Target Population Enrollment Priority

Pursuant to President Donald J. Trump Executive Order 14191—Expanding Educational Freedom and Opportunity for Families—Dated January 29, 2025 directing Education Secretary, Linda McMahon to issue Guidance on Supporting State-based K-12 Educational Choice, by allowing states to provide funds under

ESEA Title I, Part A to LEAs for direct student services that allow parents to

exercise a meaningful choice in their child’s education is a major breakthrough

for Private Schools.

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​Section 1. Purpose. Parents want and deserve the best education for their children. But too many children do not thrive in their assigned, government-run K-12 school. According to this year's National Assessment of Educational Progress (NAEP), 70 percent of 8th graders were below proficient in reading, and 72 percent were below proficient in math. Moreover, geographically based school assignments exacerbate the cost of housing in districts with preferred schools, straining the finances of millions of American families sacrificing for their children’s futures.

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Title I of the ESEA where States and local educational agencies (LEAs) have discretion to provide greater flexibility to support parents’ choices for their child’s education, focused on schools identified for support and improvement due to low performance (i.e., comprehensive support and improvement [CSI], targeted support and improvement due to consistently underperforming subgroups [TSI], and additional targeted support and improvement [ATSI])—Schools that targeted support and improvement —Schools that struggle to prepare certain subgroups such as students with disabilities or certain racial/ethnic as required by ESEA section 1111(d).

 

ESEA Section 1111(d) requires states and local school districts to create and carry out school improvement plans for public schools identified as needing extra help. It focuses on two main types of support: Comprehensive Support and Improvement (CSI) for low-performing campuses, and Targeted Support and Improvement (TSI) for specific student groups falling behind. ¹ ² ³ ⁴ ⁵

 

Comprehensive Support and Improvement (CSI)

• Who it is for: The lowest-performing 5% of Title I schools statewide, high schools with high graduation rates below 67%, and schools with persistently low-performing student groups that fail to exit targeted status. ¹ ² ³

• What is required: Local educational agencies must partner with teachers, principals, and parents to build a plan based on strong evidence. ¹

• Key rule: Plans must find the root causes of problems, look at resource allocation, and aim to improve student outcomes within a set timeline of four years
  or less. ¹ ² ³

State and District Responsibilities

• Approval and monitoring: State education agencies must review, approve, and monitor these local improvement plans.

• Resource support: Districts must help schools use federal funds and evidence-based strategies effectively to ensure that low-performing schools show real academic growth. ¹ ²

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Title I Funds, Part A that are allocated through four statutory formulas that are based primarily on census poverty estimates and the cost of education in each state.​

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Every Student Succeeds Act (ESSA)

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On December 10, 2015, President Obama signed into law the Every Student Succeeds Act (ESSA), a reauthorization of the Elementary and Secondary Education Act of 1965 (ESEA). ESSA replaces its predecessor, the No Child Left Behind Act of 2001 (NCLB).

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 ESSA offers districts greater flexibility for using federal funds to effectively implement comprehensive, districtwide research-based initiatives that maximize student academic outcomes, particularly for those students at risk of not meeting challenging state academic assessment standards.

 

ESSA renews the U.S. Department of Education’s emphasis on comprehensive needs assessments and improvement planning. The new regulations increase the district’s responsibilities for monitoring student outcomes, coordinated use of federal funds, and for offering high-quality guidance and technical assistance to schools engaged in continuous improvement planning.

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Private Non-Profit (PNP) Schools 

Equitable Services ³

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School districts who receive federal grant funds are required to provide equitable services for eligible PNP school children, teachers, and other educational personnel. The term “equitable services” refers to the process of providing students, teachers, staff, and families at eligible PNPs fair access to federally funded education programs and services, as appropriate. Services provided by the LEA for private school participants are designed to meet their educational needs and supplement the educational services provided by the private school. Educational services or other benefits, including materials and equipment, provided under this section, shall be secular, neutral, and non-ideological. The process depends on a “timely and meaningful consultation” between ISD officials and officials of eligible PNP Schools.

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A Private Non-Profit (PNP) school may opt to participate in applicable programs if it meets the following specifications:

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• The private school holds a not-for-profit status. A home school is considered a private school if it has official nonprofit status (i.e. have a tax-exempt identification number)

• The private school submits appropriate documents to determine eligibility, as requested

• The private school and/or its students (depending upon the program of interest) are located within the geographic jurisdiction of a local educational agency (LEA) that is eligible and receives funding. If the LEA does not receive funds for a specific program, it is not possible for the PNP to receive funds for that program

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Under 34 CFR 77.1, the term “nonprofit” as applied to an agency, organization, or institution means it is owned and operated by one or more corporations or associations whose net earnings do not benefit, and cannot lawfully benefit, any private shareholder or entity.  If a church that operates a school meets the definition of nonprofit, the school does not need separate nonprofit status. (USDE Office of General Counsel).

 

Equitable services are provided to eligible Private Non-Profits Schools under the following federal ESSA Title programs:

 

• Title I, Part A: Improving Basic Programs for Educationally Disadvantaged Students

• Title II, Part A: Supporting Effective Instruction

• Title III, Part A: English Learners (EL)

• Title IV, Part A: Student Support and Academic Enrichment Grants

 

The Minority Enterprise Career Schools (MECS) Academy’s target population for priority would focus on the 72,509 (61.8%) ATSI subgroup Black or African American and Hispanic or Latino economically disadvantaged, free lunch eligible 9-12 students enrolled in seven underperforming NYC GEOG DISTRICTS #16, #17, #18, #19, #21, #22, #23—BROOKLYN public schools.

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1. Example Use Cases of the ESEA Waiver Authority, ESSA Waiver Watch

2. Elementary and Secondary Education Act of 1965, As Amended by the Every Student Succeeds Act-Accountability and State Plans, Federal Register

3. Every Student Succeeds Act (ESSA), Valley View ISD

4. School Improvement and Related Provisions: Title I, Part A of the Elementary and Secondary Education Act of 1965, U.S. Department of Education, January 2025

5. Improving Equity: Understanding State Identification Systems under ESSA, Nikole Gregg, Center for Assessment, August 15, 2019​