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Playing Fair: Ensuring Comparability
ESEA Directors Institute August 2016
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Dr. Alyson F. Lerma Director of Monitoring Consolidated Planning & Monitoring (615)
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Agenda
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Session Objectives Define comparability
Per ESEA [Section1120A(c)] According to TDOE Standard Methods Determine comparability for schools and districts Review the TDOE process for documenting comparability Required forms to be uploaded to ePlan Deadline for submission Share suggested resources Answer questions
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Overview of Comparability
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Definition of Comparability
One of three Title I fiscal tests: Comparability Supplement, Not Supplant Maintenance of Effort Requirement that districts ensure that state and local funding of Title I schools is at least comparable to the funding provided to non-Title I schools
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Comparability Guidelines
Prerequisite for receiving Title I, Part A funds Must be calculated & ensured each year for all Title I schools Designed to ensure that federal funds are being used to supplement state and local financial resources
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Standard Method States may establish the method that districts use to determine comparability. TDOE uses a standard comparability method that compares student/staff ratios for state and locally-funded instructional staff in each Title I school with the average student/staff ratios for state and locally-funded instructional staff in non-Title I schools. The methods & process are the same as in
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District Responsibilities
Demonstrate that state and local funds used to provide services at Title I schools are at least comparable to the services provided at non-Title I schools Collect & use data for the current school year (not based on prior year or on projections) Maintain source documentation Make adjustments if comparability is not demonstrated
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District Responsibilities
Must have formal, written policies for complying with comparability requirements Policies must include the following information: office responsible for making comparability calculations timeline for demonstrating comparability method & process for collecting data required to demonstrate comparability the selected basis for demonstrating comparability how & when the adjustments are made in schools that are not comparable
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Demonstrating Comparability
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Demonstrating Comparability
A district can demonstrate comparability of each of its Title I schools on a district-wide basis OR a grade-span basis Districts using the standard comparability method will do so based on the average number of students per state and locally-funded instructional staff Comparability can be demonstrated by one of the following ways (on a district-wide basis): All Title I schools are compared to all non-Title I schools OR All Title I schools are compared to all Title I schools only if all the schools in a district are Title I schools [Section 1120A(c)(1)(C)]
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Demonstrating Comparability
A Title I school is deemed comparable if its student/staff ratio does not exceed 110 percent of the average student/staff ratio of non-Title I schools in the district STUDENT ENROLLMENT FTE INSTRUCTIONAL STAFF STUDENT/INSTRUCTIONAL STAFF RATIO COMPARABLE? TITLE I SCHOOLS Looking Glass Primary 189 14 13.5 NO Alice Memorial 673 60 11.2 YES Jabberwocky School 528 72.3 7.3 Lewis Carroll Academy 808 55 14.7 NON-TITLE I SCHOOLS Wonderland Elementary 484 42 11.5 Cheshire Academy 1005 88.25 11.4 White Rabbit Primary 757 70 10.8 TOTAL FOR NON-TITLES 2246 200.25 11.22 110% of Student/FTE ratio for non-Title I schools* 12.34 In order to be comparable, the student/instructional staff ratio for each Title I school may not exceed 12.34 (which is x 1.1).
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TDOE Standard Method for Comparability
If a district determines comparability on a grade-span basis, it MUST match the basic organization of the district (& MUST use the same grade spans in the CFA if using grade span ranking as method of allocation) Comparability can be demonstrated by one of the following ways (on a grade-span basis): By grade-span, Title I schools are compared to non-Title I schools OR By grade-span, Title I schools are compared to Title I schools only if all the schools in a district are Title I schools If a school crosses multiple grade span groupings where any grades in the district are served with Title I funds, it must be included in one of the grade span groupings of the district.
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Grade Span Grouping If the district has multiple schools serving grades that cross more than one of the basic grade span grouping configurations, and at least one of those schools is a Title I school, those schools may be compared as a separate grade span grouping. Example: The district has schools serving grades K-5, 6-8, 9-12, & K-8 If that district has three K-8 schools & at least one is a Title I school, this could a separate grouping. The district could have four groupings in total: K-5, 6-8, 9-12, & K-8
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Exclusions Excluding Support Staff: Other personnel who directly support instruction can be excluded from comparability determinations, BUT this exclusion must be consistent for all schools in the district Form III includes a space to indicate the intent to exclude all personnel directly supporting instruction from comparability The district must still submit Form III & note "EXCLUDED" in the space provided EXCLUSIONS to demonstrating comparability: Schools with less than 100 students Only one school at each grade span NOTE: Districts must provide information for excluded schools on the forms
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Alternative Methods Alternative methods to demonstrating comparability based on student/instructional staff ratio comparisons may also be considered: Districts MUST request pre-approval via by Oct. 15 MUST be pre-approved by CPM Monitoring Coordinator The Oct. 31 deadline still applies for demonstrating comparability
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Alternative Methods Alternative 1: Per Pupil Budgeted Instructional Expenditures Alternative 2: Student/Instructional Staff Salary Ratios Request for approval for #1 or #2 must be received via by the CPM Monitoring Coordinator no later than Oct. 15. Alternative 3: Large & Small Schools Alternative 4: High & Low Poverty When requesting approval to use #3 or #4, the LEA must first submit all completed Forms I – V showing the results of the standard method. Request for approval must be received via by the CPM Monitoring Coordinator no later than Oct. 15.
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TDOE Process for Documenting Comparability
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Required Forms Districts must complete and upload Forms I – IV as Excel files (no printed and scanned copies) Form I – School List & Enrollment Form II – Licensed Instructional Personnel Form III – Other Personnel Supporting Instruction Form IV – Comparability Calculations required unless the district has only one building per grade-span depending on the selected calculation basis (either district or grade-span), the district will use one or more versions of Form IV Form V – Comparability Summary Report & Assurances Districts must upload a printed & signed copy of Form V
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Uploading to ePlan ALL forms are due no later than Oct. 31
ALL completed forms must be uploaded to ePlan: LEA Document Library 2017 Comparability Documents & Information
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Districts NOT Demonstrating Comparability
Each district not demonstrating comparability MUST: on or before Oct. 31, upload all required forms and a letter stating it was not able to demonstrate comparability and understands it must make necessary adjustments within the same school year. TDOE will contact the district if the submitted forms show that comparability has not been met or if there is an error in the calculation, procedure, or data. If adjustments are required: all new comparability forms and a letter stating what adjustments were made must be uploaded to ePlan no later than December 1, 2016.
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Resources & Support
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Resources ePlan: eplan.tn.gov USEd website: www.ed.gov
Comparability Overview & Instructions (manual) USEd website:
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Contacts & Support Carissa Sacchetti Alyson F. Lerma
ESEA & IDEA Monitoring Coordinator Alyson F. Lerma Director of Monitoring
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Contacts & Support Vacant Renee.Palakovic@tn.gov (615) 253-3786
CPM & Fiscal Regional Consultants District Map STEWART MONTGOMERY ROBERTSON MACON CLAY PICKETT SUMNER CLAIBORNE SCOTT HANCOCK SULLIVAN CAMPBELL HAWKINS JOHNSON LAKE OBION TROUSDALE WEAKLEY HENRY JACKSON OVERTON FENTRESS HOUSTON CHEATHAM WILSON SMITH UNION GRAINGER HAMBLEN WASHINGTON CARTER DICKSON DAVIDSON BENTON PUTNAM MORGAN GREENE DYER ANDERSON JEFFERSON UNICOI GIBSON CARROLL HUMPHREYS DEKALB CUMBERLAND KNOX WHITE COCKE WILLIAMSON CROCKETT HICKMAN RUTHERFORD CANNON ROANE LAUDERDALE SEVIER HENDERSON WARREN VAN BUREN LOUDON BLOUNT HAYWOOD MADISON DECATUR PERRY MAURY BLEDSOE RHEA TIPTON LEWIS MARSHALL BEDFORD CHESTER COFFEE GRUNDY SEQUATCHIE MEIGS McMINN MONROE Central Time Zone Eastern Time Zone MOORE SHELBY LAWRENCE FAYETTE HARDEMAN McNAIRY HARDIN WAYNE GILES LINCOLN FRANKLIN MARION HAMILTON BRADLEY POLK 1 Vacant, CPM Cindy Smith, Fiscal Michelle Mansfield, CPM Brad Davis, Fiscal Bridgett Carwile, CPM Rob Mynhier, Fiscal Shalonda Meeks, CPM Brian Runion, Fiscal Deborah Thompson, CPM Dustin Winstead, Fiscal Henry LaFollette, CPM Jackie Broyles, Fiscal 2 3 4 5 6 Vacant (615) Janet (Michelle) Mansfield (731) Bridgett Carwile (615) Shalonda Meeks (615) Deborah Thompson (615) Henry LaFollette (615)
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Review & Questions
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Session Review Define comparability
Per ESEA [Section1120A(c)] According to TDOE Standard Methods Determine comparability for schools & districts Review the TDOE process for documenting comparability Required forms to be uploaded to ePlan Deadline for submission Share suggested resources Answer questions
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Questions?
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Notifications can also be submitted electronically at:
FRAUD, WASTE or ABUSE Citizens and agencies are encouraged to report fraud, waste or abuse in State and Local government. NOTICE: This agency is a recipient of taxpayer funding. If you observe an agency director or employee engaging in any activity which you consider to be illegal, improper or wasteful, please call the state Comptroller’s toll-free Hotline: Notifications can also be submitted electronically at:
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