Answer: This would be an allowable use of Title I funds only if the summer programs are academic in nature and somehow affiliated with the LEA such that the LEA awards credit for the program, or the program is an approved provider of Extended School Year services, or something similar. The US Department of Education (ED) frowns upon the use of Title I funds to pay outside agencies unless there is some clear connection to a school activity, academic progress, etc. For example, if you have a student who is going to be retained unless the student attends summer school, and there is no public summer school option that works for the student, then you likely have a great argument to use Title I funds to pay a private summer school program.
Here is the general guiding language on the use of Title I funds, from ED’s Education for Homeless Children and Youth guidance:
“Two principles govern the use of Title I, Part A funds to provide such services to homeless students. First, the services must be reasonable and necessary to assist homeless students to take advantage of educational opportunities. (ESEA section 1113(c)(3)(A); 2 CFR § 200.403(a)). Second, Title I, Part A funds must be used only as a last resort when funds or services are not available from other public or private sources, such as the USDA’s National School Lunch Program and Breakfast Program, public health clinics, or local discretionary funds (sometimes provided by the PTA) used to provide similar services for economically disadvantaged students generally.”
So for an external summer school, the likely key questions for Title I are: 1) whether the summer school assists the homeless students to take advantage of educational opportunities in some specific way (not just as in, generally, summer school is academically helpful for students experiencing homelessness–but rather: is there something about this student’s particular educational situation that makes summer school especially important?); and 2) whether there is a free option available.
Here are a few questions to consider:
- Is there a public summer school program available?
- If so, are there some particular barriers related to homelessness that prevent the student from participating in that public program?
- Does the student need to attend summer school to advance to the next grade?
- Will the student be accruing credits recognized by the LEA/SEA at the summer school?
- Is the summer school primarily academic in nature?
McKinney-Vento subgrant funds are much more flexible. There are a few different allowable uses you could fit this under, primarily–
“(8) The provision for homeless children and youths of before- and after-school, mentoring, and summer programs in which a teacher or other qualified individual provides tutoring, homework assistance, and supervision of educational activities.” 42 U.S.C. 11433(d)(8).
As you can see, there has to be some educational component, but it doesn’t necessarily need to be the primary component.
Some other allowable uses of McKinney-Vento funds that could fit:
“(1) The provision of tutoring, supplemental instruction, and enriched educational services that are linked to the achievement of the same challenging State academic standards as the State establishes for other children and youths.”
“(6) The provision of developmentally appropriate early childhood education programs, not otherwise provided through Federal, State, or local funding, for preschool-aged homeless children. (If the children are preschool aged.)”
“(7) The provision of services and assistance to attract, engage, and retain homeless children and youths, particularly homeless children and youths who are not enrolled in school, in public school programs and services provided to nonhomeless children and youths. (Summer school certainly is an engagement and retention strategy.)”