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

2.  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. …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.  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 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.

5. fai r impartia l unprejudic ed equitab le objecti ve reasonab le unbiase d equa l jus t moderat e

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

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 Words Numbers

8. 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. Words

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

10. Yes  Demonstrating comparability is a prerequisite for receiving Title I funds  Because Title I allocations are made annually, comparability is an annual requirement Words

11.  Policy changes  Procedure changes  Key Personnel changes Words

12. 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 Words

13. January- July District-level budget discussions Requirements Roles and Responsibilities Attendance Area Selection August – September Obtain preliminary data Perform preliminary calculations October Collect data Calculate comparability Make corrections as necessary November Submit to SEA by deadline Contact SEA with difficulties Maintain all required documentation

14. WordsNumbers Comparable

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

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

17. Shared Drive for Federal ProgramsComparability Folder 12 Schoolyear 2012-2013 13 Schoolyear 2013-2014 Source Data Folder Final Data Folder Numbers

18. LocationTotal of Student_ID Total Enrollment Students in Poverty % Poverty Sample School A 85 7992.9% Sample School B 518 47591.7% Sample School C 1129 85876.0% Sample School D 1060 85280.4% Sample School E 390 32783.8% Numbers TIP: Gather all of your data before you begin working with it!

19. 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. ENameCertPositionGLNOLocNameDegdef Last0, First X Teacher01xxx……Sample School A Bachelor Last1, FirstPara01xxx…..Sample School A High School Last2, First X Asst. Principal 01xxx…Sample School A Master+30 Last3, First X Teacher20xxx…Sample School A Master Last4, First X Principal01xxx…Sample School A Master+30 Last5, First X Librarian01xxx…Sample School A Master Last6, FirstSchool Clerk 01xxx…Sample School A Assoc

21.  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 Numbers

22.  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. Numbers No  Only if the State considers preschool to be part of elementary and secondary education

24. 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.  Attendance Area Selection (AAS)  Title I and non-Title I schools (if any)  Skipped schools? Numbers

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

27. 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. 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 Numbers

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

30.  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. 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. 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.  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 Numbers

37. 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.  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 Numbers

41.  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 Numbers

42. 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.  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 Numbers

46.  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). Numbers

47. Guidance Example 5

48. Guidance Example 5 (continued)

49.  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 Numbers

50.  Further refinement is necessary  High-poverty schools are compared to high-poverty schools  Low-poverty schools are compared to low-poverty schools Numbers

51. Guidance Example 6

52.  All elementary schools in the LEA are Title I schools  Each high-poverty school is compared to a limited comparison group of low- poverty schools  Logical breakpoint: significant differences in poverty levels Numbers

53.  Example 7: the LEA uses the per-pupil amount of State and local funds allocated to schools as the basis for comparison  Example 8: similar to example 7, but the LEA further refines by grade spans Numbers

54.  Guidance provides one example (question B-8)  Gives the option of using two different methods  Traditional schools: compare Title I to non-Title I using student/instructional staff ratios

55.  Charter schools: Per-student amount of State and local funds in Title I charters to the traditional non-Title I schools  Note: charter schools under the LEA must be included in the comparisons with traditional schools. They may not be treated separately. Numbers

56. Title I Coordinator East Baton Rouge Parish School System swolfe@ebrschools.org (225) 922-5584 References:  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. Accessed March 5, 2013 at http://www2.ed.gov/rschstat/eval/title-i/school-level- expenditures/school-level-expenditures.pdf.  U.S. Department of Education. Title I Fiscal Issues: Maintenance of Effort, Comparability, Supplement, Not Supplant, Carryover, Consolidating Funds in Schoolwide Programs, Grantback Requirements. Revised, February 2008. Accessed March 5, 2013 at http://www2.ed.gov/programs/titleiparta/legislation.html#fiscal.  Thank you to every state level Department of Education that posts information about its comparability procedures and processes on its website!