Spring 2019 IEA Program Private School Information Session

Hello and welcome to the Spring 2019
Private School Information Session for the Individualized Education Account
Program! This session is for private school representatives who are
interested in applying for their school to participate in the IEA Program; this
is not a session for schools that are already participating in the program.
My name is Rebecca Wright and I am the director of the IEA Program. Also on the
IEA team are Meg Cummins and Kristi Harris.
When you contact us you will receive a response back from one of the three of
us. The best way to contact us is by emailing [email protected] or
calling (615) 253-3781. Please note that it can take us up to ten business days to respond to calls and emails, but we
will get back to you; calling or emailing multiple team members will
not increase the speed at which we’re able to get back to you. All of the
information that we’re going to cover in this information session is posted on
our a webpage www.tn.gov/education/iea. The Private School Handbook which
we will also reference is posted on that web page. You can also subscribe
to receive our monthly email newsletter, the IEA Update, by going to the IEA
webpage. That update will include important announcements such as when
applications launch and any program updates. During this information session
we are going to talk about what the program is, what the eligibility requirements are for private schools, participating schools rights and responsibilities; IEA funding, and what the funds can be spent on; and then the private school application process. Just a quick overview of what the
program is: the program was adopted by the state legislature in 2015;
it creates accounts for eligible students in grades K-12 with
disabilities to use public funds for educational purposes. The program
provides options for parents to choose the educational opportunities that best
meet their child’s own unique needs. It provides parents with public funds
and the ability to use those funds on a variety of educational options which
we’ll talk about later in the presentation. It also is going to require parents to
meet certain responsibilities and they also have to waive certain rights in
order to participate in the program. The program is statewide; a student can
reside in any school district in Tennessee. There is no cap on the number
of students who can participate or the number of accounts that can be
established. Students enrolled in the IEA Program for the first time in January
2017. The application window is open one time per year for students; the student
application window for the 2019-20 school year will open in January 2019.
Applications for students are due April 15, 2019 by 3:00 p.m. CT. If the
application is approved and the parents complete all of the enrollment steps,
students will enroll in the program beginning August 1, 2019.
Students must stay enrolled in their public schools through July 31, 2019 to
maintain eligibility. Please note that there are no exceptions given to the
application deadlines; we cannot give any extensions so students must have their
complete application submitted by that deadline in order for it to be
considered. Once students are enrolled in the iea
program (e.g., after August 1) they can no longer be enrolled full-time
in a public school; students can either be enrolled as an independent homeschool
student registered with the School District or enrolled in a private school
including private virtual schools and home-school umbrella programs. Students
can transfer from one non-public school to another during the year at any time,
including home school and private school. When parents placed a child in the IEA
Program they are agreeing to take the full legal responsibility for the
education of their child, including obtaining services necessary to educate
their child. Parent also waive all of their child’s rights to services under
the federal Individuals with Disabilities Education Act (IDEA).
What this means is that students in the IEA Program do not receive any
services or accommodations through the public school system, they no longer have
an active Individualized Education Program, they are not eligible for the
services listed in the IEP through the public school system (including test
accommodations), and they are not able to get a services plan through a public
school district. Now we are going to transition into talking about private
school eligibility. In order for a private school to qualify to participate
in the IEA Program they must meet certain requirements: Conduct criminal background checks on employees in compliance with the IEA rules. Please
note that is a specific type of background check that must be
administered in order to qualify for the IEA Program. Private schools must certify
that they shall not discriminate against students or applicants on the basis of
race, color, or national origin. Private schools must comply with all
health and safety laws or codes that apply to non public schools. Private
schools must exclude from employment any person not permitted by state law to
work in a non-public school, and any person who might reasonably pose a
threat to the safety of students. Private schools must agree to comply with all IEA
laws, rules, and procedures, and complete all responsibilities as explained in the
IEA Private School Handbook. Now we’ll talk about what rights private schools have once they participate in the program. A participating school is autonomous and
not an agent of a state or federal government. Neither the state Department
of Education nor any state agencies may regulate in any way the educational
program of a participating non-public school. The creation of the IEA Program
does not expand the regulatory authority at the state, its officers, or any school
district to impose any additional regulation of non-public schools beyond
those necessary to enforce the requirements of the program. Participating non-public schools are
given the maximum freedom to provide for the educational needs of their students
without governmental control. A participating non-public school shall
not be required to alter its Creed, practices, admissions policies, or
curriculum in order to accept participating students. For a full list
of Rights please see the IEA Private School Handbook. So what responsibilities
do participating schools have once they join the IEA Program? A list of all
those responsibilities can be found in the IEA Private School Handbook. The
first one as we’ve already discussed is that private schools participating in
the IEA Program must conduct criminal background checks on employees as
defined by the State Board of Education IEA rules. That requirement is explained
in the Private School Handbook. Private schools must be academically accountable
to the parent for meeting the educational needs of a student, and, at a
minimum, annually provide to the parent a written
explanation of the student’s progress. This can be through things like report
cards or test results, for example. Participating schools must provide
parents with a receipt for all qualifying expenses, and the receipts
must meet the requirements explained in Chapter 10 of the IEA Parent Handbook. The one form that private schools
participating the program have to submit to the TDOE each year, besides the application, is a graduation and completion rate form. Participating tools must annually submit
to the Tennessee Department of Education the graduation and completion rates of
students in the IEA Program by completing that form. If requested by the department schools must submit to the TDOE a financial audit conducted by a certified public accountant. If requested by the department, schools must allow the department to conduct site visits. The purpose of the site visit is
solely to verify the information reported by the schools for the IEA
Program. These two pieces are only at the request of the department
and would not be something you would have do every year unless requested. These things would be requested, for example, if the department had concerns about a school’s compliance with IEA program laws, rules, or procedures, or if there was a complaint that we received and would need to investigate. Per state law, students participating in the IEA Program who are in grades three through
eight must take an annual assessment in English language arts and mathematics.
Parents can choose to have their child take either one of the nationally norm
reference assessments approved by the department or the TCAP assessments.
Participating schools must administer the state TCAP assessments to students
enrolled in the IEA Program if requested by the parent. For a list of the approved
norm-referenced tests, please see the IEA Parent Handbook. The assessment results
must be reported to the parent, and parents do have to submit verification
of the assessment’s administration to the department. Each year a question we
receive a lot is: will the results of the student assessment be publicly released? The answer is “no,” the Department will not compile, track, or publicly release
student assessment results. Student assessment results submitted to the
Department will only be reviewed to verify that the student has taken the
required assessment. Where do students take the assessment? If the student is
enrolled in a private school and they want to take the TCAP assessment, they would order that test through your school and your school would
administer that test. The student could also take one of the approved norm-referenced tests if your school administers the assessment. Please check the list of approved norm-referenced tests in the Parent
Handbook to see whether or not your school is already providing one of the
approved tests. If the parent is homeschooling their child, they can go to
their public school district in order to take the TCAP test, and if they want to
take a norm-referenced test they could go through a testing center
or they may contact you as a private school and ask you to administer the
test and it would be up to your school whether you would be willing to administer those norm-referenced assessments. Parents can use their IEA funds to pay for testing fees. If a student withdraws from a participating school, schools are required to refund the tuition and fees on a pro-rated basis based on the number
of days the student was enrolled in the school. All refunds must be returned by
the school directly to the department for credit to the students IEA account
within 15 calendar days of the student’s withdraw from the school. Upon a
student’s withdraw from a school, schools must send to all educational
records of the participating student to the school district or other school
identified by the parent. Now we’re going to transition to talking
about IEA funding and how those funds can be spent. One thing we receive a lot of
questions about from private schools is about proportionate share funding.
Participation in the IEA Program shall have the same effect as parental refusal
to receive IDEA services; therefore, if a student is enrolled in
the IEA Program, the student is not entitled to equitable services that the
school district has determined through the consultation described above it will
make available to that population of children. If you have any questions about
this, please contact our team. How much funding will students receive? The amount
of IEA funds students receive is based on the school district in which the student
resides and is zoned to attend. The average amount of IEA awards across the state for the 2018-19 school year is approximately $6,957, but that amount will vary across school districts. The IEA funding amounts
do change each year; to see the amount of the IEA funding for the 2018-19 school year, go to the resources section of the IEA web page, and click the ‘Per Pupil Funding-
Parents’ document. The IEA Program is a direct payment program; personal funds
spent will not be reimbursed. The department is using a prepaid debit card
system to distribute IEA funds to parents. Participating
schools must be able to run the IEA debit card to receive payment. Account
holders receive funding in ten payments deposited into the IEA debit card account;
the approximate dates of payment are posted on the IEA web page. Please note:
parents may not receive payment on those dates if their account is not in good standing with the IEA Program. For example, if they have submitted a document late or they have misspent funds. Some general guidelines for the use of
IEA funds: funds do roll over, so account holders are not required to spend the
entire sum each quarter. At least 50% of the annual IEA award must be spent by
the deadline to submit the quarter four expense report deadline. After graduating from high school or reaching 22 years of age, unused funds in an IEA account from prior
years can be used in subsequent years, up to four consecutive years, for
post-secondary education. To verify that an expense is approved, parents should
submit the applicable expense pre-approval form or contact the IEA
team before purchasing an item or service. The rule of thumb is that parents should be 100% sure that the expense is an approved expense before using the
funds. To ensure the integrity of the IEA Program, the department will closely
monitor use of all IEA funds to ensure the funds are only spent on approved
expenditures. The department has a zero-tolerance policy for misuse of IEA
funding. Account holders must repay all misspent funds, and account holders who misspend funds are subject to removal from the IEA Program. For more information, see Chapter 7 as the IEA Parent Handbook. IEA payments are reportable transactions for purposes of IRS information return reporting. IEA
payments will be reported each calendar year to the IRS on form 1099. Please
consult your tax professional for guidance on how to address the 1099 in
your tax return. “IRS Publication 970 Tax Benefits for Education” may provide
additional guidance for parents and their tax preparers and can be found at
https://www.irs.gov/forms-pubs/about-publication-970. This publication provides a worksheet that may be useful in reviewing parents’ applicable
education income and expenses. The IEA team cannot provide tax advice;
parents must contact their tax professionals if they have any
questions. How can the funds be spent? The IEA Parent Handbook does have a
complete description of each of the approved expenses and explains the
process for parents to receive pre-approval for designated expenses.
We’ll go over those expenses at a high-level during this
information session. Parents may use IEA funds to pay for tuition, fees, and/or
required textbooks at a participating non-public school. Schools must be
approved to participate in the program in order to receive the IEA funds, and
the school must be on the list of participating schools posted on the IEA
webpage. Some fees are not approved by the IEA Program; all fees submitted
must be itemized on the receipt that schools provide to parents so that the
department can verify that it is an approved fee. Parents can send their
child to any non-public school of their choosing, but the IEA funds can be used
to pay for tuition/ fees only at approved IEA participating private schools. Any
expenses that do not meet the requirements in the IEA Parent Handbook
are considered a disallowed expense. For example, IEA funds cannot be used to pay
for these, including, but not limited to, the following: paraprofessionals to
provide tutoring or therapy services, food, before and after school care, and
room and board; extracurricular and athletics fees, unless required to attend
a participating school; field trips unless required to attend a participating
school; supply fees which include consumable items and materials; clothing,
and any expenses including services paid for, provided, and/or billed outside the IEA
contract period which goes from August 1st to July 31st each year. Parents may use IEA funds only for the
benefit of a student enrolled in the IEA Program for the following expenses
listed in state law. These expenses are in addition to the participating school tuition and fees that we’ve already discussed. Fees for nationally standardized
norm-referenced achievement tests, including Advanced Placement
examinations or any examinations related to college or university admission.
Tuition, fees, and/or required textbooks at eligible post secondary institutions.
Tuition or fees for part-time enrollment in a non-public online learning program.
Fees for transportation paid to a fee for service transportation
provider. Payment for purchase of a curriculum, including any supplemental
materials required by the curriculum. Services provided under contract with a
public school, including individual classes and extracurricular programs.
Debit card fees, there are currently no debit card fees for the IEA Program, but
that is subject to change. There are some expenses that require pre-approval
before parents can use the IEA funds to pay for those expenses. These include
tutoring services provided by a tutor accredited by state, regional, or national
accrediting organization. Educational therapy services for participating
students from a licensed or accredited practitioner or provider. Computer hardware or other technological devices if approved by the department or a
physician, and are used for student’s educational needs. Contributions to ABLE
Tennessee savings accounts for the benefit of the participating student, except
the funds used for elementary or secondary education expenses shall be
for expenses otherwise allowed. Contributions to Coverdell education
savings accounts established under 26 USC 530 for the benefit of the participating
student, except the funds used for elementary or secondary education
expenses shall be for the expenses otherwise allowed. Parents will have to
submit receipts and expense reports each quarter; the department will review
expense reports and receipts. Participating schools must provide
account holders with an itemized receipt for all qualifying expenses.
Participating schools cannot send parent held IEA accounts to collections in order o settle unpaid debts. All contracts
entered into are the responsibility of the private parties involved. Now we’re going
to talk about what the application process is for private schools to
participate in the program. Before completing the application and agreement,
schools must read the following documents posted on the department’s IEA
webpage: the IEA Program law Tennessee Code Annotated Title 49 Chapter 10 Part 14, the IEA Program rules of the State Board of
Education chapters 0520-01-11; the IEA Program Procedures, the IEA
Parent Handbook, and the IEA Private School Handbook. Private school
applications are now accepted year-round; applications for the 2019-20 school year
will open in January of 2019. Schools must submit a new application each year.
In the application, schools must report the maximum number of students receiving IEAs that the school has the capacity to enroll. Participating schools must also submit the following documentation in order to
participate in the program: surety bond or statement by a certified public
accountant, the school calendar, and the list of all tuition and fees. For the
surety bond or CPA statement, you must submit one or the other. The surety bond
must be payable to the state from a surety. The amount of the surety bond
is equal to the maximum number of students enrolled in the IEA Program the
school has the capacity to enroll which is identified in the school’s
application multiplied by $1,600. If the school has been
approved as category I, II, or III non-public school for five years or more,
in lieu of a surety bond, the school can submit a statement by a certified public
accountant confirming that the private school has the ability to pay an
aggregate amount equal to the maximum number of students enrolled in IEA
Program the school has the capacity to enroll multiplied by $1,600. The templates
for both of those documents are posted on the IEA webpage. On the application,
private schools must indicate whether the school provides an inclusive
educational setting. For the purposes of the IEA Program, a participating
non-public school is considered to have an inclusive educational setting if the
following two criteria are met: 1) students with disabilities are educated
with non-disabled children. and 2) No more than 50% of the students in an
individual classroom or setting are students with disabilities. By completing
the application, participating private schools agreed to comply with all state
laws, rules, and procedures for the IEA Program, as well as the requirements in
the Parent and Private School Handbooks. Schools that do not comply will be removed from participating in the IEA Program. It’s very important that you as a school
read those handbooks in order to understand what participation in the
program would mean for you as a school. If you have any questions about participating in the program, please contact our team
directly. If the department determines that the school is eligible to participate in
the program, the Department will notify the school and list the school on the IEA webpage. If at any time the information submitted in a school’s
application changes, including, but not limited to, the name of the school
principal, the email address, physical address, and/or phone number, the school must report the changes by emailing [email protected] Schools must notify the department within 15 calendar days of the change taking effect. Failure to
provide this information to the department within 15 calendar days may
result in the suspension of a school’s participation in the program or removal
of the school from participating in the program. This concludes the Spring 2019 Private
School Information Session. If you have any questions or feedback, please email us at [email protected]
Thank you so much for taking the time to watch this presentation! We hope that it was helpful! Have a wonderful day!

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