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Comparability Form Completion Instructions

Instructions for local educational agencies to use when calculating Student/Full-time Equivalent Ratio, to determine Title I, Part A Comparability of Services.

The Comparability of Services Student/Full Time Equivalent (FTE) Teacher Calculation forms must be completed annually and in a timely manner to:

  • Ensure that all schools are in a comparable position
  • Allow the LEA to make necessary adjustments with the least amount of disruption
  • Avoid loss of Title I, Part A funding

All schools listed on the Consolidated Application Reporting System (CARS) Title I, Part A School Student Counts report should be included in the calculation forms when determining comparability of services.

Timeline for Determining Comparability of Services

It is recommended that LEAs begin determining comparability of services during the late Winter/early Spring of the prior school year.

The LEA shall make adjustments in schools that are not comparable.

Early determination of comparability allows the LEA to make adjustments with the least amount of disruption.

Student/FTE Teacher Ratio Calculations should be completed towards the beginning of the school year to allow LEAs time to make any necessary adjustments in staffing by October 31 each year.

Determining Title I, Part A Comparability of Services

When determining comparability of services among schools within the LEA, the LEA may either:

  • Compare all schools within the LEA as a whole (LEA-wide average),

    OR

  • Compare all schools within the LEA by each grade span group (Grade Span Group average).

    • The California Department of Education (CDE) has established specific grade span group designations based upon the grades served by a school. Each school is assigned one of the three allowable grade span group codes, as follows:

      • Grade Span Group Code 1 (generally elementary grades),

      • Grade Span Group Code 2 (generally middle grades), and

      • Grade Span Group Code 3 (generally high schools).

Form Completion Steps

  1. Identify Full Time Equivalent (FTE) Teachers paid using State and local funds:

    1. For each school within the LEA:

      1. Identify full time equivalent (FTE) teachers

        1. Include only those teachers whose salaries (or portion thereof) are paid using State and local funds

          1. Teachers paid with private or Federal funds should be excluded from the comparability of services calculations

            1. If the LEA is split-funding a teacher position with federal and/or private funds and State and/or local funds, the LEA shall calculate FTE using only the percentage of salary paid with State and local funds. (e.g., 0.7 FTE would be included in the FTE Teacher total for a school when 0.3 FTE of that teacher’s salary is paid using private or federal funds),

        2. Include only FTE Teachers who hold one of the following credential status’ recognized by state law:

          1. Fully Credentialed Teacher (Preliminary and Clear)
          2. University Intern Credentials
          3. District Intern Credentials
          4. Limited Assignment Teaching Permits
          5. Provisional Intern Permits (PIPs)
          6. Short-Term Staff Permits (STSPs)
          7. Variable Term Waivers
          8. Substitute permits
          9. Teaching Permits for Statutory Leave (TSPL)

      2. Calculate the FTE for each school

        Note: The Full-time Equivalent Teacher Calculation Form is provided for your convenience; it is not a required form.

      3. Capture student enrollment data and full-time equivalent (FTE) teacher calculations for each school on the same date.

  2. Selecting the Calculation Form

    1. Option 1: Select the Student/FTE Teacher Ratio Calculation form in the tab labeled “LEA-wide” to compare all schools within the LEA as a whole
    2. Option 2: Select the forms in the tabs labeled individually for each Grade Span Group to compare all schools within the LEA by each grade span group:

      1. “Grade Span Group 1 Schools”
      2. “Grade Span Group 2 Schools”
      3. “Grade Span Group 3 Schools”

  3. Completing the Student/FTE Teacher Calculation form(s):

    1. All schools that appear on the School Student Counts Report in the CARS should be included in the Student/FTE Teacher Ratio Calculation Forms.
    2. Enter student enrollment data and FTE Teacher in the designated fields:

      1. Enter the requested information for the LEA in the following designated fields: Fiscal Year; LEA CDS Code; and Name of LEA;
      2. Enter the requested information for each school in the following designated fields: School Name; School Type (a list appears in the drop down menu for that field); Grade Span Group Code; Enrollment; and Total FTE Teacher.

        Note: No data entry is required in the last two columns on the far right of the calculation form: “Student-to-Teacher Ratio” and “Is the School Comparable? Yes/No;” these fields will automatically populate once the other data is entered.

  4. Confirming Comparability

    1. The LEA shall confirm that the student/FTE teacher ratios fall within a reasonable variance.

      1. in California, the LEA may consider a school comparable if:

        1. the average student/FTE teacher ratio is equal to or less than (≤) 115 percent of the average of all schools (LEA-wide or by Grade Span Group)

          AND

        2. the average student/FTE teacher ratio is equal to or greater than (≥) 85 percent of the average student/FTE teacher ratio of all schools (LEA-wide or by Grade Span Group)

    2. If the school listed is comparable to all of the other schools within the LEA, a “Yes” will automatically populate the field in the far right column labeled “Is the School Comparable? Yes/No.”

    3. If one or more of the schools listed is not comparable to the other schools within the LEA, a “No” will automatically populate the field in the far right column labeled “Is the School Comparable? Yes/No."

      Note: If a school is not comparable, the LEA must make adjustments.

  5. Adjustments to Non-Comparable Schools

    1. If a school is not comparable, the LEA would make any needed corrections and/or adjustments (e.g., to staff assignments).
    2. Early determination of comparability allows the LEA to make adjustments with the least amount of disruption during the start or early part of a school year.
    3. LEAs must maintain source documentation to support the calculations and documentation to demonstrate that any needed adjustments to staff assignments are made.

Exemptions and Exclusions

For any school that meets one or more of the following exemptions or exclusions listed, “Exempt” will automatically populate the fields in the last two columns of the calculation form:

  1. Exemptions

    1. All public schools assigned one of the following School Types are exempt from meeting the Title I, Part A Comparability of Services requirements:
      1. Alternative Schools of Choice
      2. Continuation High Schools
      3. County Community Schools
      4. District Community Day Schools
      5. Juvenile Court Schools
      6. Opportunity Schools
      7. Special Education Schools (Public)
      8. Youth Authority Schools

        Note: To verify a School Type, please visit the home page of the California Department of Education (CDE) web site:

        1. In the search box located towards the top of the page:
        2. Select the button labeled “District,”
        3. Enter LEA name, and
        4. Click on the “Search” button
        5. A page will appear titled “District Profile: LEA Name:”
        6. Select the “California School Directory” link (located on the far right of the page under the column titled “Related Content”)
        7. Once on the page titled California School Directory:
        8. Enter “LEA Name" into the search box and
        9. Click on the "search" button
        10. A list of all schools within the LEA will appear
        11. For every school listed, a school type will appear in the column titled “District and School Type”

  2. Exclusions

    1. The LEA need not include unpredictable changes in student enrollment or personnel assignments that occur after the beginning of a school year in determining comparability of services (ESSA Section 1118[c][2][C]).

    2. The LEA may exclude schools that have 200 or fewer students.

    3. Include all schools on the calculation form; the enrollment of 200 or less will result in the exempt status appearing on the calculation form.

      1. The Comparability of Services requirement shall not apply to a LEA that has only one school for each grade span (ESSA Section 1118[c][4]) or one school within one or more grade spans within the LEA.

    4. For the purpose of determining comparability of services compliance, a LEA may exclude State and local funds expended for:

      1. language instruction educational programs; and
      2. the excess costs of providing services to children with disabilities as determined by the LEA (ESSA Section 1118[c][5]).

    5. For the purpose of determining compliance with Comparability of Services requirements, a LEA may exclude supplemental State (e.g., LCFF Supplemental and Concentration) or local funds expended under ESSA Section 1113(b)(1)(D) and 1113(c)(2)(B) in any school attendance area or school for programs that meet the intent and purposes of Title I, Part A (ESSA Section 1118[d]; 34 CFR 200.79[a]).

Records Retention

Retain records that are updated annually documenting the LEA’s compliance with the above requirements.

The LEA must maintain source documentation (for three years after the completion of the activity for which the funds were used) to support the calculations and documentation to demonstrate that any needed adjustments to staff assignments were made (ESSA Section 1118[c][3][B]; Section 443 of the General Education Provisions Act [GEPA]; and 34 Code of Federal Regulations [CFR] 76.730).

Questions:   Rina DeRose | Title I Policy, Program, and Support Office | compar@cde.ca.gov
Last Reviewed: Thursday, September 10, 2020