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Title I Comparability
Title I Comparability
The Elementary and Secondary Education Act (ESEA), reauthorized as the Every Student Succeeds Act (ESSA), states that the purpose of Title I, Part A is to “provide all children significant opportunity to receive a fair, equitable, and high-quality education, and to close educational achievement gaps.” Section 1118 of the ESSA requires local educational agencies (LEAs) to provide state- and locally-funded services in schools receiving support under Title I, Part A that, taken as a whole, are at least comparable to services provided in schools that do not receive support under Title I, Part A. This requirement must be met for schools in the same grade spans – elementary, middle, and high school (EMH).
Title I, Part A funds are intended to provide additional resources for low-performing students from high-poverty neighborhoods, beyond what is provided with State and local funds. The comparability requirement within the ESSA seeks to ensure that Title I, Part A funds are not used to provide services that would otherwise be paid for with State and local funds, thus undermining the supplemental nature of Title I, Part A funds. Comparability, however, focuses on educational materials and services provided with the State and local funds, as opposed to the supplement, not supplant requirement, which ensures schools receive the funds they would have received if the school had not participated in Title I, Part A.
Demonstrating Comparability
LEAs must submit a demonstration of compliance with the comparability requirements if the LEA has at least one Title I school, with at least 100 students, in a grade span that has two or more schools.
LEAs are not required to submit demonstration of compliance with the comparability requirements if they do not accept Title I, Part A funds or have:
- Less than 1000 students,
- Only one school per grade span, or
- Two or more schools in the same grade span, but any Title I school(s) has less than 100 students.
Based on stakeholder input and with approval from the Educational Data Advisory Committee (EDAC), LEAs no longer submit current year data through the online comparability platform. Currently, LEAs required to demonstrate comparability will conduct local analyses prior to or at the beginning of the school year and make any necessary adjustments as early in the school year as possible, to create the least disruption for students. The Colorado Department of Education (CDE) has provided Excel calculators that allow LEAs to conduct the analyses based on their specific Title I school configurations:
- All schools in grade-span receive Title I, Part A funds.
- Some schools in grade-span accept Title I, Part A funds and others not.
- Alternative methods: High-low enrollment and poverty bands, per-pupil allocation (PPA).
If unable to determine that the LEA will meet comparability requirements through the traditional FTE method, the LEA may be eligible to use the alternative high-low (enrollment or poverty) methods. LEAs that cannot demonstrate comparability through any of these FTE-based methods may do the PPA alternative analysis, based on state and local funds expended on educational materials and resources (beyond teacher FTE). LEAs operating consolidated schoolwide programs may go directly to the PPA worksheets due to their inability to assign teacher funding sources necessary to calculate comparability based on FTE.
Beginning with the 2019-2020 school year and each year thereafter, LEAs must conduct local analyses and maintain documentation of comparability prior to or early in the school year. CDE will run FTE-based comparability analyses toward the end of each school year for monitoring purposes. If CDE’s analyses do not confirm comparability, the LEA will be notified immediately and must submit data using one of the calculators for other methodology to demonstrate compliance by December 31st. If the LEA cannot demonstrate comparability for a given school year either through CDE’s methodology or by one of the other methods, CDE will work with LEA staff to develop and implement a corrective action plan.
Annual Requirements
CDE presumes that LEAs are meeting ESSA comparability requirements if they have provided written assurance in their annual ESEA Consolidated Application that they have established and implemented all of the following:
- LEA-wide salary schedule.
- Policy to ensure equivalence among schools in:
- Teachers, administrators, and other staff.
- Provision of curriculum materials and instructional supplies.
Statute requires that LEAs provide services that meet comparability requirements each year and maintain documentation to demonstrate compliance to the State biennially. However, statute also stipulates that LEAs must annually provide services in Title I schools that are, in fact, comparable to those in non-Title I schools.
Based on stakeholder input and with approval from the Educational Data Advisory Committee (EDAC), as of 2018-19, LEAs no longer submit current year data through the online comparability platform. LEAs required to demonstrate comparability will conduct local analyses prior to or at the beginning of the school year and make any necessary adjustments as early in the school year as possible, to create the least disruption for students. CDE will provide Excel calculators that allow LEAs to conduct the analyses based on their specific Title I school configurations:
- All schools in grade-span receive Title I, Part A funds.
- Some schools in grade-span accept Title I, Part A funds and others not.
- Alternative methods: High-low enrollment and poverty bands, per-pupil allocation (PPA).
If unable to determine that the LEA will meet comparability requirements through the traditional FTE method, the LEA may be eligible to use the alternative high-low (enrollment or poverty) methods. LEAs that cannot demonstrate comparability through any of these FTE-based methods may do the PPA alternative analysis, based on state and local funds expended on educational materials and resources (beyond teacher FTE). LEAs operating consolidated schoolwide programs may go directly to the PPA worksheets due to their inability to assign teacher funding sources necessary to calculate comparability based on FTE.
CDE staff will provide comparability training and technical assistance around conducting these analyses and addressing non-comparable situations. LEAs will be required to annually maintain documentation of comparability and be prepared to submit such documentation to CDE biennially.
CDE Monitoring
CDE conducts the calculations that underlie comparability using Student October and HR Snapshot data. HR data consisted of teacher FTE paid with state or local funds (primarily job class code 201). Any federally-funded FTE is eliminated from these analyses. All FTE referenced in these analyses refers only to that paid with state or local funds. LEAs in which not all Title I schools demonstrated comparability through FTE analyses will be notified of potential risk of not meeting comparability and must submit data using one of the calculators to demonstrate compliance by December 31st.
Comparability Calculations
Comparability calculations fall into two major categories, depending on the LEA’s Title I school configuration:
All schools in the grade-span receive Title I, Part A funds.
When all schools in a grade span receive Title I, Part A funding, each school’s student/teacher ratio is compared to the overall grade span ratio. Each school needs to be within 10% of the overall student/teacher ratio to be comparable. Schools with lower student/teacher ratios are considered to be over-served based on state/local funds, and those with higher student/teacher ratios are considered to be under-served with state/local funds. In the following example, all Title I schools are comparable because all student/teacher ratios fall within 10% (13.7 to 16.7 students per teacher) of the grade span overall.
Some schools in the grade span accept Title I, Part A funds and others do not.
When some schools in a grade span receive Title I, Part A funding and others do not, each Title I school’s student/teacher ratio is compared to the overall ratio for non-Title I schools. Title I schools should not exceed the non-Title I ratio by more than 10%. Schools with higher student/teacher ratios are considered to be underserved with state/local funds. In the following example, all Title I schools are comparable because none of their student/teacher ratios exceed the overall non-Title I ratio by more than 10%.
![This table shows the comparison of Title I schools to non-Title I schools by student to teacher ratio.](/sites/default/files/pics/fedprograms/Some%20Schools%20in%20Grade%20Span%20Accept%20TIA%20Funds%20-%20Table%203.png)
High-Low Enrollment or Poverty Alternative Method
When calculations do not demonstrate that all Title I schools are comparable based on the FTE methods above, and school data lend themselves to high-low band analyses, for example when a grade span includes very high and low enrollment schools, the U.S. Department of Education (ED) allows comparability FTE analyses to be conducted by separate enrollment bands. Consequently, an LEA with a wide range of elementary school enrollments and a high enrollment Title I school that is not comparable to the average non-Title I school, CDE will compare that high enrollment Title I school to the district’s high enrollment non-Title I schools. Similarly, if there is a wide range of poverty percentages, ED allows high poverty Title I schools to be compared to high poverty non-Title I schools.
Per-Pupil Allocation Alternative Method
LEAs with Title I schools that were not comparable, based on teacher FTE analyses and any applicable high-low band analyses, will have to move to the PPA alternative Excel spreadsheet. LEAs using the PPA alternative should be consistent by including the same categories of educational resources and materials purchased with state/local funds across schools. If teaching paraprofessional, librarian, and counselor salaries are included in one school, they should be included in all others. If curriculum material costs are included for some, they should be included for all.
The PPA alternative method requires the LEA to demonstrate that the per-pupil allocation for educational materials and resources from state/local funds for each Title I school is comparable to non-Title I schools in the grade span. When all schools in the grade span are Title I, each school’s PPA should fall between 90% and 110% of the grade span average.
In the example below, all schools operate Title I programs and the PPA for each should be $3,921 - $4,793. The allocation for School J is $4,917, which is more than 10% above the average; School J appears to be over-served with state/local funds. The LEA would need to work with their ESEA regional contact and other Federal Programs staff to justify and document why School J required disproportionally more state and local funds. If there is not just cause for over-serving School J, in this example, the LEA must make appropriate adjustments as early in the school year as possible.
Comparability and Supplement, Not Supplant (SNS)
Comparability’s focus is educational materials and resources specifically. Comparability should not be confused with SNS, which ensures that Title I schools receive the funds they would have received if they had not participated in the Title I, Part A program. While comparability and SNS requirements both examine how the LEA distributes state and local funds/resources to schools, they are separate tests that measure different aspects of the supplemental nature of Title I, Part A funds. As such, demonstration of comparability may not meet SNS demonstration requirements and vice versa. The following scenarios illustrate how LEAs may satisfy one requirement while violating the other.
Example 1: SNS is met, but Comparability is violated
The LEA is compliant with SNS because it can demonstrate it did not consider school Title I status when distributing state and local funds. However, the LEA does not satisfy comparability requirements because some Title I schools’ student/teacher ratios exceed the non-Title I school ratios by more than 10%.
Example 2: Comparability compliance is met, but SNS is violated
The LEA demonstrates comparability through student/teacher ratios. However, the LEA does not satisfy SNS requirements because additional state/local funds are provided to non-Title I schools for technology purchases but not to Title I schools; the LEA expects the latter to finance technology purchases with Title IA funds.
Resources
The Office of Data, Accountability, Reporting, and Evaluation along with the Office of Data Services, will host webinars to review the comparability requirements, discuss data entry into the HR collection, and demonstrate how to use the Alternative Calculator.
For Additional Information Contact:
Tina Negley
Program Effectiveness Supervisor
720-766-2793
negley_t@cde.state.co.us
Evita Byrd
ESEA Title I and IV Specialist
720-347-5667
byrd_e@cde.state.co.us
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