,
2005, through June 30, 2006).

BACKGROUND

The Elementary and Secondary Education Act of 1965, as amended by the No
Child Left Behind Act of 2001 (the Act), allows schools in an area with
a poverty level of 40 percent or more, or in which at least 40 percent
of enrolled students are from low-income families, to operate schoolwide
programs. Schools operating schoolwide programs may use funds from Title
I,

Part A, along with other federal, state, and local funds, to upgrade the
entire educational program in a school in order to improve the academic
achievement of all students, particularly the lowest-achieving students.

According to Section 1114(b)(2)(A) of the Act, 34 C.F.R § 200.26(b), and
34 C.F.R.\
§ 200.27(a)(3),[^2] the school must develop a comprehensive schoolwide
plan in consultation with the LEA and its school support team or another
technical assistance provider, and the school community. The
comprehensive plan must be based on data from a comprehensive needs
assessment or, for schools that have operated schoolwide programs for an
extended period of time, based on the state's annual assessments and
other indicators of academic achievement. The comprehensive plan must
(1) describe how the school will implement the schoolwide program
components listed under 34 C.F.R. § 200.28, (2) describe how the school
will use resources to implement the schoolwide program components, (3)
include a list of state educational agency, LEA, and other federal
programs for which the school will consolidate funds to use in its
schoolwide program, and (4) describe how the school will provide
individual student academic assessment results to parents.

According to 34 C.F.R. § 200.28, a schoolwide program must contain the
following components:[^3]

-   Schoolwide reform strategies that (1) provide opportunities for
    students to meet proficient and advanced state achievements
    standards; (2) use effective methods of instruction that are based
    on scientifically based research that strengthen the school's core
    academic program, provide an enriched and accelerated curriculum,
    increase the amount and quality of learning time, include strategies
    for meeting the educational needs of historically underserved
    populations, and are consistent with, and are designed to implement,
    state and local improvement plans; and (3) include strategies that
    address the needs of all the students in the school, particularly
    the needs of the lowest achieving students, and address how the
    school will determine if such needs have been met.

```{=html}
<!-- -->
```
-   Strategies to provide instruction by highly qualified teachers,
    including strategies to (1) attract highly qualified teachers; (2)
    provide high quality and ongoing professional development for
    teachers, principals, and paraprofessionals; (3) devote sufficient
    resources to carry out professional development activities; and (4)
    include teachers in professional development activities on the use
    of academic assessments.

```{=html}
<!-- -->
```
-   Strategies to involve parents in the planning, review, and
    improvement of the schoolwide program plan, including having a
    parental involvement policy for the school.[^4]

```{=html}
<!-- -->
```
-   Activities to ensure that students who experience difficulty
    reaching proficient or advanced levels on academic assessments are
    provided with additional support.

```{=html}
<!-- -->
```
-   Plans for assisting preschool children in the transition from early
    childhood programs to the schoolwide program.

The U.S. Department of Education allocated approximately \$174 million
in Title I funds to IDE for the 2005-06 school year. In Indiana, 160
schools operated schoolwide programs during both the 2004-05 and 2005-06
school years.

AUDIT RESULTS

We found that (1) IDE and the two LEAs we reviewed (Indianapolis and
East Chicago) had adequate processes in place to ensure that schools
implemented the elements included in their schoolwide plans but did not
ensure that schoolwide plans included all required elements, (2) the two
schools we reviewed did not include all required elements in their
schoolwide plans, and

\(3\) the two schools we reviewed implemented the elements included in
their schoolwide plans.

Both of the schoolwide plans we reviewed included a description of how
the school would use resources to implement components in its schoolwide
program, schoolwide reform strategies, and strategies to provide
additional support to low-achieving students. In addition, the
schoolwide plan for the selected school in East Chicago included
strategies to involve parents in the planning, review, and improvement
of the schoolwide plan and plans for assisting preschool students in the
transition from early childhood programs to the schoolwide program.[^5]
However, schoolwide plans for the two selected schools did not include
all required elements.

In its comments to the draft report, IDE concurred with our finding and
recommendations. The comments are summarized at the end of the finding.
The full text of IDE's comments on the draft report is included as an
attachment to the report.

FINDING -- IDE and Selected LEAs Did Not Ensure Schoolwide Plans
Included All Required Elements

IDE and the LEAs we reviewed did not ensure that schoolwide plans
included all elements required by Section 1114(b)(2)(A) of the Act. See
the following table:

+------------------------------------+----------------+----------------+
| **Schoolwide Plan Elements         |                |                |
| Included in Each Schoolwide Plan** |                |                |
+------------------------------------+----------------+----------------+
| **Required Element**               | **Indianapolis | **East Chicago |
|                                    | LEA -- John    | LEA-Eugene     |
| **(See BACKGROUND Section)**       | Marshall       | Field          |
|                                    | Middle         | Elementary     |
|                                    | School**       | School**       |
+------------------------------------+----------------+----------------+
| # 1) Component                     |                |                |
| s Listed Under 34 C.F.R. § 200.28: |                |                |
+------------------------------------+----------------+----------------+
| # Schoolwide Reform Strategies     | Yes            | Yes            |
+------------------------------------+----------------+----------------+
| > Instruction by Highly Qualified  | No             | No             |
| > Teachers[^6]                     |                |                |
+------------------------------------+----------------+----------------+
| > Parental Involvement in Program  | No             | Yes            |
| > Planning, Review, and            |                |                |
| > Improvement                      |                |                |
+------------------------------------+----------------+----------------+
| > Additional Support               | Yes            | Yes            |
+------------------------------------+----------------+----------------+
| > Transition For Preschool         | NA             | Yes            |
| > Students                         |                |                |
+------------------------------------+----------------+----------------+
| **2) Resources to Implement        | Yes            | Yes            |
| Components**                       |                |                |
+------------------------------------+----------------+----------------+
| **3) Consolidating Program Funds** | NA[^7]         | NA^7^          |
+------------------------------------+----------------+----------------+
| **4) Providing Academic Assessment | No             | No             |
| Results to Parents**               |                |                |
+------------------------------------+----------------+----------------+

#### 

Though the selected schools did not include all required elements in
their schoolwide plans, we concluded that the LEAs had processes in
place that ensured that the objectives referred to by the required
elements were carried out by each selected school. In addition to
implementing all elements included in their schoolwide plans, schools
also implemented the elements not included in their schoolwide plans.
Specifically, (1) both selected schools implemented strategies to
provide instruction by highly qualified teachers and provided parents
with individual student academic assessment results, and (2) the
selected school in Indianapolis involved parents in the planning,
review, and improvement of the schoolwide program.

According to Section 1114(b)(1) of the Act and 34 C.F.R. § 200.28, a
schoolwide plan must include, among other things, strategies to provide
instruction by highly qualified teachers and strategies to involve
parents in the planning, review, and improvement of the schoolwide plan.
In addition, Section 1114(b)(2)(A)(iv) of the Act and 34 C.F.R. §
200.28(c)(2)(ii) require a schoolwide plan to describe how a school will
provide individual student academic assessment results to parents.

Prior to the 2005-06 school year, IDE did not have a process in place to
monitor schoolwide plans.  During the 2005-06 school year, IDE
implemented both on-site and desk review monitoring of schoolwide plans.
 The monitoring checklists IDE used to review schoolwide plans covered
some of the required schoolwide program components listed under 34
C.F.R.

§ 200.28 but did not include all elements required by Section
1114(b)(2)(A) of the Act and

34 C.F.R. § 200.27(a)(3).  Specifically, the checklists did not list
that schoolwide plans must

\(1\) include a list of programs that will be consolidated under the
schoolwide program,

\(2\) describe how the school will provide individual student academic
assessment results to parents, and (3) include strategies to involve
parents in the planning, review, and improvement of the schoolwide
plan.  Thus, while IDE reviewed schoolwide plans, it did not review the
plans to ensure that they included all required elements.  In addition,
the schoolwide plan guidance IDE provided to LEAs did not include these
three required elements. IDE was not aware that the Act and implementing
regulations required schoolwide plans to include these three elements.

IDE required schools to work with one of two state-approved technical
assistance providers during the schoolwide planning process. The
technical assistance providers certified to IDE that schoolwide plans
for schools they worked with included all required components. IDE
accepted the technical assistance providers' certifications without
conducting its own review of the schoolwide plans. The selected school
in East Chicago worked with a state-approved technical assistance
provider while developing its 2005-06 schoolwide plan, and the provider
certified that it included all required components. However, as
explained above, the schoolwide plan for the selected school in East
Chicago was deficient. Technical assistance providers might not be aware
of all schoolwide plan requirements.

Not ensuring that schoolwide plans include all required elements could
potentially lead to decreased implementation of required schoolwide plan
elements and schoolwide plans that are less likely to improve the
academic achievement of all students.

Recommendations

We recommend that the Assistant Secretary for Elementary and Secondary
Education require IDE to

1.  Ensure that both schools we reviewed revise their schoolwide plans
    to include all required elements;

2.  Add the following required elements for schoolwide plans to its
    on-site and desk review monitoring checklists and to guidance
    provided to LEAs regarding schoolwide plans:

> \(a\) include a list of programs that will be consolidated under the
> schoolwide program, (b) describe how the school will provide
> individual student academic assessment results to parents, and (c)
> include strategies to involve parents in the planning, review, and
> improvement of the schoolwide plan;

3.  Notify LEAs of the changes to the guidance and advise them to take
    action as appropriate;

4.  Review, during its on-site visits to LEAs and desk reviews of LEAs'
    documents, all elements of the LEAs' schoolwide plans to determine
    whether (a) each LEA's policies and procedures ensure that
    schoolwide plans include all the required elements, (b) those
    policies and procedures are being implemented, and (c) schoolwide
    plans include all required elements; and

5.  Ensure that state-approved technical assistance providers are aware
    of all required elements for schoolwide plans.

######## Auditee Comments

IDE concurred with our finding and recommendations. In response to our
recommendations, IDE

-   Stated it will meet with the Title I Program Administrator, school
    staff, and technical assistance provider for both schools to ensure
    that schoolwide plans include all required elements.

-   Provided (1) revised on-site and desk review monitoring checklists
    that include the elements listed in Recommendation 1.2; and (2)
    guidance addressed to LEA Title I Program Administrators, per
    Recommendation 1.3, that (a) lists programs that can be consolidated
    under a schoolwide plan and (b) informs them of the elements listed
    in Recommendation 1.2. IDE stated it will present this information
    to LEAs at future meetings and will post it on its website.

-   Stated it will continue to review all elements of LEAs' schoolwide
    plans during on-site visits and desk reviews.

-   Stated it has met with each of the four state-approved technical
    assistance providers and reviewed required elements of schoolwide
    plans and IDE's on-site and desk review checklists.

OBJECTIVES, SCOPE, AND METHODOLOGY

Our audit objectives were to determine whether (1) IDE and LEAs had
adequate processes in place to ensure that schoolwide schools had
schoolwide plans that included all required elements and that these
schools implemented their schoolwide plans, (2) schoolwide plans for
selected schools included all required elements, and (3) the selected
schools implemented the elements included in their schoolwide plans. Our
audit covered the 2005-06 school year (July 1, 2005, through June 30,
2006).

To achieve our objectives, we interviewed officials and reviewed
documents from IDE and the two LEAs and schools we reviewed. For IDE, we
(1) gained an understanding of policies and procedures for ensuring that
schoolwide plans included all required elements and were being
implemented and (2) reviewed guidance it provided to LEAs and schools
regarding schoolwide plans. For the two LEAs selected, we gained an
understanding of how each LEA (1) helped its schools develop and
implement schoolwide plans and (2) monitored and evaluated schoolwide
plans. The documents we reviewed included

> 1\. IDE's organizational chart;
>
> 2\. Prior audit reports, including IDE's Single Audit Act report,
> *State of Indiana Single Audit Report, July 1, 2003, to June 30,
> 2004;*

3.  Guidance regarding schoolwide programs IDE provided to LEAs at
    various meetings, including its Title I meetings held in Fall 2005
    and Spring 2006 and Title I New Program Administrator Workshops held
    on January 10, 2006, and June 1, 2006;

4.  Documentation related to IDE's monitoring reviews of LEAs and
    schools, including its on-site and desk review monitoring
    checklists, and on-site monitoring reports;

5.  Schoolwide plans for the two selected schools for inclusion of the
    required elements listed in Section 1114(b)(2)(A) of the Act and 34
    C.F.R. § 200.27(a)(3), including the components listed in 34 C.F.R.
    § 200.28; and

6.  Documentation for the two selected schools related to the
    implementation of required schoolwide plan elements.

We selected LEAs and schools to visit. We identified the universe of
LEAs in Indiana that had at least one school (1) identified for
improvement or otherwise showing weak academic results for the 2005-06
school year and (2) that operated a schoolwide program during both the
2004-05 and 2005-06 school years. By including only those schools that
operated schoolwide programs during both of these school years, we
ensured that our review included only schools that had schoolwide
programs at the time of our review and had completed one full year of
their schoolwide programs. From this universe of 18 LEAs, we
judgmentally selected the 2 LEAs we reviewed. Based on Title I
allocations, we selected one large LEA (Indianapolis) and one medium LEA
(East Chicago). For each of these two LEAs, we randomly selected one
school meeting requirements (1) and (2) above. We randomly selected one
of seven schools in Indianapolis and one of three schools in East
Chicago. For Indianapolis and East Chicago, we selected John Marshall
Middle School and Eugene Field Elementary School, respectively.

We performed our fieldwork at the offices of IDE in Indianapolis,
Indiana; the two selected LEAs and schools in Indiana; and our offices
in Chicago, Illinois, and Kansas City, Missouri. We discussed the
results of our audit with IDE officials on December 20, 2006. We did not
use computer-processed data to achieve our audit objectives. Our audit
was performed in accordance with generally accepted government auditing
standards appropriate to the scope of review described above.

ADMINISTRATIVE MATTERS

Statements that managerial practices need improvements, as well as other
conclusions and recommendations in this report, represent the opinions
of the Office of Inspector General. Determinations of corrective action
to be taken will be made by the appropriate Department of Education
officials.

If you have any additional comments or information that you believe may
have a bearing on the resolution of this audit, you should send them
directly to the following Education Department official, who will
consider them before taking final Departmental action on this audit:

> Kerri L. Briggs
>
> Acting Assistant Secretary

Office of Elementary and Secondary Education

> U.S. Department of Education

400 Maryland Avenue, SW

Washington, D.C. 20202

It is the policy of the U.S. Department of Education to expedite the
resolution of audits by initiating timely action on the findings and
recommendations contained therein. Therefore, receipt of your comments
within 30 days would be appreciated.

In accordance with the Freedom of Information Act (5 U.S.C. § 552),
reports issued by the Office of Inspector General are available to
members of the press and general public to the extent information
contained therein is not subject to exemptions in the Act.

> Sincerely,

/s/

> Richard J. Dowd

Regional Inspector General

for Audit

Attachment

## 

## 

## 

## 

## 

**ATTACHMENT: IDE Comments to the Draft Report**

*\[Auditor's Note: The hardcopy version of this letter had the IDE
letterhead at the top of this page.\]*

February 15, 2007

Richard J. Dowd

Regional Inspector General for Audit

500 West Madison Street, Suite 1414

Chicago, Illinois 60661

Dear Mr. Dowd:

This letter is written in response to the January 17, 2007 Office of
Inspector General (OIG) Draft Audit Report titled: *Indiana Schools'
Implementation of Schoolwide Plans Under the No Child Left Behind Act of
2001*. The audit covered the 2005-06 school year and findings were based
on the IDOE's program administration and OIG site visits to schoolwide
programs operating in Indianapolis Public Schools and the School City of
East Chicago.

Indiana Department of Education (IDOE) staff has reviewed the findings
contained in the OIG draft report and concurs with its findings. To
demonstrate full compliance with federal laws and regulations, the IDOE
has taken the following corrective action in response to the specific
OIG audit finding and the resultant five OIG recommendations delineated
below.

OIG Finding: IDE and Selected LEAs Did Not Ensure Schoolwide Plans
Included All Required Elements

[OIG Recommendation #1]{.underline}: Ensure that both schools we
reviewed revise their schoolwide plans to include all required elements.

*IDOE Response: IDOE staff will meet with the Title I Program
Administrator, school staff, and the technical assistance provider to
review the revised schoolwide plans to ensure that all components are
now included. This review will be completed for both schools by March
23, 2007.*

[OIG Recommendation #2]{.underline}: Add the following required elements
for schoolwide plans to its on-site and desk review monitoring
checklists and to guidance provided to LEAs regarding schoolwide plans:
(a) include a list of programs that will be consolidated under the
schoolwide programs, (b) describe how the school will provide individual
student academic assessment results to parents, and (c) include
strategies to involve parents in the planning, review, and improvement
of the schoolwide plan.

*IDOE Response: IDOE has created a list of programs that can be
consolidated under the schoolwide plan. (See Attachment A) IDOE's
on-site and desk review monitoring checklists have been revised to
include the elements listed in Recommendation #2. (See Attachments B and
C)*

[OIG Recommendation #3]{.underline}: Notify LEAs of the changes to the
guidance and advise them to take action as appropriate.

*IDOE Response: IDOE notified LEAs of the changes to the guidance and
advised them to take action as appropriate on February 14, 2007. (See
Attachment D) In addition, this information will be presented during a
PowerPoint presentation to all districts at the Title I Administrative
Meeting on February 26 and 27, 2007. All documents also will be posted
on Indiana's Title I web site. Schools interested in participating in
the 2007-08 schoolwide planning process will be advised of the guidance
at an April 2007 meeting conducted by the IDOE.*

[OIG Recommendation #4]{.underline}: Review, during its on-site visits
to LEAs and desk reviews of LEAs' documents, all elements of the LEAs'
schoolwide plans to determine whether (a) each LEA's policies and
procedures ensure that schoolwide plans include all the required
elements, (b) those polices and procedures are being implemented, and
(c) schoolwide plans include all required elements.

*IDOE Response: IDOE will continue to review, during on-site visits to
LEAs and through desk reviews of LEA documents, all elements of the
LEAs' schoolwide plans. IDOE conducts approximately three on-site
monitoring reviews monthly. Within a three year cycle, all districts
with schoolwide programs participate in an IDOE desk review monitoring
process requiring documentation to support the district's implementation
of all required program elements.*

[OIG Recommendation #5]{.underline}: Ensure that state-approved
technical assistance providers are aware of all required elements for
schoolwide plans.

*IDOE Response: IDOE met with each of the four state-approved technical
assistance providers and reviewed required elements for schoolwide plans
as well as IDOE's on-site and desk review checklists.*

If additional documentation is needed to support the IDOE's full
compliance with the required elements of schoolwide programs, please do
not hesitate to contact Linda Miller, assistant superintendent, at
<lmiller@doe.state.in.us> or by telephone at (317) 232-0519.

Sincerely,

/s/

Dr. Suellen Reed

State Superintendent of Public Instruction

Cc: Linda Miller, Assistant Superintendent, IDOE

Lee Ann Kwiatkowski, Director of Title I, IDOE

**Attachment A**

**Consolidation of Funds in Schoolwide Programs**

**Why should schoolwide programs consolidate funds?**

● Allows school administrators and instructional staff to focus on
implementing strategies identified in the schoolwide plan and improving
the overall academic performance of the school.

● Removes barriers created by having separate academic programs.

● Greater flexibility to meet the needs of all students and families.

● Consolidates funds without requiring separate fiscal accounting
records by program.

● Eliminates the need for monthly time and attendance logs from staff
that work on a single cost objective.

**Which Federal education program funds can be consolidated in a
schoolwide program?**

● Title I, Part A Improving the Academic Achievement of the
Disadvantaged

● Title I, Part D, Subpart 2 Prevention and Intervention Programs for
Children and Youth Who Are Neglected, Delinquent, or At-Risk.

● Title II, Part A Improving Teacher Quality

● Title II, Part D Enhancing Education Through Technology

● Title III Limited English Proficient

● Title IV, Part A Safe and Drug Free Schools and Communities

● Title V Innovative Programs

● Title VI Rural and Low Income Schools

● Funds received from discretionary (competitive) grants, such as Even
Start

**●** State and local funds

**Which Federal education program funds can [not]{.underline} be
included or have restrictions?**

**●** Migrant Education Program Funds

**-Restrictions**:

-School must consult with the parents of migratory children or
organizations representing these parents, or both.

> -School must address the identified needs of migratory children that
> result from the effects of their migratory lifestyle or are needed to
> permit migratory children to participate effectively in school.
>
> -School must document that services to address those needs have been
> provided.

● Indian Education Program, Title VII, Part A, section 7115

**-Restrictions**:

> -The parent committee established under that program must approve the
> use of the funds for the schoolwide program.
>
> -The schoolwide program must be consistent with the purposes of the
> Indian Education Program

● IDEA funds

\-**Restrictions**:

-The amount of funds consolidated may not exceed the amount received
under IDEA, Part B for that fiscal year, divided by the number of
children with disabilities in the jurisdiction of the LEA and multiplied
by the number of children with disabilities participating in the
schoolwide program.

-All other requirements of IDEA, such as the rights and services
afforded to individual children with disabilities, must still be met.

● Title I, Part B, Subpart 1 Reading First is **excluded** from
consolidation.

**In addition to restrictions listed, schoolwide programs must still
meet program requirements relating to:**

● Health and safety requirements

● Civil rights

● Gender equity

● Student and parental participation and involvement

● Services to private school children

**●** Comparability of services

● Maintenance of effort

● Use of federal funds to supplement, not supplant non-federal funds

**Procedures for Consolidating Schoolwide Funds**

(In progress)

1\. Determine the amount of federal funds to be allocated to each of the
schoolwide schools from all participating federal grants.

2\. Develop a consolidated budget for each schoolwide school. The budget
should support the school\'s plan and the goals, objectives, and
strategies needed to implement the plan.

3\. Record the budget for each schoolwide school in the accounting
records of the school district. Fund 400, Schoolwide Programs Fund,
should be created for recording the expenditures of all schoolwide
schools.

4\. Allocate the consolidated monthly expenditures from Fund 400 to the
individual federal funds through posting a monthly journal entry using
account \_\_\_\_\_\_\_\_\_ for each school.

### Attachment B

![](media/image2.png){width="3.375in" height="0.9520833333333333in"}

***No Child Left Behind (NCLB)***

The IDOE Review Team will complete this document as a record of the
On-Site Review of Title I, Part A programs. It details the findings of
the Review Team regarding the key focus areas identified in this
protocol. If any areas are found to be in partial compliance or out of
compliance, a finding will be listed on the report generated by the team
from the IDOE. This report will be completed within 30 business days of
the visit to the LEA.

**LEA Name:**

**Date of Visit:**

**IDOE Team Members:**

**LEA Personnel: Superintendent:
\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_**

**Program Administrator:
\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_**

**Other:
\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_**

# 

# *Monitoring 6: Compliance with schoolwide program requirements. Section: 1114 and 34CFR Secs. 200.26-28*

+-----------------------------------+---+---+-------------------------+
| **Evidence at LEA/School**        | * | * | **Comments**            |
|                                   | * | * |                         |
|                                   | Y | N |                         |
|                                   | E | O |                         |
|                                   | S | * |                         |
|                                   | * | * |                         |
|                                   | * |   |                         |
+-----------------------------------+---+---+-------------------------+
| # Show evidence that LE           |   |   |                         |
| A provides guidance to schools ab |   |   |                         |
| out the development, implementati |   |   |                         |
| on, and evaluation of schoolwide  |   |   |                         |
| programs and program requirements |   |   |                         |
|                                   |   |   |                         |
| -   Agendas, minutes, sign-in     |   |   |                         |
|     sheets for any meetings       |   |   |                         |
|                                   |   |   |                         |
| -   Copies of any kind of         |   |   |                         |
|     evaluation used               |   |   |                         |
|                                   |   |   |                         |
| #                                 |   |   |                         |
|  Copies of notices of information |   |   |                         |
+-----------------------------------+---+---+-------------------------+
| 1.  Show evidence that LEA        |   |   |                         |
|     provides technical assistance |   |   |                         |
|     and support to schools        |   |   |                         |
|     developing schoolwide         |   |   |                         |
|     programs in the areas of      |   |   |                         |
|     needs assessment,             |   |   |                         |
|     comprehensive planning,       |   |   |                         |
|     implementation, and           |   |   |                         |
|     evaluation                    |   |   |                         |
|                                   |   |   |                         |
| -   PA's participation in the SWP |   |   |                         |
|     training provided by one of   |   |   |                         |
|     the providers approved by the |   |   |                         |
|     IDOE                          |   |   |                         |
|                                   |   |   |                         |
| -   Records of attendance at      |   |   |                         |
|     school meetings to implement  |   |   |                         |
|     schoolwide programs           |   |   |                         |
+-----------------------------------+---+---+-------------------------+
| # Show evidence that schoolwi     |   |   |                         |
| de programs are comprehensively d |   |   |                         |
| eveloped, reviewed and evaluated  |   |   |                         |
| annually, and revised accordingly |   |   |                         |
|                                   |   |   |                         |
| -   Discussion of the process     |   |   |                         |
|                                   |   |   |                         |
| -   Copies of plans and revisions |   |   |                         |
+-----------------------------------+---+---+-------------------------+
| # Explain how the distric         |   |   |                         |
| t consolidates funds and, if so;  |   |   |                         |
| how those funds are accounted for |   |   |                         |
|                                   |   |   |                         |
| -   Ledger, worksheets, other     |   |   |                         |
+-----------------------------------+---+---+-------------------------+
| # Show evidence that services     |   |   |                         |
|  students receive are supplementa |   |   |                         |
| ry to instructional services requ |   |   |                         |
| ired to be provided by the school |   |   |                         |
|                                   |   |   |                         |
| -   Evidence in description of    |   |   |                         |
|     program -- Review Program     |   |   |                         |
+-----------------------------------+---+---+-------------------------+
| # Show evidence that the SWP i    |   |   |                         |
| s being implemented in the school |   |   |                         |
|                                   |   |   |                         |
| -   Strategies in plan match      |   |   |                         |
|     application                   |   |   |                         |
|                                   |   |   |                         |
| -   Teacher interviews and        |   |   |                         |
|     classroom observation         |   |   |                         |
|                                   |   |   |                         |
| -   Surveys                       |   |   |                         |
|                                   |   |   |                         |
| -   Schedules of extended-time    |   |   |                         |
|     activities                    |   |   |                         |
+-----------------------------------+---+---+-------------------------+

+---------------------------------------+------+-----+----------------+
| # Evidence at the School Level        | **Y  | **N | **Comments**   |
|                                       | ES** | O** |                |
+---------------------------------------+------+-----+----------------+
| # Schoolwide Plan Components:         |      |     |                |
+---------------------------------------+------+-----+----------------+
| # A comprehensive                     |      |     |                |
|  needs assessment of the whole school |      |     |                |
+---------------------------------------+------+-----+----------------+
| # Implementation                      |      |     |                |
| of schoolwide reform strategies that: |      |     |                |
|                                       |      |     |                |
| -   **Provide opportunities for all   |      |     |                |
|     children to meet proficient and   |      |     |                |
|     advanced levels of student        |      |     |                |
|     academic achievement**            |      |     |                |
|                                       |      |     |                |
| -   **Use effective methods and       |      |     |                |
|     instructional strategies that are |      |     |                |
|     based on scientifically based     |      |     |                |
|     research that: strengthens the    |      |     |                |
|     core academic program**           |      |     |                |
|                                       |      |     |                |
| -   **Increases the amount of         |      |     |                |
|     learning time**                   |      |     |                |
|                                       |      |     |                |
| -   **Includes strategies for serving |      |     |                |
|     underserved populations**         |      |     |                |
|                                       |      |     |                |
| -   **Includes strategies to address  |      |     |                |
|     the needs of all children in the  |      |     |                |
|     school, but particularly low      |      |     |                |
|     achieving children and those at   |      |     |                |
|     risk of not meeting state         |      |     |                |
|     standards**                       |      |     |                |
|                                       |      |     |                |
| -   **Address how the school will     |      |     |                |
|     determine if those needs of the   |      |     |                |
|     children have been met**          |      |     |                |
|                                       |      |     |                |
| -   **Are consistent with and are     |      |     |                |
|     designed to implement state and   |      |     |                |
|     local improvement plans, if any** |      |     |                |
+---------------------------------------+------+-----+----------------+
| # Highly qualified teach              |      |     |                |
| ers in all core content area classes  |      |     |                |
+---------------------------------------+------+-----+----------------+
| 1.  **High quality and on-going       |      |     |                |
|     professional development for      |      |     |                |
|     teachers, principals, and         |      |     |                |
|     paraprofessionals**               |      |     |                |
+---------------------------------------+------+-----+----------------+
| 2.  **Strategies to attract           |      |     |                |
|     high-quality, highly qualified    |      |     |                |
|     teachers to this school**         |      |     |                |
+---------------------------------------+------+-----+----------------+
| 3.  **Strategies to increase parental |      |     |                |
|     involvement, such as literacy     |      |     |                |
|     services**                        |      |     |                |
+---------------------------------------+------+-----+----------------+
| **6a. Description how the school will |      |     |                |
| provide individual academic           |      |     |                |
| assessment results to parents**       |      |     |                |
+---------------------------------------+------+-----+----------------+
| > **6b. Strategies to involve parents |      |     |                |
| > in the planning, review, and        |      |     |                |
| > improvement of the schoolwide       |      |     |                |
| > plan**                              |      |     |                |
+---------------------------------------+------+-----+----------------+
| 4.  **Plans for assisting preschool   |      |     |                |
|     children in the transition from   |      |     |                |
|     early childhood programs such as  |      |     |                |
|     Head Start, Even Start, Early     |      |     |                |
|     Reading First, or a state-run     |      |     |                |
|     preschool program**               |      |     |                |
+---------------------------------------+------+-----+----------------+
| 5.  **Opportunities and expectations  |      |     |                |
|     for teachers to be included in    |      |     |                |
|     the decision making related to    |      |     |                |
|     the use of academic assessment    |      |     |                |
|     results leading to the            |      |     |                |
|     improvement of student            |      |     |                |
|     achievement**                     |      |     |                |
+---------------------------------------+------+-----+----------------+
| 6.  **Activities and programs at the  |      |     |                |
|     school level to ensure that       |      |     |                |
|     students having difficulty        |      |     |                |
|     mastering proficient and advanced |      |     |                |
|     levels of the academic            |      |     |                |
|     achievement are provided with     |      |     |                |
|     effective, timely additional      |      |     |                |
|     assistance**                      |      |     |                |
+---------------------------------------+------+-----+----------------+
| 7.  **Coordination and integration of |      |     |                |
|     federal, state and local funds;   |      |     |                |
|     and resources such as in-kind     |      |     |                |
|     services and program components** |      |     |                |
+---------------------------------------+------+-----+----------------+
| > 10a. List of programs that will be  |      |     |                |
| > consolidated under the schoolwide   |      |     |                |
| > plan (if applicable)                |      |     |                |
+---------------------------------------+------+-----+----------------+

**Topic 6: Continued**

Attachment C

![](media/image2.png){width="1.8944444444444444in"
height="0.5354166666666667in"}

Title I Schoolwide Plan Checklist

***Directions***: Review the Title I Schoolwide Plans prior to mailing
to the IDOE to ensure that all requirements listed below have been met.
Insert the page number where each component can be found in the column
to the right. If a plan does not include all ten components, it is out
of compliance with NCLB requirements and will need to be adjusted.

**Schoolwide Plan:** Section 1114 (b) (2) Any school that operates a
schoolwide program shall first develop (or amend a plan for such a
program that was in existence on the day before the date of enactment of
the NCLB Act of 2001), in consultation with the LEA and its school
support team or other technical assistance provider under section 1117,
a comprehensive plan for reforming the total instructional program in
the school that:

i.  Describes how the school will implement the components described
    below

ii. Describes how the school will use resources under this part and
    other sources to implement the components

iii. Includes a list of SEA programs and other federal programs that
     will be consolidated in the schoolwide program

iv. Describes how the school will provide individual student academic
    assessment results in a language the parents can understand,
    including an interpretation of those results, to the parents of a
    child who participates in the academic assessments required by the
    SEA plan.

+-------------------------------------------------------+--------------+
| # Components of a Schoolwide Plan\*:                  | **Found on   |
|                                                       | Page #:**    |
+-------------------------------------------------------+--------------+
| #                                                     |              |
|  A comprehensive needs assessment of the whole school |              |
+-------------------------------------------------------+--------------+
| #                                                     |              |
|  Implementation of schoolwide reform strategies that: |              |
|                                                       |              |
| -   Provide opportunities for all children to meet    |              |
|     proficient and advanced levels of student         |              |
|     academic achievement                              |              |
|                                                       |              |
| -   Use effective methods and instructional           |              |
|     strategies that are based on scientifically based |              |
|     research that:                                    |              |
|                                                       |              |
| -   Strengthens the core academic program             |              |
|                                                       |              |
| -   Increases the amount of learning time             |              |
|                                                       |              |
| -   Includes strategies for serving underserved       |              |
|     populations                                       |              |
|                                                       |              |
| -   Includes strategies to address the needs of all   |              |
|     children in the school, but particularly low      |              |
|     achieving children and those at risk of not       |              |
|     meeting state standards                           |              |
|                                                       |              |
| -   Address how the school will determine if those    |              |
|     needs of the children have been met               |              |
|                                                       |              |
| -   Are consistent with and are designed to implement |              |
|     state and local improvement plans, if any         |              |
+-------------------------------------------------------+--------------+
| # Highly                                              |              |
|  qualified teachers in all core content area classes  |              |
+-------------------------------------------------------+--------------+
| 1.  High quality and on-going professional            |              |
|     development for teachers, principals, and         |              |
|     paraprofessionals                                 |              |
+-------------------------------------------------------+--------------+
| 2.  Strategies to attract high-quality, highly        |              |
|     qualified teachers to this school                 |              |
+-------------------------------------------------------+--------------+
| 3.  Strategies to increase parental involvement, such |              |
|     as literary services                              |              |
+-------------------------------------------------------+--------------+
| 6 a. Description how the school will provide          |              |
| individual academic assessment results to parents     |              |
+-------------------------------------------------------+--------------+
| 6 b. Strategies to involve parents in the planning,   |              |
| review, and improvement of the schoolwide plan        |              |
+-------------------------------------------------------+--------------+
| 4.  Plans for assisting preschool children in the     |              |
|     transition from early childhood programs such as  |              |
|     Head Start, Even Start, Early Reading First, or a |              |
|     state-run preschool program                       |              |
+-------------------------------------------------------+--------------+
| 5.  Opportunities and expectations for teachers to be |              |
|     included in the decision making related to the    |              |
|     use of academic assessment results leading to the |              |
|     improvement of student achievement                |              |
+-------------------------------------------------------+--------------+
| 6.  Activities and programs at the school level to    |              |
|     ensure that students having difficulty mastering  |              |
|     proficient and advanced levels of the academic    |              |
|     achievement are provided with effective, timely   |              |
|     additional assistance                             |              |
+-------------------------------------------------------+--------------+
| 7.  Coordination and integration of federal, state    |              |
|     and local funds; and resources such as in-kind    |              |
|     services and program components                   |              |
+-------------------------------------------------------+--------------+
| 10 a. A list of programs that will be consolidated    |              |
| under the schoolwide plan (if applicable)             |              |
+-------------------------------------------------------+--------------+

> \*Consolidated plans are encouraged and accepted

Attachment D

**MEMORANDUM\
**

To: Title I Program Administrators

From: Lee Ann Kwiatkowski, Director

Division of Compensatory Education

Re: Schoolwide Programs

Date: February 14, 2007

This memorandum is to inform you of recent updated federal guidance for
schoolwide programs and how that will affect the Title I monitoring
system. As you know, schoolwide programs have the flexibility to
consolidate certain funding sources while still maintaining the intent
and purpose of Title I. The funding sources that may be consolidated
without restrictions are as follows:

● Title I, Part A Improving the Academic Achievement of the
Disadvantaged

● Title I, Part D, Subpart 2 Prevention and Intervention Programs for
Children and Youth Who Are Neglected, Delinquent, or At-Risk.

● Title II, Part A Improving Teacher Quality

● Title II, Part D Enhancing Education Through Technology

● Title III Limited English Proficient

● Title IV, Part A Safe and Drug Free Schools and Communities

● Title V Innovative Programs

● Title VI Rural and Low Income Schools

● Funds received from discretionary (competitive) grants, such as Even
Start

● State and local dollars

The following funding sources may be consolidated, **with
restrictions**.

● Migrant Education Program Funds

● Indian Education Program, Title VII, Part A, section 7115

● IDEA funds

Please refer to U.S. Department of Education Non-Regulatory Guidance for
more information on these restrictions, at
<http://www.doe.state.in.us/TitleI/pdf/nrg_fiscalguid.pdf>. Our office
is also currently working on a fiscal handbook to assist in procedures
related to consolidating funds in schoolwide programs.

Based on recent guidance from the Office of the Inspector General, we
must ensure that schoolwide programs have additional information
outlined within the schoolwide plan. The additional components are: (1)
a description of how the school will provide individual academic
assessment results to parents; (2) strategies to involve parents in the
planning, review, and improvement of the schoolwide plan; and (3) list
of programs that will be consolidated under the schoolwide plan (if
applicable). We will look for these components in both cycle and on-site
monitoring of districts with schoolwide programs.

If you have questions or concerns regarding schoolwide programs, please
contact our office at 317-232-0540 or Toll Free at 877-418-7240.

[^1]: To test processes at LEAs, we reviewed Indianapolis Public Schools
    (Indianapolis) and the School City of East Chicago (East Chicago).

[^2]: All regulatory citations are as of July 1, 2005.

[^3]: Section 1114(b)(1) of the Act contains these components.

[^4]: Our review of parental involvement strategies focused only on
    strategies to involve parents in the planning, review, and
    improvement of the schoolwide program plan.

[^5]: East Chicago's was the only elementary school we visited.
    Therefore, it was the only school required to include plans for
    assisting preschool students in the transition from early childhood
    programs to the schoolwide program.

[^6]: In each case where a school failed to meet this requirement, the
    deficiency was that it did not have in its schoolwide plan a
    strategy to attract highly qualified teachers, which is required by
    Section 1114(b)(1)(E) of the Act and 34 C.F.R. § 200.28(b)(1).

[^7]: A school is required to list the program funds it will consolidate
    in the schoolwide program only if it chooses to consolidate funds.
    Because the school did not consolidate funds, this element was not
    applicable.