Comparability

1. Comparability 2011 Title Programs Conference June 15-16, 2011

2. Presenters Jimmy Everson, Ed.D. Georgia Department of Education Title I Education Program Specialist jeverson@doe.k12.ga.us (229) 723-2664 Evelyn Maddox Georgia Department of Education Title I Education Program Specialist emaddox@doe.k12.ga.us (404) 656-2045

3. Definition of comparability Comparability requirement Criteria for meeting comparability Developing procedures for meeting comparability Staff members to be included in calculations Staff members to be excluded from calculations Required documentation for determining comparability Description of the process for determining comparability Examples of comparability calculations Questions and answers Agenda

4. Definition of Comparability To ensure that funds made available under Title I, Part A of the Elementary and Secondary Education Act of 1965 (ESEA) are used to provide services that are in addition to the regular services normally provided by a local educational agency (LEA) for participating children, the LEA must provide services in its Title I schools with State and local funds that are at least comparable to services provided in its non-Title I schools.

5. Comparability Requirement • Comparability should be demonstrated as of the October full-time equivalent (FTE) count day • Comparability Report must be submitted to GaDOE no later than November 15th each year

6. Comparability Requirement • The comparability requirementdoes not apply to an LEA that has only one building for each grade span. • An LEA may also exclude schools with 100 or fewer students from its comparability determinations.

7. Comparability Requirement • Section 1120A(c) of the ESEA provides that an LEA may receive Title I, Part A funds only if it uses State and local funds to provide services in Title I schools that, taken as a whole, are at least comparable to the services provided in schools that are not receiving Title I funds.

8. Comparability Requirement If the LEA serves all of its schools with Title I funds, the LEA must use State and local funds to provide services that, taken as a whole, are substantially comparable in each Title I school.

9. Comparability Requirement • Demonstrating comparability is a prerequisite for receiving Title I, Part A funds. Because Title I, Part A allocations are made annually, comparability is an ANNUAL requirement.

10. Criteria for Meeting Comparability • The Georgia Department of Education has established the Student/Instructional Staff Ratio as the method for LEAs to use to determine comparability.

11. Criteria for Meeting Comparability • When using 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, an LEA may consider a Title I school comparable if its average does not exceed 110 percent of the average of non-Title I schools.

12. Criteria for Meeting Comparability • The LEA may choose to compare large Title I schools in a particular grade-span to large non-Title I schools in that grade-span and small Title I schools in that grade-span to small non-Title I schools in that grade-span. • The LEA may also compare high poverty Title I schools to low poverty Title I schools.

13. Criteria for Meeting Comparability • If all schools in the district are Title I schools, an LEA may compute the average student/instructional staff ratio for all its schools and consider a school comparable if the student/instructional staff ratio falls between 90 and 110 percent of the average for all schools.

14. Developing Procedures for Meeting Comparability • An LEA must develop written procedures for complying with the comparability requirements and implement those procedures annually.

15. Developing Procedures for Meeting Comparability • An LEA may determine comparability of each of its Title I schools on a district-wide basis or a grade-span basis. • Although there is no limitation on the number of grade-spans an LEA may use, the number should match the basic organization of schools in the LEA.

16. Staff Members to be Included in Comparability Calculations

17. Staff Members to be Included in Comparability Calculations • Consistently include the same categories of staff members for both Title I and non-Title I schools • Include only staff paid with state and local funds

18. Staff Members to be Included in Comparability Calculations • Instructional staff • Core subject teachers • Instructional paraprofessionals • Music teachers • Art teachers • Physical education teachers • Guidance counselors • Speech therapists • Media specialists

19. Staff Members to be Included in Comparability Calculations • Services provided by staff that support instruction • School social workers • Psychologists

20. Staff Members to be Excluded from Comparability Calculations

21. Staff Members to be Excluded from Comparability Calculations • Prekindergarten teachers • Prekindergarten paraprofessionals • Secretaries • Cafeteria workers • Custodians • School nurses • Security personnel • Non-instructional paraprofessionals • Staff paid with private or federal funds • Principals • Assistant Principals

22. Required Documentation for Determining Comparability • Title I Comparability Report form • October FTE report for current school year • List of schools with grade configuration and Title I status • List of staff members at each school by funding source

23. Description of the Process for Determining Comparability

24. Description of the Process for Determining Comparability • Obtain a copy of the October FTE enrollment data for the current year • Determine the grouping of schools for comparison • List schools as they were listed on the Title I, Part A Consolidated Application • See grouping section in Title I Handbook

25. Description of the Process for Determining Comparability • Determine the method to be used to determine whether schools meet the comparability requirement • Compare student/instructional staff ratios for: • Each Title I school with average of non-Title I; or • Large and small Title I and non-Title I schools; or • Each school to the average for all schools (all schools are Title I); or • High poverty schools to low poverty schools (all schools are Title I)

26. Description of the Process for Determining Comparability • Obtain a list of all staff members at each school • Notate the funding source for each staff member at each school • Complete the appropriate comparability worksheet

27. Description of the Process for Determining Comparability Enter the following on the Comparability Report form: • Name of school district • Name of each school • Grade span for each school • Student enrollment minus prekindergarten • Instructional staff FTE from worksheet • If using poverty grouping, enter number of children eligible for free or reduced meals minus PK

28. Description of the Process for Determining Comparability Complete Part A of the Comparability Report form

29. Examples of Comparability Determination

30. Examples of Comparability Determination Compare Title I funded schools to non-Title I schools See Example 1 in Title I Handbook Discuss Example 2 in Title I Handbook

31. Examples of Comparability Determination Compare the student/instructional staff ratio of each school to the average of all schools in the district when all schools in the district are Title I funded See Example 3 in Title I Handbook Discuss Example 4 in Title I Handbook

32. Examples of Comparability Determination Compare elementary schools by poverty when all elementary schools in the district are Title I funded See Example 6 in Title I Handbook Discuss Example 5 in Title I Handbook

33. Questions and Answers

34. Helpful Resources • Title I Handbook – Current Edition • NCLB Act of 2001 (Blue Book) • GaDOE Web site – http://public.doe.k12.ga.us • US ED Web site – www.ed.gov • Office of Management and Budget (OMB) Circulars • Education Department General Administrative Regulations (EDGAR)

35. Title I Program Specialist Contact Information

36. Comparability 2011 Title Programs Conference June 15-16, 2011