Overview | Title IV-A Project Planning Toolkit

The Every Student Succeeds Act (ESSA) is the most recent reauthorization of the Elementary and Secondary Education Act of 1965 (ESEA). ESSA continues the civil rights foundation of ESEA, reflecting our nation's longstanding commitment to equity of opportunity for all students. The new law has a clear goal of ensuring our education system prepares every child to graduate from high school ready to thrive in college and careers. The 2015 reauthorization includes a number of provisions that promote equitable access to educational opportunity, including holding all students to high academic standards, ensuring meaningful action is taken to improve the lowest-performing schools and schools with underperforming student groups, and providing more children with access to high-quality pre-school learning opportunities. As we work to improve education outcomes for students the ultimate goal is to provide all students with a high-quality education.

Title IV, Part A, (also known as the Student Support and Academic Enrichment Grants or SSAE) in the 2015 reauthorized Elementary and Secondary Education Act supports our nation's commitment to equity of opportunity for all students. The Title IV, Part A the Student Support and Academic Enrichment (SSAE) program is intended to ensure all children graduate from high school ready to thrive in college and careers by increasing the capacity of State education agencies (SEAs), local education agencies (LEAs), schools, and local communities to:

provide all students with access to a well-rounded education,

improve school conditions for student learning, and

improve the use of technology in order to improve the academic achievement and digital literacy of all students.

Among the key values set forth in the New Hampshire ESSA Consolidated State Plan is improving our education system through personalization and competency-based teaching and learning. The New Hampshire Title IV, part A program is designed to support this vision within a framework of preparing students for the future.

Essential Requirements of the Title IV-A Student Support and Academic Enrichment Grant program:

Participation in Title I-A: In order to be eligible for TItle IV-A funds, an LEA has to have participated in Title I-A and used funds in the previous year.
Title IV-A Program Development StakeholderTeam: Stakeholders from a variety of educators, schools, community members and organziations, municipal officials, should meet to determine needs, prioritize those needs, and design the program that best uses the allocated funds. An LEA is required to develop its activities through meaningful and ongoing consultation with a group of stakeholders which should include parents, teachers, principals, other school leaders, specialized instructional support personnel, students, community-based organizations, local government representatives (which may include a local law enforcement agency, local juvenile court, local child welfare agency, or local public housing agency), Native American tribes or tribal organizations where applicable, and others with relevant and demonstrated expertise in programs and activities. Representatives from any non-public schools participating in Title IV-A services should also be included as meaningful and ongoing consultation is also required to provide equitable services to non-public students and teachers.
Timeline: An initial general application and plan for spending is needed through online Grants Management System. Individual Activities can be added in GMS on a rolling basis. NHED uses a Consolidated Application process.
Period of Availability: Title IV, Part A funds will remain available for obligation by LEAs for 27 months, beginning on July 1 and ending on September 30, per the "Tydings Amendment."
Needs Assessment: All Title IV-A programs should be based on identified and prioritized student needs for supplemental support. An LEA that receives at least $30,000 in SSAE program funds must conduct a comprehensive needs assessment that includes, at a minimum, a focus on the three content areas listed above. (ESEA section 4106(d)). The comprehensive needs assessment is part of the consolidated application process for LEAs with allocations greater than $30,000. Whether a comprehensive needs assessment, or otherwise, your needs assessment should be uploaded as part of your consolidated application.
Program Assurances: Program assurances must be reviewed by the Superintendent/Charter School Administrator and must be provided to and reviewed with the LEA school board/board of trustees. The Superintendent/Charter School Administrator must then sign each of the program assurances the LEA plans to participate in and attach the assurances document to the district page of the Grants Management System. Find and download the General and Program Assurances document from the Documents for Districts Folder. These are located in the separate subfolders for each grant year in the main document folder.
Please note that Program Assurances are different than the General Assurances, which are aligned to the Uniform Grant Guidance. Submission of the General Assurances are also required before funds can be spent.
Supplement not Supplant Requirement: These funds cannot be used in place of State or local funds that would have otherwise been used for such activities.
Equitable Services: LEAs receiving Title IV, Part A funds must comply with sections 8501-8504 of the Every Student Succeeds Act regarding equitable participation of private school students.
Appropriate and Allowable Activities: All activities should be based on need, and expenses deemed necessary and reasonable for the success of the activity. For more information regarding allowable uses of Title IV, Part A funds, please refer to the non-regulatory guidance provided by the US Department of Education. There is an Allowability Flowchart available in the Infographics subfolder in this toolkit. It outlines the porcess that should be followed in order to determine whether or not your activity is allowabile and appropriate for Tile IV-A funding.
Public Reporting of Use of Funds: At the end of the performance period of Title IV-A programs, data on the extent to which your program objectives were met by your program activities will be collected by NHED for the purposes of public reporting of how funds were used, which is a requirement of Title IV, Part A participation.

The Title IV-A Program at the NH Department of Education is supporting New Hampshire School Districts in their efforts to improve personalized learning and competency-based education through the development of programs and initiatives that ensure learning experiences are integrated with digital tools and resources literacy that enhance learning. Engaging students and school communities in activities that integrate digital tools and resources is a powerful way for schools and districts to move students towards future readiness. Title IV-A funds are intended to be used by districts to supplement an identified need in the district. The New Hampshire Title IV-A Program uses the Future Ready Framework, an evidence based framework for developing systemic personalized learning through visioning, planning, and implementation of school improvement activities, as a guide for districts seeking to determine program needs. The Future Ready District Leadership Survey is a tool that districts can use to determine where the needs are in their districts around 7 areas of the framework. The NH Title IV-A program modifies that framework slightly in order to focus the needs assessment on the three main areas supported by Title IV-A: well rounded education, safe and healthy schools, and effective use of technology. Districts can use the modified Future Ready District survey tool to find areas of need in their programs and focus their Title IV-A funding around activities that address those needs.

For more information regarding allowable uses of Title IV-A funds, please refer to the Non-Regulatory Guidance provided by the US Department of Education.

You might consider reading Blending Teaching and Technology: Simple Strategies for Improved Student Learning, a release from Future Ready Schools. You can download a pdf of the report from the web.

Needs Assessment

Districts with Grant Allocations of $30,000 or More

An LEA that receives at least $30,000 in SSAE program funds must conduct a comprehensive needs assessment that includes, at a minimum, a focus on the three content areas identified as Title IV-A Focus areas. (ESEA section 4106(d))

The Title IV-A Program, in collaboration with the T4PA Center, established a needs assessment which LEAs can use to identify areas of student support needs in each of the Title IV-A program content areas.

There is a Needs Assessment subfolder in the Documents for LEAs folder in this toolkit.

The Needs Assessment subfolder also has an easy reference chart to identify Domains and Criteria for Assessing Needs that should be considered in each of the Title IV-A Content areas.

Districts will be asked to upload their Needs Assessments in the Online Grants Management System as part of the initial consolidated application process. Planned activities should be based on identified needs for supplemental student support in the program areas, as required by the Title IV-A federal grant program.

Districts receiving $30,000 or more are required to:

Perform a comprehensive needs assessment in order to justify their activities as a determined need.

Spend at least 20% of their funds on well-rounded academic programs.

Spend at least 20% on safety and healthy students programs.

Spend at least some of the remaining available on effective use of technology.

Spend no more than 15% of their effective use of technology funds on infrastructure technology.

Districts with Grant Allocations of Less than $30,000

Districts with allocations under the $30,000 threshold may choose, but do not have to conduct, a comprehensive needs assessment. However, those districts still must base their Title IV-A activities on demonstrated needs for supplemental student support and document their needs. For example, logic models or strategic plans are acceptable ways to show the relationship between an existing need and programs or activities.

The Domains and Criteria for Assessing Needs document can also be used in this case to identify areas to explore in the Title IV-A Content areas to determine needs.

Federal Funds Information and Guidance

The NHDOE Bureau of Federal Compliance (BFC) has developed Federal Fund Information Sheets to assist subrecipients of Federal funds with understanding the compliance requirements associated with the various aspects of their grants when developing and implementing policies and procedures.

Federal Funds Information Sheets

Federal Fund Fact Sheets

District Allocations

The minimum allocation is $10,000. Check the list of allocations to see what your Title IV-A funding level will be. This document is also available for download in the Title IV-A Resources Folder.

Note: LEA allocations for previous years are given on each tab.

Period of Availability

The "Tydings Amendment" applies to Federal Title IV-A funds, and therefore, funds will remain available for obligation by school districts through September 30, 27 months after the July 1 start date. All funds must be spent within 45 days of the September 30, closing, which puts the final date for spending at November 14.

Requirement to Supplement not Supplant

In considering how to use Title IV-A program funds, LEAs must be mindful that federal funds may be used only to supplement, and not supplant, non-Federal funds that would otherwise be available for activities authorized under the Title IV-A. (ESEA section 4110). This means that, in general, LEAs may not use Title IV-A program funds if the cost of those activities would have otherwise been paid with State or local funds in the absence of the Title IV-A program funds. Title IV-A funds cannot supplant State or local funds.

SEC. 4110. SUPPLEMENT, NOT SUPPLANT. Funds made available under this subpart shall be used to supplement, and not supplant, non-Federal funds that would otherwise be used for activities authorized under this subpart.

Supplement means to build upon or add to.
Supplant means to replace or take the place of.

Federal law prohibits recipients of federal funds from replacing state, local, or agency funds with federal funds. Existing funds for a project and its activities may not be displaced by federal funds and reallocated for other organizational expenses. If state or local law, or district policy, requires the program, equipment, or service, it cannot be purchased using federal funds. This is illegal.

On the other hand, federal agencies encourage supplementing - that is, adding federal funds to what is available in state, local, or agency funds.

Equitable Services

LEAs must comply with Sections 8501 through 8504 of the Every Student Succeeds Act regarding equitable participation of private school students. In general, consistent with the number of eligible children in areas served by the LEA receiving a Title IV-A grant who are enrolled in private elementary or secondary schools in areas served by the LEA, after timely and meaningful consultation with the appropriate private school officials, provide to those children and their teachers or other educational personnel, on an equitable basis, educational services or other benefits that address their needs under the grant award.

To avoid any questions about this provision, it is recommended that you list the appropriate schools in your project description and report that they have been contacted, and on whether or not those schools will participate in your activities.

The ESEA Equitable Services page on the NHED website has information, guidance, and equitable services calculators available for download and use.

There are training materials and documents available in the Equitable Services Folder Title IV-A Documents for Districts Folder of this toolkit.

Documents can change or be updated each year, so be certain to access the most recent document available.

Obligation of Funds
Funds allocated to an LEA for educational services and other benefits to eligible private school children, teachers and other educational personnel, and families must be obligated in the fiscal year for which the funds are received by the LEA. (ESEA sections 1117(a)(4)(B) and 8501(a)(4)(B).)

Ombudsman
To help ensure equitable services and other benefits for eligible private school children, teachers and other educational personnel, and families, an SEA must designate an ombudsman to monitor and enforce ESEA equitable services requirements under both Title I and Title VIII.
(ESEA sections 1117(a)(3)(B) and 8501(a)(3)(B).)

Consultation
The topics subject to consultation have been expanded to include the following:

How the proportion of funds allocated for equitable services is determined.
Whether the LEA will provide services directly or through a separate government agency, consortium, entity or third-party contractor.
Whether to provide equitable services to eligible private school children by pooling funds or on a school-by-school basis.
When, including the approximate time of day, services will be provided.
Whether to consolidate and use funds available for Title I equitable services in coordination with eligible funds available for equitable services under programs covered under section 8501(b) to provide services to eligible private school children in participating programs.
The written affirmation that consultation has occurred must provide the option for private school officials to indicate such officials' belief that timely and meaningful consultation has not occurred or that the program design is not equitable with respect to eligible private school children.

(ESEA section 1117(b)(1).)

The Equitable Services Consultation Cycle infographic is available in the Infographic subfolder within the Training Materials folder in the Documents folder of this toolkit.

Change to Existing Requirement: Updates to Programs Covered Under Title VIII
ESSA updated the covered programs to include the following:

Title I, Part C - Education of migratory children
Title II, Part A - Supporting effective instruction state grants
Title III, Part A - English language acquisition, language enhancement, and academic achievement
Title IV, Part A - Student support and academic enrichment grants
Title IV, Part B - 21st Century Community Learning Centers

(ESEA section 8501(b).)
How to provide equitable services under Title IV, Part A:
SEAs and LEAs are required to provide equitable services for private school students and teachers under Title IV, Part A. Title VIII, Part F (sections 8501-8504) of the ESEA, as amended by the ESSA, governs equitable services for SSAE.

USED Issues Equitable Services Guidance on Religiously-Affiliated Contractors
The U.S. Department of Education announced it will now allow religiously-affiliated organizations to contract to provide equitable services to students under the Elementary and Secondary Education Act (ESEA). Under ESEA, districts have to offer qualifying students who attend private schools the same services as their public-school peers. However, statutory language in ESEA prohibits money from going directly to private schools, instead requiring districts to provide services themselves or use contractors (this prohibition does not apply to contractors working with a public-school district).

A recent U.S. Supreme Court decision in Trinity Lutheran Church of Columbia, Inc. vs. Comer, however, found that such restrictions were unconstitutional. In that case, the Court found that a Missouri State program which denied a church the ability to apply for a playground resurfacing grant was unconstitutional because the prohibition was based solely on the religious character of the organization.

The announcement was made in draft updated guidance the equitable services requirements of ESEA. The guidance is based on an earlier version but has been updated to reflect the change in policy based on the Trinity Lutheran case. Ultimately under this updated guidance, districts will still be able to decide which contractors are used, and the services required would have to be completely secular and non-ideological. In an effort to avoid concerns about self-dealing, the contractor may not be affiliated with the private school where the services are being offered. The guidance also emphasizes that these districts must continue to follow all other fiscal and equitable services requirements of the law.

Some advocates have criticized this decision, saying it is interpreting a very narrow decision too broadly – and that access to State grants should not be equated with the provision of educational services.

The Title I, Part A Providing Equitable Services to Eligible Private School Children, Teachers and Families - Non-Regulatory Guidance (2019) is available from the US Department of Education.
The Equitable Services for Eligible Private School Children, Teachers, and Other Educational Personnel Non-Regulatory Guidance (2023), which covers Title IV-A, is available from the US Department of Education, and in the Equitable Services subfolder of the Documents folder in this toolkit.

Equipment Purchases Using Title IV-A Funds

All equipment with valued at $250 or greater, purchased using federal Title IV-A funds, must be inventoried and tracked by the LEA. Equipment over $5000 must also be tagged with a "purchased through Title IV-A funds" tag. The Title IV-A Program at the NH Department of Education will have tags available for districts who need to tag equipment over $5000 purchased as part of their Tilte IV-A program activities. The Department will record the tag numbers each district has. However, it is the district's responsibility to report the number of tags it needs to the Title IV-A Program, tag the purchased equipment, inventory it, and then track all equipment purchased using Title IV-A funds. Equipment tags and tracking documentation will be examined during site visits and expected in the final Title IV-A Program report.

Resource and Reading Links

New Hampshire ESSA Consolidated State Plan https://www.education.nh.gov/sites/g/files/ehbemt326/files/inline-documents/sonh/essa-consolidated-state-plan.pdf

Office of ESEA Programs at the NH Department of Education https://www.education.nh.gov/who-we-are/division-of-learner-support/bureau-of-instructional-support/integrated-programs

Updates from the US Education Department https://www2.ed.gov/policy/elsec/leg/essa/essaguidance160477.pdf

Title IX, Part E Uniform Provisions Subpart 1 - Private Schools Equitable Participation Guidance (still applicable unless otherwise noted in the "Updates" above) http://www2.ed.gov/policy/elsec/guid/equitableserguidance.doc

Non-Public Schools Listed by Name https://my.doe.nh.gov/Profiles/PublicReports/PublicReports.aspx?ReportName=SchoolsNonPublic

Non-Public Schools Listed by Town https://my.doe.nh.gov/Profiles/PublicReports/PublicReports.aspx?ReportName=SchoolsNonPublicByTown

Equitable Services Folder in the Toolkit https://drive.google.com/drive/folders/163Kdnd9WMCbme3qgg7eCdOKgVyVaF7Rg

Non-Regulatory Guidance: Fiscal Changes and Equitable Services Requirements Under the Elementary and Secondary Education Act of 1965 (ESEA), as amended by the Every Student Succeeds Act (ESSA)(2016) https://www2.ed.gov/policy/elsec/leg/essa/essaguidance160477.pdf

Title IV-A Program Overview

NH Title IV-A Student Support and Academic Enrichment Grant Program