Changing the Rule: How the Change in the “Supplement Not Supplant” Provision Can Help Support Music Education

Title I, Part A of the Every Student Succeeds Act (ESEA) seeks to provide funding to ensure that all children have a fair, equal, and significant opportunity to obtain a high-quality education. Historically, these funds have been used to provide a host of services such as intervention specialists, tutoring, materials, and print resources to support students’ academic growth. Although the use of Title I funds varies between schools and school districts, the hurdle to broadening the use of these funds for music education is in part rooted in a provision known as “Supplement Not Supplant” (SNS). 

The SNS provision worked to ensure that Title I, Part A funds would be used as a supplemental resource; not a replacement of funding that would have otherwise come from local and state sources. In collecting feedback relating to the SNS provision and compliance process, the U.S. Department of Education (ED) found that those responsible for implementing the provision felt that it was a restrictive process. An unintended consequence of this process was that LEAs and schools did not have the flexibility to implement new spending avenues, because Title I-A funds must supplement an already existing program. 

After receiving public input on the SNS provisions, the compliance process went through a change to provide more flexibility to meet student needs. In 2019, the U.S. Department of Education created an informational document entitled “Supplement Not Supplant Under Title I, Part A of The Elementary and Secondary Act of 1965 as Amended by Every Student Succeeds Act.” The document highlights the history of the SNS provision and shift in the compliance process to what is now called “Title I neutral” funding methodology. According to the document, a Title I neutral funding methodology does not consider federal funds when LEAs are determining the allocation of state and local funds. With this funding methodology, funds provided through federal sources would therefore be supplemental. As a result of this shift, LEAs are no longer required to provide how the usage of Title I funds are supplemental, thus allowing for a broader avenue for spending opportunities, including music education.  

Although the change in compliance could allow for flexibility in spending, opponents are concerned that this could mean less oversight of federal funding at the state and local levels, which could increase inequitable spending for students. These advocates sought to have LEAs provide a basic per pupil spending formula to ensure equitable funding across a district. The Title I neutral funding formula does not require LEAs to identify a per pupil formula nor provide information regarding if additional funding are being provided for special programs such as magnet school or school with high populations of advanced learners.  

Music education advocates must be aware of potential hurdles when advocating for the use of Title I funds for music education. One of those hurdles is providing an explanation as to how funds spent on music education can support either a schoolwide or targeted assistance program that upgrades the educational environment for students. Another hurdle may be navigating the process of educating administrators and federal grant managers, as they may be operating under the older version of allowable spending opportunities.  

When music education advocates seek to advocate for Title I funds to be spent on music education, it would be helpful to align funding asks with overall schoolwide or district wide goals. Along with aligning funding asks, advocates should prepare to have multiple conversations with administrators to educate them on music education being an allowable use of federal funds. For more information on how to advocate on the local level, please see the NAfME Local Advocacy Action Plan. 

education funding and supplement not supplant
Group of musicians, playing instruments in a semi-circle with a vocalist in the center and a director at the front of the ensemble. Instruments include: trombone, saxophone, guitar, and violin. Vector illustration: Macrovector


March 15, 2022. © National Association for Music Education (