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Private School Hygiene- Best Practice Reminders for CA Private Schools
While there are still several months remaining in the current school year, many administrators are already preparing for the 2026–2027 academic year. In that spirit, CAPSO offers the following general reminders to support private schools with navigating key programs and requirements.
Please note: The information below is provided for general informational purposes only and is not legal advice. Schools should consult qualified legal counsel regarding their specific circumstances.
1. E-Rate
Schools that participate in the federal E-Rate program are encouraged to structure participation so that vendors are the direct recipients of any reimbursements. Schools are reminded to avoid receiving reimbursements directly, particularly in light of the U.S. Supreme Court’s decision in Wisconsin Bell, Inc. v. United States ex rel. Heath (2025), in which the Court held that E-Rate funds are subject to the federal False Claims Act (FCA), the implication of which is that E-Rate funds may constitute federal funds.
Because the Court affirmed that E-Rate disbursements constitute federal funds for purposes of FCA liability, schools should thoughtfully review how reimbursements are processed and consult qualified counsel regarding their participation structure. Click here to learn more about that case.
2. Title Funds (IA/IIA/IIIA/IVA)
Consultation for the 2026–2027 school year typically begins in the spring. Private schools should watch for communication from their local LEA regarding the Intent to Participate process. Private schools are encouraged to consider participation in these programs, as eligible students and educators may receive equitable services under the Elementary and Secondary Education Act (ESEA), as amended by the Every Student Succeeds Act (ESSA).
If you have not received an Intent to Participate form by mid-March, you may wish to contact your LEA directly to inquire about participation.
Please remember that Title support is provided in the form of services; private schools should
not receive Title funds directly. Click here to learn more about participating in ESEA/ESSA.
3. Child Find under IDEA
Spring is often an appropriate time to coordinate with your local SELPA and/or LEA regarding students who may have suspected learning differences in preparation for the upcoming school year. Under the Individuals with Disabilities Education Act (IDEA), public school districts are responsible for locating, identifying, and evaluating students with suspected disabilities, including those enrolled in private schools. This obligation—commonly referred to as the “Child Find” process—is typically initiated by a parent, often in collaboration with the private school, through the local public school district. Students who are found eligible and receive service plans generate IDEA funds that are provided in the form of services. These services are designed to support student success within the private school setting and to address identified learning needs. Click here to learn more about the Child Find Process and navigating IDEA.
4. SB 848
CAPSO was pleased to host two webinars focused on supporting private schools in navigating the requirements of SB 848. As schools prepare for the 2026–2027 academic year, they are encouraged to review relevant policy updates, training requirements, and human resources implications associated with this student-safety-focused legislation.
CAPSO members may access the CAPSO SB 848 Guide Sheet for implementation details and timeline considerations. Click here to read the full legislative language of SB 848.
By popular demand, CAPSO will offer a repeat of our SB 848 webinar for members who were unable to attend. The webinar will be offered on April 14, 2026 at 10am.
The registration link is in the CAPSO Members E-Mailer. If you are a CAPSO member and are receiving this email, please update your information using the red box at the top of this email to be moved to the members-only E-Mailer distribution list.
Reminder: As a matter of good governance, an annual review of all school policies remains an important practice to help ensure continued alignment with applicable laws and regulations.
5. Minimum Salary Threshold for Exempt Teachers
As California private schools and systems begin to determine salaries for the 2026-2027 academic year, it is critical to remember CA Labor Code Section 515.8. This labor code section outlines specific minimum threshold salary requirements for exempt private school teachers in California private schools. To support our members with this calculation, CAPSO maintains a worksheet and consolidates the relevant district and county office salaries. Click here to access CAPSO's exempt teacher salary resources and worksheet.
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