For questions or more information, contact: Cindy Hirsch Education Program Specialist 602-542-7466

1. ARIZONA DEPARTMENT OF EDUCATIONProgram Operations Academic Achievement Division2008 LEA Comparability Guidelines For questions or more information, contact: Cindy Hirsch Education Program Specialist 602-542-7466 cindy.hirsch@azed.gov

2. Annual Federal Fiscal Requirement to Ensure Fairness in State & Local Spending at Title I schools Pre-Requisite for receiving future Title I-A Funds PROCEDURESANNUAL CALCULATIONS & DOCUMENTATIONBIENNUAL ASSURANCE COMPARABILITY WHAT TITLE I SCHOOLS WHERE 40th Day of School WHEN HOW WHY

3. USED FISCAL GUIDANCEMay 2006http://www.ed.gov/programs/titleiparta/fiscalguid.doc

4. http://www.ade.az.gov/asd/nclblibrary/ ADE RESOURCES Academic Achievement Division • No Child Left Behind Updates • No Child Left Behind Document Library Financial Information • Comparability/MOE/Supplement • FY08 Comparability Guidelines • FY08 Comparability Handbook • FY08 Comparability Worksheet Instructions • FY08 Comparability Worksheet

5. LEARESPONSIBILITIES

6. Step OneWritten Procedures The administration of the LEA must adopt written procedures that include - • a yearly timeline for demonstrating compliance • identification of the office responsible for making the calculations • choosing the measure and process used to determine whether schools are comparable • how and when the LEA makes adjustments in schools that are not comparable.

7. SAMPLE LEA COMPARABILITY PROCEDURE TIMELINE This example is located in the FY08 Comparability HandbookAND in the FY08 Comparability Guidelinesin the No Child Left Behind Document Library This is an example adapted for Arizona LEAs from the federal guidance May, 2006 Late Winter Governing Authority budget discussions should incorporate evaluations of past Title I A process and methodology, proposals for comparability compliance for the upcoming year, and solicit input from school representatives. Spring Governing Authority engages in instructional staff salary determinations and/or negotiations, which may result in a salary schedule. Authority may review methods of determining comparability, determine applicability and decide whether to use statutory assurance method or alternate methodology. Confirm or assign expected personnel roles and responsibilities – data collection, calculation, custodian of records, etc. School administration will adopt, revise or confirm written Comparability Procedures, including timeline. Summer Apply for grant allocation. Identify LEA Title I and non-Title I schools. Identify date and collection methodologies for gathering data needed to complete calculations for upcoming year. Fall Collect data. Meet with staff and calculate comparability. Make corrections to Title I schools that are not comparable. Address evolving issues. Maintain all required documentation with the Custodian of Records. File biennial report with ADE if due.

8. Step Two ALL LEAs complete LEA Profile showing: • school sites • Enrollment • grade span • poverty level FY08 Comparability Worksheet Exemptions & Exclusions EXEMPT LEAs have only one building per grade span. Exempt from STEP TWO TESTING comparability, only. • EXCLUDED SCHOOL SITES • are LEAs with only two schools – one large and one small. • are Title I schools with 100 or fewer students • Excluded from STEP TWOTESTING comparability, only.

9. Step TwoTesting Comparability & Making Adjustments Testing is aHIGHLY SCRUTINIZEDmonitoring event. What federal auditors look for: - Up-to-date LEA Profile - 40th day matching enrollment and spending or instructional staff data - Staff and/or spending data that shows extraction of federally funded staff or programs. - Completed ADE worksheets that show comparability. Substitute worksheets often do not show thorough picture, exercise discretion. FY08 Comparability Worksheet Testing comparability must be done every year, as of the 40th day, even if the Assurance of Comparability is not due or if there is exclusion.

10. Step TwoTesting Comparability & Making Adjustments • LEA must make any needed resource reallocations for that year by putting additional staff and/or funds into the school and documenting the adjustment. • If reallocations are made after November 30th, the LEA must contact ADE by the due date and submit a Revised Assurance of Comparability by December 31st. • NOTE: The use of state and local funds to support ELL education and the excess costs of serving children with disabilities may be excluded from state and local spending.

11. Step ThreeDocumentation LEAs that receive federal Title I A fundsmust be prepared to substantiate comparability procedures and calculations during every monitoring and auditing event. Acceptable documentation - • Written comparability procedure • LEA Profile • Comparability calculation test – worksheets. enrollment figures, staff and spending, backing out federally funded spending. OR Proof of Exemption/Exclusions OR District-wide salary schedule. Policy to ensure equivalence among schools in teachers, administrators, and other staff. Policy to ensure equivalence among schools in the provision of curriculum materials and instructional supplies. Test of the policy to show the policies resulted in compliance (same as #3 above)

12. Step FourAssurance of Comparability • LEAs must submit the Assurance of Comparability to ADE biennially (once every two years). FY 2008 Assurance of Comparability LEAs beginning with letters M-Z (Due 11/30/2007) Common Logon - Academic Achievement Reports FY 20xx Assurance of Comparability LEAs beginning with Letters M-Z (or A-L) due 11/30/20xx A – L November 30 in even (actual) year, e.g., 2008 M - Z November 30 in odd (actual) year, e.g., 2007 LEAs must be prepared to substantiate comparability procedures and calculations during every monitoring and auditing event.

13. Links FY 2007-08 Assurance of Comparability LEAs beginning with letters M-Z (Due November 30) No Child Left Behind Document Library FY08 Comparability Guidelines FY08 Comparability Handbook FY08 Comparability Worksheet Instructions FY08 Comparability Worksheet

14. Use of State & Local Funds 110% 90% LEGEND Title I $$ State $$ LEA - both NonTitle I School Title I School LEA All Title I