Breaking Silos in Title I and IDEA

June 10, 2011 | By Thompson Education | Post a Comment

(This post was written by Andrew Brownstein, one of Thompson’s federal education policy editors, and originally appeared on Title I-Derland, Thompson’s blog on federal K-12 policy.) Roughly 2.5 million students receive services under both Title I and the Individuals with Disabilities Education Act (IDEA), but aid to this population is hindered by requirements that “overlap, and are often duplicative and/or contradictory,” according to a recent report.

The report, “Recommendations for Improved Coordination between Title I and IDEA,” is likely to get an ear on Capitol Hill and the U.S. Department of Education because it was drafted by two key advocacy organizations: The National Association for State Directors of Special Education and the National Title I Association. The recommendations are modest, chiefly aimed at improving efficiency and cutting the red tape that often blocks effective cooperation between the two vast education bureaucracies.

Take, for example, the relatively simple issue of data collection. IDEA requires 16 separate submissions, on issues ranging from assessment to discipline, spread out over seven different dates each year. In addition, that law has a separate data collection under the Annual Performance Report, while Title I collects information from states via a unified No Child Left Behind system called the Consolidated State Performance Report. Though the three systems report the same types of data, the actual figures do not correspond because the dates of collection differ. Moreover, there is confusion because the two laws use different terms or slightly different definitions for similar data points.

“There’s a lot of overlap, and it’s actually expensive,” said Rich Long, the National Title I Association’s executive director. “It’s not always clear what this data is being used for.”

The two groups recommend that reporting be limited to 5-10 of the “most critical” issues, to be collected in a single consolidated data statement that includes Title I, IDEA and other relevant K-12 requirements.

Other issues are less clear-cut. Under IDEA, for example, schools that over-identify children for special education are required to redirect 15 percent of their federal funds to provide support for struggling learners, often using a multi-tiered model called “Response to Intervention,” or RTI. ED guidance says that such funds can’t be used for students in the basic, or first, level of instruction, but can be used for students identified as needing more intensive support (level #2 or higher). The two organizations recommend that any school or district be allowed to use up to 15 percent of its IDEA funds, regardless of whether it has been ordered to do so, and that they have the ability to use them for all tiers, including the basic tier.

An even thornier issue in the case of RTI is Title I’s “supplement not supplant” requirement. Essentially, Title I is designed to be an “extra” support above and beyond state and local funding. If a state or district requires all schools to implement RTI, using Title I funds for that purpose can create a risk of supplanting. The two organizations have asked ED to allow waivers that would allow states to exempt schools from the supplanting requirement if they are using funds to implement a “robust” RTI model.

“There’s a lot of confusion and ambiguity about this,” Long said.

For more details on the organization’s recommendations, check out the July issue of the Title I Monitor.


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