09. Policy

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The North Carolina School Boards Association (NCSBA) recently learned of a new policy requirement established by the North Carolina Department of Public Instruction (NCDPI) for recipients of Title I funds.  Title I contains a long-standing requirement on comparability of services, which means that LEAs must use state and local funds in Title I schools to provide services that are comparable to those provided in non-Title I schools.  This year for the first time, LEAs must provide assurance that they have board-adopted policies to ensure comparability of services and that they have procedures in place to ensure compliance with the requirements.  This comparability documentation, including assurance that the LEA has the requisite policy, was due to NCDPI by December 1. 
 
On November 29, NCSBA provided a new sample policy 3565/8307 that was accepted by the Federal Programs Division as meeting the new requirements.  Due to the impossibility of boards of education passing a new policy in less than two days, NCSBA advised that Title I coordinators contact DPI and ask for an extension.  On December 1, DPI advised Title I coordinators that it is not requiring adoption of a new policy as a condition of receiving funding in the 2016-2017 school year, and that each LEA “may continue to use policies (a single policy or multiple policies) that were in place in previous years for the purpose of signing the written assurance.”  
 
In light of all this, board attorneys have advised the following:
  • There is no need to hold an emergency meeting to consider adoption of this policy.
  • Given that DPI says it does not expect LEAs to adopt a new policy for purposes of funding this school year, there is also no need to request any extension of time.
  • Since no districts currently have policies addressing these requirements, local boards should proceed with consideration of a policy at its next meeting.  The policy will be a funding requirement in subsequent years; therefore, reasonably prompt adoption of a policy will help avoid any question of compliance and ensure that NCSBA’s future policy revisions keep the district up to date.
New policy 3565/8307, Title I Program Comparability of Services, is presented as first-read information.  Brian Weaver will answer any questions you may have. 
 
The board may waive a second reading and adopt the policy as presented at this time.   
 
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