| TO: | Federal-Programs Coordinators & District Procurement Teams |
| FROM: | KidsCode Gift (Mokawill LLC) |
| RE: | Alignment of KidsCode Gift programming with ESSA Title IV-A (SSAE) allowable uses |
| DATE: | August 31, 2026 |
1. What is Title IV-A (SSAE)?
Title IV, Part A of the Every Student Succeeds Act (ESSA) provides states with Student Support and Academic Enrichment (SSAE) grants. These funds are awarded to State Educational Agencies (SEAs), which sub-grant them to Local Educational Agencies (LEAs) — public school districts — in proportion to their prior-year Title I share. The purpose of Title IV-A is to improve students' academic achievement by increasing the capacity of LEAs to provide all students with access to a well-rounded education, improve school conditions for student learning, and improve the use of technology to improve academic outcomes.
Title IV-A funds are organized into three broad content areas, defined under ESSA §4104(b)(3):
- Well-rounded educational opportunities (§4104(b)(3)(A)(i)) — including STEM and computer science
- Safe and healthy students (§4104(b)(3)(A)(ii)) — including digital citizenship and online safety
- Effective use of technology (§4104(b)(3)(A)(iii)) — supported by ESSA §4109
2. How KidsCode Gift Qualifies
KidsCode Gift is a supplemental computer science and AI-literacy enrichment program for students ages 7–16. The program aligns with two of the three Title IV-A content areas:
2a. Well-Rounded Education — §4104(b)(3)(A)(i)
Computer science is explicitly named as an allowable use under the well-rounded education content area. KidsCode Gift delivers a structured CS curriculum mapped to the CSTA K-12 Computer Science Standards (2017) across Levels 1B, 2, and 3A. Students build real projects in HTML, CSS, JavaScript, Python, and AI application development — producing a digital portfolio of functional websites, games, and apps.
- STEM / computer science enrichment — explicitly allowable
- CSTA-mapped curriculum with a published standards crosswalk
- Hands-on project-based learning producing tangible student outcomes
2b. Safe & Healthy Students — §4104(b)(3)(A)(ii)
The safe-and-healthy-students content area supports programs that promote a healthy, safe, and supportive learning environment. KidsCode Gift contributes to this area through embedded digital citizenship and online safety instruction:
- Digital citizenship woven into every course — responsible online behavior
- Online safety instruction — password security, data privacy, safe publishing
- AI ethics curriculum — bias, transparency, privacy, and responsible AI use
3. Evidence of Alignment
CSTA-Mapped CS Curriculum
A published standards crosswalk maps each course module to specific CSTA K-12 standard identifiers across Algorithms & Programming, Data & Analysis, Impacts of Computing, and more.
COPPA-Compliant Practices
The platform is designed for students under 13 and operates in compliance with COPPA. No student data is shared with third parties for commercial or marketing purposes. Parental consent is collected before student accounts are activated.
Teacher Background Checks
Every teacher connected through the platform undergoes a background check before being vetted. The school contracts and supervises the teacher directly, maintaining on-site oversight of delivery.
Audit-Ready Records
Student progress data, attendance, and project outcomes are maintained throughout the program. At audit time, coordinators can demonstrate that the program delivered the supplemental CS enrichment that was justified in the grant application.
4. Supplement, Not Supplant
Federal guidance is explicit that Title IV-A funds must provide additional educational opportunities — not replace items a district would have funded otherwise. KidsCode Gift is positioned as a new enrichment offering, not a replacement for existing instruction. The program introduces computer science and AI literacy content that is not typically part of the district's baseline curriculum, satisfying the supplement-not-supplant requirement. Coordinators should confirm this positioning against their district's specific circumstances.
5. Procurement Guidance for Districts
- Step 1
Request alignment documents
Obtain the CSTA standards crosswalk and this Title IV-A memo for your file. Contact contact@kidscodegift.com.
- Step 2
Consult your federal-programs coordinator
Forward the documents to the coordinator who manages Title grants. They confirm whether your allocation can cover the purchase and whether it fits your needs-assessment priorities.
- Step 3
Needs assessment (if spending $30,000+)
Districts spending $30,000 or more on Title IV-A activities must conduct a comprehensive needs assessment. If applicable, ensure CS/STEM is identified as a priority.
- Step 4
Supplement-not-supplant analysis
Confirm with your coordinator that Title IV-A funds are supplementing — not supplanting — existing spending. Document that KidsCode Gift is a new enrichment offering.
- Step 5
Purchase justification & procurement
Write the purchase justification citing the CSTA mapping and ESSA §4104(b)(3)(A)(i) and (ii). Then run standard district procurement: RFP, quote, or sole-source justification per your threshold.
- Step 6
Implementation & audit trail
Once approved, implement the program. We maintain records of student progress, attendance, and outcomes for audit readiness.
6. Allowable Use Language for Grant Applications
The following language may be adapted for use in a district's Title IV-A grant application or purchase justification:
“The district proposes to use Title IV-A (SSAE) funds to provide supplemental computer science and AI-literacy enrichment through KidsCode Gift, a CSTA-mapped curriculum program serving students in grades 3–10. This expenditure aligns with ESSA §4104(b)(3)(A)(i) (well-rounded educational opportunities, including STEM and computer science) and §4104(b)(3)(A)(ii) (safe and healthy students, through embedded digital citizenship and online safety instruction). The program is a new enrichment offering that supplements — and does not supplant — existing district instruction. The curriculum is mapped to the CSTA K-12 Computer Science Standards (2017), and the vendor provides a standards crosswalk and alignment memo for the district file.”
Important Disclaimer
This memo is a self-prepared alignment document. It has not been reviewed or approved by the U.S. Department of Education or any state education agency. Whether any specific district can spend Title IV-A funds on this program depends on the district's state rules, allocation, needs assessment, and supplement-not-supplant analysis — all of which must be confirmed by the district's federal-programs coordinator. KidsCode Gift is not a compliance law firm; treat this memo as strategic logic to be verified by your coordinator. We never claim a school is “Title IV-A funded” — that is a determination only the district's coordinator can make.
KidsCode Gift is operated by Mokawill LLC. For questions about this memo or to request additional documentation, contact contact@kidscodegift.com. See also the CSTA K-12 Standards Crosswalk.