Texas Therapy Consultants Funding GuideHouston, TX

Guidance for District Leaders

We’ve put together this guide to assist superintendents, special education directors, finance officers, and grant administrators in identifying federal and supplemental funding streams that may support the provision of related services, evaluation services, and school-based mental health supports delivered through contracted providers such as Texas Therapy Consultants (TTC).

This resource reflects allowable uses under federal statute and common district implementation practices. Final determinations regarding allowability, supplement-not-supplant compliance, and grant alignment remain the responsibility of the Local Education Agency (LEA) and its state education agency.

IDEA Part B – Related Services and Evaluation Support

Under the Individuals with Disabilities Education Act (IDEA), Part B funds are allocated to LEAs to ensure students with disabilities receive a Free Appropriate Public Education (FAPE) in the Least Restrictive Environment (LRE). “Related services,” as defined in 34 CFR §300.34, include speech-language pathology services, occupational therapy, physical therapy, psychological services, and counseling services when required to assist a child with a disability to benefit from special education.

Common Allowable Expenditures

IDEA Part B funds may support:

• Direct provision of related services specified in a student’s IEP
• Initial evaluations and re-evaluations
• Functional behavioral assessments and psychological evaluations
• Participation in ARD/IEP meetings
• Documentation and progress monitoring required for compliance
• Contracted personnel when districts are unable to staff required services

Districts experiencing workforce shortages frequently utilize IDEA funds to contract licensed providers to maintain compliance with IEP timelines and prevent compensatory service exposure.

When utilizing IDEA funds for contracted therapy services, districts typically ensure:

• Services are documented within the IEP
• Personnel meet state licensure requirements
• Time and effort documentation is maintained, as applicable
• Expenditures align with the district’s Special Education Consolidated Grant application

IDEA Early Intervening Services (EIS) and Coordinated Early Intervening Services (CEIS)

IDEA permits LEAs to allocate a portion of Part B funds toward Early Intervening Services to support students who have not yet been identified as needing special education but require additional academic or behavioral support.

Allowable uses may include:

• Behavioral consultation and intervention
• Targeted small-group supports within MTSS frameworks
• Screening and evaluation services tied to Child Find obligations

Districts implementing CEIS following significant disproportionality findings may also use funds to strengthen behavioral and intervention capacity at Tier II and Tier III levels.

Title I, Part A – Schoolwide and Targeted Assistance Contexts

Title I funds are primarily designed to improve academic outcomes for students experiencing poverty. However, under schoolwide program models (34 CFR §200.25), campuses may use Title I funds to upgrade the entire educational program when services are aligned to the campus improvement plan.

Within schoolwide campuses, allowable uses may include:

• School-based counseling supports that remove barriers to academic achievement
• Integrated student support services
• Personnel who contribute to improving academic outcomes

Districts should ensure that expenditures:

• Are reflected in the Campus Improvement Plan
• Meet supplement-not-supplant requirements
• Are tied to measurable academic or engagement outcomes

Title IV, Part A – Student Support and Academic Enrichment (SSAE)

Title IV, Part A provides flexible funding to improve student health, safety, and access to a well-rounded education.

The statute explicitly supports:

• School-based mental health services
• Counseling programs
• Safe and healthy school initiatives
• Integrated student support systems

Districts increasingly utilize Title IV funds to strengthen mental health infrastructure, particularly in response to staffing shortages or rising student behavioral needs.

When braided appropriately, Title IV funds may support contracted school psychologists, counselors, or mental health professionals serving identified student populations.

McKinney-Vento (Title IX, Part A)

Funds under the McKinney-Vento Homeless Assistance Act are designed to ensure educational stability for students experiencing homelessness.

Allowable supports may include:

• Counseling services
• Evaluation services
• Targeted academic and behavioral interventions
• Services that address barriers to school attendance and engagement

District homeless liaisons typically coordinate allowable expenditures in collaboration with finance departments.

Rural Education Achievement Program (REAP – Title V)

Rural districts participating in the Small, Rural School Achievement (SRSA) or Rural and Low-Income School (RLIS) programs may use funds flexibly across allowable Title program categories.

REAP funds are often used to:

• Supplement special education staffing
• Contract therapy services in geographically isolated districts
• Support compliance when recruitment is challenging

Title VI – Indian Education

Districts serving Native American students may access Title VI funds to provide culturally responsive educational supports. When services are aligned to approved Title VI plans, related services and counseling may be included as part of comprehensive student support models.

Braiding and Layering Federal Funds

Districts frequently braid funding streams to build sustainable service models.

A common funding structure may include:

• IDEA Part B for direct IEP-mandated therapy services
• Title IV for broader mental health supports
• Title I (schoolwide campuses) for integrated academic and behavioral services
• REAP for rural supplementation

Effective braiding requires:

• Clear documentation of funding source allocation
• Alignment to district and campus improvement plans
• Maintenance of service logs and compliance documentation
• Internal fiscal controls to prevent duplication of charges

Procurement Pathways for Contracted Related Services

District procurement processes vary; however, contracted therapy services are typically secured through one of the following mechanisms:

1. Competitive Solicitation

• Request for Proposal (RFP)
• Request for Qualifications (RFQ)
• Request for Competitive Sealed Proposals (CSP)

2. Cooperative Purchasing

Districts may purchase through approved education service centers or purchasing cooperatives when vendors are awarded contracts through compliant competitive processes.

3. Direct Professional Services Agreements

For specialized licensed services, districts may enter into professional services contracts subject to board approval and local procurement policy.

In all cases, districts generally require:

• Proof of licensure
• Background check verification
• Certificate of insurance
• W-9 and vendor registration documentation
• Documentation of compliance with state education code

Risk Mitigation and Compliance Considerations

From a governance perspective, districts often contract related service providers to:

• Maintain compliance with IEP service minutes
• Reduce exposure to state complaints and due process hearings
• Avoid compensatory education liabilities
• Stabilize services during workforce shortages

Documented staffing shortages, evaluation backlogs, and missed service minutes frequently inform funding and procurement decisions.

Disclaimer

Allowability of expenditures depends on state guidance, local grant applications, and federal compliance requirements. LEAs should consult their state education agency, special education finance specialists, and grant administrators before allocating funds.