Federal Regulations & Title I FAQ

Title I is a federal program authorized by the Every Student Succeeds Act of 2015 (ESSA) that provides additional funding to schools, enabling them to better support students from families living in communities with greater economic needs. All4Ed.org created a succinct summary of Title I nationally. Each year, Arlington Public Schools (APS) identifies Title I schools based on federal guidelines and available funding. It makes two determinations: which APS schools are eligible and which will participate. 

Federal guidelines state:

• Schools with 75% or more of their students identified as economically disadvantaged meet the criteria for mandatory participation in a Title I program.
• For all schools below 75%, districts may choose to focus their funds at specific grade levels.
• Schools with 35% or more meet the criteria to be considered for participation in a Title I program using a Targeted Assistance program model in which specific students at the school are able to benefit from the Title I program.
• Additionally, schools with 40% or more meet the criteria to be considered for participation leveraging a Schoolwide program model in which all members of the school community benefit.

Currently, the Identified Student Percentage (ISP) as found in the annual April 1 CEP Report is the data used to rank schools from highest to least economic need. The ISP divides the number of Directly Certified Students by the total student enrollment for the school. Federal regulations allow a multiplier of 1.6 to be applied to the percentage when used for determining Title I eligibility to approximate the household-income-based applications for free meals that are not considered in the direct certification figure. This measure, including the multiplier, is used uniformly for all APS schools in 2025-26 determinations.

Direct certification means that students automatically qualify for free school meals based on their household’s participation in the other programs such as Supplemental Nutrition Assistance Program (SNAP), Temporary Assistance for Needy Families (TANF), Medicaid, or students who are in foster care or experiencing homelessness.

Meeting the criteria to be considered for participation in the Title I program does not mean that schools will participate in the Title I program. After determining which schools are eligible, APS lists its schools in order of highest economic need and determines how many schools on the list starting from the top can be meaningfully supported based on the total funding received. The total amount of funding APS receives is determined annually and varies. In this way, APS identifies which of the eligible schools will participate in the Title I program. For School Year 2025-26, APS’ participation threshold is 39%.

No. When calculating the two components of the ISP, direct certification and enrollment, all students attending the school are counted.

Yes, identification of Title I schools is an annual process.The law allows for one “grandfather” year of identification when a school falls below the service threshold. This is to moderate the programmatic impact of fluctuating economic data.There is no waiting period for a school to (re)enter Title I.

APS Title I funds are used in combination with other local, state, and federal funds to support our students experiencing homelessness and in foster care regardless of the school that they attend. Title I contributes support for the position that coordinates identification and address of these students’ needs. Nonprofit private schools that enroll students residing in Arlington Title I boundary zones are eligible to participate in the program in a Targeted Assistance model for the benefit of those students. 

The article, Understanding the Relationship  Between Community Eligibility and Title I Funding, by Food Research & Action Center provides an overview.

Are they the same? 

No. While Title I and CEP share a common purpose of supporting communities with high levels of student economic need, they are separate programs. Each defines their own criteria, methods, and options for achieving that purpose. CEP is focused on food and nutrition; while Title I is focused on student academic needs.CEP is an option within the USDA National School Lunch Program that enables the district to identify schools or groups of schools based on collective economic data to offer breakfast and lunch at no charge to all students while simultaneously reducing the administrative burden of the traditional school meal application process. 

Is a school’s status in one program dependent on the other? 

No. Determinations for a school’s eligibility and participation in each program are made independent of one another.

Can we solicit and collect household applications for free meals for Title I purposes even though we are a CEP school? 

No. CEP schools may not solicit household applications for the National School Lunch Program. School districts are also not allowed to use household applications from CEP schools as economic data for Title I eligibility determinations. 

APS is only currently implementing the Schoolwide program model. For these schools: The school community will create a Title I Schoolwide Program Design and School Action Plan that will guide their work as a Title I Program School. In APS, this is an expansion of the School Action Plan that all schools use to guide their work. APS’ Federal Programs team provides support to the school community in understanding and making the transition and implementing the program throughout the year.

Does the school retain its CEP status such that all students continue to receive free meals?

CEP status is not impacted when exiting Title I status.

What changes for teachers at the school with respect to eligibility for federal loan forgiveness? 

Loan forgiveness is not determined or managed by APS. There are many facets and individual situations are unique. This is largely because there are different forgiveness program options and criteria for those options for different loan types, even amongst the federal loan types. If one considers private loans as well, there is even more variability.

• • Teachers may find this summary from studentaid.org helpful in understanding the four distinct federal loan forgiveness programs and how they can be applied to various types of federal loans.
  • A teacher may wish to seek advice about their unique situation directly from one of these suggested contacts from studentaid.gov.

Here are some areas we would highlight for exploration.

• • For the federal Public Service Loan Forgiveness program, APS as a whole is an eligible employer.
  • It is a common misconception that loan forgiveness through the federal Teacher Loan Forgiveness Program (TLFP)  is based on the school’s Title I status. It is based on each school’s low-income rate as recognized by US ED in their annual Teacher Cancellation Low Income (TCLI) Directory. This is a broader identification than Title I schools, so the school may still qualify even while exiting Title I status.
  • If a teacher worked at the school when the school was eligible according to the TCLI Directory, all of their continuing years at the school (with no break in service) count towards the five years of service needed for the Teacher Loan Forgiveness Program. Section 10 (p.6) of the Application states:

If your school or educational service agency is included in the TCLI Directory for at least one qualifying year of your teaching service, but does not qualify for inclusion in the TCLI Directory during subsequent years, your subsequent years of teaching at that school or educational service agency may be counted toward the required five years of teaching. Any years of teaching before the school or educational service agency qualified for inclusion in the TCLI Directory may not be counted.

• • Teachers are guided not to apply for forgiveness through TLFP until the end of their fifth full-time, consecutive year. When ready to apply:
    • Information about the TLFP, and a link to the application, is here on the TLFP webpage.
    • This article from studentloanplanner.com includes tips for avoiding mistakes that can lead to an application being rejected and may be useful when preparing the application.
    • For employment verification from APS, visit this APS Human Resources Sharepoint page (while logged in) to complete the release form and submit the request to verify your employment history.

What is the impact to the school’s Title I School-Family Partnership?

Schools are invited to continue using practices such as the School-Family Partnership Principles and resources such as the School-Family Partnership Survey. The APS Family and Community Engagement (FACE) program continues to be available to support.