Key Policy Letters Signed by the Education Secretary or Deputy Secretary

May 10, 2023

Dear College, University, and School District Leaders:

As you know, the COVID-19 pandemic has had a significant impact on our students' learning and mental health and has widened long-standing inequities and opportunity gaps for low-income students, students of color, English learners, and students with disabilities. Thanks to your leadership and close collaboration with parents, families, and educators, many more students are on the path to recover from the pandemic and succeed in school, college, and future careers. However, the continued challenges our students face make it clear that we must provide even more support to help them fully recover.

The purpose of this letter is to encourage colleges, universities, and school districts to work together to use Federal Work Study (FWS) and other federal resources to increase the number of college students supporting school-aged children and youth as tutors, mentors, student success coaches, and other student support roles in our nation's schools and out-of-school time programs.

At this time of national need, President Biden has called for an additional 250,000 Americans to serve as tutors and mentors and in other high-impact roles supporting our preschool, elementary, and secondary students. The Administration has urged states, school districts, and colleges and universities to partner together to support our students. In July 2022, the U.S. Department of Education (Department), AmeriCorps, and the Everyone Graduates Center at Johns Hopkins University launched the National Partnership for Student Success (NPSS) – a research-based, locally driven, public-private partnership. The NPSS helps schools, districts, nonprofits, and state and local governments create, expand, and improve evidence-based programs that support the academic recovery, mental health, and overall well-being of students. Specifically, the NPSS supports these organizations in deploying tutors, mentors, student success coaches, postsecondary transition coaches, and integrated student support coordinators ("NPSS roles") to address student needs.i As of March 2023, the NPSS has grown to a coalition of nearly 130 local, state, and national entities and organizations.

Authorized under the Higher Education Act's Title IV student aid programs, FWS provides part-time employment to students attending colleges and universities who need additional earnings to help meet their costs of postsecondary education and encourages students receiving FWS assistance to participate in community service activities. See 20 U.S.C.A. § 1087-51 (a). To be eligible for these funds, both students and the college or university must meet the relevant FWS requirements. For example, these funds are only available to students eligible for Title IV aid, and a college or university must employ the student directly or have entered into an agreement with a relevant outside organization to employ the student.

President Biden has called for colleges and universities to prioritize using FWS funds for 1) job-related roles and career experiences for students; and 2) public service roles that support school-aged students in classrooms and community settings. This letter highlights the benefits of using FWS funds to support pandemic recovery for school-aged students in a way that also offers career exploration and skills growth to college students. The Department expects to release additional information on ways FWS can further support career-connected, work-based learning to complement and reinforce students' educational programs and career goals.

Colleges and Universities

The Department is calling on colleges and universities that receive FWS to use these funds to support community service, and specifically to support NPSS roles in local schools or out-of-school time programs (such as afterschool and summer programs), consistent with all other FWS requirements.

In particular, the Department is calling on colleges and universities to set a public goal to, within the next two years:

  • use at least 15 percent of their FWS funds to compensate college students employed in community service activities, devoting any increase in FWS compensation for community service to employment in NPSS roles located in schools or out-of-school time programs; or significantly increase the number of college students in NPSS roles regardless of the funding source supporting these roles; and1
  • share data with the NPSS on the number of college students serving in these roles, including those receiving support through FWS or other programs.

Colleges and universities can sign up to join the Administration's effort to increase the number of college students serving in these roles, share their goals and progress, and participate in a professional learning community through the NPSS, using this link: https://www.partnershipstudentsuccess.org/colleges/.

Colleges and universities across the country have already demonstrated the potential of leveraging FWS funds to support school-age children and youth, in partnership with local schools and nonprofit organizations. Some examples, which are non-exhaustive, include:

  • Colleges and universities that partner with Jumpstart's College Corps use FWS to send trained college students to implement early childhood education curriculum in preschools around the country.ii
  • New York University uses FWS funds to support students serving as math and reading tutors in local public schools, nonprofit organizations, and community centers throughout New York City.iii
  • Arizona State University's America Reads program employs work-study students to provide tutoring, mentoring, and academic skill-building support, in partnership with multiple schools and community sites throughout Maricopa County.iv
  • The Peer Power program at the University of Memphis sends FWS students to local high schools to serve as success coaches to 9th graders.v

Since many FWS community service jobs take place off-campus, transportation is often cited as a barrier to placing college students into these positions. To address this challenge, we encourage colleges and universities to consider providing transportation or covering costs associated with transportation for students participating in off-campus community service jobs using non-FWS resources and to include the time a student spends in transit to community service activities as time compensated by FWS (consistent with 34 CFR 675.18(h)).

In addition to the benefits to school-aged children and participating college students, using FWS funds for NPSS roles benefits colleges and universities as well. The federal share of compensation paid for these roles can be much more generous than other FWS roles. Specifically, the federal share of FWS compensation can reach 100 percent when the FWS student is employed as a reading or math tutor for school-aged children or when they are performing qualifying family literacy activities or civic education activities. The federal share of FWS compensation can be as high as 90 percent when a college student is employed at a nonprofit or at a federal, state, or local public agency, subject to FWS requirements, including those at 34 CFR 675. Finally, these efforts promote postsecondary readiness for school-aged children, building strong connections between school-aged children and local college students.

The Department also encourages colleges and universities to use other programs to support NPSS roles, such as credit-bearing volunteer or civic engagement programs; educator preparation programs; and AmeriCorps programs, including by using grant funds to support AmeriCorps programs in schools. Department funds may be used to fulfill matching requirements for AmeriCorps programs.vi

School Districts

The Department encourages school districts to engage with local and regional colleges and universities to establish partnerships that will enable college students to fill NPSS roles in schools and out-of-school time programs. School districts are also encouraged to partner with other local government agencies and community-based organizations to place caring adults in NPSS roles, or to establish programs focused on these student supports. The appendix includes information on Department funds that school districts can use to support NPSS roles.

If you are a district leader and do not know where to start, are having difficulty attracting volunteers or staff, or need help identifying a college, university, or other partner, I encourage you to take advantage of technical assistance through the NPSS here https://www.partnershipstudentsuccess.org/schools-districts/.

The NPSS has also issued voluntary quality standards for NPSS roles, a brief outlining how states can establish state partnerships for student success, and a toolkit for school districts on implementing student support programs. Today, the NPSS is releasing a toolkit for colleges and universities on how they can support NPSS roles.

To learn more about NPSS, including opportunities for free technical assistance to implement or expand high-impact student support programs, help with matching your college or university with a local school or youth-serving organization, or vice versa, and access to learning communities and other resources, please visit www.partnershipstudentsuccess.org.

Thank you for your commitment to our nation's children and youth, and to their future success.

Sincerely,
/s/
Miguel A. Cardona, Ed.D.
U.S. Secretary of Education

APPENDIX: Department Funding Available to Local Educational Agencies (LEAs) to Support NPSS Roles

A range of federal resources can be used and braided2 to support college students, and others, serving in NPSS roles consistent with all other program requirements (including the requirements of the Uniform Guidance in 2 CFR part 200).3 The below is a non-exhaustive list of such funds:

  • Elementary and Secondary School Emergency Relief Funds (ESSER) and the Governor's Emergency Education Relief (GEER) Fund: ESSER and GEER funds, including the $122 billion in the American Rescue Plan ESSER funds, may be used to compensate, hire, and train staff to serve in NPSS roles that address the impact of the COVID-19 pandemic, or to enter into an agreement (e.g., a contract or interagency agreement consistent with procurement requirements or otherwise legally authorized) for these activities. An LEA or another subrecipient is not authorized to award subgrants with ESSER or GEER funds.
  • Bipartisan Safer Communities Act (BSCA) Stronger Connections Grants: In June 2022, President Biden signed the BSCA into law, which provided $1 billion in Stronger Connections Grants for state educational agencies to competitively award subgrants to high-need school districts to establish safer and healthier learning environments. These funds were awarded to states in September 2022, for states to award to school districts on a competitive basis. To the extent it is consistent with an LEA's Stronger Connections subgrant, funds may be used to hire staff into NPSS roles; contract with external service providers; train current staff; and support recruitment efforts. Hiring of any additional personnel must comply with the statutory requirements described in Question B-9 of the Department's Bipartisan Safer Communities Act Stronger Connection's Grant Program Frequently Asked Questions resource.
  • Elementary and Secondary Education Act of 1965 (ESEA) Title I, Part A: With the Consolidated Appropriations Act, 2023, under President Biden, federal funding for Title I, Part A has increased by $1.9 billion since FY21, an 11 percent increase, to a total amount of $18.4 billion. In general, Title I, Part A funds, including school improvement funds under section 1003, can support hiring individuals into NPSS roles consistent with all other Title I, Part A requirements. For a Title I school that implements a schoolwide model, any use of funds must be consistent with the schoolwide plan.vii
  • ESEA Title I, Part D: Title I, Part D, Subpart 2 funds may be used to hire for NPSS roles that support students in locally operated correctional facilities or at-risk students attending schools in the school district, consistent with all other Title I, Part D requirements.viii
  • ESEA Title II, Part A: Given the robust evidence base for the impact of individuals serving in these roles, in general, Title II, Part A funds, including both state-level and LEA-level funds, could be used to support NPSS roles consistent with all other Title II, Part A requirements. For example, Title II, Part A funds can be used to train individuals and students in educator preparation programs serving as tutors.ix
  • ESEA Title III, Part A: Title III, Part A funds may be used to support NPSS roles, if these individuals are providing supplemental support to English learners, consistent with all other Title III, Part A requirements, including the requirement that Title III funds be used to supplement, and not supplant, state, local, or other federal funds. Title III, Part A funds may also be used to provide effective professional development for these individuals in meeting the needs of English learners.x
  • ESEA Title IV, Part A: Title IV, Part A Student Support and Academic Enrichment Grant funds may be used to support NPSS roles, consistent with all other Title IV, Part A requirements.xi
  • ESEA Title IV, Part B – Nita M. Lowey 21st Century Community Learning Centers (21st CCLC): 21st CCLC grants generally provide academic enrichment opportunities during non-school hours, particularly for students who attend schools with high concentrations of students from low-income backgrounds and students who need academic support. Subgrantees may be school districts, schools, community-based organizations, and other for-profit and non-profit entities. These organizations may be good partners in NPSS work and can access NPSS technical assistance from the NPSS.xii
  • ESEA Title V, Part B: Title V, Part B funds for Rural Education Achievement Programs may be used to hire for NPSS roles and may be particularly helpful in the rural areas that are served by these grants.xiii
  • ESEA Title VI, Part A, Subpart 1: Indian Education Formula Grants may be used to hire for NPSS roles, if those individuals are providing supplemental services to meet the unique cultural, language, and educational needs of Native American and Alaska Native students, as defined in the ESEA. Funds must be used in a manner consistent with all requirements of Title VI, Part A and the hiring preference mandated by the Indian Self-Determination and Education Assistance Act (P.L. 93-638).xiv
  • ESEA Title VII: Most Impact Aid funds, except funds for the additional payments for children with disabilities and construction payments, are considered general aid to the recipient school districts and may be used to hire for NPSS roles.xv
  • Education for Homeless Children and Youths: Funds granted under the McKinney-Vento Education for Homeless Children and Youth Program may be used to hire for NPSS roles, if those individuals are supporting homeless children and youth, consistent with all other requirements of the program.xvi The McKinney-Vento program particularly encourages the participation of persons with lived experience of homelessness in providing guidance and services to youth who are currently experiencing homelessness.
  • Full-Service Community Schools: Full-Service Community Schools grant funds may be used to hire for NPSS roles consistent with an approved grant application.xvii
  • Promise Neighborhoods: Promise Neighborhoodsgrant funds may be used to hire for NPSS roles, consistent with an approved grant application.xviii
  • Individuals with Disabilities Education Act (IDEA) Part B grants: There may be certain circumstances under which funds received under IDEA Part B grants, including section 611 for children with disabilities ages 3 through 21 and section 619 for children with disabilities ages 3 through 5, may be used to hire for NPSS roles, such as if a person in an NPSS role who meets the relevant IDEA personnel qualification requirements is working directly with children with disabilities to provide required services in conformity with each child's individualized education program, if consistent with all statutory and regulatory requirements of the IDEA Part B program. An LEA considering using IDEA Part B funds for such purpose should also consider any impact on the LEA's maintenance of effort under IDEA.xix

Endnotes

1 As outlined in 34 CFR 675.18, colleges and universities that participate in FWS are required to use at least 7 percent of their allocation to employ students in community service jobs with at least one FWS student employed as a reading tutor for children in a reading tutoring project or performing family literacy activities. While the Department has waived the community service requirement through the 2023-2024 award year, the Department encourages colleges and universities to ramp up the use of FWS for these community service jobs now, meeting the 15 percent target outlined in this letter, by supporting high-impact NPSS roles.

2 "Braiding" funds occurs when different funding streams are used together to leverage the support provided for different needs while maintaining documentation to support the charging and allocation of costs to multiple separate funding streams or programs. Each funding stream maintains its identity and continues to be subject to the relevant statutory and regulatory requirements.

3 A state or school district could choose to hire for NPSS roles by leveraging funds from multiple programs if they keep all necessary records to support the allowability and allocability of the individuals' time under the programs, respectively, and ensure that funding is consistent with any supplement, not supplant requirements.

i Research shows that high-quality programs that place trained adults into NPSS roles can help support academic recovery, foster supportive learning environments, and improve student engagement and overall well-being (see links: tutors, mentors, post-secondary transition coaching, integrated student supports coordinators (this study is of Communities in Schools' model), student success coaches.

vi For additional information, and how Department funds may be used to meet AmeriCorps matching requirements, please see https://oese.ed.gov/files/2022/04/americorps-matching-letter.pdf.

xiv Additional information about ESEA Title VI, Part A, Subpart 1 is available at https://oese.ed.gov/offices/office-of-indian-education/indian-education-formula-grants/.

xv Additional information about Impact Aid is available at https://oese.ed.gov/offices/office-of-formula-grants/impact-aid-program/.

xvi Additional information about the McKinney-Vento Education for Homeless Children and Youth Program is available at https://oese.ed.gov/offices/office-of-formula-grants/school-support-and-accountability/education-for-homeless-children-and-youths-grants-for-state-and-local-activities/.

xix Additional information about IDEA programs is available at https://sites.ed.gov/idea/state-formula-grants/.


   
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