1. Understanding the Basic Premise of Comparability 2015 ESEA Directors Institute August 25, 2015

2. Consolidated Planning & Monitoring Janine R. Whited Director of Project Management Janine.Whited@tn.gov

3. Working Lunch Schedule 11:45 – 12:00 –Select Lunch Option and Return for Presentation 12:00 – 12:45 –Presentation Begins – Enjoy Lunch 12:45 –Dessert will be Served by CPM Staff as the Presentation Continues 12:45 – 1:15 –Attendee Participation for Remainder of Presentation

4. Let Eat and Work! Please select your lunch and Return by 12:00

5. Claudio Sanchez, NPR Education Correspondent: Frozen In Time, Remembering The Students Who Changed A Teacher's Life Jonathan Kozol looks back on the events he wrote about 50 years ago, in Death at an Early Age. http://www.npr.org/sections/ed/2015/06/30/418599078/frozen-in-time-remembering-the-students-who-changed-a-teachers-life

6. Comparability Overview

7. Basic Premise of Comparability The basic premise of comparability is to ensure the LEA can demonstrate that state and local funds used to provide services at Title I schools are at least comparable to the services at non- Title I schools.

8. Prerequisite for Receiving Title I Funds 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.

9. Standard Comparability Method Under the Elementary and Secondary Education Act (ESEA), the Tennessee Department of Education (TDOE) may establish the method LEAs use to determine comparability. The standard comparability method TDOE uses 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.

10. TDOE Standard Method for Comparability –Non-Title Schools Student/Staff Ratio ABC Elem: 20.0 DEF Elem: 21.3 GHI Elem: 21.4 –AVERAGE: 21.0 –110% of AVG: 23.1 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 schools in the district. –In the example below, the average student/staff ratio of the non-Title schools is 21.0 and 110% of that average is 23.1 –The Title I school, JKL Elementary, is not comparable because its student/staff ratio is more than 23.1 –Title I Schools Student/Staff Ratio JKL Elem: 24.1 – NO MNO Elem: 21.4 – YES PQR Elem: 22.3 – YES

11. TDOE Standard Method for Comparability If all schools in the LEA, or all schools within a particular grade span are Title I, a Title I school is deemed comparable if its student/staff ratio does not exceed 110 percent of the average student/staff ratio of Title I schools. Alternative methods to demonstrate comparability may also be considered as described later in this presentation.

12. Comparability Deadlines No later than October 31, the LEA shall annually demonstrate if comparability requirements have been met and all required forms must be uploaded to the ePlan LEA Document Library / 2016 / Comparability folder regardless of method used to demonstrate comparability. If the LEA is unable to demonstrate comparability by the October 31 deadline, the LEA must still upload all required forms by October 31 and a letter stating that the LEA was not able to demonstrate comparability and understands it must make necessary adjustments within the same school year.

13. Comparability Deadlines If the LEA’s first submission, after review by TDOE, shows comparability has not been met due to an error in data, calculation or procedure, and adjustments are required, the LEA will be notified. If adjustments are required to demonstrate comparability, all new comparability forms and a letter stating what adjustments were made must be uploaded to ePlan no later than December 1 of the same school year.

14. 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.

15. Basis for Demonstrating Comparability LEAs using the standard comparability method will determine comparability based on the average number of students per state and locally-funded 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; or All Title I schools are compared to all Title schools OR –Grade-span basis where, 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

16. Data Collection 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 – V which include: –the list of all schools in the LEA (including charter schools and small schools) with student enrollment and the number of low income students; –the lists of instructional and other personnel supporting instruction, counting full-time equivalents (FTEs) by funding source; –the comparability calculations; and –the summary report and assurances.

17. Maintaining Source Documentation The LEA must maintain source documentation to support the calculations and forms submitted to demonstrate comparability, and, any needed adjustments made to staff assignments.

18. Required Forms Form I – School List & Enrollment 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 versions of Form IV Form V – Comparability Summary Report & Assurances

19. Required Forms All required forms are available for download from ePlan and must be completed by all LEAs regardless of method used to demonstrate comparability. All completed forms must be uploaded to the ePlan LEA Document Library / 2016 / Comparability folder no later than October 31.

20. Clarifications Clarifications

21. Basic Premise of Comparability Remember, the basic premise of comparability is to ensure the LEA can demonstrate that state and local funds used to provide services at Title I schools are at least comparable to the services at non-Title I schools. For this reason, the grade span groupings used for comparing schools to demonstrate comparability are very important. Grade span groupings must match the basic organization of schools in the LEA.

22. Grade Span Grouping Defined grade span groupings for comparability must take into consideration which grades the LEA serves with Title I funds. For instance, 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/or non-Title I elementary and middle schools, but not the non-Title I high schools. However, if a school crosses multiple grade span groupings where any grades in the LEA are served with Title I funds, it must be included in one of the grade span groupings of the basic organizations of the LEA.

23. Grade Span Grouping If the LEA 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. For example, if the LEA's basic organization primarily includes schools serving grades K-5, 6-8, and 9-12, the LEA would have three grade span groupings. Additionally, if the LEA also has two schools serving K-8, and at least one of those schools is a Title I school, the LEA would have four grade span groupings – the fourth being K-8.

24. Schools Crossing Grade Span Groupings No school may be excluded from comparability simply because it crosses multiple grade span groupings. For instance, if the LEA's basic organization primarily includes schools serving K-5, 6-8, and 9-12, the LEA would have three grade span groupings. If the LEA also has only one K-6 school, the school could be included in the K-5 grade span grouping but K-6 could not be identified as a separate grade span grouping. Likewise, if the LEA has two K-8 schools, but both are non-Title I schools, the LEA would still have only three grade span groupings for comparability because at least one of those K-8 schools is not a Title I school.

25. Options for Schools Crossing Grade Span Groupings If a school serves grades that cross more than one grade span grouping, the LEA has the following options for including the school in comparability determinations: –OPTION 1: Include a school in the grade span grouping with which the school has the most grades in common: A K-6 school could be compared within the K-5 grade span grouping. A K-8 school could be compared within the K-5 grade span grouping. A 6-12 school could be compared within the 9-12 grade span grouping. A K-12 school could be compared within the K-5 grade span grouping.

26. Options for Schools Crossing Grade Span Groupings –OPTION 2: Divide the grades the school serves by the grade span groupings. Then include the school in each grade span grouping it crosses based on the grades: A K-6 school could be compared within both the K-5 and 6-8 grade span groupings. –Grades K-5 would be compared within the K-5 grade span grouping. –Grade 6 would be compared within the 6-8 grade span grouping. A K-8 school could be compared within both the K-5 and 6-8 grade span groupings. A 6-12 school could be compared within both the 6-8 and 9-12 grade span groupings. A K-12 school could be compared within the K-5, 6-8, and 9-12 grade span groupings.

27. Options for Schools Crossing Grade Span Groupings –OPTION 3: If the LEA has multiple schools serving grades that cross more than one grade span grouping, and at least one of those schools is a Title I school, those schools may be compared as a separate grade span grouping. If all schools that serve grades crossing more than one grade span grouping are non-Title I schools, option one or two must be used. Option three may not be used to exclude non-Title I schools from comparability determinations.

28. Options for Schools Crossing Grade Span Groupings –OPTION 3: (cont.) Example for comparing multiple schools as a separate grade span grouping: If the LEA has multiple K-8 schools, and at least one of those schools is a Title I school, the schools may be compared within a separate K-8 grade span grouping. If none of the schools are Title I, option one or two must be used and the schools may not be compared as a separate grade span grouping.

29. Grade Span Grouping Examples EXAMPLE 1: –All schools in the LEA are Title I schools. –The LEA has three K-5 schools, two 6-8 schools, and one 9-12 school, but also has one K-6 and one K-8 school. –Because the LEA has only one K-6 and one K-8 school, those schools cannot be separate grade span groupings, but must be compared within one of the three basic grade span groupings. Example 1: –K-5 –6-8 –9-12 Example 2: –K-5 –6-8 –K-8 –9-12 Example 3: –K-6 –7-8 –9-12 OR MAYBE

30. Grade Span Grouping Examples EXAMPLE 2: –The LEA serves both Title I and non-Title I schools. –The K-5 and 6-8 schools are all served by Title I and one of two K-8 schools is served by Title I. There are two 9-12 non-Title I schools. –Because the LEA has multiple K-8 schools, and at least one of those schools is a Title I school, those schools may be compared as a separate K-8 grade span grouping. –Because none of the Title I schools in the LEA serve any grades 9-12, the high schools may be excluded from the calculations. Example 1: –K-5 –6-8 –9-12 Example 2: –K-5 –6-8 –K-8 –9-12 Example 3: –K-6 –7-8 –9-12 OR MAYBE

31. Grade Span Grouping Examples EXAMPLE 3: –The LEA serves both Title I and non-Title I schools. –The LEA has four K-6 schools, three 7-8 schools, and two 9-12 schools, but also has one K-8 school and one 6-12 Title I school. –Because the LEA has only one K-8 and one 6-12 school, those schools cannot be separate grade span groupings, but must be compared within one of the three basic grade span groupings. Example 1: –K-5 –6-8 –9-12 Example 2: –K-5 –6-8 –K-8 –9-12 Example 3: –K-6 –7-8 –9-12 OR MAYBE

32. Excluding Support Staff If the LEA opts to exclude other personnel directly supporting instruction from comparability determinations, the exclusion must be consistent for all schools in the LEA. Form III has been updated to provide a space for the LEA to indicate its intent to exclude all personnel directly supporting instruction from comparability. The LEA must still submit Form III and note "EXCLUDED" in the space provided.

33. Schools are Not Comparable If the LEA is unable to demonstrate comparability by the October 31 deadline, the LEA must still upload all required forms by October 31 and a letter stating that the LEA was not able to demonstrate comparability and understands it must make necessary adjustments within the same school year. If adjustments are required to demonstrate comparability, all new comparability forms and a letter stating what adjustments were made must be uploaded to ePlan no later than December 1 of the same school year.

34. Uploading Files to ePlan Forms I – IV are Excel files which must be completed and uploaded to the ePlan LEA Document Library / 2016 / Comparability folder. Please do not print and scan Excel files. If Excel files are printed and scanned, the LEA will be requested to upload the completed Excel files. Only Form V is to be printed, signed and scanned before it is uploaded to the ePlan LEA Document Library / 2016 / Comparability folder.

35. Alternative Methods Documented The standard method for demonstrating comparability is based on student/instructional staff ratio comparisons. Any method approved must be one that does not compromise the intent of the law for demonstrating comparability. The October 31 deadline applies to all alternative methods. –Alternative 1: Per Pupil Budgeted Instructional Expenditures –Alternative 2: Student / Instructional Staff Salary Ratios –Alternative 3: Large and Small Schools –Alternative 4: High and Low Poverty For assistance with alternatives, please contact CPM.

36. Alternative Methods Documented An alternative method may be considered with prior approval by TDOE. –Alternatives 1 & 2: Request for approval must be received by TDOE no later than October 15. –Alternatives 3 & 4: When requesting approval to use this alternative, the LEA must first submit all completed Forms I – V showing the results of the standard method. Request for approval must be received by TDOE no later than October 15.

37. Comparability Support

38. CPM Comparability Support CPM Regional Consultants – Map of District AssignmentsMap of District Assignments 1)Corey Currie Corey.Currie@tn.gov (731) 234-5417 Corey.Currie@tn.gov 2)Janet (Michelle) Mansfield Janet.Mansfield@tn.gov (731) 225-3627 Janet.Mansfield@tn.gov 3)Bridgett Carwile Bridgett.Carwile@tn.gov (615) 626-3466 Bridgett.Carwile@tn.gov 4)Courtney Woods Courtney.Woods@tn.gov (615) 864-5471 Courtney.Woods@tn.gov 5)Deborah Thompson Deborah.Thompson@tn.gov (615) 864-5162 Deborah.Thompson@tn.gov 6)Jacki Wolfe Jacki.Wolfe@tn.gov (423) 262-3296 Jacki.Wolfe@tn.gov

39. CPM & Finance Regional Consultant District Map LAKE OBION WEAKLEY DYER GIBSON LAUDERDALE HAYWOOD FAYETTE CROCKETT BENTON SHELBY TIPTON HENRY CARROLL HUMPHREYS HENDERSON MADISON HARDEMAN McNAIRY HARDIN HOUSTON STEWART ROBERTSON MONTGOMERY DICKSON CHEATHAM PERRY HICKMAN WILLIAMSON DAVIDSON MAURY LEWIS WAYNE LAWRENCE MARSHALL GILES SUMNER MACON TROUSDALE WILSON RUTHERFORD BEDFORD LINCOLN SMITH DEKALB WHITE PUTNAM JACKSON CLAY CANNON COFFEE FRANKLIN MOORE PICKETT OVERTO N FENTRESS CUMBERLAND BLEDSOE WARREN VAN BUREN GRUNDY SEQUATCHIE MARION SCOTT MORGAN CAMPBELL ROANE LOUDON RHEA HAMILTON BRADLEY McMINN POLK MEIGS MONROE BLOUNT SEVIER KNOX ANDERSON CLAIBORNE GRAINGER JEFFERSON HANCOCK HAWKINS SULLIVAN JOHNSON CARTER UNICOI HAMBLEN GREENE COCKE WASHINGTON UNION Corey Currie, CPM Cindy Smith, Fiscal Michelle Mansfield, CPM Brad Davis, Fiscal Bridgett Carwile, CPM Rob Mynhier, Fiscal Courtney Woods, CPM Brian Runion, Fiscal Deborah Thompson, CPM Dustin Winstead, Fiscal Jacki Wolfe, CPM Jackie Broyles, Fiscal 120 Chester 200 Decatur 240 Fayette 350 Hardeman 360 Hardin 380 Haywood 390 Henderson 391 Lexington (PK-8) 490 Lauderdale 550 McNairy 570 Madison 680 Perry 792 Shelby 793 Arlington 796 Germantown 794 Bartlett 798 Millington 795 Collierville 797 Lakeland 840 Tipton 960 West TN School for Deaf 030 Benton 090 Carroll 092 Hollow Rock- Bruceton 093 Huntingdon 094 McKenzie 095 South Carroll 097 West Carroll 170 Crockett 171 Alamo (PK-6) 172 Bells (PK-5) 230 Dyer 231 Dyersburg City 275 Gibson 271 Humboldt City 272 Milan SSD 273 Trenton 274 Bradford SSD 400 Henry 401 Paris SSD (K-8) 420 Houston 430 Humphreys 480 Lake 660 Obion 661 Union City 810 Stewart 920 Weakley 985 ASD 110 Cheatham 140 Clay 180 Cumberland 190 Davidson 210 DeKalb 220 Dickson 250 Fentress 440 Jackson 560 Macon 630 Montgomery 670 Overton 690 Pickett 710 Putnam 740 Robertson 800 Smith 830 Sumner 850 Trousdale 930 White 950 Wilson 951 Lebanon SSD (PK-8) 970 Dept of Children’s Serv. 971 Dept of Corrections 963 TN School for the Blind 961 York Institute (9-12) 020 Bedford 040 Bledsoe 080 Cannon 160 Coffee 161 Manchester (PK-8) 162 Tullahoma 260 Franklin 280 Giles 310 Grundy 410 Hickman 500 Lawrence 510 Lewis 520 Lincoln 521 Fayetteville 580 Marion 581 Richard City 590 Marshall 600 Maury 640 Moore 750 Rutherford 751 Murfreesboro (PK-6) 770 Sequatchie 880 Van Buren 890 Warren 910 Wayne 940 Williamson 941 Franklin SSD (PK-8) 010 Anderson 011 Clinton (PK-6) 012 Oak Ridge 050 Blount 051 Alcoa City 052 Maryville 060 Bradley 061 Cleveland 070 Campbell 330 Hamilton 530 Loudon 531 Lenoir City 540 McMinn 541 Athens City (PK-9) 542 Etowah City (K-8) 610 Meigs 620 Monroe 621 Sweetwater (PK-8) 650 Morgan 700 Polk 720 Rhea 721 Dayton City (PK-8) 730 Roane 760 Scott 761 Onieda 100 Carter 101 Elizabethton 130 Claiborne 150 Cocke 151 Newport City (K-8) 290 Grainger 300 Greene 301 Greeneville 320 Hamblen 340 Hancock 370 Hawkins 371 Rogersville (K-8) 450 Jefferson 460 Johnson County 470 Knox 780 Sevier 820 Sullivan 821 Bristol 822 Kingsport 860 Unicoi Co 870 Union Co 900 Washington 901 Johnson City 964 East TN School for Deaf Central Time Zone Eastern Time Zone Revised 8/17/2015 CHESTER DECATUR 12 3 4 5 6

40. Questions? While dessert is being served Are there any questions?

41. Illustrating Comparability

42. Schools in the LEA Each Table in the Room Represents a School Title I Non-Title

43. Allocating State & Local Funds to Schools Comparable State & Local Funds at Title I Schools Title I Non-Title

44. Allocating Title I Funds to Title I Schools SUPPLEMENTAL Title I Funds are Like the Cherry On Top of State & Local Funds Title I Non-Title

45. Are Title I Schools Comparable? State & Local Funds Cannot be Limited at Title I Schools and Increased at Non-Title I Schools Title I Non-Title I

46. What is SUPPLANTING? Title I Non-Title I If Title I Funds are used In Place of State & Local Funds, THIS IS SUPPLANTING

47. Did you receive a dessert? DESSERTS served at the tables REPRESENT STATE & LOCAL FUNDS at your school

48. REMEMBER REMEMBER Each Table Represents a School and DESSERTS served at the tables REPRESENT STATE & LOCAL FUNDS at your school

49. Did you receive a dessert? If you did not receive a DESSERT your school did not receive COMPARABLE STATE & LOCAL FUNDS

50. What do you do for those without a dessert? For your Title I schools to be COMPARABLE you must reallocate STATE & LOCAL FUNDS

51. Share your extra dessert! Share your extra DESSERT so every school will have COMPARABLE STATE & LOCAL FUNDS

52. Questions Feedback

53. Questions?

54. Feedback Survey At the end of each day, please help us by providing feedback. Today, please use the survey link below. –https://www.surveymonkey.com/r/2015-ESEA-Aug-25https://www.surveymonkey.com/r/2015-ESEA-Aug-25

55. 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