Title II, Part A Frequently Asked Questions

What is meant by the supplement not supplant requirement?

There is a federal provision of supplement, not supplant in Title II, Part A: Funds received under this subpart shall be used to supplement, and not supplant, non-Federal funds that would otherwise be used for activities authorized under this subpart(s) [Title I, Part A (section 1120A (b); Title II, Part A (section 2113(f), 2123(b; and Title VI, Part B (section 6232)) of the ESEA].

Supplanting may occur if federal funds are used to provide services required by other federal, state, or local laws; or were provided with non-federal funds in a prior year. To determine whether a fiscal expenditure supplements and does not supplant, school districts should ask the following questions:

  • Are the services that the district wants to fund with ESEA funds required under state, local, or another federal law?

  • Are the Title II, Part A funds being used to provide services that the LEA provided with non-federal funds in prior years?

If the answer to either of these questions is yes, then the use of funds is not supplementary to core services required by other federal, state, or local laws, and it is supplanting. Supplanting is not permitted for the use of Title IIA funds.


If a district requires certain professional development for every teacher to improve instruction, would using Title II, Part A funds be supplanting?

It depends. If professional development is required by state law or local policy, then using Title II, Part A funds to pay for the training would be a supplanting issue. However, if the training is required of teachers as part of the LEA’s districtwide plan or the teachers’ individual growth plan rather than prescribed by state law or local policy, the training could be provided with Title II, Part A funds.


Who is eligible to receive services that are provided through Title II, Part A funds?

The intended beneficiaries of the Title II, Part A program are teachers, paraprofessionals, principals, and other school leaders. The term “other school leaders” is defined in Section 8101(44) as a principal, assistant principal, or other individual who is:

  • An employee or officer of an elementary school or secondary school, local educational agency, or other entity operating an elementary school or secondary school; AND

  • Responsible for the daily instructional leadership and managerial operations in the elementary school or secondary school building.


Are private schools eligible to participate in Title II, Part A programming?

Yes, private school teachers, principals, and other educational personnel are eligible to participate in Title II, Part A. An LEA is required to consult annually in a timely and meaningful way with private school officials regarding their participation in Title II, Part A. The activities undertaken by the private school should be matched to the needs of their students, teachers, and principals. Federal regulations in 34CFR 299.7(c) require a district to examine the particular needs of private school students and not simply make available to private school teachers the kinds of services it makes available to public school teachers. Districts should be aware that Title II, Part A funds cannot be used to pay for the salary or benefits of private school teachers. Additionally, Title II, Part A funds are never provided directly to the private school or an organization providing oversight to one or more private schools. Rather the district serves as the fiscal agent for the private school, reimbursing providers for their services.


When must budget amendments be submitted?

Budget amendments must be submitted if there is a significant change in program objectives when there is an increase or decrease in the total amount of the grant when a local school system wishes to extend the length of the grant, and/or when there is an increase/decrease of an object code that exceeds $1000 or 15% of the line (whichever is greater). All budget amendments must be submitted at least 45 days prior to the end of the grant period.


What expenses are allowable and what expenses are unallowable?

Below is a list of common allowable expenses. This list is not exhaustive.


Salaries

  • Salaries for the Title II, Part A Program Administrator, Grant Manager, and Professional Development Coordinator (note: only the portion of the salary dedicated to Title II, Part A administration is allowable)

  • Salaries for the Secretary/Bookkeeper for Title II, Part A grant work (note: only the portion of the salary dedicated to Title II, Part A administration is allowable)

  • Salaries for Instructional Coaches

  • Salaries for New Teacher Mentors

  • Teacher salaries to reduce class-size


Stipends

  • Stipends for mentors or individuals serving as supervising practitioners to student teachers or new teachers

  • Stipends for participating in collaborative planning or peer observations

  • Stipends for attending or facilitating professional learning

  • Stipends to attend or lead development and support for district-based preparation programs for teachers, paraprofessionals, and school leaders

  • Relocation stipends used for recruiting effective educators.


Contractual Services

  • Consultants who are providing professional learning to improve content knowledge and/or classroom practice for any subject, social and emotional learning, school climate, inclusive practice, behavioral health, and other issues related to school conditions for student learning

  • Substitutes for teachers attending Title II-A funded professional learning

  • Event space or equipment rental for Professional Learning


Supplies & Materials

  • Supplies that are reasonable and necessary for the professional learning experience, such as books and instructional software

  • General professional learning supplies such as chart paper, pens, binders, easels, sticky notes, etc.

Note: All supplies and materials must be directly connected to professional learning. Meals or snacks for professional learning attendees is not allowable. Supplies to be used in the classroom or by students are also not allowable.


Travel Related to Professional Learning

  • Conference registration for professional learning

  • Course reimbursement

  • Expenses for transportation, per diem, and lodging (if the costs are reasonable and necessary)


Other Costs

Costs to improve the recruitment, placement, support, and retention of culturally competent and responsive educators, especially educators from underrepresented minority groups, to meet the needs of diverse student populations


Fringe Benefits

Fringe benefits for salaries being paid out of Title II, Part A


Indirect Costs

Indirect costs at or below the negotiated rate approved for the local school system



Contact:

Jennifer Wojcik
Coordinator of Professional Learning

Office: (410) 767-0346
jennifer.wojcik@maryland.gov

Sue Baile
Operational Coordinator

Office: (410) 767-0279
sue.baile@maryland.gov