Texas Even Start Administrative Manual

June 2004, (Revised January 2008, September 2008)

Even Start Guidance

STATE ADMINISTRATION (cont'd)

Competition for Subgrants

The Even Start statute establishes certain required information that each local subgrant application must contain. (Section 1237) However, each State may develop its own application for funding and may require additional information relevant to its own subgrant competition. (EDGAR, section 80.37(a)) For example, a State may require applicants to address that State’s Even Start indicators of program quality, priorities for funding that target areas that are especially underserved and in need of Even Start services, or any other relevant criteria to obtain the most qualified applicants. (See Local Application section.) However, any State priorities must be consistent with the statutory competitive priorities in section 1238(a)(2) explained below.

A State must follow certain statutory requirements in awarding subgrants, including using statutory selection criteria and statutory priorities and using a review panel that includes certain required members. (Section 1238(a) and the Review Panel and Selection Criteria sections.) However, e xcept as required by the Even Start statute or other Federal statutes or regulations, a State follows its own policies and procedures when awarding subgrants and, therefore, has substantial discretion over the competitive process for allocating funds to high-quality local projects that can help families most in need of Even Start services attain literacy achievement results. (EDGAR, section 80.37(a)) For example, a State’s process could include such things as on-site reviews, convening of panelists in one location for a paper review, or a two-tiered review process (using a combination of an on-site review and paper review).

Before issuing their instructions for a subgrant competition, the Department encourages States to consult with their Committees of Practitioners in developing the application review process, and any additions to the statutory selection criteria, and priorities that are consistent with those statutory requirements. (See Committee of Practitioners section.)

The SEA must establish a review panel to review and approve local subgrant applications. The review panel must consist of at least three members, including one early childhood professional, one adult education professional, and one individual with expertise in family literacy. Additional members may include one or more of the following: a representative of a parent-child education organization, a representative of a community-based literacy organization, a member of a local board of education, a representative of business and industry with a commitment to education, or an individual who has been involved in the implementation of the State’s Title I programs, which include Reading First and Early Reading First. (Section 1238(a)(3)) In order to ensure a fair and objective evaluation of applications, an SEA must follow State conflict-of-interest requirements or policies that it may have with respect to the review of subgrant applications.

Selection Criteria

The review panel evaluates and approves local applications in accordance with the statutory selection criteria and priorities in section 1238(a) of the ESEA and any additional State requirements that are consistent with those statutory selection criteria and priorities. Those criteria include the likelihood of success in meeting the purposes of the Even Start program, and effectively implementing the 15 required program elements (see the Local Administration – Program Elements section). The approved applications also must be representative of urban and rural regions of the State. (Section 1238(a)(1)(G))

In addition, the applicant must demonstrate that the area to be served has a high percentage or a large number of children and families who are in need of Even Start services as indicated by high levels of poverty, illiteracy, unemployment, limited English proficiency, or other need-related indicators. (Section 1238(a)(1)(B)) Applicants must also show how they will provide services for at least a three-year age range, demonstrate the greatest possible cooperation and coordination between a variety of relevant service providers, include a cost-effective budget, demonstrate the applicant’s ability to provide the local share of the program’s costs, and show the greatest promise for providing models that may be adopted by other family literacy projects and other LEAs. (Sections 1238(a)(1)(C)-(F) and (H))

The SEA must give priority to applications that target services to areas of the State with a high percentage or large number of children and families in need of Even Start services, as indicated by high levels of poverty, illiteracy, unemployment, limited English proficiency, or other similar need-related factors. (Section 1238(a)(2)(A)) Examples of other similar need-related factors, as listed in section 1238(a)(1)(B), are: a high number or percentage of children to be served by the program who reside in a school attendance area eligible for participation in Title I, Part A programs, a high number or percentage of parents who have been victims of domestic violence, and a high number or percentage of parents who are receiving “Temporary Assistance to Needy Families.” In addition, the SEA must give priority to applications for projects that are located in areas designated as empowerment zones or enterprise communities. (Section 1238(a)(2)(B)) To find areas in the State that have been designated as empowerment zones or enterprise communities, contact the Governor’s office.

Eligible Entity

To qualify as an “eligible entity” for an Even Start subgrant, an applicant must be a partnership between one or more LEAs and one or more nonprofit community-based organizations, public agencies other than an LEA, institutions of higher education (including two- and four-year institutions), or public or private nonprofit organizations of demonstrated quality other than an LEA. (Section 1232(e)(1))

A partnership may take a number of different forms and can designate any partner as the fiscal agent for the subgrant or form a formal legal entity that is a partnership to serve as the fiscal agent. However, in each case, the partners should clearly delineate their respective roles and functions, identify the partner(s) that will serve as the fiscal agent, and agree in writing to any required assurances and authorizations.

The partnership provisions in the Even Start law strengthen the connections between schools and communities and improve a project’s ability to reach families in greatest need of services through community outreach. The connection of a project to an LEA and a school’s resources also allows for greater ease in the continuity of family literacy services, especially when children make the transition between an early childhood education provider to a school.

In order to reach out to the greatest number of possible applicants, the Secretary encourages States to inform all potentially eligible partners of the availability of funds for an Even Start program and the process they should follow in applying for a subgrant.

Even Start projects are cooperative projects that build on high-quality, existing community resources to create a new range of services to serve families' educational needs. (Section 1231(2)(A)) In addition to the formal partners who comprise the eligible entity applying for funding and administering the grant, an Even Start project has a number of collaborators who provide direct instructional or support services to participating families and may contribute to the local project’s matching or cost share. These collaborators might include such local agencies as: the community library, the community college, the welfare agency, a day care program, a professional association, a faith-based organization, or a volunteer organization. The Department encourages projects to cultivate community investment in the program by building on high-quality community resources or bolstering the quality of these community resources, if necessary by supplementing those services.

Project Funding

Minimum Subgrant Amounts

The Secretary encourages States to make subgrants that are of sufficient size, scope, and quality to be effective in meeting the purposes of Even Start, allow projects to meet their program objectives and participant achievement goals, and make maximum use of the resources available at the local community level. (Section 1233(b)) SEAs are encouraged to make continuation awards of sufficient size to ensure each project’s continuity of high-quality services and successful program outcomes and participant achievement results. After reserving funds for administration and technical assistance and funding continuation grants for projects that demonstrate sufficient progress toward meeting their individual program objectives and the State’s Even Start indicators of program quality, States must use the remaining funds to award new subgrants. (Section 1233(b))

The minimum amount of Federal funds required for a subgrant for programs in their first through eighth year of operation generally is $75,000 per year. The minimum subgrant size of $75,000 per year is reduced to $52,500 for recipients in their ninth and succeeding years. If less than $75,000 of Federal funds remain available for a fiscal year after the State has awarded all other subgrants, the SEA may fund one subgrant of less than $75,000 for a project in its first through eighth year of operation for that fiscal year, or one subgrant of less than $52,500 for a project in its ninth or subsequent year of operation for that fiscal year. However, each State may have only one project operating under these conditions at any given time. (Section 1233(b)(2))

Federal and Local Share

An Even Start project’s funding is comprised of a portion of funds attributable to the Federal grant (Federal share) and a portion contributed by the project (local share). The amount of the local share in the first year of the local project’s grant must be at least 10 percent of the total cost of the project. In the second year of Federal funding, the project must provide at least 20 percent of the total cost of the second-year budget; in the third year, at least 30 percent of the third-year total budget cost; in the fourth year, at least 40 percent of the fourth-year total budget cost; in the fifth through eighth years, at least 50 percent of each year’s total budget cost; and in each subsequent year, at least 65 percent of each year’s total budget cost. (See Duration of a Project – Continuing Eligibility section.) (Section 1234(b)(1))

It is not necessary to reduce a project’s grant award each year in order to satisfy the requirements for the progressively increased local share. Instead, a State may keep a project’s grant award constant and require a sufficient increase in the local share. Or, a State may even increase the grant award for subsequent years, so long as there is a sufficient local share. The important consideration is that each project receives sufficient funds to operate a high-quality program that generates successful participant achievement results.

A local project may provide its local share in cash or through in-kind contributions, fairly evaluated. The project may obtain its local share from any source, including any Federal funds other than Even Start funds. (Section 1234(b)(1)(B)) For an explanation of how to place a value on specific third-party in-kind contributions, see EDGAR, section 74.23 (for institutions of higher education and non-profit organizations) and section 80.24 (for LEAs and Indian tribes).

An Even Start project may only use allowable costs to satisfy the project’s local share. (See EDGAR, section 80.24.) For example, indirect costs are not allowable for Even Start local projects and, therefore, may not be used to meet a project’s local share. (Section 1234(b)(3))

In addition, a project may only count costs or values of third-party in-kind contributions toward satisfying its local share for one Federal grant or contract at a time. For example, if Head Start is a collaborating agency with an Even Start project and counts a volunteer teacher’s time for all of the children (including the children participating in Even Start) toward satisfying a Head Start matching requirement, the Even Start project may not count that same teacher’s time toward meeting the Even Start local share. In the alternative, the Head Start program and the Even Start program may agree to split the value of the volunteer teacher’s time proportionately, based on the numbers of Head Start and Even Start children served by that teacher, between the two programs for the purpose of each program’s respective matching requirement.

Under the statute, Even Start funds generally may not be used for the indirect costs of a local Even Start project. Under certain circumstances, the Secretary may waive this limitation for Indian tribe or tribal organization Even Start grants from the Department. (Section 1234(b)(3))

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