Title I Part A Comparability of Services Requirement

 

Word Version

October 16, 2012

TO THE ADMINISTRATOR ADDRESSED:

SUBJECT: Title I, Part A Comparability of Services Requirement

This letter is to notify local educational agencies (LEAs) that participate in Title I, Part A that they are required to conduct comparability testing and to submit that data to the Texas Education Agency (TEA) by Monday, November 12, 2012.

Background

The No Child Left Behind Act of 2001 (NCLB) (Public Law 107–110, Section 1120A[c]) requires that campuses receiving Title I, Part A funding must receive the same level of services through state and local funds as campuses that are not receiving Title I, Part A funding. If all of an LEA’s campuses are receiving Title I, Part A funds, then the LEA must ensure:

  1. That the services provided by state and local funds at their Title I, Part A campuses are substantially comparable, taken as a whole, at each Title I campus; or
  2. That the services provided by state and local funds at their Title I, Part A campuses with higher percentages of low-income students are equal to or greater than the services provided at their Title I, Part A campuses with lower percentages of low-income students.

How to Respond

LEAs that receive Title I, Part A funding and that have more than one building for each grade span are required to submit two documents to TEA: the Comparability Assurance Document and the Comparability Computation Form (CCF). LEAs should use their latest budgeted data for the 2012–2013 school year to conduct the comparability testing required to complete the CCF.

LEAs that do not participate in Title I, Part A, or that have only one campus for each grade-span group, are required to submit only the Comparability Assurance Document.

The required documents may be downloaded from the NCLB Reports section of the Texas Education Agency Secure Environment (TEASE). To download the forms:

  1. Log on to TEASE at https://seguin.tea.state.tx.us/apps/logon.asp
  2. Select “NCLB Report—No Child Left Behind Reports.”
  3. Select “Download Response Templates.”
  4. Select the applicable title to download the template.

LEAs will also use TEASE to submit their completed documents. To upload the forms:

  1. Log on to TEASE at https://seguin.tea.state.tx.us/apps/logon.asp.
  2. Select “NCLB Report—No Child Left Behind Reports.”
  3. Select “Upload Response Templates.”
  4. Select the applicable title to upload the template.

Current instruction manuals for completing the documents are published online.

Deadline

LEAs must submit the required comparability of services documents on or before Monday, November 12, 2012. Failure to meet this important deadline will result in suspension of the LEA’s Title I, Part A funds.

TEASE and NCLB Reports

Individual LEA staff members must have a TEASE userid and logon to access and submit the comparability documents. Staff members who do not have a TEASE userid and logon should visit the TEASE Information Center. An overview of the TEASE online request process is also available online. Further assistance with TEASE access is available from the eGrants Help Desk at (512) 463-7025 or at egrants@tea.state.tx.us.

To add NCLB Reports to an existing TEASE account, log on to TEASE, select “Add/Modify Application Access,” and select “NCLB Reports” from the menu.

Additional Guidance

The US Department of Education (USDE) has published and/or clarified the following additional guidance on comparability of services:

  1. The LEA must choose one of the following tests and apply it successfully district-wide to prove that it is compliant with the Title I, Part A comparability requirement.

Test 1: Comparison of State and Local Expenditures per Pupil

Test 2: Comparison of Per-Pupil Expenditures for State and Local Base Salaries

Test 3: Comparison of Pupil/Non-Federally-funded Instructional Staff Ratio

For example, if the LEA chooses Test 3, then the LEA must be compliant for Test 3A and/or Test 3B district-wide depending upon the type of campuses within the grade-span group being tested.

 

Grade-Span Grouping Configuration identified by LEA

Type of Campuses in the Grade-Span Grouping

District-Wide Test Chosen

Compliance must be shown for

Elementary Schools (Large)

Title I and Non–Title I

3

3A

Elementary Schools (Small)

Title I Only

3

3B

Middle Schools

Title I and Non–Title I

3

3A

High Schools

Title I Only

3

3B

  1. The USDE has clearly stated that only one division to a single grade-span group (small campuses and large campuses) may be made based on a disparity of enrollment. The LEA has the flexibility to decide where the higher enrollment/lower enrollment division is made, but there may only be one division. For example, in an LEA where there is a significant disparity in enrollment at a particular grade span (i.e., high schools ranging from 150 students to 3,500 students), the higher-enrollment high school campuses grouped for comparison might include campuses with 900 students to 3,500 students and the lower-enrollment group could include campuses from 150 students to less than 900 students.
  1. In general, campus groupings must be made based on broad organizational categories: elementary, middle, and high school. LEAs may not group campuses by exact grade spans. The expectation by the USDE is that this will produce fewer grade-span groupings within each LEA and will result in more campuses being compared to similar campuses.
  2. LEAs with fewer than 1,000 students are not exempted from the comparability of services requirement.

If you have questions regarding the Title I, Part A Comparability of Services requirement, please email the Division of Federal Program Compliance at FPC_Compliance@tea.state.tx.us.

Sincerely,

Mara Ash, Senior Director
Division of Federal Program Compliance

 

 

Page last modified on 5/22/2013 12:28:30 PM.