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Title I, Part A Comparability

Letter Head: Tom Torlakson, State Superintendent of Public Instruction, California Department of Education

January 17, 2013

Dear Select State and Federal Categorical Program Directors:


This letter is being sent to inform all local educational agencies (LEAs) of the requirement to demonstrate Title I comparability and to conduct comparability calculations annually. In accordance with the Elementary and Secondary Education Act, LEAs are required to perform the calculations every year to demonstrate that each of their Title I schools is equivalent among schools in teachers, administrators, and other staff, and equivalent among schools in the provision of curriculum materials and instructional supplies. LEAs are to document compliance with the comparability requirement to the California Department of Education (CDE) once every two years.

LEAs receiving this letter that are located in county codes 1–30 (Alameda through Orange) are required to submit an electronic 2012–13 Comparability Report to the CDE by February 18, 2013. LEAs located in county codes 31–58 (Placer through Yuba) are to complete the comparability calculation requirement and retain the documentation on site.

The School Turnaround Office (STO) has prepared instructions, samples, and calculation forms to calculate comparability. The forms are designed to provide each LEA with immediate feedback about whether or not a Title I school meets the comparability requirement. The procedures, guidelines, calculation forms and instructions, and technical assistance are posted on the CDE Title I, Part A Comparability Documents Web page at

All LEAs required to submit a comparability report must complete and transmit by e-mail the following:

  • Local Educational Agency Profile (Form A)
  • School Data (Form B)

  • List of school names used to populate these forms (2012–13 Consolidated Application and Reporting System)

  • Forms for calculating comparability, (Forms D–G, as appropriate; please see Enclosure, Comparability Form Selection Chart, for more details)

If a school is not comparable, LEAs must make immediate fiscal and/or staffing adjustments and then re-enter the data that demonstrates compliance before submitting the report to the CDE. LEAs may use other calculation methods, but they will need to design their own form to demonstrate compliance.

Verification Review

Each year the CDE will conduct random verification reviews of 2.5 percent of the LEAs to verify and validate submitted comparability data. The verification reviews will include an analysis of the following documentation:

  • Written LEA policy and procedures, including the timeline for how the LEA will meet comparability requirements
  • Verification of data used in the calculation for staff and students
  • Data supporting allowable exclusions of funds and/or staff from the calculation
  • Evidence that schools skipped for Title I funding and locally-funded charter schools have been included in the calculation
  • Evidence that data for staff and students were collected on the same date

A notification of findings for items not meeting requirements will be shared with each LEA visited. The LEA must make immediate adjustments to rectify the situation and submit revised reports with the proper supporting documentation.


LEAs that are located in county codes 1–30 (Alameda through Orange) must submit comparability calculations to the CDE by e-mail to no later than February 18, 2013. CDE will only accept those LEA reports that demonstrate all schools have met comparability requirements. The CDE will withhold the second apportionment of Title I, Part A funds for LEAs that fail to submit a report by this due date.

If you have any questions regarding this subject, please contact Lou Ann Harada, Associate Governmental Program Analyst, STO, by phone at 916-319-0299 or by e-mail at



Christine Swenson, Director
Improvement and Accountability Division

Enclosure (DOC)

cc:       Select Superintendents of Schools


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