Question on the allowable use of Title 1A homeless reservation and how to calculate (or define) “excess cost” of transportation. If an LEA does not provide high school students with transportation, then would the entire cost to transport a homeless high school student be considered “excess” and therefore an allowable Title 1 A set aside expense?

Answer: Yes, with a couple of caveats. Normally, to calculate the excess cost, you’re looking at the difference between the transportation being provided to the McKinney-Vento student and what the district typically would provide other students. So in this case, since the district provides no transportation at all, the entire cost would be excess.

Two caveats:

1. Make sure the student isn’t entitled to transportation for some other reason, such as pursuant to an IEP
2. The district cannot use its entire set-aside to pay for transportation. The set-aside must provide McKinney-Vento students with services comparable to those provided to other Title I students.

So the set-aside must provide those other, comparable services first (e.g. tutoring or graduation coaching for your high schoolers, etc.), and then can be used to cover excess transportation costs with the money left over. Ultimately, this particular district might need to increase its Title IA set-aside amount if it’s going to dip into it significantly to cover transportation costs.

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