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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. 

Comparability 2017-18 Data Collection

As in previous years, all LEAs receiving Title I, Part A funds must submit comparability data through the FTE-based online platform provided by CDE.  If the LEA does not meet comparability requirements through the online platform, the alternative excel spreadsheets may be utilized.  If, upon submission of the data, LEAs are not in compliance with the comparability requirements, CDE will support the LEA to make changes in the current school year to come into compliance. 

LEAs operating a Consolidated Schoolwide program may submit the per-pupil allocation (PPA) alternative spreadsheets in advance, rather than submitting comparability data through the online platform, due to the inability to assign teacher funding sources necessary to determine comparability through the FTE method.

LEAs must submit comparability data no later than January 31, 2018. 

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 2017-18 Comparability Respondent form.  

Comparability 2017-18 Data Collection Webinar

LEAs must submit 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.

The Office of Data, Program Evaluation and Reporting hosted webinars in December 2017 and January 2018 to review the comparability requirements and how-to use the online platform. If you missed these webinars and would like the training materials, please email Donna Morganstern at

System Access


For Additional Information Contact:

Donna Morganstern
Data, Accountability, Reporting, and Evaluation 
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Barbara Vassis 
Data, Accountability, Reporting, and Evaluation 
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