1. Demonstrating Comparability School Year 2014-15 October 2014October 2014

2. Overview Title I, Part A Comparability 2

3. Prerequisite for Receiving Title I, Part A Funds Annual Requirement  Demonstrating comparability is a prerequisite for receiving Title I, Part A funds.  Because Part A allocations are made annually, comparability is an annual requirement.  The Local Educational Agency (LEA) must perform comparability calculations every year to demonstrate that all of its Title I schools are in fact comparable and make adjustments if any are not. 3

4. TDOE Method Student/Staff Ratio  Under ESEA, the Tennessee Department of Education (TDOE) may establish the method LEAs use to determine comparability.  TDOE uses student/instructional staff ratios to compare the average number of students per instructional staff in each Title I school with the average number of students per instructional staff in non-Title I schools.  A Title I school is comparable if its average student/staff ratio does not exceed 110 percent of the average of non-Title I schools.  If the LEA serves all of its schools, or all schools within a particular grade span, with Title I funds, a Title I school is comparable if its average student/staff ratio does not exceed 110 percent of the average of Title I schools. 4

5. Deadlines  No later than October 30, the LEA shall annually demonstrate if comparability requirements have been met and all required forms must be uploaded to the ePlan LEA Document Library.  If, after review by TDOE of the first submission, comparability is shown to have not been met due to an error in data, calculation or procedure, and adjustments to resources and allocations are required, those adjustments must be made that same school year.  If adjustments to resources and allocations are required, all new comparability forms must be submitted via upload to ePlan no later than December 1 of the same school year. 5

6. LEA Written Procedures  An LEA must develop procedures for complying with comparability requirements. [Section 1120A(c)(3)] *  These procedures should be in writing and should, at a minimum, include the LEA’s identification of the office responsible for making comparability calculations, timeline for demonstrating comparability, the method and process for collecting data required to demonstrate comparability, the selected basis for demonstrating comparability, and how and when the LEA makes adjustments in schools that are not comparable.  See sample procedures and timeline in the Overview document. * Checked during monitoring. 6

7. Basis: District or Grade-span  LEAs will determine comparability based on the average number of students per instructional staff. The LEA may demonstrate comparability using either calculation basis below: District basis where, – All Title I schools are compared to all non-Title I schools*; and/or – All Title I schools are compared to all Title I schools OR Grade-span basis where, – By grade-span, Title I schools are compared to non-Title I schools; and/or – By grade-span, Title I schools are compared to all Title I schools in the grade span * If the Title I schools in the LEA serve only grades K-8, but not grades 9-12, the comparability calculations only need to include the Title I and non-Title I elementary and middle schools, but not the non-Title I high schools. 7

8. Data Collection for the Current School Year  The data must be collected for the current school year and cannot be based on projections from the prior year.  Data collection encompasses all data reported on Forms I – IV which includes a list of all schools in the LEA (including charter schools and small schools) with student enrollment and the number of low income students, and lists of instructional and other personnel supporting instruction, counting FTE by funding source.  The LEA must maintain source documentation to support the calculations and forms submitted to demonstrate comparability, and, any needed adjustments made to staff assignments. 8

9. Required Forms 9

10.  The following required forms are available for download from ePlan and must be completed by all LEAs and uploaded to ePlan. Form I – Schools List & Enrollment by Grade Span Form II – Licensed Instructional Personnel Form III – Other Personnel Supporting Instruction Form IV – Comparability Calculations – (required unless the LEA has only one building per grade-span) – (depending on the LEA’s selected calculation basis, either district or grade- span, the LEA will use one, or more, of four available versions of Form IV) Form V – Comparability Summary Report & Assurances 10

11. Form I School List & Enrollment by Grade Span  Form I is required for all LEAs and the completed form must be uploaded to ePlan. Complete one Form I for the entire LEA. List all schools in the LEA, including charter schools and small schools, and complete all student count and enrollment columns. The grade span must be based on the grade span reported on the School Eligibility page in ePlan. While the grade span must be based on the School Eligibility page in ePlan, student enrollment must be based on the current school year and not the prior year projections. 11

12. Form II Licensed Instructional Personnel  Form II is required for all LEAs and the completed forms must be uploaded to ePlan. Complete one Form II for each school in the LEA. List all licensed instructional personnel at the school. Instructional personnel may include licensed classroom teachers and other licensed personnel assigned to the school who provide direct instructional services, including principals, assistant principals, instructional coaches, librarians, physical education teachers, guidance counselors, speech therapists and licensed social workers and psychological personnel. Do not include any pre-school personnel. The LEA should consistently include the same categories of staff members for both Title I and non-Title schools. 12

13. Form III Other Personnel Supporting Instruction  Form III is required for all LEAs and the completed forms must be uploaded to ePlan. Complete one Form III for each school in the LEA. List all other personnel supporting instruction at the school. Other personnel supporting instruction assigned to the school may include paraprofessionals and other non-licensed personnel such as social workers. Aides not involved in providing instructional support may not be included. Other personnel that may not be included are clerical, custodial, food service and any other personnel not providing instructional support. Do not include any pre-school personnel. The LEA should consistently include the same categories of staff members for both Title I and non-Title schools. 13

14. Form IV Comparability Calculations  Form IV is required for all LEAs and the completed form must be uploaded to ePlan. (unless the LEA has only one building per grade-span)  The LEA must determine which version(s) of Form IV are appropriate. Comparing Title I schools to non-Title I schools: – Form IV-a compares Title I schools to non-Title I schools on a district basis. – Form IV-b compares Title I schools to non-Title I schools on a grade-span basis. Comparing Title I schools to other Title I schools: – Form IV-c compares each Title I school to all Title I schools on a district basis. – Form IV-d compares each Title I school to all Title I schools on a grade- span basis. 14

15. Form IV Determining which Version(s) to Use  Example of an LEA using forms IV-b and IV-d to calculate comparability: K-5: The LEA has three elementary schools, all of which are served by Title I. – Two of the schools serve grades K-5 and one serves K-6. – The LEA would use Form IV-d to compare the three Title I schools to one another. 6-8: The LEA has only one middle school serving grades 6-8 and the school is served by Title I. – Because this is the only school in that general grade span, the school may be excluded from the comparability calculations. There are no other 6-8 schools with which to compare the school. 9-12: The LEA has two high schools, one Title I and one non-Title I. – The Title I school serves grades 7-12 and the non-Title I school serves grades 9-12. – To ensure the Title I school is comparable, it must be compared to the non- Title I school in the same general grade span using Form IV-b. 15

16. Form V Comparability Summary Report & Assurances  After completing Forms I – IV, the LEA will complete Form V to provide a comparability summary report, with assurances.  Whether the LEA is demonstrating comparability on a district or grade-span basis, or has only one building for each grade span, a summary of the number of schools by grade span must be provided showing the number of Title I and non-Title I schools for each grade span.  Schools serving fewer than 100 students should be reported in the section provided.  The LEA shall report each general grade span for schools in the LEA, including charter schools. 16

17. Form V Comparability Summary Report & Assurances  Grade spans must be based on the general grade spans reported in ePlan on the School Eligibility page.  If the schools in ePlan were spiraled based on the general grade spans K-5, 6-8 and 9-12, the same grade spans must be used for the schools included in the comparability calculations.  Form V must be signed and dated by the LEA responsible official attesting to the assurances listed and the accuracy of the comparability report.  If a school serves grades in more than one grade span group, the LEA shall include that school in the grade span with which the school has the most grade levels in common. 17

18. Uploading Completed Forms to ePlan  All completed forms must be uploaded to the LEA Document Library in ePlan.  In the LEA Document Library locate the folders: 2015 – Comparability Documents & Information  All excel files must be uploaded as excel files. Please do not print and scan excel files.  Do print, sign and scan Form V. 18

19. Completing the Forms Understanding the Required Fields 19

20. Form I  In column 1, list each school in the LEA.  In column 2, indicate if the school is Title I with an *.  In column 3, report the grade span from the ePlan School Eligibility page.  In columns 4 & 5, report students counts based on the current school year. (do not use the projected enrollment counts from the ePlan School Eligibility page)  In column 6, report enrollment counts by grade. (total of grade columns must equal the count in column 4)  Student counts in columns 4 & 5 will be entered on Form IV, columns 3 & 4. 20

21. Form II  In column 1, list all licensed instructional personnel at the school. All teachers must hold a TN teaching license.  In column 2, report the position in the school for each person named in column 1. Be specific, for example: 2nd grade teacher  In column 3, if applicable, enter FTE excluded from comparability calculations. An LEA may exclude State and local funds expended for language instruction education programs; and the excess costs of providing services to children with disabilities as determined by the LEA.  In column 4, report full time equivalent (FTE) from federal funding, if any. If the person is paid partially from state/local funds and partially from federal funds, make the appropriate entry in each column (4 and 5).  In column 5, report full time equivalent (FTE) from state/local funding, if any. Add totals on Forms II & III and enter sum on Form IV, column 6. 21

22. Form III  In column 1, list all other personnel supporting instruction at the school.  In column 2, report the position in the school for each person named in column 1. Be specific, for example: Paraprofessional, Special Ed. Assistant; Title I Ed. Assistant; Computer Lab Assistant, etc.  In column 3, if applicable, enter FTE excluded from comparability calculations.  In column 4, report full time equivalent (FTE) from federal funding, if any. If the person is paid partially from state/local funds and partially from federal funds, make the appropriate entry in each column (4 and 5).  In column 5, report the full time equivalent (FTE) from state/local funding, if any.  Column 6 is calculated based on the entry in column 5. One (1.0) full time equivalent non-certified instructional position is equal to.5 full time equivalent for comparability calculations. (Column will calculate to equal 1/2 of entry in column 5.) Add totals on Forms II & III and enter sum on Form IV, column 6. 22

23. Select – Form IV-a – IF:  If the LEA has both Title I schools and non-Title I schools to compare; AND  The LEA has elected to calculate comparability on a district basis. The LEA must complete the two tabs in Form IV-a file: List non-Title I schools on TAB: IV-a NON-Title I (ALL) – report all non-Title I schools in the LEA List Title I schools on TAB: IV-a Title I (ALL) – report all Title I schools in the LEA – these Title I schools will be compared to the non-Title I schools 23

24. Select – Form IV-b – IF:  If the LEA has both Title I schools and non-Title I schools to compare; AND  The LEA has elected to calculate comparability on a grade-span basis. The LEA must complete two tabs for each grade span in the Form IV-b file: List non-Title I schools on TAB: IV-b NON-Title I (span 1) (use additional tabs for span 2; span 3; etc.) – by grade-span, report non-Title I schools in the LEA List Title I schools on TAB: IV-b Title I (span 1) (use additional tabs for span 2; span 3; etc.) – by grade-span, report Title I schools in the LEA – these Title I schools will be compared to the non-Title I schools of the same grade-span 24 Specify K-5, 6-8, etc.

25. Select – Form IV-c – IF:  If the LEA has only Title I schools to compare OR has no non-Title I schools to compare to the Title I schools; AND  The LEA has elected to calculate comparability on a district basis. The LEA must complete only one tab in the Form IV-c file: List Title I schools on TAB: IV-c Title I (ALL) – report all Title I schools in the LEA – all Title I schools will be compared to all Title I schools 25

26. Select – Form IV-d – IF:  The LEA has only Title I schools to compare OR has no non-Title I schools to compare to the Title I schools; AND  The LEA has elected to calculate comparability on a grade-span basis. The LEA must complete one tab for each grade span in the Form IV-d file: List Title I schools on TAB: IV-d Title I (span 1) (use additional tabs for span 2; span 3; etc.) – by grade-span, report Title I schools in the LEA – Title I schools will be compared to Title I schools of the same grade-span 26 Specify K-5, 6-8, etc.

27. Form V 27  Complete all LEA information.  Check the appropriate response for submission type and comparability basis.

28. Form V 28  Enter the data collection date.  The data must be collected for the current school year and cannot be based on projections from the prior year.  Enter each grade span based on the School Eligibility page in ePlan.  Enter the number and total of Title I schools.  Enter the number and total of Non-Title I schools.  Schools with 100 or few students may be excluded and must be listed separately.

29. Form V 29  Form V must be printed, signed and scanned before it is uploaded to ePlan.  By signing, the LEA responsible official is indicating he/she understands that the LEA must document implementation of the listed policies, procedures and salary schedules; demonstrating comparability is a prerequisite for receiving Title I, Part A funds; and is attesting to the accuracy of all information provided.

30. Sample Calculations 30

31. Our School District This sample district serves both Title I and non-Title I schools Forms IV-a or IV-b may be used  4 Elementary Schools 2 Non-Title I 2 Title I  4 Middle Schools 2 Non-Title I 2 Title I  1 High School Non-Title I (note the high school will not be included because no Title I schools in the LEA serve grades 9-12) 31 Results can vary depending on the method selected to calculate comparability. Using the same schools, student enrollment counts and staff FTE, the LEA had the following results: District basis:  1 Title I school not comparable Grade-span basis:  2 Title I schools not comparable

32. Form IV-a 32 Ratio is from the Non-Title I schools worksheet Enter data Calculated Enter data Calculated District Results (Comparing all schools serving grades K-5 & 6-8)

33. Form IV-b 33 Calculated Grade-span Results (Comparing schools serving grades K-5 only) Enter data Calculated Ratio is from the Non-Title I schools worksheet Enter data Calculated

34. Form IV-b 34 Calculated Grade-span Results (Comparing schools serving grades 6-8 only) Ratio is from the Non-Title I schools worksheet Enter data Calculated Enter data Calculated

35.  4 Elementary Schools ALL Title I  4 Middle Schools ALL Title I  1 High School Non-Title I (note the high school will not be included because no Title I schools in the LEA serve grades 9-12) 35 Results can vary depending on the method selected to calculate comparability. Using the same schools, student enrollment counts and staff FTE, the LEA had the following results: District basis:  All Title I schools are comparable Grade-span basis:  All Title I schools are comparable Our School District This sample district serves only Title I schools for grades K-8 Forms IV-c or IV-d may be used

36. 36 District Results (Comparing all schools serving grades K-5 & 6-8) Form IV-c Enter data Calculated

37. 37 Grade-span Results (Comparing schools serving grades K-5 only) Form IV-d Enter data Calculated

38. 38 Grade-span Results (Comparing schools serving grades 6-8 only) Form IV-d Enter data Calculated

39. Comparability Questions or Assistance 39  Regional Consultants 1) Corey.Currie@tn.gov Corey.Currie@tn.gov 2) Janet.Mansfield@tn.gov Janet.Mansfield@tn.gov 3) Bridgette.Jones@tn.gov Bridgette.Jones@tn.gov 4) Bridgett.Carwile@tn.gov Bridgett.Carwile@tn.gov 5) Jacki.Wolfe@tn.gov Jacki.Wolfe@tn.gov  “Nashville Office” 6) Janine.Whited@tn.gov Janine.Whited@tn.gov

40. 40 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: 1-800-232-5454 Notifications can also be submitted electronically at: http://www.comptroller.tn.gov/hotline