Letter from USDOE – Clarifying Districts/Schools Can Spend Title I Funds on Arts Education
During times when funding is tight, it is particularly heartening to read the letter below from the head of Title I at the U.S. Department of Education. Dr. Chism sent this letter to all state Title I coordinators specifically to remind them that the arts, as core subject areas, are eligible for funding through Title I.
Title I funding is the largest category of federal funding that goes to schools. It is often incorrectly believed to be solely for supporting tested subject areas, but – as you will read in this letter – the arts are, in fact, eligible. There are certain other priorities and conditions associated with Title I that must be met, several of which are articulated in the letter.
Those of you who work in Title I schools will want to read this letter carefully and consider whether you have arts-related ideas that quality for such funding.
June 6, 2013
Dear Title I State Coordinators:
Student Achievement and School Accountability Programs (SASA), within the U.S. Department of Education, have recently received inquiries about the role of arts education within the Title I, Part A (Title I) program. In response to those inquiries, I would like to take this opportunity to address how the arts can be used to achieve educational achievement of children served under Title I. As a general observation, I note that the Elementary and Secondary Education Act of 1965, as amended (ESEA), defines the arts as a core subject, and, as such, the arts play a significant role in the development of children and their learning process.
As local educational agencies (LEAs) in your State work with you and your team to plan their Title I programs for the 2013-14 school year, I believe that this is an appropriate time to note that activities that support the arts, in conjunction with other activities, can form an important part of an LEA’s Title I program. In maintaining consistency with Title I requirements, an LEA may use Title I funds to support standards. Please keep in mind that whether Title I funds may be used for a particular activity depends on how that activity fits within the context of Title I. In particular, the activity must help facilitate Title I’s overall purpose of improving the achievement of students who are failing, or most at risk of failing, to meet the academic content and achievement standards developed by the State.
In addition to advancing the overall purpose of Title I, using funds for arts education also must be consistent with other applicable requirements. Title I funds in a schoolwide program school must address the specific educational needs of students, particularly the lowest-achieving students in the school identified by the needs assessment and articulated in the comprehensive plan. Title I funds in a targeted-assistance school must address supplemental educational needs of students who are failing, or most at risk of failing, in order to meet the State’s academic achievement standards. The use of Title I funds must also be reasonable and necessary for the proper and efficient performance under the Title I program (Office of Management and Budget Circular A-87, Attachment A, C.1.a, codified at 2 C.F.R. Part 225).
To determine the eligibility of Title I funds being used in support of arts education, an LEA must analyze such use in the context of its Title I program and the needs of its students. Depending on those needs, an LEA may use Title I funds to support activities related to the arts, provided those activities are part of an instructional strategy that is designed to improve the academic achievement of at-risk students so they can meet the State’s academic standards. As the use of Title I funds is tied to each school’s needs it would be expected that those funds would generally support different activities from school to school.
Thank you for your efforts to provide a high-quality education to students, particularly the low-achieving students served by Title I. I hope that as you continue this excellent work in the 2013-2014 school year and beyond, LEAs and schools will successfully identify those activities, including activities that support arts education, that are tailored to improving the academic achievement of low-achieving students.
Monique M. Chism, Ph.D. Director, Student Achievement and School Accountability Programs