Maximizing the Title I Set-Aside for Homeless Students: An Actionable Guide for Practitioners, Leaders, and Advocates
This guide explains how schools, districts and advocates can make the most of Title I, Part A funds to meet legal requirements, remove barriers, and improve outcomes for students experiencing homelessness.
Real Districts. Real Strategies. See What's Working.
We’re spotlighting districts across the country that are thinking creatively about how to increase and maximize their set-aside dollars. From Houston to Nashville to rural Vermont, districts of all sizes and contexts are finding ways to make these funds work harder for students experiencing homelessness.
Why Title I Matters for Students Experiencing Homelessness
A high-quality education is the surest path to lifelong success – and a proven strategy to prevent future homelessness. Yet more than 1.5 million children and youth face unique educational barriers caused by homelessness—frequent moves, lack of stable study environments, transportation challenges, and unmet basic needs. These barriers create attendance and academic challenges that are more severe than those caused by poverty alone.
Targeted, well-funded interventions for homeless students work—boosting attendance, improving academic performance, and increasing high school graduation rates.
In order to provide the interventions that homeless students need – and that are required by law – schools must blend and braid funding from multiple sources.
Title I, Part A (Title I) of the Elementary and Secondary Education Act (ESEA) is the largest federal K–12 education program, funded at over $18 billion annually. More than 90% of local educational agencies (LEAs) are eligible to receive Title I funds.
All homeless students are Title I-eligible students – and ensuring their success is central to Title I’s mission of helping disadvantaged students meet high academic standards. Maximizing Title I, Part A is an effective strategy for addressing the unique barriers caused by homelessness and improving attendance, achievement, and graduation rates.
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This guide is organized around the questions that SchoolHouse Connection hears most often from both practitioners and advocates. It is designed for a broad audience of state and local education leaders, Title I and homeless education professionals, and education advocates.
Section I offers plain-language answers to common questions about determining and using funds effectively.
Section II highlights local success stories showing how strong partnerships and data-informed decisions can drive results.
Section III focuses on state leadership, outlining opportunities to strengthen guidance, oversight, and collaboration so every district can ensure Title I funds reach the students who need them most.
Section I: Common Questions about Title I, Part A and the Homeless Set-Aside
Understanding Title I, Part A and the Homeless Set-Aside
Understanding Title I, Part A and the Homeless Set-Aside
1. What is Title I, Part A of the Elementary and Secondary Education Act of 1965 (as amended)?
Title I, Part A (Title I) of the Elementary and Secondary Education Act (ESEA) is the largest federal K–12 education program, funded at over $18 billion annually. More than 90% of local educational agencies (LEAs) are eligible to receive Title I funds. By comparison, the McKinney-Vento Act’s Education for Homeless Children and Youth (EHCY) program is currently funded at $129 million. At this funding level, only 21% of LEAs are able to receive EHCY competitive subgrants.
Title I funds are allocated to LEAs and schools primarily based on the number and percentage of children from low-income families. LEAs and schools use these funds to help low-income children achieve proficiency on challenging academic standards and to improve the performance of low-achieving schools (20 U.S.C. § 6301).
For students experiencing homelessness, Title I, Part A is especially important because they are automatically eligible for Title I services, regardless of whether they attend a Title I school (20 U.S.C. § 6315(c)(2)(E). Funds can be used for both academic and educationally related support services (such as food, clothing, and other non-academic supports needed for school participation) to remove barriers to school enrollment, attendance, and success.
2. Are all homeless students eligible for Title I, Part A services?
Yes. Children and youth who meet the definition of homelessness in the McKinney-Vento Act (42 U.S.C. § 11434a(2)) are automatically eligible for Title I, Part A services, whether or not they are staying in a Title I school attendance area or meet the academic standards required of other students (20 U.S.C. § 6315(c)(2)(E); ED Guidance, 2018, Question M-1).
Students experiencing homelessness may be served in:
Schoolwide programs
Targeted assistance programs
Through the Title I, Part A homeless set-aside (available for students in any school in LEAs that receive Title I, Part A funds)
A student who becomes permanently housed during the school year remains eligible for Title I services for the remainder of that school year (ED Guidance, 2018, Question M-3).
Tip:
Lack of awareness about who is considered homeless contributes to under-identification of homeless students. Share SHC’s McKinney-Vento Definition of Homelessness with educators and administrators.
3. Are all LEAs (school districts) required to reserve some of their Title I, Part A funds for homeless students?
Yes. In addition to serving students experiencing homelessness under school-wide and targeted assistance programs, all LEAs that receive Title I, Part A funds must reserve a portion of those funds specifically to meet the needs of children and youth experiencing homelessness (20 U.S.C. § 6313(c)(3)(A)(i)). This is often referred to as the “homeless set-aside.”
The homeless set-aside:
Must be based on the LEA’s total Title I allocation
Is required whether all schools in an LEA are Title I schools, or there is a mix of Title I and non–Title I schools
Tip:
For more information on the reservation of funds in LEAs where all schools are Title I schools, see ED’s guidance, Question M5a.
4. Why are a portion of Title I funds set aside for students experiencing homelessness?
A high-quality education is the surest path to lifelong success – and a proven strategy to prevent future homelessness. Yet more than 1.5 million children and youth face unique educational barriers caused by homelessness—frequent moves, lack of stable study environments, transportation challenges, and unmet basic needs. These barriers create attendance and academic challenges that are more severe than those caused by poverty alone.
Targeted, well-funded interventions for homeless students work—boosting attendance, improving academic performance, and increasing high school graduation rates.
In order to provide the interventions that homeless students need – and that are required by law – LEAs must blend and braid funding from multiple sources, including the Title I, Part A homeless set-aside. Layering funding will ensure maximum resources to meet the needs of students experiencing homelessness.
5. What is the relationship between the McKinney-Vento Act’s Education for Homeless Children and Youth (EHCY) program and Title I, Part A?
The McKinney-Vento Act’s Education for Homeless Children and Youth (EHCY) program requires state and local educational agencies to remove barriers to the identification, enrollment, attendance, and success of children and youth experiencing homelessness. The McKinney-Vento Act statute and federal EHCY program guidance (Section M) include specific requirements and recommended best practices for partnership across the EHCY and Title I programs. Similarly, the Title I authorizing statute includes requirements for partnership across the EHCY and Title I programs, with specific mandates related to targeting Title I program supports to children and youth experiencing homelessness.
The McKinney-Vento Act is the blueprint for ensuring that homeless students have full access to education, so they can succeed in school and in life. The resources of the Title I, Part A homeless set-aside can help turn the promise of the McKinney-Vento Act into reality.
Determining and Adjusting the Homeless Set-Aside Amount
6. How much Title I, Part A funding are LEAs required to reserve for homeless students?
Federal law does not set a specific percentage or dollar amount for the homeless set-aside. Instead, LEAs must determine the amount “necessary” to provide comparable services to homeless children and youth, and to meet their unique needs (20 U.S.C. § 6313(c)(3)(A)(i)). The law states that the Title I Part A homeless set-aside may be based on a needs assessment that takes into consideration the number and needs of homeless children and youth in the LEA.
In general, the amount should be sufficient to provide educationally-related support services to both identified homeless students and those who may become homeless later in the year, and large enough to cover services such as food, clothing, and other non-academic supports needed for school participation and learning.
While some LEAs reserve nominal amounts for students experiencing homelessness, others reserve significant funding and reap the benefits of improved student outcomes as a result. See question 10 below for how to find out how much your LEA reserves for homeless students.
7. How do LEAs decide how much Title I, Part A funds to set aside for homeless students?
There is no single required method for calculating a Title I homeless set-aside. Some state education agencies recommend or require LEAs to use a specific formula (see our analysis of state Title I guidance here). However, in most states, the most common methods for determining Title I Part A set–aside amounts are:
Needs Assessment. A needs assessment identifies the number and needs of students experiencing homelessness in an LEA. This process may be the same as the needs assessment required for an Education for Homeless Children and Youth (EHCY) subgrant application. The benefits of using a needs assessment include:
Allocating funds based on documented student needs rather than estimates.
Incorporating data to guide decisions.
Providing a clear, transparent process for setting the amount.
Homeless Student Count × Per-Pupil Allocation. This method multiplies the LEA’s Title I per-pupil allocation by the number of children and youth experiencing homelessness identified in the most recent school year. When applying this approach, it is important to consider potential changes in the homeless student population due to shifts in the economy, housing availability, employment, natural disasters, or other local, state, or national factors.
Match or Exceed the EHCY Subgrant Amount. LEAs that receive an EHCY subgrant may set aside an amount equal to or greater than the subgrant. This approach can demonstrate a coordinated commitment between EHCY and Title I programs and may strengthen the LEA’s EHCY application.
Data-Informed Adjustment of the Previous Year’s Amount. This method begins with the previous year’s set-aside and adjusts it based on:
Past expenditures.
Planned programming for students experiencing homelessness, including continuation of effective programs and introduction of new initiatives.
Trend data such as:
Changes in the number of identified homeless students.
Academic performance and educational needs of these students.
Broader local, state, or national conditions (e.g., poverty levels, housing market changes, natural disasters).
Tip #1:
Download and use this work sheet from the National Center for Homeless Education (NCHE) to guide the conversation between the homeless education coordinator and the Title I coordinator.
Tip #2:
Get real-life examples of how LEAs determined and used their Title I Part A homeless set-aside funds.
8. Who should be involved in deciding the amount and use of the Title I, Part A homeless set-aside?
When developing their local Title I plans, LEAs are required to describe how their Title I program is coordinated with their EHCY program, and to describe the Title I services – including through the Title I Part A homeless set-aside – that will be provided to students experiencing homelessness to support their school enrollment, attendance, and success [20 U.S.C. § 6312(a)(1); 20 U.S.C. § 6312(b)(6)].
This means the school district homeless liaison should be directly involved in determining the set-aside amount and deciding how it will be used.
Other stakeholders include:
The Title I and/or federal programs director
Parents and youth who have experienced homelessness
Counselors or social workers familiar with student needs
Community-based partners who work with homeless families and youth.
Involving multiple perspectives ensures that the set-aside is responsive to both academic and non-academic needs, and that funds are integrated with other local, state, and federal resources.
Tip:
Gather both qualitative and quantitative data from stakeholders on the needs and effectiveness of services provided to students experiencing homelessness. Use this data to build awareness within business offices and federal programs offices and advocate for funds.
9. Can the amount of the Title I, Part A homeless set-aside be adjusted during the school year, including if homelessness increases unexpectedly due to natural disasters?
Yes. While the initial set-aside amount is established before the start of the school year, LEAs can and should adjust the amount if needs increase. For example, natural disasters, economic crises, or sudden housing disruptions can lead to spikes in student homelessness.
LEAs should monitor the number of identified homeless students and their needs throughout the year, and to adjust Title I budgets accordingly. Adjustments may require internal budget amendments or reallocation of unspent funds from other Title I activities.
Tip:
Establish a mid-year and end-of-year review process with the liaison and Title I Director to assess whether the set-aside remains sufficient. Having this process in place can make it easier to respond quickly to unanticipated increases in need.
Using Homeless Set-Aside Funds
10. What services can be provided to homeless students with Title I, Part A homeless set-aside funds (i.e., what are the allowable uses)?
Title I homeless set-aside funds may be used to provide services to children and youth experiencing homelessness—including those attending Title I schools—that may not ordinarily be provided to other Title I students (20 U.S.C. § 6313(c)(3)(C)(ii)). This flexibility acknowledges that students experiencing homelessness often face unique educational barriers beyond those experienced by low-income students who are safely and stably housed.
The statute and U.S. Department of Education guidance identify specific allowable uses for homeless set-aside funds, including:
Paying the salary of the local liaison, even if the liaison has no other Title I duties (20 U.S.C. § 6313(c)(3)(C)(ii)(I)); in larger LEAs, funds also may support additional staff who are carrying out liaison duties under the McKinney-Vento Act (ED, 2018, Question M-10).
Paying the excess cost of school of origin transportation, if not reimbursed by the state (20 U.S.C. § 6313(c)(3)(C)(ii)(II); ED, 2018, Question M-6a); this includes transportation for formerly homeless students for the remainder of the school year in which they become permanently housed (ED, 2018, Question M-3). This use of funds promotes school stability and recognizes that formerly homeless students may experience homelessness again, even during the same school year.
Providing educationally related support services to children in shelters and other locations where homeless students may live (20 U.S.C. § 6313(c)(3)(A)(i)).
ED’s EHCY Program Guidance, Question M-4 includes 17 additional allowable uses, including tutoring, supplemental instruction, counseling, school supplies, fees for extracurricular activities, and referrals to health and mental health services. Services must be 1) reasonable and necessary to assist students experiencing homelessness to take advantage of educational opportunities; and 2) used as a last resort when services are not reasonably available from other public or private sources.
Tip:
Get real-life examples of how LEAs use Title I Part A homeless set-aside funds to respond to student needs.
Strengthening Practice and Advocacy
11. How can I find out how much Title I, Part A funds my LEA reserves for homeless students, and how these funds are used?
There is no single public database where you can look this up—yet. Finding this number may take persistence, but it is possible, and it’s the first step toward stronger oversight and use of these funds.
Where to start locally: In most LEAs, the Title I Director or federal programs director should know how much Title I funds have been reserved for students experiencing homelessness because they must submit this information in their local Title I application to the state.
In fact, when developing their local Title I plans, federal law requires LEAs to describe how their Title I program is coordinated with their Education for Homeless Children and Youth (EHCY) program, as well as the Title I services – including through the Title I, Part A homeless set-aside – that will be provided to students experiencing homelessness to support their school enrollment, attendance, and success. [20 U.S.C. § 6312(a)(1); 20 U.S.C. § 6312(b)(6)].
The school district homeless liaison also should know this information, but unfortunately, despite strong federal law and guidance, liaisons may not always be involved in set-aside planning or have direct access to the figures.
Where to go at the state level: State education agencies are required to collect the amount of the Title I, Part A homeless set-aside for each LEA and report these data to the U.S. Department of Education (ED). While ED does not currently make these data publicly available, you can:
If the state coordinator or another SEA staff cannot provide it, submit an information request to your state education agency through the process it uses for Freedom of Information Act (FOIA) or public records requests.
Tip:
When requesting this information, be specific—ask for “the Title I, Part A homeless set-aside amount and description of uses for [district name] for [school year].” This increases your chances of getting the right data the first time.
12. How can I advocate for better use of Title I, Part A homeless set-aside funds in my LEA?
Advocating for a stronger and more strategic use of the Title I homeless set-aside starts with knowing the numbers, making the case, and building ongoing collaboration with decision-makers.
Step 1: Get the Facts
Find out how much your LEA reserved for homeless students this year and how the funds were used. See the longer answer to question 10 above for more information on how to find the set-aside amount and uses.
Gather local data on student homelessness to show trends and needs.
Impact on Student and District Success – Share how strategic use of funds can improve:
Student attendance, stability, and graduation rates;
Academic performance;
LEA-level outcomes for all students, such as increased average daily attendance (ADA) and related state funding.
Emphasize how targeted support for students experiencing homelessness can help achieve the goals of the Title I program, school, district, or state – especially if schools are in improvement status under Title I.
Step 3: Share Success Stories
Highlight the positive results of past investments—especially from ARP-HCY funds—such as improved attendance, reduced mobility, or increased graduation rates.
Use both data and short, compelling student or family stories.
Step 4: Plan Next Steps Together
Schedule a meeting to discuss:
The appropriate set-aside amount based on current needs;
How funds will be spent strategically to remove barriers and support success;
Clear processes for the liaison to access funds;
A recurring check-in to review what’s working and what needs adjustment (“continuous quality improvement”).
Encourage community partners to also share their perspectives with decision-makers—multiple voices help build momentum.
Tip:
Keep the conversation solutions-oriented. Bring data, statutory requirements, and examples of what’s working in similar districts and schools. Tie the issue of student homelessness to larger issues the LEA is trying to tackle, like chronic absence, high school graduation, or declining enrollment. Decision-makers are more likely to act when they see both the urgency and a clear plan for how the funds will be used effectively.
13. What are some tools and templates from other LEAs that I can use?
Local educational agencies use their Title I, Part A homeless set-aside funds in varied ways that respond to community needs and help homeless students thrive. These local spotlights showcase practical, replicable strategies from LEAs of different sizes and settings—urban, suburban, and rural—including those with and without McKinney-Vento EHCY subgrants.
How much Title I, Part A funding reserved: $583,500
The existing process evaluates prior-year spending, budgeted versus actual expenditures, demographic shifts (including identification numbers and the distribution of identified students), and adjusts the following year’s budget accordingly.
In APS, the McKinney-Vento team reports to theTitle I Coordinator, who reports to the Federal Programs Director. Because the homeless education team is housed under Federal Programs within the Division of Finance, it receives strong support.
The current homeless set-aside is approximately 4.5% of the district’s total Title I allocation.
Most set-aside funds cover the salaries and benefits of the four McKinney-Vento advocates and a portion of the Title I Director’s salary. These funds support the entire McKinney-Vento team. Each advocate serves 15–20 schools, including charters, providing training, technical assistance, and support to school staff at each site.
Current FY26 budget (amounts are budgeted but not spent):
$500,000 (approximate) for salaries and benefits
$50,000 for supplies to keep the resource room (built during COVID) fully stocked
$10,000 for gas vouchers for families
$10,000 for professional development and conference attendance
$5,000 for extracurricular activities, field trips, activities, and other fees
$2,000 for translation and interpretation
$2,000 for updated McKinney-Vento posters and communication materials
Use of the set-aside funds has contributed to improved attendance, though the exact data is still being reviewed.
The McKinney-Vento staff work has also strengthened school relationships. Although centrally housed, the homeless education staff are now more connected to schools, and staff have a clearer understanding of available resources.
“As a success, I consider a school year where issues don’t escalate to me because students and families are getting what they need. Over the last few years, our Title I Director has built strong systems to ensure resources are readily available. The work supported by these funds is so valued that we’ve been told they would be the last to be cut in a tight budget year.” —Joey Willett, APS Federal Programs Director
Some coordination happens naturally. For example, Title I funds support tutoring, and students identified as experiencing homelessness receive priority for those services.
The Title I Coordinator works in a specialized resource office alongside teams serving newcomer students, migrant education, and Medicaid. APS describes this set up as “blending people” rather than blending funds. Because these student populations intersect, collaboration is strong, and other teams can replicate effective McKinney-Vento systems.
APS also partners closely with the Regional Transportation Department, which allows youth ages 19 and under to ride free with a school ID. The McKinney-Vento team collaborates with transportation staff, while transportation costs are covered by the district’s general budget.
The federal programs director, who oversees Title I, II, III, Title IV and Title VI programs, continually looks for opportunities to braid or blend funds — for example, using Title II to expand access to McKinney-Vento professional development and Title IV to support after-school programs for students experiencing homelessness.
“The McKinney-Vento team doesn’t have to advocate for funds because the support is top-down. The homeless set-aside is the first budget I build. We treat the amount as flexible — since I manage the budget, I can adjust it as needed throughout the year. These funds are essential, and we rely on general funds and partner support to cover any remaining needs. Families get what they need not only through the Title I set-aside, but also through our partnerships and program support.”
– Joey Willett, APS Federal Programs Director
Thompson School District (Loveland, Colorado)
How much Title I, Part A funding reserved: Approximately $200,000
In Thompson School District, the Title I homeless set-aside is determined through a comprehensive needs assessment, which is part of the district’s broader LEA-level needs assessment. As part of this process, the Director of Federal and State Programs examines goals and outcomes from the Education for Homeless Children and Youth (EHCY) subgrant and Colorado’s Educational Stability Grant, focusing on attendance, academic progress, school stability, and sense of belonging.
To gather additional insight, the Director and his team conduct “empathy interviews,” asking three targeted questions to 100 students experiencing homelessness. For example, if district data shows attendance concerns, students are asked about how they get to school and other barriers to attendance. These responses help determine whether funds should support needs such as gas cards, mileage reimbursement, or an FTE partnership between McKinney-Vento and transportation.
“After every quantitative data point is a qualitative story. We do a lot of student interviews and engagement interviews, so we are working with this qualitative data as well.” —Jesse Tijerina, Director of Federal and State Programs
The Title I homeless set-aside currently funds a combination of 1.5 FTE, inclusive of an Educational Stability Specialist and McKinney-Vento liaison. It also covers extra hours for the district’s 30 points of contact – certified staff at each school who receive specialized training to support highly mobile students.
Set-aside funds also support youth leadership opportunities such as leadership workshops, mentoring programs, and college tours, covering costs like registration fees, field trip expenses, and staff compensation. In addition, the funds help pay for graduation needs, including caps and gowns.
The Director of Federal and State Programs prioritizes braiding funds across federal programs to build capacity. The district currently employs three educational stability specialists whose positions are supported by a combination of McKinney-Vento, Title I set-aside, and Educational Stability Grant funds (including McKinney-Vento, Migrant Education, and Foster Care).
“About 78% of Title I set-aside funds go toward staff FTE. I invest in FTE – hiring the right people for the right jobs. The rest supports capacity building. Highly mobile youth require highly mobile staff. When we have the right FTE, we can do more for students.” —Jesse Tijerina, Director of Federal and State Programs
One difficult-to-measure impact is the sustained awareness created by these investments. Every school now has a designated staff member who can support students experiencing homelessness, along with district-level staff who oversee this work across all grade spans. Funding FTE ensures consistent, knowledgeable support at every site.
Thompson School District has seen improvements across key measures, including higher student engagement in activities, reduced truancy, and increased graduation rates. Students report that these gains stem from having a trusted person to turn to when they face barriers to participation, attendance, or graduation.
Thompson School District does not rely on Title I set-aside funds for emergent needs because the McKinney-Vento program receives $20,000 annually from the district’s education foundation. These funds also provide every graduating senior experiencing homelessness with a Chromebook for college.
“The homeless set-aside doesn’t function without braided funding. Through cross-programming and braided funds, we’re able to support eight family–school–community liaisons (including one at the family resource center), a data technician, a full-time liaison, a point of contact at each school, and a 13-member High Mobility team—supported in part by the Title I set-aside.” —Jesse Tijerina, Director of Federal and State Programs
“If the grant writer is separate from implementation, the spending can become disconnected from the actual work. I benefit from being both the grant writer and the person responsible for the program—I gather the data, review it, and write the plan. When the grant writer and the McKinney-Vento program aren’t aligned, there will always be a disconnect, and funds won’t be used where they’re truly needed.”
– Jesse Tijerina, Director of Federal and State Programs
Polk County Public Schools (Bartow, Florida)
How much Title I, Part A funding reserved: $440,000
Polk County Public Schools conducts an annual comprehensive needs assessment for all federal programs, including Title I, Part A. The full needs assessment is available here.
Homeless Liaison Ben Ruch and his team analyze data from the Florida Department of Education and their student database.
Staff Capacity: Polk County uses Title I, Part A homeless set-aside funds to increase staff capacity, funding five positions: the homeless liaison, three advocates, and one staff member supporting high school unaccompanied homeless youth. The advocates cover 50-60 schools each within their regions. Ben explains, “Without staff, we couldn’t provide the services or supplies funded by Title IX. Our federal programs team supports us and advocates for the staff we need.”
Tutoring: The district also contracts a third-party agency for tutoring services. When McKinney-Vento staff identify a need, they submit a tutoring request, and the agency arranges sessions at locations like public libraries or remotely, with devices provided if necessary. Transportation support is also available from the LEA to help students access tutoring.
Polk County has increased their identification of students experiencing homelessness in recent years, currently serving over 5,000, as a direct result of the additional staff positions funded by the Title I Part A homeless set-aside.
Additionally, the tutoring initiatives have contributed to an increase in the promotion rate of students experiencing homelessness from one grade to the next. In fact, most students that receive multiple sessions of tutoring are promoted each year and pre & post tests show improved scores.
Polk County uses McKinney-Vento Education for Homeless Children and Youth (EHCY) subgrant funds and donations to meet additional needs of students.
“I build reports to track trends, reviewing data biweekly, monthly, and yearly. This data guides our budget and grant proposals, including how we deploy Title I, Part A homeless set-aside funds. Beyond the basic supplies we cover with Title IX (EHCY) funds, we use those set-aside dollars for school readiness, ensuring that anyone who needs services can access them.”
– Ben Ruch, Homeless Liaison
Bullitt County Schools (Shepherdsville, Kentucky)
How much Title I, Part A funding reserved: $15,000
The LEA used a needs assessment from Kentucky’s application for the McKinney-Vento Education for Homeless Children and Youth (EHCY) program to determine how much Title I funds to set-aside for homeless students. Kentucky also provides a Monitoring Form that LEAs may use to plan for use of funds.
Title I Part A homeless set-aside funds are used to support a part-time teacher for tutoring, credit recovery, and FAFSA completion. Of the total salary, 24% was funded by the Title I set-aside, 50% is funded by general funds, and the rest is paid by a Metro United Way grant.
Use of the Title I Part A homeless set-aside funds for a part-time McKinney-Vento teacher has increased student attendance by providing personalized, targeted interventions including phone calls, texts, and home visits.
Additionally, the LEA notes that student use of services has increased, including assistance with transportation, basic needs, mental and physical health referrals. This is also likely due to a singular, dedicated staff member to serve as the “face” of the McKinney-Vento program.
Communication with unaccompanied homeless youth and parents in particular has improved.
State and local funds pay for the remaining 50% of the teacher-mentor position.
The homeless liaison’s data-driven advocacy has helped secure donations and grants from community organizations to supplement Title I funding.
“Title I Set Aside funds are vital to our work in Bullitt County. They help us meet urgent needs and keep students experiencing homelessness connected to school and support. I advocate for these funds because they directly advance equity and uphold the goals of the McKinney-Vento Act.”
– Tiffany Reynolds, MSSW, CSSW
Cabarrus County Schools (Concord, North Carolina)
How much Title I, Part A funding reserved: $120,000
For the 2024-2025 school year, Cabarrus County initially allocated $90,000 in Title I, Part A funds, matching its McKinney-Vento subgrant allocation.
For the 2025-2026 school year, the set-aside will increase to $120,000 due to an evaluation of program funds and uses by the Title I Director.
Tutoring: Two tutors at three elementary schools, working approximately 20 hours/week.
General support: All McKinney-Vento students will receive regular check-ins, school supplies, internet access support, and other resources.
Liaison salary: Notably, in 2025–26, the liaison’s salary will be fully covered by the McKinney-Vento subgrant, allowing the Title I funds to expand tutoring services at the two middle schools with the greatest need. (The cost of the liaison’s salary was previously split between McKinney-Vento subgrant funds and the Title I, Part A set aside.)
Community-based partnerships: Title I, Part A set-aside funds are used to support on-site tutoring at a local housing partner’s dedicated tutoring room, and help cover the cost of its two-week summer camp for students in the program.
Summer social workers: Title I, Part A funds ensure that ten additional school social workers are available during the liaison’s one-month absence over the summer. Each social worker spends two to three weeks during the summer contacting families to verify housing status. For housed families, social workers assist with enrollment in other LEAs as needed. In July, social workers follow up with families previously identified as homeless to determine continued eligibility and ensure students are prepared for the new school year.
At the elementary schools with tutoring support, administrators regularly review and share student academic data. While students may not yet be at grade level, progress is evident—especially in reading proficiency, where the impact of tutoring is most significant:
Participating students who performed below or well below grade-level performed at or above grade level by the end of the year.
Participating students also attend school more regularly, marked by a decrease in absences among elementary students experiencing homelessness from the beginning of the year to the end of the year.
Local funds are used for excess transportation costs. Therefore, no Title I, Part A homeless set-aside funds are used for transportation.
School supplies are funded through community donations.
“When American Rescue Plan funds ended, we were determined to figure out a way to provide the same services. We’ve seen a great benefit from the tutoring offered to our students, and our district really understands and sees the need to support our McKinney-Vento program. We’ve doubled the number of homeless students identified, but our funding had not increased. Before I could even advocate for more funds, our Title I Director came to me first because we are using our funds well and our proficiency and attendance data show that what we are doing is working. Homelessness doesn’t end when the school year does. Summer social workers help connect families to resources, meeting a critical need.”
– Liz Batson, McKinney-Vento Specialist
Tulsa Public Schools (Tulsa, Oklahoma)
How much Title I, Part A funding reserved: Approximately $235,000
The Title I, Part A homeless set-aside is determined annually as a percentage of the district’s total Title I allocation.
Allocation decisions are made by the district’s federal programs director based on identified needs.
The majority of the Title I homeless set-aside is used to support transportation for students experiencing homelessness. Transportation supports include yellow bus routes, SUVs, third-party transportation vendors, and public transit passes for adults accompanying elementary-aged students. Funds are also used to purchase gas cards, supported through partnerships with local gas stations that ensure cards are restricted to fuel purchases. Families receiving transportation support are required to complete a transportation expectations agreement.
A portion of the set-aside supports a part-time tutor in a transitional living program, including instructional and enrichment supplies for students in the program. The tutor provides academic support in reading, writing, and math, as well as enrichment activities such as art, music, and yoga. Tutoring services increase to full-time hours during the summer and are fully funded by the Title I homeless set-aside.
Students in transitional living programs show strong engagement and enthusiasm when provided with academic and enrichment materials. Enrichment supplies, including art and music materials, contribute positively to student well-being and participation. Formal academic or social-emotional data are limited due to the high mobility of students experiencing homelessness. Many students do not remain in the transitional living program long enough to measure sustained academic impact.
Transportation services are essential but challenging to evaluate, as student mobility often disrupts continuity. At this time, there is no clear data showing a reduction in chronic absenteeism attributable to transportation supports.
As the largest school district in the state, the district is eligible for a McKinney-Vento subgrant of approximately $100,000. The McKinney-Vento subgrant serves as the foundation of the homeless education program and funds a specialist position.
ESSER funds were used to purchase and stockpile non-expiring items such as hygiene supplies and culturally responsive hair care products.
The district collaborates with local nonprofits to provide clothing and household items not allowable under Title I funding. Nonprofit grants support access to an online “store” for items such as laundry detergent and disinfectant wipes.
Faith-based organizations have partnered with the district to support uniform needs through donation drives.
Community partnerships allow Title I and McKinney-Vento funds to remain focused on transportation and core educational supports while addressing broader student needs.
“To be honest, without the set-aside there would be no program; support would rely almost entirely on the community. The set-aside is important because it allows us to demonstrate what we are doing, which helps the community see the needs we are addressing and how they can support students and families experiencing homelessness. It also provides a platform to educate others about what homelessness truly looks like, beyond stereotypes, and frees me to be more engaged in the community.”
– Twanna Johnson, McKinney-Vento Coordinator
Metropolitan Nashville Public Schools (Nashville, Tennessee)
How much Title I, Part A funding reserved: $630,000
Prior to ARP-HCY funding, the Title I, Part A homeless set-aside was less than half of its current level and generally aligned with the amount of the LEA’s McKinney-Vento subgrant.
During the ARP-HCY period, the district intentionally experimented with short-term investments — particularly staffing and transportation — to understand true program costs and impact.
Rising transportation expenses, especially from third-party vendors, revealed that the district had not strategically allocated enough Title I funding.
By demonstrating the impact of ARP-HCY-funded services and clearly outlining the costs the district would have to absorb if these services were not budgeted, staff successfully advocated for an increased Title I set-aside.
The Director of Special Population Services—Foster, Homeless and Migrant, contributes to the overall LEA consolidated application process, which allows for advocating for student needs.
The majority of MNPS’ Title I, Part A homeless set-aside covers the cost of excess transportation for students experiencing homelessness, including mileage reimbursement, buses, contracted vendors, and district-operated car services.
The homeless set-aside also funds four key staff positions, which provide program infrastructure and a focus on resources. The staff positions include:
One community partnerships coordinator
Two outreach specialists
One program assistant
Using Title I, Part A homeless set-aside funds for transportation has allowed the district to absorb increasing transportation costs without reducing services, particularly as third-party vendor expenses rose. This use of funds has enabled the transition from vendor-heavy transportation models to a hybrid approach that includes district-run car services, which external evaluators found to be associated with improved student attendance.
Data and evaluations demonstrated that ARP-HCY-funded staffing positions were impactful, helping justify their continuation through Title I funds.
The addition of a dedicated community partnerships role led to the elimination of approximately $150,000 previously budgeted in the set-aside for clothing and school supplies. These needs are now covered entirely through donations because of this specific staff position.
Ten years ago, the Director of Special Population Services and the HERO (Homeless Education Resource Office) team created an independent, volunteer-run 501(c)(3) nonprofit to help meet needs that are not covered by federal funds, including clothing, school supplies, sports participation, and college transition support.
The nonprofit secures resources and grants from community partners such as United Way and Vanderbilt University. Donations are provided to the nonprofit from local churches, national organizations like Soles4Souls, as well as local NFL players. Recently one NFL player donated $12,000 to be used toward sports equity, allowing students to get sports physicals and other needed supplies for participation. The Director of Special Population Services and the HERO team are able to use all donated funds to directly support the tangible needs of students in MNPS.
MNPS also receives approximately $430,000 in McKinney-Vento subgrant funds.
“If I hadn’t had the time and money to experiment with expanding staff under ARP-HCY, I never would have been able to continue the positions with Title I, Part A homeless set-aside funds. We were able to leverage short-term funding to leverage an increase in the set-aside because our data shows that these positions were impactful. Showing the impact was the best way to get the district to hone in on making the set-aside enough to support the cost of the program.”
– Catherine Knowles
Director of Special Population Services—Foster, Homeless and Migrant
Spring Independent School District (Houston, Texas)
How much Title I, Part A funding reserved: Nearly $500,000 for the 2025-2026 school year
$400,000 for transportation
$70,000 for uniforms and school supplies
$5,000 for professional development
Students Identified as Homeless: Approximately 332
Spring ISD determines its Title I set-aside by reviewing prior year reservation amounts as well as a needs assessment conducted by the district’s federal programs team. Rising transportation costs — driven by bus driver shortages and increased reliance on private transportation — were a key factor in increasing the allocation from the 24-25 school year to the 25-26 school year. Strong collaboration between the Family and Community Engagement (FACE) team (where the homeless education program is located), the federal compliance director, and district leadership has helped ensure the set-aside reflects actual student needs. Spring ISD allocates well above the minimum 1% required under ESSA for family engagement, signaling district leadership’s commitment to support students experiencing homelessness. As Executive Director of FACE, Tranita Carroll stated, “we really do go above and beyond the minimum set aside amount required in ESSA, which speaks to the value our superintendent places on supporting and engaging families experiencing homelessness.”
Spring ISD’s Title I set-aside fully funds its homeless education program, including two program staff, and prioritizes both immediate needs and long-term academic success:
Transportation: The largest investment, ensuring students experiencing homelessness can attend school consistently, even when private transportation is required.
Staffing: A 100% Title I-funded Homeless Services Coordinator position housed within the FACE department, strengthening trust, coordination, and early intervention for students. “My phone never stops ringing.” explained Marcus Jones, the Coordinator of Homeless, Foster, and Military-Connected Programs. “Parents know I’ll answer and give them what they need. In one year we’ve developed that trust from our families.”
Basic Needs Supports: Uniforms, school supplies, hygiene items, and household goods distributed for free through a biweekly “storefront”where families can walk the aisles and shop, just like any other store.
Food Access: A partnership with the Houston Food Bank provides families with regular access to fresh and shelf-stable food.
Family Engagement and Literacy: Targeted outreach, including special individualized invitations to district events, parent orientation sessions, and an annual literacy initiative distributing 35,000 new books to help families build home libraries.
Professional Development: Expanded training for all district staff on McKinney-Vento implementation and best practices, made possible with the staff time that is covered by the set aside.
Spring ISD has seen measurable improvements as a result of its targeted use of Title I set-aside funds. By addressing transportation and basic needs, the district has increased student attendance and engagement, while reducing behavioral challenges linked to instability. Academic monitoring and early intervention by the Homeless Services Coordinator have strengthened coordination among counselors, principals, and family engagement staff.
These efforts contributed to Spring ISD’s improvement in Results-Driven Accountability (RDA) outcomes, allowing the district to exit a prior RDA determination. In addition, expanded McKinney-Vento training for school-based staff has improved identification and service delivery across the district. Growing trust with families — reflected in consistent communication and participation — has further reinforced the effectiveness of the district’s Title I investments.
Lastly, Spring ISD’s efforts to increase services through the Title I Set Aside have captured the attention of neighboring LEAs. Spring ISD staff have hosted shadowing days and fielded questions from other districts about their FACE model.
“They really have done a great job of using the Title I set aside to increase identification and properly support students experiencing homelessness.”
– Twiana Collier
Education Specialist, Texas Region 4
North Country Supervisory Union (Newport, Vermont)
How much Title I, Part A funding reserved: $10,800
In the North Country Supervisory Union (NCSU), the number of students identified as experiencing homelessness under the McKinney-Vento Act has remained stable over the past three years. Due to ongoing state funding uncertainty, the Title I, Part A homeless set-aside remains unchanged from last year, calculated by estimating about 100 identified students at approximately $100 per student.
NCSU maintains a three-year professional development plan across the LEA, and the McKinney-Vento program prioritizes professional development as the key factor in improving student identification. About 46% ($5,000) of the Title I, Part A homeless set-aside funds support the homeless liaison and one additional staff member in attending a national conference. This training equips the McKinney-Vento Liaison and Community Schools Coordinator with new strategies to train all NCSU staff on the educational impacts of homelessness.
Approximately 46% ($5,000) of set-aside funds support transportation. In this rural region with limited resources, transportation is essential for educational stability. Funds cover LEA driver wages and gas vouchers for families.
The remaining 7% ($700) of the set-aside provides basic needs — such as eyeglasses, retainers or other dental work, and school supplies — since other funding sources are no longer available.
The McKinney-Vento liaison reports that both receiving and delivering professional development have had the greatest impact on identifying students over the past three years. Transportation funding has also significantly improved students’ attendance, stability, and participation.
The liaison described how Title I set-aside funds enabled a student experiencing homelessness to participate in theater by providing gas vouchers that accommodated late rehearsal times. “It made all the difference for this student, who is doubled up and really wanted to participate. Without the vouchers, they would not have had a way to stay after school.”
The liaison also noted that the set-aside funded mileage reimbursement for staff transporting a student who lived an hour away, serving as a bridge until a driver could be hired with the set-aside. This support ensured the student’s experience remained seamless and that transportation barriers did not affect attendance.
The liaison leverages multiple funding sources to strengthen McKinney-Vento supports. Working closely with the afterschool coordinator, she secured new state afterschool funds generated through cannabis legalization — part of a $10 million annual statewide allocation. This funding allowed NCSU to create a five-week evening STEAM series for middle schoolers and their families, offering hands-on activities and shared meals.
A congressional earmark funds the kitchen, laundry, food pantry, and living-room space used by families experiencing homelessness and by middle school groups. This earmark also covers half of the liaison’s salary.
In addition, a state grant supports a paraeducator-level staff member who works on attendance three days a week.
Community organizations and youth-focused partners provide further donations and designated funds, rounding out the financial support for the McKinney-Vento program.
“Professional development is the most important thing we can invest in. To truly serve students experiencing homelessness, we have to shift belief systems — helping educators see students differently, understand their potential, and make learning accessible to everyone. The Title I homeless set-aside makes this possible. It gives us rare opportunities for high-quality training and networking, which shapes how we identify and support students. As educators take on more social service responsibilities, these PD opportunities help staff embrace their roles, learn effective and respectful ways to illustrate student circumstances, and build the skills needed to support students’ basic needs and learning without causing harm.”
– Samantha Stevens
McKinney-Vento Liaison and Community Schools Coordinator
Wood County Schools (Parkersburg, West Virginia)
How much Title I, Part A funding reserved: $92,024.63 for FY25-26
In Wood County Schools, the Title I, Part A homeless set-aside is determined through a multi-step process, not by a flat minimum or automatic grant match, to ensure funds are targeted where they are most needed and used effectively. This layered approach ensures allocations address current needs, build on past successes, and avoid duplicating existing community support. This process includes:
Needs Assessment: Each year, Wood County Schools reviews school-level needs assessments—including academic data, demographics, and input from staff and families—to identify priorities and guide funding decisions.
Reflection on Prior Purchases: The LEA reviews prior year purchases to evaluate their impact and determine whether to continue, adjust, or discontinue those expenditures.
Community Resources: Before allocating federal funds, Wood County Schools identifies existing supports from community partners, local organizations, and district initiatives. This ensures Title funds remain supplemental and fill unmet needs.
Community Partnerships: Wood County’s strong community support for vulnerable students has allowed the LEA to use federal funds for roles that enhance these efforts—such as the McKinney-Vento Liaison, who effectively connects families to vital resources and services.
Liaison salary: Tammy’s salary, funded by Title I, Part A homeless set-aside funds, enables her to connect with community partners who provide basic needs items.
Basic needs supplies: For what partners can’t supply, Tammy uses set-aside funds to purchase essentials, ensuring students don’t wait to have their needs met before attending school.
Academic support: She also partnered with the local shelter, Children’s Home Society, to support students academically. Title I set-aside funds purchased computers and workspaces at the shelter and fund evening one-on-one online tutoring in specific subjects.
Talking with other liaisons has helped Tammy use Title I, Part A homeless set-aside funds more creatively. She shares, “I don’t think I’ve had a senior who hasn’t graduated. Success comes from students knowing where and how to access resources. Meeting basic needs removes barriers to attendance, and providing shelter students with computers helps them keep up and succeed in class.”
“I try to piggyback on how Title I funds are being used and make sure that my budget has everything I think I’ll need. I can always make budget adjustments, but this way I have what I need when I can’t use funds from other places. I try to be creative in meeting student needs.”
– Tammy Jones, McKinney-Vento Liaison
Eau Claire Area School District (Eau Claire, Wisconsin)
How much Title I, Part A funding reserved: $70,000
The Title I, Part A homeless set-aside is not based on a formula, percentage, or per-pupil amount. Instead, the business office, in collaboration with the liaison, determines the amount based on actual spending needs.
Recently, the Eau Claire Area School District (ECASD) was monitored by the Wisconsin Department of Public Instruction and found not to be providing services to homeless students in non-Title I schools. In response, ECASD administration developed a plan to use set-aside funds to address the issue.
The set-aside amount hasn’t changed recently, so ECASD will need to consider potential increases in the future. “We need to plan for the possibility of not receiving future Education for Homeless Children and Youth (EHCY) subgrants and how to increase our Title I set-aside,” said Dani Graham, ECASD Homeless Liaison.
Academic, Social, and Emotional Mentor: Approximately $55,000 in Title I, Part A homeless set-aside funds (79% of the LEAs overall Title I Part A homeless set-aside) supports a full-time, permanent Academic, Social, and Emotional Mentor who provides “Title-like services” to McKinney-Vento students in non-Title I schools. Support includes check-ins, resource referrals, postsecondary planning, and connecting students to extracurricular activities for approximately 80 students across the LEA. The Mentor also collaborates closely with the ECASD Graduation Coach, funded by the Education for Homeless Children and Youth (EHCY) subgrant. Counselors and social workers at non-Title I schools receive a list of identified students from Dani Graham and determine which students the mentor will serve, typically prioritizing those with greater social-emotional needs.
Transportation: Approximately $15,000 in Title I, Part A homeless set-aside funds covers additional transportation needs, including city bus passes, gas cards, and taxi services.
Graduation rates have risen significantly. In the 2022-23 school year, the homeless student graduation rate was 43%. The following year, collaboration between the Title I-funded mentor and graduation coach helped increase the homeless student graduation rate to 76%. ECASD expects to soon exceed their goal of 80%.
Although data are not yet available, attendance has improved due to the mentor position. The mentor offers students a trusted connection and access to different transportation support, reinforcing the importance of showing up to school.
One of the greatest impacts of the mentor position is building strong connections with students. As trust grows, students experiencing homelessness often refer their peers to the mentor, leading to increased identification, support, and outcomes.
ECASD receives an EHCY subgrant that funds the graduation coach position, who supports 12th-grade students experiencing homelessness. While the coach and Mentor have separate caseloads, they work closely together.
“I could use our set-aside funds for school supplies, but we receive many donations, so we focus the funds on other needs. The mentor connects directly with students in schools, which has made a huge difference—something I don’t have the capacity to do as the liaison. We look for someone exceptional for the mentor role, ideally with lived experience or real-world perspective. People skills are key; the rest can be taught. Our goal is to support kids and families by building relationships, meeting them where they are, and earning their trust.”
– Dani Graham, McKinney-Vento Liaison
Section III – Guiding the Way: Opportunities for States to Strengthen Title I Support for Homeless Students
States play an essential—yet often overlooked—role in shaping how Title I, Part A homeless set-aside funds are reserved and used to support children and youth experiencing homelessness. As the bridge between federal requirements and local implementation, State Education Agencies (SEAs) set the tone for transparency, consistency, and strategic use of these funds across school districts.
This brief, designed to accompany SchoolHouse Connection’s Actionable Guide for Maximizing the Title I, Part A Set-Aside for Homeless Students, spotlights how state-level leadership can catalyze effective, strategic, and impactful support for homeless students. By examining state practices and identifying opportunities to strengthen SEA guidance, this resource aims to help states, school districts, and advocates work together to fulfill the promise of Title I: ensuring that every student has the support needed to succeed in school and beyond. (For a detailed breakdown of individual state guidance documents, see Appendix A.)
Findings from an Analysis of State Guidance, Federal Monitoring, and Practitioner Feedback
The Critical Role of States
Despite federal law mandating that every Local Educational Agency (LEA) receiving Title I Part A funds must reserve a portion specifically for homeless students – and despite existing federal guidance – the path for determining, monitoring, and spending those funds often depends on the guidance and oversight provided at the state level.
A dramatic variation in per-pupil Title I, Part A set-aside amounts for homeless students—even within a single state—underscores the urgent need for stronger state leadership and guidance. For example, our analysis found that in one Midwestern state, set-aside allocations for homeless students ranged from as little as $0.28 to as high as $10,140 per student, while a Northeastern state saw per-pupil amounts from $0.61 to over $2,300. This wide and unpredictable variation reveals that, left without robust state benchmarks and tools, LEAs may set aside inadequate amounts, risking underfunding of critical supports or inefficiently using resources.
Beyond the dramatic variation in per-pupil set-aside amounts, federal monitoring findings and practitioners’ insights reinforce the critical need for a more active and hands-on state role in Title I, Part A homeless set-aside practices.
Evidence from Federal Monitoring Reports
Inconsistent Practice and Compliance: Federal monitoring reports from the U.S. Department of Education repeatedly document inconsistencies in how LEAs set aside and use funds for homeless students, as well as gaps in liaison awareness and local compliance with requirements.
Need for Improved State Oversight: The federal monitoring reports advise states to implement clear processes for reviewing LEA set-aside amounts, determining sufficiency, coordinating other funding sources, and strengthening written policies to support improved guidance and monitoring—roles only states can effectively fulfill.
Practitioner Insights
Demand for Clearer Guidance: Feedback from hundreds of LEA staff and homeless liaisons responding to SHC’s annual liaison survey and participating in webinars highlights confusion and uncertainty about how much to reserve and what expenditures are allowable, with many participants explicitly requesting more detailed state templates, benchmarks, and model tools for decision-making.
Key Findings and State Spotlights
Few States Provide Guidance on Set-Aside Amounts
Only 30% of State Education Agencies (SEAs) provide guidance to Local Educational Agencies (LEAs) on determining Title I, Part A set-aside amounts, leaving most LEAs without clear direction on how much to reserve for homeless students. Moreover, a mere 6% of SEAs require a minimum homeless set-aside amount, and only a handful (3 out of 50) specify benchmarks, resulting in wide variation in per-pupil allocations within and between states.
State Spotlights
Virginia’s Project HOPE hosts a Title I Range Analysis Tool that lets LEAs compare different calculation methods by student numbers. This promotes transparency and consistency.
Vermont requires a $500 minimum and requires justification if the per-pupil amount appears low.
Gaps in State Guidance on Allowable Uses of Funds
Less than half of SEAs provide guidance on allowable uses of Title I set-aside funds, leading many LEAs to uncertainty and under-utilization of available resources for homeless students.
Federal law 20 U.S.C. § 6313(c)(3)(A)(i) allows funds to be used for services that other Title I students may not receive, including transportation and defraying the position of the school district McKinney-Vento liaison. Federal guidance provides even more specificity and examples, including food, extended learning, exam fees, and supplies. Yet over half of SHC’s survey respondents said clarity on this issue from states would improve their use of funds.
State Spotlight
New York offers a one-page guide explaining the purpose of the set-aside and listing eligible uses, giving LEAs quick and practical direction.
Few States Make Monitoring Guidance Widely Available
Only 4% of SEAs make their Title I, Part A homeless set-aside monitoring guidance publicly available. In many states, these materials are shared only with McKinney-Vento liaisons through private communications. This limited access is a missed opportunity because effective use of set-aside funds requires the involvement of multiple district staff, such as Title I directors and finance officers – not just liaisons. Moreover, homeless liaisons often lack the authority to determine the amount reserved or how funds are spent.
The absence of transparent guidance contributes to uneven practices across districts and recurring compliance issues flagged in federal monitoring reviews. The U.S. Department of Education has repeatedly recommended that states:
Establish clear processes to review LEA set-aside amounts and assess their adequacy;
Align McKinney-Vento subgrants and Title I set-asides so the two funding streams complement each other and expand available services; and
Strengthen written policies and monitoring procedures to ensure consistency and accountability.
State Spotlight
Arkansas provides an example of strong practice: its Office of Public School Accountability publicly and explicitly outlines the criteria it uses during monitoring. This transparency reduces confusion for districts and improves readiness for both state and federal oversight.
Recommendations
The recommendations below collectively call for state leadership rooted in transparency, clear expectations, meaningful oversight, and respect for practitioner expertise—so that every homeless student, in every school district, receives the support Title I promises.
1. Increase Transparency of LEA Title I Part A Homeless Set-Aside Amounts
The absence of public reporting means LEAs cannot benchmark their practices against similar districts, contributing to funding disparities and missed learning opportunities. Moreover, without publicly available LEA set-aside amounts, local homeless service providers and other stakeholders have limited information to inform needs assessments.
By annually publishing LEA Title I, Part A homeless set-aside amounts on the SEA website, both LEA and community stakeholders can help identify patterns of underspending and inform continuous improvement. This transparency addresses longstanding calls from district homeless liaisons and program coordinators for clearer, more accessible data, so educators can compare practices and discern adequacy for the communities they serve.
ED collects LEA Title I Part A homeless set aside amounts from SEAs as part of the annual federal data collection. This data should be made public on eddataexpres.ed.gov along with other federal homeless education data.
In 2025, Illinois enacted a bipartisan bill, HB 3377, that requires school districts to report the amount of Title I Part A funding reserved for students experiencing homelessness, how such funds were spent, and other information. See Fact sheet and Press Release.
2. Publish State-Specific Guidance and Tools
Local school districts often have more “buy-in” when guidance comes from a state education agency, and features positive examples or tools from LEAs of comparable size within the same state.
States can supplement federal guidance by providing clear, actionable state guidance that reflects state priorities and is tailored to LEA needs —including sample needs assessments, local calculation templates, and clearly defined minimums where possible. Providing these resources responds directly to feedback from practitioners who voiced confusion and frustration in multiple surveys and webinars, eager for tools that enable strategic planning.
SEAs also can issue specific memos or guidance for LEAs that do not receive McKinney-Vento EHCYy subgrants, outlining how these districts can support students experiencing homelessness through Title I, Part A set-asides. This ensures all LEAs, not just subgrantees, understand their responsibilities and options.
Cross-publication of Title I and McKinney-Vento guidance (on both program’s SEA web pages, in coordinated memos, etc.) is critical for holistic service delivery and clarity. Without this alignment, Title I district staff—many of whom lack familiarity with the nuances of the McKinney-Vento Act— may struggle to find information and integrate supports.
3. Monitor for Quality, in Addition to Compliance
SEAs can incorporate a robust review of set-aside practices into state monitoring protocols, making expectations explicit for amount reserved, allowable uses, and documentation of other funding sources. By clarifying what state reviewers look for—and training on strategic spending—states can reduce anxiety for both SEA and LEA staff, foster compliance, strengthen readiness for federal monitoring, and ensure funds reach students who need them most.
ED currently includes Title I Part A homeless set-aside monitoring as part of its monitoring of the McKinney-Vento EHCY program. However, state homeless education coordinators often do not have decision-making authority for the Title I program in their agencies, and may have limited ability to influence Title I policy and practice. ED should ensure that any findings related to the Title I Part A homeless seatside are also reflected in Title I Part A monitoring findings.
4. Center Practitioner Voices and Experience
Fiscal decisions about set-aside amounts are often made by Title I or finance staff rather than those most familiar with homeless student needs, limiting the impact of set-aside funds. For example, SHC’s 2024 Homeless Liaison Education Survey found that McKinney-Vento liaisons are more often involved in decisions about how to spend Title I set-aside funds (50.74%) rather than in determining how much to set aside (40.93%), despite their deep knowledge of student needs.
States can use input from school district homeless liaisons, federal program directors, families, youth, and service partners to continuously refine their approach. Making them visible partners in policy strengthens practice on the ground.
Video Playlist of Title I Webinars
Be sure to click this icon in the upper-right corner of the video player for the full library!
Find more information and download the slides on each Title I webinar page.
This analysis draws on a combination of federal, state, and practitioner-focused sources to identify patterns and gaps in state guidance for Title I, Part A homeless set-aside funds.
Federal Monitoring Reports: Reviewed 2023–2024 U.S. Department of Education (ED) monitoring reports covering the Education for Homeless Children and Youth (EHCY) Program, ARP-HCY, and Title I, Part A homeless reservation requirements to identify recurring findings and federal recommendations.
State-Level Guidance: Analyzed publicly available guidance documents and policies from State Education Agency (SEA) websites and direct SEA contacts, focusing on instructions for LEAs regarding determining and monitoring set-aside amounts, allowable uses, and oversight practices.
Practitioner Input: Incorporated insights from the 2024 SchoolHouse Connection Homeless Liaison Education Survey, which included responses from over 400 liaisons and LEA staff nationwide, as well as discussions and feedback from a national webinar involving participants from all 50 states.
State Spotlights: Highlighted exemplary state practices by selecting representative guidance and tools from states such as Virginia, Colorado, Vermont, New York, and Arkansas, demonstrating the diversity and impact of SEA leadership.
Appendix A: Title I, Part A Set-Aside for Homeless Students SEA Guidance
State
Title I, Part A Set-Aside for Homeless Students Basic Guidance
Title I, Part A Set-Aside Allowable Uses
Title I, Part A Set-Aside Guidance on Determining Set-Aside Amounts
Title I, Part A Set-Aside Publicly Available Monitoring Guidance
