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The Title I law requires school districts with more than one school attendance area for each grade span to meet Title I comparability requirements. The schedule for reviewing comparability requirement at the state department has been moved from spring to winter, so that if we encounter problems with comparability reports, there is still time to make changes before the school year ends.
Title I comparability requirements state that a school district may receive Title I funds only if state and local funds will be used in schools receiving Title I funds to provide services that, taken as a whole, are at least comparable to services in schools that are not receiving Title I funds. If the district is serving all schools under Title I, they may receive Title I funds only if they will use state and local funds to provide services that, taken as a whole, are substantially comparable in each school.
The comparability regulations include documenting compliance in the following three areas:
  1. A local educational agency-wide salary schedule;
  2. Ensuring equivalence among schools in teachers, administrators, and other staff; and 
  3. Ensuring equivalence among schools in the provision of curriculum materials and instructional supplies.
Comparability reports are to be submitted and reviewed at the end of each school year. Meeting comparability is a prerequisite to receiving approval on your subsequent year’s consolidated application, which is processed during the summer. Demonstrating comparability is an annual requirement.
Previously, school districts were informed that they could develop and submit a policy to ensure that the comparability requirements were met on an annual basis. However, when the USDE released final fiscal guidance which addresses the comparability requirements and outlines new USDE expectations, the guidance states that all districts must actually perform the calculations necessary each and every year to demonstrate that all of its Title I schools are, in fact, comparable. Therefore, districts will need to submit actual documentation (not a policy) for each of the three comparability components listed above.

Under ESSA, (section 1118(b), Title I, Part A, supplement, not supplant has been amended and now a methodology test which does not require districts to identify individual costs or services is required. A district must provide a written methodology they are using for compliance with this provision.


Comparability Report Parts