MEMORANDUM

At the Non-public School conference on December 2, 2005, many questions were generated regarding non-public schools and Title I services.  Under Title I, it’s the obligation of the LEA where the non-public school child resides to provide Title I services.  The resident LEA has the obligation to collect the poverty data for their resident non-public school children who live in the participating public school attendance area and determine the PPE.  Then the LEA can either provide services to their resident students who are at-risk of failing (and live in a predicating public school attendance area) directly with the funds their children generated or transfer the funds to the LEA where the non-public school is located and have that LEA provide the services to the resident LEAs at-risk children (who live in the residents participating public school attendance areas.).

The resident LEA under Title I has the legal responsibility to provide (or make arrangements to provide) Title I services.  The LEA where the non-public school is located has absolutely no responsibility for non-public school children who are not their residents and may not use Title I funds generated by their residents in the census poverty data to service children who are not residents of their LEA. 

The location of the non-public school in a participating public school attendance has no bearing on determining who gets services.  The IG made findings on this several years ago in California.  If you have any questions about non-public schools, please contract your program consultant at 317-232-0540.