Comparability

1. Comparability Tell your story using numbers and words Susan Andre, Title I Coordinator East Baton Rouge Parish School System

2. Presentation Purpose… Share generally accepted facts about the Comparability requirements Share approaches to comply with the Comparability requirements Describe various accepted methods of meeting the Comparability requirements Provide opportunities to discuss, review, and examine the non-regulatory guidance question/answers and computation examples

3. ESEA, Title I, Section 1120A requires that… …taken as a whole, services provided in Title I schools from state and local funds be at least comparable to those provided in non–Title I schools.

4. In 2011, a USDOE publication on Comparability stated… U.S. Department of Education, Office of Planning, Evaluation and Policy Development, Policy and Program Studies Service, Comparability of State and Local Expenditures Among Schools within Districts: A Report from the Study of School-Level Expenditures, by Ruth Heuer and Stephanie Stullich, Washington, D.C., 2011. The purpose of this comparability requirement is to ensure that federal assistance is providing additional resources in high-need schools rather than compensating for an inequitable distribution of funds that benefits more affluent schools. The Title I comparability requirement allows school districts to demonstrate compliance in a number of ways, including through a district-wide salary schedule

5. reasonable equitable unbiased impartial equal moderate objective just fair unprejudiced

6. Words More simply put… A process of ensuring, maintaining, and demonstrating equity in resources among all of an LEA’s schools.

7. Words • District-wide salary schedule • Policy for equivalent staffing • Policy for equivalent instructional materials and supplies • Numbers • Student/instructional staff ratios • Student/instructional staff salary ratios • Expenditures per pupil • Resource allocation plan based on student characteristics

8. Words #1: Is a written assurance filed with the SEA sufficient to demonstrate comparability? No In addition to the written assurance, there must be… Documentation that policies were implemented and that they resulted in equivalence among schools. Documentation that comparability was determined using a measure such as student/staff ratios, etc.

9. Words Roles and Responsibilities Human Resources Student Information Systems Instructional Technology LEA Federal Programs Office Finance Office LEA Legal Counsel

10. Words #2: Must an LEA determine comparability every year? Yes Demonstrating comparability is a prerequisite for receiving Title I funds Because Title I allocations are made annually, comparability is an annual requirement

11. Words Remain Informed… Policy changes Procedure changes Key Personnel changes

12. Words #3: When should comparability be determined? As early as possible The process must allow the LEA to identify and correct non-comparable schools during the current school year The SEA may establish deadlines

13. LEA Timeline

15. Importance of Numbers • Numbers Numbers both test and prove the policies LEA is required to test annually SEA is required to collect at least once every two years

16. A Word About the Numbers • Numbers Math required: about 8th grade level of competency If you can compute an average and understand ratios, you can do the math Difficulty: gathering the documentation

17. Organization Example • Numbers

18. Source Data: Student Enrollment • Numbers TIP: Gather all of your data before you begin working with it!

19. #4: Are there circumstances where comparability does not apply? • Numbers Yes Schools with fewer than 100 students An LEA with only one grade span per level Charter schools that are their own LEAs

20. Source Data: Instructional Staff

21. #5: Which staff members should be included or excluded? • Numbers Depends on the procedures established by the LEA (or SEA, as appropriate) Instructional staff: teachers and others who provide direct instructional services or services that support instruction Be consistent! Include the same categories of staff members in the ratios for both Title I and non-Title I schools

22. #6: What is the position of ED on the inclusion of paraprofessionals? • Numbers Paraprofessionals may only provide instructional support under the direct supervision of a teacher “we urge SEAs and LEAs to consider carefully whether a paraprofessional supported with State and local funds should be considered equivalent to a teacher or other instructional staff” Do not include aides not involved in providing instructional support

23. #7: Should preschool staff and student enrollment be included? • Numbers No Only if the State considers preschool to be part of elementary and secondary education

24. #8: How can the LEA determine which staff are paid with State and local funds in a schoolwide program? • Numbers If the LEA continues to track its funds separately, calculations are the same as for targeted assistance schools Determine the percentage of Federal funds to the total funds available in a schoolwide program school Use a method for determining comparability that is not dependent on identifying instructional staff paid with State and local funds.

25. Source Data: AAS Information • Numbers Attendance Area Selection (AAS) Title I and non-Title I schools (if any) Skipped schools?

26. Source Data: AAS Information • Numbers What information is needed from the Attendance Area Selection?

27. Attendance Area Selection Title I & non-title I schools Title I schools only • Comparing Title I schools to non-Title I schools • Guidance methods: • Example 1 • Example 2 • Comparing higher-poverty schools to lower-poverty schools • Guidance methods: • Example 3 • Example 4 • Example 5 • Example 6 • Numbers

28. #9: Should skipped schools be included in comparability calculations? • Numbers Yes • In order to be skipped, a school must be comparable • Exclude any supplemental State and local funds in skipped schools that make it eligible to be skipped • Treat the skipped school as a Title I school

29. Calculations • Numbers Apply the method chosen Determine if the schools are comparable If not, further refine the calculations

30. Guidance Examples Examine the example closely. What can you tell about the LEA from the example? What information did the LEA need? Would this method work for your LEA? Why or why not? Could you logically alter this method to make it work for your LEA (with SEA permission, of course)?

31. Guidance Example 1

32. Guidance: Example 1 • Numbers Title I and non-Title I elementary schools are compared Annually compares student/instructional staff ratios for its non-Title I schools 110% of Student FTE ratio for non-Title I schools (12.8 x 1.1)

33. #10: Does the LEA have the option to divide grade spans into large and small groups? • Numbers Yes, but… There should be a significant difference in the enrollments of schools within the grade span Example, if the largest school has an enrollment that is two times that of the smallest school

34. Guidance Example 2

35. Guidance Example 2 (continued)

36. Guidance: Example 2 • Numbers Large and small Title I and non-Title I elementary schools are compared The LEA serves 12 of its 21 elementary schools Divides its elementary schools between large and small Then compares student/instructional staff ratios

37. #11: If all schools in an LEA (or grade span grouping) are Title I, must the LEA demonstrate comparability? • Numbers Yes If all schools are served with Title I funds, the LEA must use State and local funds to provide services that are substantially comparable in each school

38. Guidance Example 3

39. Guidance Example 3 (continued)

40. Guidance: Example 3 • Numbers All LEA schools are Title I schools Different grade spans are compared Method 1: LEA determines if all schools fall between 90 and 110 percent of the student/instructional staff average

41. Guidance: Example 3 • Numbers • Further refinement is necessary • Divides schools into grade spans • Grade spans • Elementary Schools • Middle Schools • High Schools* *There is only one high school in the district, so a comparability calculation is not required

42. #12: Are there limitations on the number of grade spans an LEA may use? • Numbers No, but… The number of grade spans should match the basic organization of schools in the LEA

43. Guidance Example 4

44. Guidance Example 4 (continued)

45. Guidance: Example 4 • Numbers All elementary schools are Title I Large and small schools are compared Method 1: LEA determines if all schools fall between 90 and 110 percent of the student/instructional staff average

46. Guidance: Example 4 • Numbers Further refinement is necessary Divides schools into larger and smaller Largest school = 641 students, yet the example uses a break point of 420 (as opposed to 50% or 320).

47. Guidance Example 5

48. Guidance Example 5 (continued)

49. Guidance: Example 5 • Numbers All elementary schools are Title I Method 1: LEA determines if all schools fall between 90 and 110 percent of the student/instructional staff average

50. Guidance: Example 5 • Numbers Further refinement is necessary High-poverty schools are compared to high-poverty schools Low-poverty schools are compared to low-poverty schools