The Every Student Succeeds Act (ESSA) created important new requirements and opportunities for serving children and youth experiencing homelessness through Title I Part A of the Elementary and Secondary Education Act. Title I Part A is the largest federal preK-12 education program, funded at nearly $16 billion, and reaching the majority of school districts in the United States.
The Title I Part A amendments on homelessness are particularly important in light of the harmful effects of homelessness on student achievement. Based on 2016-2017 data from 44 states, the national graduation rate for homeless students is 64% — significantly lower than the graduation rate for low-income students (77%) and all students (84.6%).
As of the 2017-2018 school year, all state and local educational agencies (LEAs) are required to report disaggregated information on the graduation rates and academic achievement of homeless children and youth. This requirement shines a spotlight on the academic struggles of children and youth experiencing homelessness, and set a baseline against which states and LEAs can measure progress over time.
Ensuring that Title I Part A funds are reserved in adequate amounts, and used appropriately to meet the needs of homeless students, will be a key strategy to closing achievement gaps.
Which LEAs are required to reserve Title I Part A funds for children and youth experiencing homelessness?
Under ESSA, all local educational agencies (LEAs) that receive Title I Part A funds must reserve funds to support homeless students. This means that even school districts that are composed entirely of schoolwide Title I schools will be required to set aside funds for children and youth experiencing homelessness. A more detailed explanation of this ESSA amendment may be found in a July 2018 letter from the U.S. Department of Education.
How much funding must LEAs reserve for children and youth experiencing homelessness?
ESSA includes a new requirement that the amount of Title I funds reserved for homeless children and youth must be based on the total allocation received by the LEA, and reserved prior to any allowable expenditure of transfers by the LEA.
In 2017, questions were raised about how this requirement intersects with the required reservation for equitable participation for private school students. These questions prompted a Congressional Research Service (CRS) memo response. The CRS memo states that “current ESEA statutory language directs that the reservation of funds for homeless children be made based on the total amount of Title I-A funding provided to the LEA.” The memo goes on to specify:
[T]he ordinary meaning of the words in the statute, together with the available legislative history of ESSA, would seem to support the view that Congress had unambiguously directed that both reservations should be calculated independently based on the entire amount allocated to an LEA.… For example, if $100,000 were allocated to an LEA under Title I-A of the ESEA, then both the reservation of funds for homeless children under Section 1113 and the reservation of funds for equitable participation under Section 1117 would be based on that $100,000 total.
This CRS clarification of this requirement underscores the need for LEAs to determine the Title I homeless set-aside early in the LEA’s planning processes – before any Title I Part A funds are expended.
How should LEAs calculate the specific amount of Title I Part A funds to reserve for children and youth experiencing homelessness?
Guidance from the U.S. Department of Education recommends that LEA set-aside amounts be determined based on a needs assessment that reviews homeless student enrollment averages and trends over 2-3 years, and multiplies that number by the average per-pupil cost of providing Title I services. ED also advises that the needs of McKinney-Vento students should be reviewed at least twice per school year, and that each year’s set-aside should include an evaluation of the effectiveness of past activities in accomplishing the goals of both Title I and McKinney-Vento for individual students and the overall programs.
While needs assessments will vary from state to state, the Title I Part A homelessness needs assessment created by the state of Washington offers a comprehensive and useful template for other school districts and States.
How should LEAs use Title I Part A funds to support children and youth experiencing homelessness?
In ESSA, Congress clarified that Title I Part A funds reserved for homeless children and youth may be used for services not ordinarily provided by Title I, including local liaisons and transportation to the school of origin.
The U.S. Department of Education guidance (Question M-4, pp. 40-41) provides a list of some of the specifically authorized services, and also outlines two general principles for using Title IA funds:
- Services must be reasonable and necessary to enable homeless students to take advantage of educational opportunities.
- Funds must be used as a last resort when services are not reasonably available from another public or private source.
As part of its needs assessment, LEAs should consider services and activities that meet the greatest identified challenges. For example, comparing the poverty rate in the LEA to the number of identified homeless children and youth may indicate a need to bolster identification efforts, perhaps through more dedicated time for the McKinney-Vento liaison position (particularly in light of the new ESSA requirement that liaisons have time and capacity to be “able to” carry out their duties). Gaps in educationally-related support services may exist for certain age groups, such as preschool children, or high school students. Children and youth experiencing homelessness may face barriers participating in certain courses or activities.
An intentional, comprehensive review of the numbers and needs of children and youth experiencing homelessness in the community, in coordination with the school district homeless liaison and with area homeless service providers, is the best way to ensure that Title I Part A funds are used appropriately to help homeless students stay in school, graduate, and transition to post-secondary education.
Where in the law does it say that?
We’ve created a two-page document of the homelessness provisions in Title I Part A, with the relevant ESSA legal citations.