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June 30, 2014

Dear Colleague:

As educators across the country work to empower all students to  meet the academic and career preparation demands of the 21st  century, the role of school counselors has never been more important.  School counselors are often the vital link  between students’ aspirations for the future and tangible opportunities for  postsecondary success.  They are also  particularly important for our neediest students, who require expert and  accessible guidance as they navigate a challenging and complicated college  admissions and career preparation landscape.   As State and local educational agencies (SEAs and LEAs) prepare for the  start of the 2014–2015 school year, I want to call attention to the urgent need  for highly effective school counselors and discuss the importance of amplifying  the impact of school counselors on students’ academic success, social-emotional  well-being, and college and career readiness.

If the nation is to meet President Obama’s goal of having the  highest proportion of college graduates in the world by 2020, it is imperative  that all students have consistent access to school counselors who possess the  training and skills to help students reach their highest aspirations.  School counselors are pivotal in helping  students manage their academic programs as well as the inevitable life events  that may threaten students’ ability to succeed in school.  Yet, as the Civil Rights Data Collection  recently found, one in five American high schools operates without any school  counselors on staff (http://www.ed.gov/blog/2014/03/five-new-facts-from-the-civil-rights-data-collection/).  This is an untenable situation for millions  of students who need the support of site-based school counselors, whose job it  is to ensure their students’ success.

Schools that do employ counselors may not use them to full  advantage.  Despite the critical role school  counselors play in supporting students’ college and career readiness, they  often are asked to perform many “non-counseling” duties that can distract from  their core work and ultimately leave students without the individualized  attention they need to complete their academic course work, successfully navigate  the college admissions and financial aid processes, and/or prepare for  productive careers.  Increasing the  number of students who graduate from high school ready for college and careers  requires that all students benefit from a holistic support system that ensures  consistent access to effective school counselors.

Schools and LEAs should support their school counselors by providing  them with the time, space, and resources they need to work effectively on  behalf of students, while also holding them accountable for measurably  improving the college and career readiness of the students they serve.  Doing this well will require that SEAs and  LEAs make wise investments in professional development for school counselors,  create or provide data platforms that can enable school counselors to extend  their impact and reach all students, and provide high-quality training for  principals and teachers so they understand how to most appropriately utilize  and build on the capacities of school counselors.

Additionally, schools and LEAs can further support student success  by engaging school counselors in a leadership capacity to serve as trainers and  providers of professional development designed to improve all educators'  understanding of the college awareness, admissions, and financial aid  processes.  This strategy could help  school counselors focus their energies on meeting students' academic,  social-emotional, and college- and career-readiness needs, especially those of the  many first-generation college-bound students who are now graduating from our  high schools.  A systemic and sustainable  approach to supporting school counselors in meeting increased professional demands  should include a consideration of how federal funds and programs can help  improve and expand the reach of school counselors.  To that point, please find attached a list of  federal initiatives and programs that may support the hiring, development, and  retention of effective school counselors, including school counselor-led  professional development activities.

Decades of professional experience confirm—and an emerging body of  research indicates—that school counselors play a critical role in helping to  ensure that our nation's students graduate from high school ready for college  and careers.  Without the support of  school counselors, millions of students would neither graduate from high school  nor fulfill the essential requirements of the college admissions and financial  aid processes.  I urge SEAs and LEAs to  use the summer months to strategize and develop policies and programs that  enable school counselors to become more effective at helping greater numbers of  students—especially low-income students, minority students, students with  disabilities, and English learners—successfully access postsecondary education or  career opportunities.



| | Sincerely, 
| | -----------
| | /s/        
| | Arne Duncan

Enclosure

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The  U.S. Department of Education (ED) administers a number of programs that a State  educational agency (SEA) or local educational agency (LEA) may leverage to  provide support for school counselors.  Below  is a listing of the major federal programs whose funds may be used to support  school counselors, links to the relevant program Web sites, and a brief  description of how funds under each program might be used.

Please be aware that  the use of funds to support school counselors must meet the applicable  requirements of each program.  For  example, the use of funds must be consistent with allowable costs, including  the applicable cost principles.  In  addition, a number of programs contain a requirement that federal funds be used  only to supplement, and not supplant, funds from non-federal sources that  would, in the absence of the federal funds, be available for particular  activities.

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**Elementary  and Secondary School Counseling Programs**

The Elementary and Secondary School Counseling program (ESSC)  provides competitive grants to enable LEAs to establish or expand school  counseling programs.  The ESSC statutory  authority permits LEAs to use grant funds for the counseling of elementary and  secondary students on postsecondary topics such as the high school courses  students need to take in order to prepare for college, as well as on academic  and career planning.  Professional  development for school counselors is generally an allowable use of program  funds.

**FAFSA  Completion Initiative**

In  March 2014, President Obama announced the launch of the FAFSA Completion  Initiative aimed at increasing the number of students who complete their FAFSAs  and, thus, boosting the number of students who are able to fulfill their  college and career aspirations.  The  FAFSA is a critical gatekeeper on the road to college and other postsecondary  opportunities.  The FAFSA Completion  Initiative cannot be successful, however, without school counselors' support  and engagement.  To contribute to the  success of this initiative, ED has released a suite of resources to support  school counselors in their work of driving FAFSA completion and will soon begin  partnering with SEAs, enabling them to begin sharing valuable, real-time  information with schools and LEAs on student progress in completing the  FAFSA.  In addition, in December 2013,  ED’s Federal Student Aid office launched the Financial Aid Toolkit  to help counselors understand the basics of federal  student aid, provide tips on hosting events (along with sample PowerPoint  presentations), provide suggested messages for social media and e-mail  outreach, and help find other training opportunities.

**Improving Basic Programs Operated by  Local Educational Agencies (Title I, Part A)**

The Title I, Part A program focuses on improving the  academic achievement of low-achieving students in schools with high  concentrations of children from low-income families.  There are two types of Title I programs: schoolwide  programs and targeted assistance programs.   How Title I, Part A funds may be used depends on the type of program.

Title I Schoolwide  Programs:

- A schoolwide program must include schoolwide  reform strategies that, among other requirements, address the needs of all  children in the school, but particularly the needs of low-achieving children as  identified in the school’s comprehensive needs assessment and articulated in  its schoolwide plan.  When supported by  the needs assessment, college and career awareness and preparation, such as  college and career guidance or professional development for school counselors,  may be part of a schoolwide plan and Title I funds may be used to support such  activities.

Title I Targeted Assistance Programs:

- A Title I school operating a targeted assistance  program may use its Title I funds for professional development that is related  to the needs of participating Title I students and is provided to staff who  work with those students.  Therefore, a  school using Title I, Part A funds to operate a targeted assistance program may  elect to use part of its funding to support professional development for school  counselors if this professional development is focused on improving the college  and career readiness of Title I participating students, and such services are  otherwise not available for all students.

Please  refer to ED’s nonregulatory guidance on the use of Title I, Part A funds  (available at: http://www2.ed.gov/policy/gen/leg/recovery/guidance/titlei-reform.pdf)  for additional information on determining whether a particular use of Title I,  Part A funds is allowable.

**Improving  Teacher Quality State Grants Program (ESEA Title II, Part A)**

The purpose of the ESEA Title II, Part A program is to  increase academic achievement by improving teacher and principal quality. The  funds from ESEA Title II, Part A may also be used to support pupil services  personnel (*including* school  counselors) in very specific circumstances.

Provisions related to LEAs:

- LEAs may use Title II, Part A funds to develop  and implement “mechanisms to assist schools in effectively recruiting and  retaining highly qualified teachers, principals, and pupil services personnel”  (Section 2123(a)(1)).  This provision  includes activities designed to recruit and retain school counselors.  For example, if an LEA uses Title II, Part A  funds to provide professional development activities focused on “effective  instructional strategies, methods, and skills, and use of challenging State  academic content standards and student academic achievement standards, and  State assessments” (Section 2123(a)(3)(A)(ii)) as a recruitment and retention  strategy for highly qualified teachers and principals, school counselors may  also be included in such activities.

However, the funds may only be  used for pupil services personnel if (1) 100 percent of an LEA’s teachers  of core academic subject classes are highly qualified (Section 1119(a)(2)); and  (2) the mechanisms used to recruit and retain pupil services personnel are  consistent with those used to help schools effectively recruit and retain  highly qualified teachers and principals (Section 2123(a)(1)).  An LEA may use Title II, Part A funds for recruitment  efforts (e.g., job fairs) that focus on pupil services personnel, but may not  use those funds to provide financial or other personal incentives to these personnel  if they accept a position working in the LEA.

- LEAs may use Title II, Part A funds to carry out  programs and activities designed to improve the quality of the teacher force  and to improve the quality of principals and superintendents (Sections  2123(a)(5) and 2123 (a)(6)).  LEAs may  therefore use Title II, Part A funds to fund school counselor-led professional  development activities for teachers, principals, and superintendents that focus,  for example, on helping them to ensure all students achieve academically and are  college- and career-ready.

- LEAs may use Title II, Part A funds to provide  training in how to teach and address the needs of students with different  learning styles, particularly students with disabilities, students with special  learning needs, and English learners, as well as training in methods to improve  student behavior in the classroom and identifying early interventions to help  students with special needs, such as those mentioned above (Section  2123(a)(3)(B)).  Capable school  counselors could provide such training.

Provisions related to SEAs:

- SEAs may use their Title II, Part A funds for  the same activities listed above for LEAs, with the same conditions (Section  2113(c)(4)).

- SEAs may use Title II, Part A funds to include  pupil services personnel in its professional development activities if the SEA  determines participation is appropriate (Section 2113(c)(6)).

Finally, SEAs and LEAs should note that, although sections  2113(c)(4) and 2123(a)(2) of Title II, Part A permit SEAs and LEAs to provide  financial and other incentives to hire highly qualified teachers—and SEAs and LEAs  may target these incentives, for example, on those who likely would be most  effective in increasing student achievement—this provision does not extend to  pupil services personnel.

**McKinney-Vento  Education for Homeless Children and Youth Program**

The Education for Homeless Children and Youth (EHCY)  program is authorized under Title VII, Subtitle B of the McKinney-Vento  Homeless Assistance Act (McKinney-Vento Act) and is designed to address the  challenges that homeless children and youth face in enrolling, attending, and  succeeding in school.  Consistent with  the purpose of the program, an LEA receiving a subgrant may use EHCY funds to  support counseling services for students experiencing homelessness that expand  upon or improve services provided as part of the regular educational program.

For example, section 723(d)(12) of the McKinney-Vento Act  specifically authorizes the use of EHCY funds for pupil services, which may  include counseling for students experiencing homelessness related to their  academic, social-emotional, and college- and career-readiness needs.  In addition, section 723(d)(3) of the  McKinney-Vento Act provides that EHCY funds may be used for professional  development and other activities for educators and pupil services personnel,  including counselors, to heighten the understanding of the needs and rights of  homeless children and youth.  Additional  information regarding the EHCY program is available at http://www2.ed.gov/programs/homeless/legislation.html

**Prevention and Intervention Programs for  Children and Youths Who Are Neglected, Delinquent, or At Risk**

The Prevention and Intervention Programs for the  Education of Children and Youth Who Are Neglected, Delinquent, or At-Risk under  Title I, Part D of the ESEA  include two programs:  the State agency program (Subpart 1) and the  local educational agency program (Subpart 2).   These programs are designed (1) to improve educational services for  neglected or delinquent children and youth so that they have the opportunity to  meet the same challenging State academic content and achievement standards that  all children in the State are expected to meet; (2) to provide services needed  to make a successful transition from institutionalization to further schooling  or employment; and (3) to prevent at-risk youth from dropping out of school.

With respect to the Subpart 1 State agency program,  section 1418 of the ESEA requires that a State agency receiving a subgrant  reserve 15-30 percent of grant funds for transition services to help children  and youth who are neglected reenter school successfully or find employment  after they leave a State-operated institution.   These transition services may include counseling services as well as college  program placement services; information concerning, and assistance in  obtaining, available student financial aid; and job placement services.  More generally, Subpart 1 funds may be used  to hire additional educational staff, including counselors.

The Subpart 2 local educational agency program authorizes  SEAs to make subgrants to LEAs with locally operated residential institutions  for neglected or delinquent children or youth within their boundaries.  Under section 1424 of the ESEA, an LEA  receiving a Subpart 2 subgrant may use grant funds for counseling, including  mental health counseling, drug and alcohol counseling, and career counseling,  and in assisting eligible at-risk children and youth in securing student loans  or grants for postsecondary education.

Additional  information regarding Title I, Part D is available at http://www2.ed.gov/programs/titleipartd/legislation.html

**School Improvement Grants**

School Improvement Grants (SIG) provide support to turn  around a State’s lowest-achieving schools.  States must award their SIG funds directly to LEAs that demonstrate the  greatest need for the funds and the strongest commitment to using those funds  to raise substantially the achievement of students by implementing rigorous  intervention models in their persistently lowest achieving Title I schools, as  well as secondary schools that are eligible for, but do not receive, Title I  funds.

The SIG final requirements require participating schools  to implement one of four school intervention models:  (1) the “turnaround” model; (2) the “restart”  model; (3) school closure; and (4) the “transformation” model.  A school implementing the “transformation” or  “turnaround” model is required to provide ongoing high-quality, job-embedded  professional development that is aligned with the school’s comprehensive  instructional program and designed with school staff to ensure that they are  equipped to facilitate effective teaching and learning and have the capacity to  successfully implement school reform strategies.  Under the “restart” model, professional  development is an allowable activity.   Thus, the use of SIG funds to provide professional development to school  counselors is generally allowable in a school that is implementing one of these  three school intervention models, each of which represents a comprehensive  approach to addressing the needs of the students in a school as identified  through the LEA’s needs assessment.

SIG funds can be used to support a myriad of activities  as part of a comprehensive approach to turning around a school; it is possible  that those activities could include hiring school counselors or expanding  school counseling resources, etc.  Any  activity would need to be directly related to the  full and effective implementation of the selected model consistent with the LEA’s  approved SIG application, address the needs identified in the needs assessment  required by the SIG final requirements, and advance the overall goal of the SIG  program of improving student academic achievement in the school.

Please refer to question I-30 in ED’s SIG guidance  (available at: http://www2.ed.gov/programs/sif/sigguidance03012012.doc) and  the SIG final requirements, as published in the *Federal Register* (available at: http://www2.ed.gov/programs/sif/2010-27313.pdf),  for additional information regarding the factors to be considered in  determining whether a particular use of SIG funds is allowable.

**21st  Century Community Learning Centers Program (Title IV, Part B)**

The 21st Century Community Learning Centers (CCLC)  program supports the creation of community learning centers that provide  opportunities for academic enrichment through a variety of activities during  non-school hours for children, particularly students who attend high-poverty  and low-performing schools.  21st CCLC funds  may be used to support a variety of counseling programs, including, for  example, school counseling staffs serving in the role of after-school college  and career prep advisors or other roles supporting academic or enrichment  activities.