Finding Text
2024-003 - Special Tests and Provisions – Participation of Private School Children
Assistance Listing Number 84.010 Title 1
Department of Education
Passed Through North Dakota Department of Public Instruction
Criteria
For programs funded under Title I, Part A (Assistance Listing 84.010), a local educational agency,
after timely and meaningful consultation with private school officials, must provide equitable
services to eligible private school children, their teachers, and their families. Eligible private school
children are those who reside in a participating public school attendance area and have
educational needs under Section 1115(c) of the ESEA (20 USC 6315(c)). The amount of funds a
local educational agency makes available for equitable services under Title I, Part A must be
equal to the proportion of funds generated by private school children from low-income families
who reside in participating public school attendance areas. A local educational agency must
determine the proportional share available for services for eligible private school children based
on the total amount of Title I funds received prior to any expenditures or transfers of funds within
the program, such as reservations for administration, parental involvement, and district-wide
activities (20 USC 6320(a)(4)(A)). Local education agencies determine the proportional share by
multiplying the proportion of children from low-income families who attend private schools and
live in participating Title I attendance areas by the local educational agency’s total Title I allocation
(including any funds transferred into Title I).
Condition
The documentation the District provided supporting numbers of private school children attending
used in the allocation of funds provided to private schools did not agree to the allocation
calculation.
Context
Two participating private schools are within the District’s service area. The supporting
documentation for students attending both of these participating private schools did not agree to
the allocation calculations.
Cause
The District did not maintain proper supporting documentation to support the number of students
from participating private schools.
Effect
Allocation of Title I funding provided to local private schools may not be correct.
Questioned Costs
None
Repeat Finding
This is not a repeat finding.
Recommendation
We recommend the District retain all supporting documentation in accordance with their record
retention policies and ensure the supporting documentation and the information used in the
allocation calculations agree.
Management’s Response
The discrepancy stemmed from the timing of data collection for the nonpublic schools. Worksheet
G was initially completed using estimated numbers during a different month (October) than when
final numbers were collected, resulting in a mismatch with the Final Rank & Serve data. Although
the final numbers used were those approved by DPI, we do not have a corresponding Worksheet
G to verify those figures from that specific month. Moving forward, we will collect Worksheet G
forms monthly from our nonpublic schools -mirroring the process used for public schools through
our child nutrition system. This will ensure consistent documentation and verification of data, and
prevent future discrepancies. Additionally, we recognize that the nonpublic schools' systems are
unable to retrieve historical free/reduced lunch data month by month, which reinforces the need
for this proactive monthly collection.