Answer: From the information that you provided, it sounds like this program would meet the criteria for a preschool under the McKinney-Vento Act, because it is run by the LEA. However, the district is not required to pay McKinney-Vento children’s tuition, because that would not be “comparable” to what is provided to other children. Certainly, waiving the tuition or using Title I or other funds to pay the tuition is strongly recommended to remove barriers to enrollment, but it is not required under the Act.
For this kind of program, the McKinney-Vento protections come into play with respect to school of origin. Thus, if a child who is enrolled in this preschool program becomes homeless, the program would become a school of origin, and, if it were in the best interest of the child to continue to attend, transportation would be required (even if not provided to other children).