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Title I Comparability

The Elementary and Secondary Education Act (ESEA), as authorized by 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.” The requirement that Title I, Part A funds supplement, and not supplant, state and local funds is a longstanding provision of ESEA, intended to ensure that federal funds provide additional educational resources that students and teachers in high-poverty schools need to succeed. Consequently, if Title I schools do not receive their fair share of state and local dollars before Title I dollars are added, Title I, Part A funds do not serve their intended purpose of providing additional educational resources needed to serve disadvantaged students.  

Comparability 2016-17 Data Collection

We are approaching the time for the 2016-17 Comparability data collection.  During 2016-17, as we await the finalization of USDE regulations and develop systems to comply with ESSA, CDE will not change the comparability data collection system or process. Please see the "2016-17 Comparability Memo" sent to Title I directors for an update on the process for the 2016-17 Comparability Data collection.  Included in this memo is a preliminary list of districts that, most likely, will need to demonstrate comparability in 2016-17.  This list was compiled without benefit of enrollment numbers and could change as enrollment numbers become available and/or districts make changes to their Title I school assignments.  For example, districts with fewer than 1,000 students do not have to demonstrate comparability, nor do districts with only one school per grade span even if that school receives Title IA funds.  Title I schools with 100 or fewer students do not have to be comparable, although their data are used in overall calculations. 

A first step in this process is for each superintendent to authorize a Comparability Respondent.  Respondents from previous years are still in the system and do not need to be re-authorized.  However, if you do not already have a respondent or you need to assign a new one, complete and return the 2016-17 Comparability Respondent form linked below.  


Comparability 2016-17 Data Collection Webinar

Demonstrating comparability is a key requirement for accepting Title IA funds. Districts that accept Title IA funds must show that their Title IA schools are funded at the same level as non-Title IA schools – prior to any Title IA allocations [Section 1120A(c)]. This ensures that Title IA funding through NCLB is “supplemental,” in accordance with federal law.

Districts that have at least one Title I school (100+ students) in a grade span with two-plus schools should prepare to participate in the 2014-15 comparability data collection that opens from early November through the end of December. Districts that accept Title IA funds but do not meet these criteria (for example, have only one school in the grade span) do not need to demonstrate comparability.

In 2014-2015, districts once again will compile and report comparability data through the online system using the recommended FTE method. Districts that cannot demonstrate comparability through this FTE method may attempt federally approved alternative methods using the Alternative Comparability Calculator posted below. The reporting window will open in early November and continue through the end of December 2014. 

To access the online system, each participating district will need to have one respondent authorized by the Superintendent. If your district does not have an authorized respondent already, or your respondent has changed, complete the Respondent Information sheet below and submit it to CDE for assignment of passwords. If your currently authorized respondent plans to continue in that capacity, it is not necessary to re-submit the respondent form.

System Access


For Additional Information Contact:

Donna Morganstern
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