SUPPORTING SCHOOL REFORM BY 

LEVERAGING FEDERAL FUNDS IN A 

SCHOOLWIDE PROGRAM

Non-Regulatory Guidance

September 2016 

Under the Congressional Review Act, Congress has passed, and the President has 

signed, a resolution of disapproval of the accountability and State plans final 

regulations that were published on November 29, 2016 (81 FR 86076). This 

guidance document is unaffected by that resolution and remains applicable. 
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Aligning Title I and School Reform

Title I, Part A (Title I) of the Elementary and Secondary Education Act of 1965 (ESEA) supports

reforms and innovations to improve educational opportunities for low achieving students. Title I 

is designed to provide all children significant opportunity to receive a fair, equitable, and highquality education, and to close educational achievement gaps. (ESEA section 1001). To this 

end, Title I helps State educational agencies (SEAs), local educational agencies (LEAs), and 

schools meet the educational needs of low-achieving students in schools with high 

concentrations of students from low-income families. 

Over the past few years, SEAs and LEAs have initiated changes and innovations to increase the 

quality of instruction and improve academic achievement for all students. Nearly all SEAs have 

adopted college- and career-ready standards and have developed assessments aligned with those 

standards. SEAs and LEAs are also moving forward with improvements in such areas as teacher 

and leader evaluation and support systems, turning around low-performing schools, and 

expanding access to high-quality schools. Depending on the needs of each school, these reforms 

span a continuum from focusing on specific needs of historically underserved populations to 

implementing rigorous school intervention models designed to turn around a State’s lowestperforming schools. Collectively, these reforms have resulted in significant progress: high 

school graduation rates and the number of students attending college are at all-time highs, while 

dropout rates are at historic lows.

For an LEA implementing these reforms and innovations, it is essential to use Federal education 

funds effectively and efficiently. Of the two types of Title I programs an LEA can operate —

targeted assistance or schoolwide — only the latter permits the LEA to use Title I funds to 

support comprehensive schoolwide reforms. In a schoolwide program, an LEA may use Title I 

funds to implement reforms to upgrade the entire educational program of the school. In contrast, 

in a targeted assistance program, an LEA may use Title I funds only for Title I students — i.e., 

those who are failing, or most at risk of failing, to meet the State’s academic achievement 

standards. (ESEA section 1111(b)(1)(A)).

On December 10, 2015, President Obama signed into law the bipartisan Every Student Succeeds 

Act (ESSA), which reauthorizes the ESEA. This new law builds upon the critical work SEAs 

and LEAs have undertaken in recent years, and includes provisions to expand that progress. The 

new law allows SEAs and LEAs the opportunity to broaden their definitions of educational 

excellence, while maintaining critical civil rights for all students. Additionally, the ESSA 

includes provisions designed to enable SEAs and LEAs to focus on providing students the 

diverse, integrated curriculum and learning experiences necessary for a well-rounded education.

Under the ESSA, schoolwide programs remain a key tool for using Title I funds to improve 

academic achievement and enable a school to more effectively leverage Federal funds to upgrade 

its entire educational program. 

This document explains how operating a schoolwide program under Title I can be beneficial to 

LEAs and schools as they explore how to most effectively leverage their local, State, and Federal 

funds in order to promote school reforms and raise student achievement. In particular, this 
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document highlights specific advantages and flexibilities inherent in schoolwide programs, 

clarifies common misunderstandings about schoolwide programs that may persist, and serves as 

a resource, in conjunction with existing guidance, for SEAs, LEAs, and schools.

The U.S. Department of Education (Department) has determined that this guidance is significant 

guidance under the Office of Management and Budget’s Final Bulletin for Agency Good 

Guidance Practices, 72 Fed. Reg. 3432 (Jan. 25, 2007). See 

www.whitehouse.gov/sites/default/files/omb/memoranda/fy2007/m07-07.pdf. Significant 

guidance is non-binding and does not create or impose new legal requirements. The Department 

is issuing this guidance to provide SEAs, LEAs, and schools with information to assist them in 

meeting their obligations under the ESEA, as amended by ESSA. 

This guidance supersedes the Department’s guidance, entitled “Supporting School Reform by 

Leveraging Federal Funds in a Schoolwide Program,” issued on June 10, 2015. 

If you are interested in commenting on this guidance, please email us your comments at 

OESE.guidance@ed.gov or write to us at the following address: Office of Elementary and 

Secondary Education, 400 Maryland Avenue, SW, Washington, DC 20202. For further 

information about the Department’s guidance processes, please visit 

www2.ed.gov/policy/gen/guid/significant-guidance.html.

Using Title I Schoolwide Programsto Support School Reform

A Title I schoolwide program is a comprehensive reform strategy designed to upgrade the entire 

educational program in a Title I school in order to improve the achievement of the lowestachieving students. (ESEA section 1114(a)(1)).1 Under the ESEA, a school may operate a 

schoolwide program if it meets any of the following conditions:

 A Title I school with 40 percent or more of its students living in poverty, regardless of the 

grades it serves.

 A Title I school that receives a waiver from an SEA to operate a schoolwide program 

without meeting the 40 percent poverty threshold.

 A Tier I or Tier II school in a State that requested and received a waiver through the School 

Improvement Grant (SIG) program that receives funds to implement one of the SIG 

intervention models.2

An SEA has discretion to grant a waiver to allow a Title I school to operate a schoolwide 

program without meeting the 40 percent poverty threshold if the SEA has determined that a 

 1 Throughout this document, unless otherwise indicated, citations to the ESEA refer to the ESEA, as amended by the 

ESSA.

2 Although the SIG program is no longer authorized under the ESSA, because Congress has provided funding for the 

SIG program for fiscal years (FYs) 2015 and 2016, schools may still be receiving funding under SIG for several 

additional school years.
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schoolwide program will best serve the needs of students in the school who are failing, or at risk 

of failing, to meet the challenging State academic standards. (ESEA sections 1114(a)(1)(B) and 

(b)(6)). To grant such a waiver, an SEA must take into account how a schoolwide program will 

best serve the needs of the students in the school in improving academic achievement, and other 

factors. (ESEA section 1114(a)(1)(B)). As an SEA considers exercising this new flexibility, the 

Department encourages the SEA to establish a process, informed through feedback from the 

public, and criteria to ensure that schools receiving a waiver will operate a schoolwide program

in a way that improves the achievement of students in the school who would otherwise be 

eligible to receive Title I services through a targeted assistance program.

Benefiting from Operating a Schoolwide Program

A school that operates a schoolwide program is able to take advantage of numerous benefits, 

including:

 Serving all students. A school operating a schoolwide program does not need to identify 

particular students as eligible to participate. (ESEA section 1114(a)(2)(A)(i)).

 Consolidating Federal, State, and local funds (see discussion below). A school 

operating a schoolwide program may consolidate Federal, State, and local education funds 

to better address the needs of students in the school. (ESEA section 1114(a)(1), (3)).

Implementing a Schoolwide Program

There are three required components of a schoolwide program that are essential to effective 

implementation: conducting a comprehensive needs assessment, preparing a comprehensive 

schoolwide plan, and annually reviewing and revising, as necessary, the schoolwide plan.

 Conducting a comprehensive needs assessment. To ensure that a school’s comprehensive 

plan best serves the needs of those children who are failing, or are at-risk of failing, to meet 

the challenging State academic standards, the school must conduct a comprehensive needs 

assessment. (ESEA section 1114(b)(6)). Through the needs assessment, a school must 

consult with a broad range of stakeholders, including parents, school staff, and others in the 

community, and examine relevant academic achievement data to understand students’ most 

pressing needs and their root causes. (ESEA section 1114(b)(2); 34 C.F.R. § 200.26(a)). 

Where necessary, a school should attempt to engage in interviews, focus groups, or 

surveys, as well as review data on students, educators, and schools to gain a better 

understanding of the root causes of the identified needs.

 Preparing a comprehensive schoolwide plan that describes how the school will improve 

academic achievement throughout the school, but particularly for the lowest-achieving 

students, by addressing the needs identified in the comprehensive needs assessment.

(ESEA section 1114(b)(7)). The schoolwide plan must include a description of how the 

strategies the school will be implementing will provide opportunities and address the 

learning needs of all students in the school, particularly the needs of the lowest-achieving 
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students. (ESEA section 1114(b)(7)(A)(i), (iii)). The plan must also contain descriptions 

of how the methods and instructional strategies that the school intends to use will 

strengthen the academic program in the school, increase the amount and quality of learning 

time, and help provide an enriched and accelerated curriculum, including programs and 

activities necessary to provide a well-rounded education. (ESEA section 

1114(b)(7)(A)(ii)). To ensure that the plan results in progress toward addressing the needs 

of the school, the plan should include benchmarks for the evaluation of program results.

This plan may be integrated into an existing improvement plan.

 Annually evaluating the schoolwide plan, using data from the State’s assessments, other 

student performance data, and perception data to determine if the schoolwide program has 

been effective in addressing the major problem areas and, in turn, increasing student 

achievement, particularly for the lowest-achieving students. Schools must annually revise 

the plan, as necessary, based on student needs and the results of the evaluation to ensure 

continuous improvement. (ESEA section 1114(b)(3); 34 C.F.R. § 200.26(c)).

Using Federal Funds Flexibly in a Schoolwide Program

Consistent with the benefits identified above, a school operating a schoolwide program may use 

Title I funds for any activity that supports the needs of students in the school as identified 

through the comprehensive needs assessment and articulated in the schoolwide plan. (ESEA 

section 1114(b)). In designing and implementing the schoolwide plan, a school must implement 

strategies that: (1) provide opportunities for all children to meet challenging State academic 

standards; (2) use methods and instructional strategies that strengthen the academic program in 

the school, increase the amount and quality of learning time, and help provide an enriched and 

accelerated curriculum, which may include programs, activities, and courses necessary to 

provide a well-rounded education; and (3) address the needs of all students, but particularly those 

at risk of not meeting challenging State academic standards. (ESEA section 1114(b)(7)(A)). 

Examples of Uses of Funds in a Schoolwide Program (Based on the Needs Assessment)

• High-quality preschool or full-day kindergarten and services to facilitate the transition from 

early learning to elementary education programs.

• Recruitment and retention of effective teachers, particularly in high-need subjects.

• Instructional coaches to provide high-quality, school-based professional development.

• Increased learning time.

• Evidence-based strategies to accelerate the acquisition of content knowledge for English 

learners.

• Activities designed to increase access and prepare students for success in high-quality

advanced coursework to earn postsecondary credit while in high school (e.g., Advanced 

Placement, International Baccalaureate, early college high schools, and dual or concurrent 

enrollment programs).

• Career and technical education programs to prepare students for postsecondary education and 

the workforce.
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Examples of Uses of Funds in a Schoolwide Program (Based on the Needs Assessment)

• Counseling, school-based mental health programs, mentoring services, and other strategies to 

improve students’ nonacademic skills.

• School climate interventions (e.g., anti-bullying strategies, positive behavior interventions 

and supports).

• Equipment, materials, and training needed to compile and analyze student achievement data 

to monitor progress, alert the school to struggling students, and drive decision making.

• Response-to-intervention strategies intended to allow for early identification of students with 

learning or behavioral needs and to provide a tiered response based on those needs.

• Activities that have been shown to be effective at increasing family and community 

engagement in the school, including family literacy programs.

• Devices and software for students to access digital learning materials and collaborate with 

peers, and related training for educators (including accessible devices and software needed 

by students with disabilities).

• Two-generation approaches that consider the needs of both vulnerable children and parents, 

together, in the design and delivery of services and programs to support improved economic,

educational, health, safety, and other outcomes that address the issues of intergenerational 

poverty.

The above table provides examples of some of the potential uses of funds available to schools 

when operating a schoolwide program. Each school, in conjunction with LEA officials, has the 

discretion to determine the specifics of a schoolwide plan, including which methods and 

instructional strategies will be used, based on the school’s identified needs in its comprehensive 

needs assessment.

Dispelling Misunderstandings about Uses of Title I Funds in a 

Schoolwide Program

The following are some common misunderstandings regarding the flexibilities available in using 

Title I funds to operate a schoolwide program:

Misunderstanding Explanation of Law

Title I funds may be used only to support 

reading and math instruction.

Title I funds may be used in a schoolwide 

program to support academic areas that the 

school’s needs assessment identifies as 

needing improvement.

Title I funds may be used only to provide 

remedial instruction. 

The purpose of a schoolwide program is to 

upgrade the entire educational program in the 

school in order to raise the achievement of the 

lowest-achieving students. This does not 

need to be achieved through remedial 
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Misunderstanding Explanation of Law

instruction, however. At times, this may be 

best achieved by preparing low-achieving 

students to take advanced courses — for 

example, providing an intensive summer 

school course designed to accelerate their 

knowledge and skills, offering an elective 

course to prepare them to take advanced 

courses, or providing after-school tutoring 

while they are taking advanced courses.

Title I funds may be used only to serve lowachieving students.Title I funds may be used to upgrade the 

entire educational program in a schoolwide 

program school and, in doing so, all students 

may benefit from the use of Title I funds. 

However, consistent with the purpose of Title 

I, the reason to upgrade the entire educational 

program in a school is to improve the 

achievement of the lowest-achieving students.

If a school does not consolidate funds through 

a schoolwide program, Title I funds may be 

used only to provide services in a pull-out 

setting.

Regardless of whether funds are consolidated, 

a schoolwide program school need not use 

Title I funds to provide services only in a 

pull-out setting, although this practice is not 

prohibited. Title I funds may be used to 

upgrade the entire educational program in a 

schoolwide program school and serve all

students, even if the school does not 

consolidate Title I funds with its other funds. 

However, the primary purpose of a 

schoolwide program is to raise the 

achievement of the lowest-achieving students 

by upgrading the entire educational program, 

and can best be achieved by consolidating 

funds. (Please see the discussion below that 

identifies additional advantages of 

consolidating Title I funds with other Federal, 

State, and local funds in a schoolwide 

program.)

Title I funds may be used only for instruction. Title I funds may be used for activities and 

strategies designed to raise the achievement 

of low-achieving students identified by a 

schoolwide program school’s comprehensive 

needs assessment and articulated in the 

school’s comprehensive schoolwide plan. For 

example, Title I funds may be used to 

improve the quality of instructional materials, 

improve attendance, improve school climate, 
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Misunderstanding Explanation of Law

counteract and prevent bullying, provide 

counseling, mentoring, and school-based 

mental health programs, or provide positive 

behavioral interventions and supports.

Title I funds may not be used to support 

preschool-aged children.

A schoolwide program school may use Title I 

funds to operate, in whole or in part, a 

preschool program to improve cognitive, 

health, and social-emotional outcomes for 

children from birth to the age at which the

LEA provides a free public elementary 

education. Such programs are designed to 

prepare children for success in kindergarten. 

All preschool-aged children who reside in the 

school’s attendance area are eligible to 

participate.

Individuals with Disabilities Education Act 

(IDEA) Part B funds may not be consolidated 

in a schoolwide program.

A schoolwide program school may 

consolidate funds received under Part B of the 

IDEA. (Please see the discussion below on 

consolidating Title I funds with other Federal, 

State, and local funds in a schoolwide 

program for an explanation of the limitations 

on the amount of Part B funds that may be 

consolidated.) A school that consolidates 

funds under Part B may use those funds in its 

schoolwide program for any activities under 

its comprehensive schoolwide plan but must 

comply with all other requirements of Part B 

of the IDEA. 

Safeguarding the Interests of Historically Underserved Populations

Although a school may use Title I funds to serve all students in a schoolwide program, there are 

protections to ensure that low-achieving students and historically underserved populations of 

students do not get ignored. 

 The very purpose of a schoolwide program is to upgrade the entire educational program of 

the school in order to raise the achievement of the lowest-achieving students. (ESEA 

section 1114).

 A comprehensive schoolwide plan must include strategies for —

 meeting the educational needs of all students, including each subgroup of students

defined in section 1111(c)(2) (economically disadvantaged students; students from 

major racial and ethnic groups; children with disabilities; and English learners). 

(ESEA section 1114(b)(7)(A)(i)); and
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 addressing the needs of all students but particularly the needs of students who are 

failing, or are at risk of failing, to meet the challenging State academic standards. 

(ESEA section 1114(b)(6), (7)(A)(iii).

 An LEA operating a schoolwide program must comply with all Federal civil rights laws that 

prohibit discrimination based on race, color, national origin, sex, disability, and age. These 

laws include Title VI of the Civil Rights Act of 1964, Title IX of the Education 

Amendments of 1972, Title II of the Americans with Disabilities Act, the Equal 

Educational Opportunities Act (EEOA), Section 504 of the Rehabilitation Act of 1973, and 

the Age Discrimination Act of 1975. In addition, LEAs must comply with the 

requirements under the IDEA with respect to children with disabilities. (ESEA sections 

1114(a)(3)(B), 8306(a)(1)).3

 An LEA must ensure that each schoolwide program school receives funds from nonFederal sources to provide services that are required by law for students with disabilities 

and English learners before using Title I funds in the school. (ESEA section 

1114(a)(2)(B)). 

 If a schoolwide program school consolidates Federal funds, it must maintain records that 

demonstrate that it meets the intent and purposes of each Federal program whose funds it 

consolidates. (ESEA section 1114(a)(3)(C)).

 Before a schoolwide program school may consolidate Title I, Part C Migrant Education 

Program (MEP) funds, it must, in consultation with migrant parents, an organization 

representing those parents, or both, first meet the unique educational needs of migrant 

students that result from the effects of their migratory lifestyle, and those other needs that 

are necessary to permit these students to participate effectively in school. The school also 

must document that these needs have been met. (ESEA section 1306(b)(4); 34 C.F.R. § 

200.29(c)(1)).

 Before a schoolwide program school may consolidate Title VI, Part A, Subpart 1 Indian 

education formula funds to LEAs, the LEA’s Indian committee, composed of parents and 

family members of Indian children, representatives of Indian tribes on Indian lands located 

within 50 miles of a school that has Indian students, teachers, and if appropriate, high 

school students, must approve the inclusion of those funds and the LEA must identify how 

the consolidation of those funds will produce benefits to Indian students that would not be 

achieved if the funds were not used in a schoolwide program. (ESEA section 6115(c)).

 3 Additional information about SEAs’ and LEAs’ legal obligations under Title VI of the Civil Rights Act of 1964 

and the EEOA can be found in a Dear Colleague Letter about EL students and limited English proficient parents 

jointly released by the Department of Education and Department of Justice, available at 

http://www2.ed.gov/about/offices/list/ocr/letters/colleague-el-201501.pdf.
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Consolidating Federal, State, and Local Funds in a Schoolwide 

Program

By making systemic changes that knit together services funded from a variety of sources into a 

comprehensive framework, schools have a better chance of increasing the academic achievement 

of all students. To encourage this approach and better leverage all available funding, a

schoolwide program school has the flexibility to consolidate funds from Title I and other Federal 

education programs with State and local funds. (ESEA section 1114(a)(1), (3)). By 

consolidating funds in a schoolwide program, a school can more effectively design and 

implement a comprehensive plan to upgrade the entire educational program in the school as 

informed by the school’s comprehensive needs assessment. When a school consolidates funds in 

a schoolwide program, those funds lose their individual identity and the school may use the 

funds to support any activity of the schoolwide program without regard to which program 

contributed the specific funds used for a particular activity. Each SEA must ensure that it will 

modify or eliminate State fiscal and accounting barriers so that these funds can be more easily 

consolidated. (ESEA section 1111(g)(2)(E)).

Advantages of Consolidating Funds

in a Schoolwide Program

 Flexibility to allocate all available resources effectively and efficiently.

 A school is not required to meet most of the statutory and regulatory requirements of the 

specific Federal programs included in the consolidation, provided it meets the intent and 

purposes of those programs. 

 A school is not required to maintain separate fiscal accounting records by Federal program 

that identify the specific activities supported by each program’s funds.

NOTE: A schoolwide program school has flexibility in its use of Title I funds even absent 

consolidation. The uses of Title I funds described throughout this document are available to a 

schoolwide program school that does not consolidate its Title I or other Federal 

funds. Consolidation, however, affords even greater flexibility, as discussed above.

As noted above, a schoolwide program school may consolidate funds received under Part B of 

the IDEA. The IDEA provides a straightforward formula for LEAs and their schools that wish to 

consolidate a portion of their IDEA Part B funds in any fiscal year to carry out a schoolwide 

program. (IDEA section 613(a)(2)(D); 34 C.F.R. § 300.206). First, the LEA determines the 

amount of funds it received under the IDEA section 611 (ages 3-21) and 619 (ages 3-5) 

programs. Second, the LEA must divide the total amount of its IDEA grants by the number of 

children with disabilities in the jurisdiction of the LEA. Third, the LEA then multiplies this 

figure by the number of children with disabilities who will be participating in the schoolwide 

program.

The IDEA places the following conditions on LEAs and schools that consolidate IDEA funds in 

a schoolwide program:
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 The IDEA funds must still be counted as Federal funds for IDEA’s excess cost and 

supplement not supplant calculations required by 34 C.F.R. § 300.202(a)(2)-(3).

 Regardless of how the IDEA funds are expended, children with disabilities in a 

schoolwide program school must:

 receive services in accordance with a properly developed individualized education 

program (IEP); and

 be afforded all of the rights and services guaranteed to children with disabilities and 

their parents under the IDEA.

The following guidance documents contain additional information on consolidation of funds that 

may be useful for schools operating schoolwide programs:

 Title I Fiscal Issues, pp. 49-63 (Feb. 2008) (available at 

http://www2.ed.gov/programs/titleiparta/fiscalguid.pdf) (provides information on 

consolidating funds in a schoolwide program).

 Notice Authorizing Schoolwide Programs to Consolidate Federal Education Funds and 

Exempting Them From Complying With Statutory or Regulatory Provisions of Those 

Programs, 69 FR 40360-64 (July 2, 2004) (available at www.gpo.gov/fdsys/pkg/FR2004-07-02/pdf/04-15121.pdf) (provides information regarding what Federal education 

programs may be consolidated in a schoolwide program and how a school can ensure that 

it meets the intent and purposes of the Federal programs included in the consolidated 

schoolwide program).

Using Federal Funds to Supplement School Reform

Despite the flexibilities that schoolwide programs offer LEAs and schools when using Federal 

funds, schools participating in a schoolwide program may still only use funds to supplement the 

amount of funds that would be made available for the school from State and local sources in the 

absence of Federal funds. (ESEA sections 1114(a)(2)(B), 1118(b)). Additional information

regarding compliance with this requirement will be issued by the Department at a later date.