Title I, Part C Frequently Asked Questions

Federal Program Compliance Division

[email protected]

This document provides the answers to program-related questions received by the Division. You can also

navigate through the document using the Bookmarks in your PDF viewer. The newest questions that have been

added will be noted by “*” and in blue font.

For questions or additional information, please contact us at ESSASuppor[email protected].

Questions and responses are organized by the following topic areas:

• Topic 1 – Migratory Students

• Topic 2 – Identification & Recruitment

• Topic 3 – Coordination/Collaboration

• Topic 4 – Serving Migratory Students

• Topic 5 – Texas New Generation System/Migrant Student Information Exchange (TX-

NGS/MSIX)

• Topic 6 – Early Childhood Education

• Topic 7 – Family Engagement

• Topic 8 – Priority for Service (PFS)

• Topic 9 - MEP Funding and Use of Funds

• Topic 10 – Other

Topic 1 – Migratory Students

Q1: What is the definition of a “migratory child”?

A1: As defined by ESSA, Section 1309(3), a “migratory child” is a child or youth who made a qualifying

move in the preceding 36 months—

• as a migratory agricultural worker or a migratory fisher; or

• with, or to join, a parent or spouse who is a migratory agricultural worker or a migratory

fisher.

According to the MEP Policy Guidance, Chapter II, A1, the migratory child is a child or youth:

• The child is not older than 21 years of age; and

• The child made a qualifying move in the preceding 36 months as a migratory agricultural

worker or a migratory fisher, or did so with, or to join a parent/guardian or spouse who is a

migratory agricultural worker or a migratory fisher; and

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• With regard to the qualifying move, the child moved due to economic necessity from one

residence to another residence, and—

o From one school district to another; or

o In a State that is comprised of a single school district, has moved from one

administrative area to another within such district; or

o Resides in a school district of more than 15,000 square miles and migrates a distance

of 20 miles or more to a temporary residence.

Q2: What is the definition of a “migratory agricultural worker”?

A2: As defined by ESSA, Section 1309(2), a “migratory agricultural worker” is an individual who made a

qualifying move in the preceding 36 months and, after doing so, engaged in new temporary or

seasonal employment or personal subsistence in agriculture, which may be dairy work or the initial

processing of raw agricultural products. If an individual did not engage in such new employment

soon after a qualifying move, such individual may be considered a migratory agricultural worker if

the individual actively sought such new employment and has a recent history of moves for

temporary or seasonal agricultural employment.

Q3: What is the definition of a “migratory fisher”?

A3: As defined by ESSA, Section 1309(4), a “migratory fisher” is an individual who made a qualifying

move in the preceding 36 months and, after doing so, engaged in new temporary or seasonal

employment or personal subsistence in fishing. If the individual did not engage in such new

employment soon after the move, the individual may be considered a migratory fisher if the

individual actively sought such new employment and has a recent history of moves for temporary or

seasonal fishing employment.

Q4: What is the definition of a “qualifying move”?

A4: As defined by ESSA, Section 1309(5), a “qualifying move” is a move due to economic necessity—

• from one residence to another residence; and

• from one school district to another school district,

except— (i) in the case of a State that is comprised of a single school district, wherein a qualifying

move is from one administrative area to another within such district; or (ii) in the case of a school

district of more than 15,000 square miles, wherein a qualifying move is a distance of 20 miles or

more to a temporary residence.

MEP Policy Guidance Chapter II, C3, states that, “qualifying work” as shorthand for temporary or

seasonal employment or personal subsistence in agriculture or fishing. Under 34 C.F.R. § 200.81(n),

“qualifying work” means temporary employment or seasonal employment or personal subsistence

in agriculture or fishing.

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Topic 2 – Identification & Recruitment

Q1: Under Relationship to child or children are we currently required to put a dash or are we allowed

to type the relationship to the child even though we are conducting the interviews via phone?

A1: According to the COVID-19 protocols we shared last year recruiters should put a dash “-“ on Section

F of the COE and provide the following comment on the COE SDF "Due to the pandemic, the

interviewee [insert Full Name and relationship to the child(ren)] verified by phone interview the

eligibility information on [insert date XX/XX/XX]."

However, if you are experiencing issues inserting a dash “-“ on the ECOE, the recruiter can enter the

relationship of the interviewee.

Q2: Can you provide clarification on using the ECOEs for families with new economic necessity moves

and previous qualifying work eligibility?

A2: When capturing a new move due to economic necessity, please complete a new COE (paper or

electronic) for any subsequent qualifying move (moves with a new QAD). Even if the qualifying

activity was captured in a previous COE.

Q3: If a user has no ECOE access or is having issues accessing the ECOE, how should they proceed?

A3: MEP staff who are unable to access the ECOE should complete a paper COE following the guidelines

outlined on the 2019-2020 and 2020-2021 Texas Manual for the Identification and Recruitment of

Migratory Children. Once the COE has been completed, they can input the data into the NGS

system.

Q4: Considering the recently shared USDE letter regarding remote recruitment that mentions travel

distance I wanted to ask about upcoming residency verification. Will we be allowed similar

flexibility to make phone calls?

*A4: Even though it is recommended that MEP staff verify residency through face-to-face contact with

migratory families or through school enrollment records, we recognize that such methods are not

always feasible or practical. Therefore, telephone calls and text messages are acceptable

alternatives provided the MEP staff asks the questions necessary to verify the migratory

child/children’s residency in the district. It is the expectation that communications via text be

documented in the same way as telephone calls or face-to-face communications.

Topic 3 – Coordination and Collaboration

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Q1: Is coordination with other state, federal, and state programs a requirement?

A1: Section 1308 under ESSA describes the need to improve coordination among programs.

Q2: Are there any guidance documents that newbies can be referred to with best practices for

collaboration with other programs?

A2: TEA is currently working on the Assisting Interstate/Intrastate Mobile Students (AIIMS) Guidebook

that will include best practices on coordination/collaboration.

A3: One way is to consider which migratory children’s needs can be met by services provided by other

state and federal programs. Set up meetings with the identified programs to provide an overview of

the MEP and learn about one another’s program and what services they offer. Open or keep lines of

communications with the contacts from those other programs. Advocate for your migratory children

by coordinating and collaborating within the school and the community in order to ensure

maximum benefits for those students.

Topic 4 – Serving Migratory Students

Q1: Must an LEA serve an eligible migratory child who attends a private school?

A1: Yes. Section 8501(b) of the statute requires SEAs that receive MEP funds to provide special

educational services or other benefits on an equitable basis to eligible children who are enrolled in

private schools, and to their teachers and other educational personnel. This must be done after

timely and meaningful consultation with appropriate private school officials. (MEP Policy Guidance,

Chapter V, H1)

An LEA receiving assistance under Title I, Part C, must provide eligible private nonprofit school

children and their teachers or other educational personnel, with equitable services or other benefits

under this program. Before an LEA makes any decision that affects the opportunity of eligible

private nonprofit school children, teachers, or other educational personnel to participate, the LEA

must engage in timely and meaningful consultation with private school officials and maintain

written documentation of such efforts. (Program-Specific and ESSA Provisions and Assurances)

Q2: If a district’s data are showing that reading is a need for migratory students, may the district

expend funds on a supplemental reading program with pre-and post- assessments in lieu of

Project SMART? The reading program would be a service offered only to migratory students and

meet SDP Goal 1-1? Although Project SMART does have literacy embedded, it does not measure

reading growth or support targeted reading instructional strategies.

A2: The district can choose to provide supplemental reading instruction in the summer.

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Q3: Do districts have to offer Project Smart?

A3. Project SMART is the summer curriculum to be used when providing supplemental mathematics

instruction to migratory children in grades K-8. If there is no need for it in the district because the

migratory students are utilizing other summer services, then the district does not have to provide it.

Q4: Do Project SMART instructors need to be certified teachers?

A4. It is up to the district.

Q5: Are districts able to use Title I funds to pay teachers to implement the Project SMART Curriculum

for Migratory students?

A5: That is a district choice. MEP funds are supplemental.

Q6: How will virtual instructors collect pre- and post-assessment Project SMART data?

A6: Use the appropriate Project SMART Virtual Assessment Data Collection flow chart (K-1 or Gr 2-8) to

determine whether to submit the assessment data or not. If data is submitted, the appropriate

Project SMART Virtual Assessment Data Collection (PS-VADC) Checklist should be completed for

each student and kept on file by district MEP staff as documentation.

Q7: For Project SMART, should students’ pre-assessment scores be entered in TX-NGS if they are

unable to complete the post-assessment?

A7. Yes, students’ pre-assessment scores should be entered, and post-assessment scores can be left

blank.

Q8: For Project SMART, if a student is testing virtually and the pre-assessment meets the criteria for

submitting the score, but the post-assessment does not meet the criteria for submitting, should

the pre-assessment score be entered in TX-NGS?

A8. Yes, the student’s pre-assessment score should be entered, and the post-assessment score should

be left blank.

Q9: Would this supplemental service be considered Migrant-funded?

A9: This cannot be considered MEP-funded if not paid with MEP funds.

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Q10: What is the best way to serve migratory students who are not wanting to attend school due to

moving so much?

A10: The first step should be to encourage the child to enroll in school; then to utilize the school

resources to meet their academic needs and work with existing dropout prevention programs in the

LEA. In addition, LEAs should reach out to their respective ESCs for guidance on strategies on

working with the migratory Out-of-School Youth (OSY).

Topic 5 – Texas New Generation System/Migrant Student

Information Exchange (TX-NGS/MSIX)

Q1: What is recommended ratio of TX-NGS staff?

A1: State recommendations regarding TX-NGS personnel are as follows: one TX-NGS Data Specialist for

every 300 migratory students, prorating the number of positions depending on the LEA’s migrant

enrollment.

Q2: How are we to encode students who have a formal assessment (STAAR and/or EOC) score of

“OTHER”?

The scale score is reported as zero. These students were not exempt nor were they absent.

“OTHER” was marked due to COVID-19. (Explanation: The testing was face-to-face on campus;

student was still remote enrolled. Parent opted to not send child to campus for testing. District

coded student as “OTHER”.

A2: Under Assessment Interpretation on TX NGS, students who were marked absent for testing because

of a quarantine situation, can be marked as absent. Students who were coded O for “Other” plus 0

in the agency field because they did not go to school to take the test, can be marked failed under

Assessment Interpretation. The Assessment Score on TX-NGS can be “Other”, since for the

purpose of flagging for PFS, TX-NGS will not capture “0”.

Q3: Many times, migrant staff directly work and coordinate within the school system for a migratory

child to receive services, such as getting tested for special education, tutoring through other

funding sources including the child’s classroom teacher, etc. If the child obtains such services,

should this be encoded as a referral on TX-NGS?

A3: If the child would have been entitled to the services, regardless of MEP-funded personnel efforts, it

cannot be counted as a referred service.

Q4: Which TX-NGS reports list the Family ID?

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A4: There are three (3) reports that show the Family ID:

• the Continuing Enrollment Residency Worksheet,

• the Migrant Continuing Residency Report, and

• the COE Family Report.

Q5: Is it a requirement to enter grades for a 12th grader who is graduating in the current school year?

A5: No, it is not necessary to input the final semester spring grades for students who graduate. Data

Entry Specialists should only enter this data for those students who did not graduate in the current

school year. However, the graduation termination code and the graduation date must be entered on

the system for all students who graduate.

Topic 6 – Early Childhood Education

Q1: Can “A Bright Beginning” (ABB) be implemented virtually?

A1: Due to the COVID-19 pandemic, virtual implementation of ABB is allowed.

Q2: I just want to verify the accuracy – especially the information on how MEP students are coded as

Eco Dis and also the information regarding coding of early childhood (i.e. Bright Beginnings Home-

based).

A2: Migrant students ages 3-21 who are enrolled in school in campus-based programs but have not yet

received a high school diploma are coded with a MIGRANT-INDICATOR-CODE (E0984) of 1.

Migratory student ages three and four, who are enrolled in home-based early childhood programs,

should be coded as “enrolled, but not in membership (ADA-ELIGIBILITY-CODE 0)”. Migratory three-

and-four-year-olds served in a campus-based program funded wholly or in part by Title I, Part C

(Migrant) funds should be coded with grade-level PK. Migratory three-and-four-year-olds served in a

home-based early childhood program funded wholly or in part by Title I, Part C (Migrant) funds and

should be coded with grade-level EE. Migratory students with a certificate of eligibility (COE) are

coded with an ECONOMIC-DISADVANTAGE-CODE (E0785) of 99. A copy of the current COE should be

provided to the PEIMS contact.

Q3: If a 3-year-old receiving speech services has a COE on file with the district, does the child need to

be coded as a migratory in PEIMS?

A3: Our data standards say the following: “The student does not have to actually receive migrant-

funded services in order to be coded as a participant in the program (code 1). The student simply

has to be eligible under the federal legal definition of an eligible migratory child. To be eligible under

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the federal definitions listed above, the child must have a current COE on file at the district or

regional education service center completed and signed by an individual trained by the Texas

Migrant Education Program (MEP).”

Q4: We are encoding our home-based ‘A Bright Beginning’ students into TX-NGS as mandated, and we

are providing our SSA districts’ PEIMS contacts with both the copy of the COE and the Unique

Student Count Report. The PEIMS contacts are then asking us for birth certificates, social security

numbers, and various other paperwork to which we do not have access.

Can PEIMS contacts not enroll ABB home-based students as denoted above or is additional

paperwork required?

A4: The student attendance accounting handbook deals with the documents that are required to enroll

a student. In section 3.3 it goes through in detail what a district will need to register a student.

Section 3.3. talks about the documentation of identity and age and gives various items that can be

used for enrollment. There is no need to ask for a social security card, as the district can create a

state ID for the student.

Topic 7 – Parent and Family Engagement

Q1: What is the function of a Parent Advisory Council (PAC)?

A1: A PAC advises the Local Education Agency on concerns of migratory parents that relate to the

planning, operation, and evaluation of Migrant Education programs and projects in which their

children participate. (MEP Policy Guidance Chapter VII, B2)

Q2: Who is eligible to be a member of a PAC?

A2: Parents or guardians of eligible migratory children and individual who represent the interests of

such parents are eligible to serve as PAC members. (MEP Policy Guidance, Chapter VII, B5)

Q3: May MEP be used to support parents’ attendance at workshops and conferences?

A3: Yes, the Local Education Agency may use MEP funds for costs that are reasonable and necessary to

support the attendance of migratory parents at workshops and conferences that enable them to

participate more effectively in the local program or to conduct home-based activities. The LEA

should develop criteria, in consultation with parents, to determine the reasonable number of

parents who may attend national meetings. Upon return, attendees should provide information,

and, if possible, training on the conference topics to other parents. (MEP Policy Guidance, Chapter

VII, C5)

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Q4: Can the district combine their PAC meeting with other parent meetings such as logging in to see

their child’s grades, STAAR reading and Math information, and health information. Should they

keep them separate or is it okay to combine them? If a district is holding meetings and giving

training to our parents on how to log on to your child's grades and how to set alerts to text you

when your child is failing, of if they plan on giving some kind of computer training for the

migratory parents, can this count on Fidelity of Strategy Implementation (FSI) for parent

trainings?

A4: First of all, we want to ensure that the district is meeting the requirement in ESSA, Section

1304(c)(3) which states that in planning and operation of programs and projects, both the State and

LEA-level agency are to consult with the parents of migratory children, including Parent Advisory

Council (PAC). If the question is “Can the Migrant PAC Meeting set for migratory parents include

academic topics overviews as part of the agenda,” then the answer is yes, if it is part of seeking

consultation for program implementation and evaluation. If the purpose is to just provide

information and training to the migratory parents, the LEA could set up time for just training and

then have the PAC meeting following that training. LEA must ensure that migratory parents have

sufficient stand-alone time, separate from that devoted to other general topics to discuss migrant-

specific issues. This should be reflected in the PAC agenda and minutes.

In response to the question about parent trainings to be reflected in the FSI, these trainings could be

included if it is addressing the Measurable Program Outcome (MPO).

Q5: May MEP funds be used to provide refreshments or food during a PAC meeting or training?

A5: According to the MEP Policy Guidance, Chapter VII, C7, “Reasonable expenditures for refreshments

or food, particularly when such meetings extend through mealtime, are allowable.” (Also, refer to

Q71 of Legislation Migrant Education Program.)

Q6: Can a PAC meeting be conducted virtually?

A6: TEA, in coordination with ESC-20, conducted State PAC meetings virtually during the 2020-21 year.

The meetings worked well, and parents were able to participate effectively. The LEA should ensure

that parents have access to the needed technology and support throughout the process.

Q7: Is sharing the budget a requirement for PAC meetings?

A7: Sharing the budget is not a requirement. What is required is that the program obtains meaningful

consultation from the parents. Discussing the budget can be used as a way to help parents

understand the resources the district has to help migratory student, but just remember that any

discussion has to lead back to meaningful consultation.

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Topic 8 – Priority for Service (PFS)

Q1: Does the PFS Action Plan need its “own section” in the District Improvement Plan (DIP)? What if a

district addresses Migrant population students/parent within a specific main district goal, but

there is not a specific goal/section just for migratory students? Can they include their PFS Action

Plan and ID&R Plan as addendums in their DIP.

A1: Yes, the PFS Action Plan needs its own section in the DIP. According to the 2021-2022 ESSA

Consolidated Federal Grant Application Program Guidelines, page 21 and in Program Specific

Provisions and Assurance, page 23, In providing services with Title I, Part C, funds, LEAs shall give

priority to serving Priority for Service (PFS) migratory children with MEP funds before using migrant

funds to address the needs of other migratory children. PFS students are defined as migratory

children who have made a qualifying move within the previous 1-year period and (1) who are failing

or most at risk of failing to meet the state’s academic standards; or (2) have dropped out of school.

[Section 1304(d)] The Title I, Part C Migrant Coordinator will include a Priority for Service Action Plan

as a separate section in the District Improvement Plan labeled or identified (e.g., “Migrant PFS Action

Plan”). It can be an addendum, but it should be labeled or identified.

Q2: Are other ESCs encountering a major decline in their PFS numbers?

A2: Priority-for-Service numbers are fluctuating across the state. It is important to review the PFS

Report, identify the reason for the PFS flag, and address the needs.

Q3: Do we need to focus on the priority-for-service (PFS) students when providing MEP services since

our migrant funds have drastically decreased?

A3: The needs of PFS students should always be considered first.

Topic 9 – MEP Funding and Use of Funds

Q1: How does the state determine the amount of Title I, Part C Allocations?

A1: In determining the amounts for Title I, Part C allocations, the state considers the following:

• TX-NGS Priority for Service (PFS) classification counts;

• TX-NGS Number and Needs indicator counts; and

• LEA’s availability of Other Sources of Funding (OSF).

Refer to the ESSA Funding Reference Manual for the specific funding formula.

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Q2: Where do I get information on entitlements?

A2: Refer to the Entitlements web page.

Q3: Can Title I, Part C funds be used in place of other funds?

A3: The LEA shall use funds received under the Title I, Part C, program to supplement, and to the extent

practical, increase the level of funds that would, in the absence of federal funds be made available

from nonfederal sources for the education of students participating in programs and projects

assisted under Title I. In no case may these funds be used to supplant funds from nonfederal

sources.

Refer to Program-Specific Provisions and Assurances, page 22.

Q4: Is there a limit to how much an LEA can carry over from one fiscal year to another?

A4: There is no limit to how much an LEA can carry over from one fiscal year to the next. However, the

LEA should ensure the needs of the migratory children are addressed.

Q5: Should the State examine the amount of MEP funds that local operating agencies carry over from

one fiscal year to the next? (MEP Policy Guidance, Chapter I, D5)

A5: SEAs should examine how much money local operating agencies carry over in order to determine

whether to reallocate funds that remain unobligated at the end of the fiscal year. If a local operating

agency has a significant amount of carry over, the SEA might choose to adjust the local operating

agency’s subgrant downward to make available the funds that the local operating agency did not

spend in the prior year. This allows the SEA to reallocate unobligated MEP funds for new uses in the

subsequent fiscal year.

Q6: What are the guidelines for LEAs that decide not to receive Title I Part C funds?

A6: There are no guidelines for LEAs that are eligible for MEP but elect not to apply.

Q7: Will an LEA’s MEP funding be affected if it provides services through collaboration that will be

entered as non-migrant funded?

A7: Services provided through collaboration that are entered as non-migrant funded supplemental

services do not affect the LEA’s MEP funding.

Q8: May Migrant Education Program (MEP) funds be used to purchase t-shirts to be worn by

Identification and Recruitment (ID&R) staff during their field work? Legislation Migrant Education

Program Q&As, Q89)

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A8: MEP funds may be used to pay for the cost of t-shirts for ID&R staff, provided the MEP abides by the

criteria that all State and local education agencies (LEAs) must consider in determining whether a

particular cost is an allowable use of funds:

1. It must comport with the results of the State’s Comprehensive Needs Assessment (CNA) and

the strategies outlined in the State’s Service Delivery Plan (SDP);

2. MEP funds must first be used to meet the identified needs of migratory children that result

from their migratory lifestyle, and to permit these children to participate effectively in

school;

3. It must meet the needs of migratory children that are not addressed by services available

from other Federal or non-Federal programs;

4. The MEP funds are used to supplement, rather than supplant the use of non-Federal funds;

and

5. The costs must comport with the cost principles described in the Uniform Guidance (Subpart

E of 2 CFR Part 200). The cost principles require, among other things, that costs of the service

or activity be reasonable and necessary, and be allocable (or chargeable) to the MEP relative

to the benefit received.

Q9: EDGAR currently requests two (2) quotes for purchases using federal funds. Does this rule apply

when purchasing Migratory student snacks for tutorials and/or Migrant PAC meetings? Does this

rule apply for any purchases under the Migrant funding?

A9: Whenever using federal funds to purchase goods or services, an LEA must ensure that it is following

the procurement regulations in EDGAR – 2 CFR 200.320 Methods of procurement to be followed.

TEA has developed an EDGAR FAQ document that addresses some of the common questions we

receive. Section 7 of the FAQ addresses questions regarding procurement.

If you are purchasing food with migrant funds, you must determine the total amount of federal

funds (including all other federal funds the LEA receives) to be spent on food in order to see which

procurement method applies. If total food purchases using federal funds does not exceed $10,000

per budget year, then the micro-purchase method can be used, which does not require price

quotes. If the total amount is greater than $10,000, then the small purchase method must be used.

Q10: Can MEP funds be used to pay for hotspots?

A10: LEAs may follow the guidance in the COVID FAQ, #50 and follow guidance in FAQ under Project

SMART regarding purchasing electronic devices. In summary, the purchase of electronic devices with

MEP funds is allowable if the LEA has not provided devices for all other students, and MEP staff have

identified the need for a child to participate in the program. The LEA may provide devices for

students/parents to check-out in order to participate in MEP-funded services and may provide

access to the internet (via a hub that is checked out). However, MEP staff should ensure that:

a) The devices can be purchased, received, and delivered to the students in time for the

program to be implemented;

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b) Students/parents are taught how to use the devices; and

c) Students are provided training on internet safety.

Q11: If we can document that parents are in need of food and the district does not provide a pantry,

can we provide non-perishable items for them?

A11: We provide the following guidance in the COVID FAQ, Question #2, (TEA’s COVID-19 Support:

District Waivers, Finance & Grants page has the most up-to-date Federal Funding and Grants FAQ

document.)

LEAs must continue to ensure that eligible migratory children are provided services from other

available Federal, State, and local programs for which they are eligible. (See ESEA section

1306(b)(2)). For example, food for eligible migratory children should generally be provided by other

Federal and non-Federal programs (e.g., school meals programs administered by the United States

Department of Agriculture (USDA) Food and Nutrition Service, and community food banks). During

this emergency, if food is not immediately available from other programs, the MEP may provide food

to meet the identified needs of migratory children for a limited period, until other resources become

available. In addition, see https://www.fns.usda.gov/disaster/pandemic/covid-19 for additional

information.

Q12: Can graduation gowns be purchased with Migrant funds?

A12: This is allowable if the LEA has exhausted all possible sources (programs) that could provide the caps

and gowns. The LEA must document its efforts to secure that service with other funds, and ensure it

is an identified need. If there are no other available sources to provide these items, they may be

purchased with MEP funds, loaned to migratory students, and returned to the LEA. The LEA should

establish a process to determine such need, including the lending process.

Q13: Can recognition awards be purchased with MEP for MEP students?

A13: Awards are not allowed to be purchased with MEP funds. The LEA may reach out to other programs

or community agencies for donation of such items.

Q14: Can food be purchased to encourage parents to attend meetings?

A14: Chapter VII, Question C7 of the MEP Non-Regulatory Guidance (NRG) states that reasonable

expenditures for refreshments or food provided during parent meetings or training are allowable,

particularly when such meetings extend through mealtime. However, it does not distinguish

between snacks and a meal. This can be an allowable cost if there is a connection to a programmatic

purpose and the cost is reasonable and necessary.

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Q15: If an employee is split funded through Title I, Part A & Title I, Part C, would this individual be

able to assist as a state testing monitor for a secondary campus that is not Title I?

A15: Title I, Part C

Title I, Part C funds may only be used to meet the unique educational needs of migratory students.

They cannot be used for activities for non-migratory students. Unless they are only going to assist

with State testing monitoring of migratory children, this is not allowable as part of the TIC time for

this employee.

Title I, Part A

Title I, Part A funds may only be used to meet the intent and purpose of the Title I, Part A

program. Thus, it would be unallowable for Title I, Part A funded personnel to be providing

services at non-Title I, Part A served campuses.

Q16: If an LEA is part of an SSA with an ESC, do it still get carryover as if it had applied for the funds

directly on our own?

A16: The carryover funds go to the fiscal agent, in this case the ESC.

Topic 10 – Other

Q1: Are school districts required to print out the Family Survey for all students in the district even

though they answer no to all questions?

A1: According the latest Manual for Identification and Recruitment for Migratory Children, page 5.9, If a

family survey is being used, the returned surveys should be examined for the following:

• Are there an adequate number of returned surveys (at least 90 percent of all families)?

• Which surveys have “yes” answers, indicating prospective migratory families?

• Surveys with “yes” answers will require follow-up to determine if a family is eligible for the

MEP.

• Contact with potentially eligible migratory families should be done by August 31 or as soon as

possible.

The ESCs and LEAs may work collaboratively to determine the best way to collect that information

Q2: What are acceptable forms of documentation for sign-in sheets?

A2: Given the increased use of virtual meeting environments the past school years, participant rosters

that include the meeting title, meeting date, and stakeholder names and roles would be acceptable

Title I, Part C FAQ Document

V 2.0 (6/08/2022)

substitutes for the more traditional sign-in sheets. This eliminates the need of a participant

signature.

Q3: What is the process or is there a process to dispose of obsolete technology bought with MEP

funds years ago?

A3: The information requested on the question can be found in the following link:

https://tea.texas.gov/finance-and-grants/grants/grants-administration/forms-for-prior-approval-

disclosure-and-justification

There is a form called Inventory Disposition.

Q4: Is there one location where all the Migrant documents can be found?

A4: Migrant resources can be found on TEAs Title I, Part C webpage and additional documents can be

found in the Texas Migrant Resource Portal (TMEP).

Q5: What is the deadline for completing the comprehensive needs assessment (CNA)?

A5: The State Comprehensive Needs Assessment (CNA) is completed every three years; however, the

Local Needs Assessment (LNA) is to be conducted annually by LEAs to identify the unique needs of

migratory students in their area and plan accordingly. There is no assigned deadline for completing

the LNA. It is recommended that it be done in the Spring when planning for activities for the

following school year, before completing the ESSA Consolidated Federal Grant Application.

Q5: How long are paper COEs supposed to be kept?

A5: Page 2.40 of the latest Texas Manual for Identification and Recruitment of Migrant Children states

that, an inactive COE file must be kept for children identified in previous years and retained for

seven (7) years from last QAD. For termination due to graduation, obtaining a Certificate of High

School Equivalency, death of child or a parent/guardian request, the records (e.g., copy of COE,

copy of COE SDF, documentation of termination) will be treated as inactive, and kept for seven (7)

years from last QAD. In addition, also stated on that page is, the only exception to the above

timelines involves old COEs that are being reviewed because of an ongoing investigation or

audit. COEs that are material to an investigation or audit should not be destroyed until the

investigation or audit has been closed.

In addition, page 5.32 provides examples of timelines to follow.