Office of Commissioner of Higher Education
Title II, Part A: Improving Teacher Quality Grant Program
Developing a Grant Project that Meets Federal Requirements
Conflicts of Interest
Circumstances giving rise to conflicts of interest may be highly complex and are often subjective. Both individuals and institutions can have conflicts of interest. Conflicts of interest are to be avoided if they would place the institution in a position of choosing between (or potentially having to choose between) taking an action that is consistent with or furthers the values and mission of the institution, and one that may appear to be consistent with and beneficial to the institution but, in actuality, is inconsistent with or harmful to the institution’s missions.
Title II grant sub-recipients are expected to avoid situations that may impart bias; that may involve inappropriate use of institutional resources, including other employees or information; or that may involve or have the appearance of self-dealing. As faculty conduct research in which they have a financial interest – either because of their ownership interest in the funding source or because of their ownership interest in a company having right to commercialize the results of the research – faculty must be particularly careful to avoid conflicts that may adversely influence their objectivity, integrity, or professional commitment and to avoid those conflicts that may have the appearance of doing so.
Each grant project must include (1) a private or state institution of higher education and the division of the institution that prepares teachers and principals AND (2) a school of arts and sciences AND (3) a high-need local education agency (LEA). The LEA may be a single public school or a public school district.
The partnership may include an additional non-principal member in the partnership.
A community college may be an additional, non-principal member of any partnership.
A low-performing school that does not meet the definition of high need may be an additional, non-principal member of any partnership.
Partnerships 50% Rule
Section 2132(c) of the NCLB law requires that no single participant in an eligible partnership, (i.e.,no single high-need LEA, no single higher education institution and its division that prepares teachers and principals, no single school of arts and sciences, and no other single partner), may “use” more than 50 percent of the subgrant. The provision focuses not on which partner receives the funds, but on which partner directly benefits from the funds.
Click here for ED's non-regulatory guidance on partnership allowances.
Approved Project Activities
Activities must be related to the needs of teachers, principals, and paraprofessionals. The project should have attainable goals that will be accomplished, and will demonstrate an improvement in student achievement and/or increase the number of highly qualified teachers. Proposals must include evidence that the project will provide professional development activities in the specific discipline(s) as well as in the related pedagogy.
Click here for more detailed information on allowable activities.
Approved Subject Areas
The following areas are approved as "core subjects" by the U.S. Department of Education: English, reading or language arts, mathematics, science, foreign languages, civics and government, economics, arts, history, and geography.
Formats for projects include, but are not limited to, institutes, seminars, intense summer and year-long courses, or combinations thereof. The most effective projects have been summer programs of at least two weeks with 80 or more contact hours, using a hands-on, inquiry based, problem-solving approach, and incorporating follow-up activities during the school year. One, two, and three-year projects are supported.
Multi-year projects are expected to provide a coordinated plan of activities for participants over two or three years rather than repeating an annual project two or three times.
Multiple Principal Investigators
A project may designate multiple individuals as PIs who share the authority and responsibility for leading and directing the project, intellectually and logistically. As such, each PI is responsible and accountable to the applicant organization, or, as appropriate, to a collaborating organization, for the proper conduct of the project or program including the submission of all required reports. The presence of more than one identified PI on an application or award diminishes neither the responsibility nor the accountability of any individual PI.
A proposal that involves PIs that appear to have questionable qualifications and expertise or appear to make an insufficient contribution to justify a PI role will not fair well in the review process. Applicants must include a leadership plan when proposing a multiple PI approach. The leadership plan should describe the roles and areas of responsibility of the named PIs, the process for making decisions concerning scientific direction, allocation of resources, disputes that may arise, and other information related to the management of the proposed team project. The purpose of the leadership plan is to facilitate and enhance scientific productivity and ensure that there is a decision-making process in place.
Approved Budget Activities
Faculty Salaries: Grant funds can be used to pay the appropriate portion of the IHE faculty salary needed to develop and administer the professional development. The "appropriate portion" of the salary is determined using time and effort estimates.
Tuition: Grant funds can be used to pay for tuition assistance for the professional development participants (i.e. the LEA teachers).
Note: A grant project is allowed to request funding for both faculty salaries and tuition assistance. Requesting funding for both aspects of a project is not considered "double-dipping" by the U.S. DOE.
Staff Remuneration: If K-12 teachers are hired as part of the teaching staff, their remuneration should be commensurate with their contribution, based on considerations similar to those used for faculty salaries.
Supplies: Title II, Part A funds may be used to purchase materials and supplies used in professional development activities, including the materials (such as graphing calculators) that a teacher will need in order to apply the professional development in a classroom setting. However, Title II, Part A does not permit the use of program funds to purchase materials and supplies (e.g., iPads) that, although they may benefit students, are not directly connected to the teachers’ professional development. Other ESEA funds, most notably Title V, Part A funds, may be used to purchase instructional materials or technology for students if the purchases are part of an “innovative assistance program” as this term is used in Title V.
In general, federal funds cannot be used for non-federal or non-allowable purposes. To this end, ED encourages projects to seek out matching funds from, say, the College of Education or the College of Arts and Science for purchasing supplies that when no longer needed for the original federally-funded project can be used for other non-federally-funded activities.
Stipends: The suggested maximum for stipends to full time participants is $250 per week. Stipends for participants in a program that is less than full-time shall be adjusted proportionally.
Participants shall not receive stipends in addition to their regular salary for activities during
weekdays of the academic year. If credit is granted at no cost to the participants, then the
awarding of participant stipends is not allowed. An additional stipend may be provided to participants as reimbursement costs related to required project activities (such as books, manipulatives, and meals).
Teacher Substitutes: As reasonable and necessary, Title II, Part A funds may be used to pay for substitute teachers if, and only if, (a) those regular classroom teachers they are replacing were hired with Title II, Part A funds to reduce class size, or (b) the teachers are participating in Title II-funded “programs and activities that are designed to improve the quality of the teacher force, such as…innovative professional development programs…” [Section 2123(a)(5)(A)]. LEAs also must ensure that the hiring of these substitutes supplements, and does not supplant, the use of local and State funds they would otherwise be spending for such substitutes.
Travel Costs: Only in-state travel at the state rate may be paid from grant funds. Out-of-state travel costs may not be paid using grant funds.
Indirect Costs: Indirect costs are limited to eight percent (8%) of the Title II Higher Education funds for the project.
Addressing Rural District Needs: One possible way that rural districts can provide teachers with professional development activities is by offering distance-learning opportunities. Many State colleges and universities currently offer distance learning. Through distance learning a teacher in a rural area can take professional development courses that meet his/her specific needs.
Supplement, not Supplant: Title II, Part A funds must be used to supplement, and not supplant, any non-Federal funds that would otherwise be used for authorized Title II, Part A activities.
Click here for ED's non-regulatory guidance on budget allowances.
When an administrator approves the proposal and cost sharing is indicated in a proposal, the responsible administrator is indicating approval of the cost sharing commitments being made. The approval of the project director (a.k.a. PI) also indicates that the project director will be responsible for documenting and reporting the cost share to the agency; therefore, it is imperative that administrators only approve cost sharing commitments that are necessary, allowable, and allocable (related/integral to the specific project in question).
Cost sharing is normally stated in the budget. However, cost sharing commitments can be stated in the budget explanation or justification or in the text of the narrative. No matter where cost sharing commitments are found within the proposal, statements of cost sharing commitment can be legally binding on the institution should the proposal be funded, even when not required by the sponsor.
The following checklist is provided to help both project directors and administrators make decisions about cost sharing:
Cost Sharing Checklist
- Is the cost sharing either mandatory or is there persuasive evidence that cost sharing is necessary?
- Is the cost sharing being proposed directly related and integral to this project?
- Will it be possible to document and document the cost sharing for reporting purposes?
- Is the type and source of cost share being proposed allowed by the grant sponsor?
- Will the cost sharing take place within the project period?
- Has the contributed effort of project personnel been approved by each individual’s chair/dean or director?
- Have all cash contributions been documented/approved by someone authorized to do so?
- Have all third party contributions been documented/approved by each organization’s authorized representative?
If the answer to any of these questions is, “no,” cost sharing should not be included in the proposal.
Grant projects must be based on research that involves the application of rigorous, systematic, and objective procedures to obtain reliable and valid knowledge relevant to education activities and programs. Valid research is defined as research that
- employs systematic, empirical methods that draw on observation or experiment;
- involves rigorous data analyses that are adequate to test the stated hypotheses and justify the general conclusions drawn;
- relies on measurements or observational methods that provide reliable and valid data across evaluators and observers, across multiple measurements and observations, and across studies by the same or different investigators;
- is evaluated using experimental or quasi-experimental designs in which individuals, entities, programs, or activities are assigned to different conditions and with appropriate controls to evaluate the effects of the condition of interest, with a preference for random-assignment experiments, or other designs to the extent that those designs contain within-condition or across-condition controls;
- ensures that experimental studies are presented in sufficient detail and clarity to allow for replication or, at a minimum, offer the opportunity to build systematically on their findings, and
- has been accepted by a peer-reviewed journal or approved by a panel of independent experts through a comparably rigorous, objective, and scientific review. (Note: practitioner journals or education magazines are not the same as peer-reviewed academic journals.)
The statute also requires that all activities supported with program funds must be based on a review of scientifically based research, and the grant project must maintain documentation that explains why it expects those activities to improve student academic achievement.
Pre-service Teacher Training
SAHE-funded partnerships may use Title II, Part A funds to provide highly qualified paraprofessionals with professional development in core academic subjects, including pre-service training that can lead to a B.A. degree or teacher certification. (Note, grant funds cannot be used to pay for the degree, they can only be used to pay for the training that directly applies to Title II, Part A.)
Program income includes, but is not limited to, income from fees for services performed, the use or rental of real or personal property acquired under federally-funded projects, the sale of commodities or items fabricated under an award, license fees and royalties paid on patents and copyrights, and interest on loans made with award funds. Program income earned during the project period* shall be retained by the subrecipient and, in accordance with the terms and conditions of the award, shall be used in one or more of the following ways:
- Added to funds committed to the project by the Federal awarding agency and subrecipient and used to further eligible project objectives
- Used to finance the non-Federal share of the project
- Deducted from the total project allowable cost in determining the net allowable costs on which the Federal share of costs is based
*Unless Federal awarding agency regulations or the terms and conditions of the award provide otherwise, subrecipients shall have no obligation to the Federal Government with respect to project income earned from license fees and royalties for copyrighted material, patents, patent applications, trademarks, and inventions produced under an award; however, Patent and Trademark Amendments (35 U.S.C. 18) apply to inventions made under an experimental, developmental, or research award.