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Title I, Part A Comparability FAQ

Frequently Asked Questions and Answers for Title I, Part A Comparability.

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Is my LEA required to submit a comparability report to CDE?

An LEA is only required to document compliance with the comparability requirement biennially, it must perform the calculations every year to demonstrate that all of its Title I schools are comparable and make adjustments if any are not.

Navigate to the LEAs Required to Comparability Calculations Web page to view which LEAs are required to conduct and submit Title I, Part A comparability calculations.

Which Comparability Forms do I need to complete?

All LEAs must complete and submit Forms A and B. Form C is for LEA internal use only. LEAs with BOTH Title I and non-Title I schools in the same grade span may complete and submit Form D or E. LEAs with ONLY Title I schools in the same grade span may complete and submit Form F or G.

Refer to the Comparability Form Selection Chart for more details.

Do LEAs need to have board-adopted policies and established procedures for meeting comparability requirements?

The CDE requires LEAs to annually provide written assurances, through the Consolidated Application and Reporting System (CARS), that comparability calculations were conducted, requirements were met, and source documents are maintained.

An LEA must have board-adopted policies and established procedures for meeting comparability requirements, which needs to be indicated on Form A - Local Educational Agency Profile of the Comparability Forms.

Refer to the Meeting Title I, Part A Comparability Requirements document for more details.

Which schools and LEAs are exempted from the comparability requirement?

An LEA that has only one school for each grade span or schools with 100 or fewer students are exempt from the Title I comparability requirements.

Do charter schools need to be included in comparability calculations?

Locally-funded charter schools must be included in the calculations of their respective grade spans. Direct-funded charter schools do not need to be included in comparability calculations.

How do I group schools by enrollment size?

When grouping schools by grade spans, an LEA must reflect the actual grade span configuration of the schools in the LEA on Form B - School Data of the Comparability Forms. When there are significant enrollment differences among schools, an LEA has the option to split a grade span by the size of the school enrollment for comparability demonstration purposes, thus comparing similarly sized schools.

An LEA may use this option within a grade span provided the school with the largest enrollment is approximately twice as great as the enrollment of the smallest school.

Refer to the Meeting Title I, Part A Comparability Requirements document for more details.

What is the definition of instructional staff?

Instructional staff is defined as those who provide either direct instructional services or instructional support to students. These computations may include classroom teachers only, or all certificated instructional personnel assigned to schools providing direct instructional services and support , such as music, art, physical education teachers, guidance counselors, speech therapists, librarians, school social workers, and psychologists.

Please note that paraprofessionals should not be included.

LEAs may make these calculations using certificated classroom teachers only or all certificated instructional staff. However, the LEA must consistently include the same staff members in the ratios for Title I schools and the non-Title I schools.

What will happen if a comparability report is not submitted or fails the comparability test?

LEAs with schools that fail the initial comparability test are given additional time to hire staff, adjust student enrollment, provide additional funding, and/or correct or provide more current data to resolve non-comparability issues. If needed, the District Innovation and Improvement Office will provide technical assistance to LEAs not meeting comparability in all schools in order to ensure that all required LEAs meet comparability requirements.

LEAs that do not submit their reports or revised reports by the appropriate due dates, the CDE will withhold their apportionment of Title I, Part A funds until such reports are submitted and reviewed.

Questions: District Innovation & Improvement Office | DIIO@cde.ca.gov | 916-319-0836 
Last Reviewed: Friday, October 20, 2017
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