The concept of “supplement not supplant” (SNS) stands as one of the most critical fiscal compliance requirements for school districts receiving federal Title I, Part A funding. Yet despite its importance, it remains widely misunderstood and is often a source of confusion for educational leaders. Under the Every Student Succeeds Act (ESSA) of 2015, significant changes were made to how Local Education Agencies (LEAs) demonstrate compliance with SNS requirements – changes that offer both new flexibility and new responsibilities for district leaders.
This article explores the evolving landscape of supplement not supplant requirements, highlights common misconceptions, and provides practical guidance for school leaders seeking to maximize the impact of Title I funding while ensuring full compliance with federal regulations.
Understanding the Fundamental Principle
At its core, the supplement not supplant provision serves a straightforward purpose: ensuring that federal Title I, Part A funds provide additional support to disadvantaged students rather than replacing state and local funding. The provision exists to guarantee that Title I schools receive all the state and local funds they would otherwise receive if they were not eligible for Title I funding.
According to ESEA Section 1118(b)(1), an LEA must use Title I, Part A funds only to supplement the funds that would, in the absence of Title I funding, be made available from state and local sources for the education of students participating in Title I programs. This requirement ensures that students in Title I schools receive federal resources in addition to—not instead of—state and local funding.
The Paradigm Shift: From NCLB to ESSA
The Old Approach Under NCLB
Under the No Child Left Behind (NCLB) Act of 2001, compliance with supplement not supplant was evaluated through three presumptions of supplanting. A Title I expenditure was presumed to be supplanting if it was used for:
- An activity required by federal, state, or local law
- An activity that was paid for with state or local funds in the prior year
- The same services for Title I students that state and local funds supported for non-Title I students
This approach required LEAs to justify individual Title I expenditures by demonstrating they were supplemental, creating significant administrative burden and limiting the strategic use of Title I funds.
The New Methodology-Based Approach Under ESSA
ESSA fundamentally changed the supplement not supplant compliance framework. Under the new approach, states can no longer require LEAs to identify how individual costs or services supported by Title I, Part A are supplemental. Instead, LEAs demonstrate compliance by showing that the methodology they use to allocate state and local resources to schools is “Title I neutral”—meaning state and local funds are distributed without regard to a school’s Title I status.
This shift accomplishes several important objectives:
- It reduces administrative burden on LEAs by eliminating the need to justify individual Title I expenditures
- It provides greater flexibility in how Title I funds can be used to support student achievement
- It encourages the effective coordination of Title I funds alongside other resources to assist students with the greatest needs
Resource Allocation Methodology (RAM): The New Compliance Standard
A Resource Allocation Methodology (RAM) refers to the procedure an LEA uses to distribute state and local funds across schools. Under ESSA, this methodology must demonstrate Title I neutrality, showing that the distribution of state and local funds is not influenced by whether a school receives Title I funding.
Types of Resource Allocation Methodologies
A Resource Allocation Methodology (RAM) refers to the procedure an LEA uses to distribute state and local funds across schools. Under ESSA, this methodology must demonstrate Title I neutrality, showing that the distribution of state and local funds is not influenced by whether a school receives Title I funding.LEAs have flexibility in designing their RAMs, but common approaches include:
- Per-pupil allocation: Distributing a fixed amount of state and local funds per student, regardless of the school’s Title I status.
- Weighted per-pupil allocation: Providing additional funding based on student characteristics (such as English learners, students with disabilities, or grade level), again without consideration of a school’s Title I status.
- Personnel and non-personnel resource-based allocation: Distributing staff positions and non-personnel resources to schools based on enrollment or other objective factors that do not include Title I status.
- Hybrid approach: Combining elements of multiple methodologies to allocate state and local resources to schools.
LEAs may employ a single districtwide methodology or different methodologies based on school type, grade span, or other factors. The key requirement is that each methodology must be neutral with regard to Title I status.
When Is a RAM Not Required? Understanding Exemptions
Not all LEAs are required to document a Resource Allocation Methodology. An LEA is exempt from this requirement if:
- The LEA has only one school
- The LEA has all Title I schools
- All grade spans are exempt (a grade span is exempt if it has a single school, all schools in the span are Title I schools, or all schools in the span are non-Title I schools)
While exempt LEAs are not required to maintain a RAM, they must still adhere to the fundamental supplement not supplant requirement under ESEA Section 1118(b)(1) and comply with all federal, state, and local laws. Additionally, exempt LEAs should maintain documentation of their exemption status.
Components of an Effective Resource Allocation Methodology
For LEAs that are not exempt, a well-documented RAM should include:
- School enrollment and Title status: Enrollment data that the LEA uses to allocate funds each year, along with indication of each school’s Title I status.
- Statement of methodology: A clear explanation of the type of methodology used (per-pupil, weighted per-pupil, or personnel and non-personnel costs) and whether it applies districtwide or varies by school category.
- Criteria used in methodology: Details on how state and local funds are distributed, such as per-pupil amounts, weights assigned by student characteristic, or personnel allocation ratios.
- Mathematical calculation: The application of the methodology showing how the LEA arrived at the total allocations of state and local funds for each school.
- Excluded funds: Documentation of any state and local funds that meet the criteria for exclusion from the RAM (discussed in the next section).
- Assurances: A statement confirming that state and local funds are allocated according to the RAM and that any excluded funds are used without regard to schools’ Title I status.
Resources That Can Be Excluded from the RAM
Two categories of state and local funds may be excluded from a Resource Allocation Methodology:
- Resources not allocated to schools: Expenditures for districtwide activities (like transportation or centralized administrative services) may be excluded from school allocations. However, these resources must still be used in a manner that does not consider Title I status.
- Supplemental state and local funds for programs that meet the “intent and purpose” of Title I: Per ESEA Section 1118(d), supplemental state and local funds used for programs that meet the intent and purpose of Title I (as clarified in 34 CFR 200.79) may be excluded from supplanting determinations. This allows an LEA to fund a program that meets Title I’s intent and purposes with state and local funds in non-Title I schools while using Title I funds for similar programs in Title I schools.
While these funds can be excluded from the RAM, they must be separately documented to ensure overall compliance with supplement not supplant requirements.
Common Misconceptions and Pitfalls
Several misunderstandings often arise regarding supplement not supplant requirements:
Misconception 1: "Traditional presumptions of supplanting still apply to Title I, Part A"
Under ESSA, the three presumptions of supplanting that were used under NCLB no longer apply to Title I, Part A. Once an LEA demonstrates it has a Title I-neutral methodology for allocating state and local resources, the use of Title I funds is not subject to these traditional tests. This provides significant flexibility for LEAs to use Title I funds in ways that were previously restricted.
For example, an LEA that has been paying for reading intervention software with state and local funds at a Title I school can shift these costs to Title I, Part A funding without violating supplement not supplant requirements, provided the LEA’s RAM shows that state and local resources are allocated without regard to Title I status.
Misconception 2: "A school's Title I status can never be considered when allocating resources"
While the general rule is that state and local resources must be distributed without regard to Title I status, there is one important exception. Per ESEA Section 1118(d), an LEA may consider a school’s Title I status when allocating supplemental state and local funds for programs that meet the intent and purpose of Title I, Part A.
For instance, an LEA could use state and local funds to support an after-school tutoring program for struggling students at non-Title I schools while using Title I funds for a similar program at Title I schools, without violating supplement not supplant requirements.
Misconception 3: "Changes to SNS alter the allowable uses of Title I funds"
The changes to supplement not supplant requirements do not modify what constitutes an allowable use of Title I funds. All Title I expenditures must still be:
- Necessary and reasonable
- Aligned with the purpose of the Title I program
- Consistent with program-specific requirements
Misconception 4: "Comparability and supplement not supplant are the same thing"
While both comparability and supplement not supplant examine how LEAs distribute resources to schools, they are separate compliance requirements that measure different aspects of resource allocation:
- Comparability requires that state and local funds provide services that, taken as a whole, are comparable between Title I and non-Title I schools.
- Supplement not supplant requires that state and local funds be distributed to schools without taking into account a school’s participation in the Title I program.
An LEA might satisfy one requirement while failing to meet the other. For instance, an LEA could distribute state and local funds without regard to Title I status (meeting SNS requirements) but have significantly higher student-to-teacher ratios in Title I schools than in non-Title I schools (violating comparability)
Practical Strategies for Compliance While Maximizing Flexibility
School leaders can employ several strategies to ensure compliance with supplement not supplant requirements while maximizing the strategic impact of Title I funds:
1. Develop a clear, well-documented RAM
Create a Resource Allocation Methodology that clearly demonstrates how state and local resources are distributed without regard to Title I status. Document all components of the methodology and maintain records that show its implementation.
2. Revisit the RAM annually
While continuous demonstration of compliance throughout the school year is not required, LEAs should review their RAM annually to ensure it accurately reflects their current approach to allocating state and local resources.
3. Leverage the flexibility provided by ESSA
Take advantage of the elimination of the traditional presumptions of supplanting to use Title I funds more strategically. Activities previously funded with state and local resources can now be supported with Title I funds, provided the RAM demonstrates Title I neutrality.
4. Ensure coordination between fiscal and program staff
Effective compliance requires close collaboration between district fiscal officers and program administrators. Regular communication can help ensure that resource allocation decisions align with both compliance requirements and educational goals.
5. Maintain proper documentation
Even if a RAM is not required to be submitted to the state education agency, maintain thorough documentation of the methodology or exemption status for monitoring purposes. Be prepared to provide this documentation during state or federal monitoring visits.
Addressing Common Challenges in Behavior Tracking For Teachers
The analysis phase in student behavior tracking helps to obtain a profile of the student’s behavior and understand possible causes. Monitoring student behavior is important to prevent dropout rates by engaging students. Structured routines in classrooms create a predictable environment which greatly assists students in managing their behaviors and emotions.
Effective communication is essential for successful completion of the behavior tracking process. A daily check-in sheet can include replacement skills, assessment of emotions, and guidance for problem-solving. These tools help students develop replacement skills that effectively replace negative behaviors and improve decision-making.
Any interventions in behavior tracking must comply with district and school policies and procedures. Adhering to these guidelines ensures that behavior tracking efforts are effective and aligned with broader educational goals. Additionally, adults support students in taking responsibility for their behaviors by asking processing questions to help them make better decisions.
Future Trends in Student Behavioral Tracking
The rise of hybrid learning models will prompt the development of more sophisticated tracking systems that monitor student behavior in both in-person and remote settings. The rollout of 5G technology is expected to facilitate faster data collection and real-time monitoring in behavior tracking systems. These advancements will make it easier for educators to track and respond to student behaviors in real-time.
Digital transformation in education is likely to streamline administrative tasks related to student behavior tracking, making systems more efficient. Smart communication tools are set to evolve, facilitating better real-time feedback between students, teachers, and parents regarding behavioral progress. These tools will enhance the ability of educators to provide timely and effective interventions.
Artificial intelligence is anticipated to play a significant role in education by improving the analysis of student behavior and learning patterns. Competency-based education is set to gain traction, allowing students to progress based on their mastery of skills, which can influence behavior tracking methods. These trends will shape the future of student behavioral tracking, making it more adaptive and responsive to the needs of students.
Maintaining Compliance: Monitoring and Oversight
The state education agency may request a copy of an LEA’s Resource Allocation Methodology or Statement of Exemption when reviewing Title I, Part A expenditures. Common monitoring findings related to supplement not supplant include:
- Applying traditional presumptions of supplanting to Title I, Part A
- Incorrectly claiming exemption from the requirement to maintain a RAM
- Failing to document that resources not allocated to schools are distributed in a Title I-neutral manner
- Confusing comparability requirements with supplement not supplant requirements
To avoid these issues, LEAs should regularly review their compliance strategies and stay informed about state and federal guidance on supplement not supplant requirements.
Wrapping Things Up
The transition from NCLB to ESSA brought significant changes to how LEAs demonstrate compliance with supplement not supplant requirements. By shifting from individual cost justifications to a methodology-based approach, ESSA provides greater flexibility in the use of Title I funds while maintaining the fundamental principle that federal resources should supplement, not replace, state and local funding.
School leaders who understand these changes and develop clear, well-documented Resource Allocation Methodologies can ensure compliance with supplement not supplant requirements while strategically leveraging Title I funds to improve educational outcomes for their most vulnerable students. By avoiding common misconceptions and implementing best practices, LEAs can navigate the complexities of federal funding requirements while focusing on their core mission: providing high-quality education to all students.
