Answer: Under the Every Student Succeeds Act, all local educational agencies (LEAs) that receive Title I, Part A funds are required to reserve funds for students experiencing homelessness. 20 U.S.C. § 6313(c)(3)(A). 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. The liaison should be involved in determining the amount and uses of the set-aside as part of the LEA’s Title I, Part A plan. (See Question M-8 of the U.S. Department of Education’s Guidance, text provided below.)

Once the amount and categorical uses of the set-aside are defined in the Title plan, the liaison should be able to access the funds freely for any use that is in-line with the plan. It seems inappropriate for the fiscal manager to deny any requests that are in-line with the Title I Part A plan. The liaison will have a much better understanding than the fiscal manager of the breadth of needs of McKinney-Vento students and is in a much better position to prioritize the uses of funds based on the severity of those needs. While each district can have its own policy on how funds are accessed and used, the liaison absolutely needs to be the driver of funding that serves McKinney-Vento students, including Title I funding.

M-8. What is an LEA required to include in its Title I, Part A plan regarding services for homeless students?

Under section 1112(b)(6) of the ESEA, an LEA must describe in its Title I, Part A plan the services it will provide homeless children and youths, including services provided with funds reserved under section 1113(c)(3)(A) of the ESEA, to support the enrollment, attendance, and success of these children and youths. An LEA’s Title I, Part A application also should include a description of the method used for determining the amount reserved, whether by a needs assessment or some other method (e.g., past homeless student enrollment and support service cost data), and how the liaison was consulted or involved in determining the set-aside.”

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