Answer: Yes. Now that ESSA’s Title I amendments are in effect, all LEAs that receive Title I, Part A funds must reserve funds for students experiencing homelessness. Even if the LEA has not identified McKinney-Vento students in the past, virtually no LEA (charter or otherwise) can be 100% sure that they will never have a student experience homelessness in the coming year. Domestic violence, natural disasters, family conflict – all sorts of things can come up in the upcoming school year that could result in student homelessness. In addition, it’s important to look at liaison capacity and what is being done in the school/LEA to identify McKinney-Vento students. The fact that the school has not yet identified a McKinney-Vento student does not necessarily mean they’ve never had one, or that they don’t have several right now. The school may not have identified students experiencing homelessness due to insufficient identification and outreach activities. Our Guidelines for Designating LEA-Level and Building-Level McKinney-Vento Liaisons tool can help LEAs evaluate liaison capacity to determine if Title I funds should be directed to increasing that person’s capacity, which should help improve identification.
Therefore, LEAs should set aside some Title I, Part A funds regardless, possibly to increase liaison capacity, or at least because you never know when a new student will come in, and/or when an unanticipated need will come up.