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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.

Demonstrating comparability of services is a prerequisite for receiving Title I, Part A funds. Title I, Part A allocations are made annually; therefore, comparability is an annual requirement. Starting with the 2020–21 school year, local educational agencies (LEA) will begin using the updated calculation forms and instructions (revised December 2019) to determine comparability of services.

All schools listed on the Consolidated Application Reporting System (CARS) Title I, Part A School Student Counts report are required to meet comparability of services requirements.

  1. Capture student enrollment data and full-time equivalent (FTE) teacher calculations for each school on the same date
    1. Calculating enrollment for half-day kindergarten classes is different than calculating enrollment for full-day classes.
      1. When calculating enrollment for half-day kindergarten classes at each school, the total enrollment for all half-day kindergarten classes is to be divided by two.
      2. The adjusted enrollment for half-day kindergarten is then added to the enrollment for the school
      3. Once added, the total enrollment for the school is entered into the Student/FTE Teacher Ratio Calculation form.
    2. Identify teachers paid using State and local funds for each school LEA-wide
      1. 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
      2. Exclude teachers paid with private or Federal funds.
      3. 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).
      4. The Full-time Equivalent Teacher Calculation Form is provided for your convenience; it is not a required form.
  2. Calculate the student/FTE teacher ratio for each school
    1. Complete either the:
      1. Student/FTE Teacher Ratio Calculation form for All Schools LEA-wide (regardless of the grade span group), OR
      2. Student/FTE Teacher Ratio Calculation form by Grade span Group within the LEA
        1. Each school is assigned one of the following three grade span group codes:
          1. Grade Span Group Code 1 (generally elementary grades)
          2. Grade Span Group Code 2 (generally middle grades), and
          3. Grade Span Group Code 3 (generally high schools)
    2. Enter student enrollment data and FTE Teacher in the designated fields
    3. All schools that appear on the School Student Counts Report in the CARS should be included in the Student/FTE Teacher Ratio Calculation Forms
      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
        2. Include all schools on the calculation form; the school type will result in the exempt status appearing on the calculation form.
        3. For additional information about School Type, please visit the CDE School Type Crosswalk web page.
      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.
        4. 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.
        5. 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]).
        6. 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]).
  3. Student/FTE Teacher Ratio Calculations
    1. The LEA shall confirm that the student/FTE teacher ratios fall within a 30 percent variance.
    2. 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
      1. 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)
  4. 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 middle 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.
  5. Records Retention
    1. Retain records that are updated annually documenting the LEA’s compliance with the above requirements.
    2. The General Education Provisions Act Section 443 states that the LEA shall maintain such records for three years after the completion of the activity for which the funds were used.
Questions:   Rina DeRose | compar@cde.ca.gov | 916-323-0472
Last Reviewed: Thursday, December 12, 2019