NCLB Title I ComparabilityPaul Williams

Principal ConsultantISBE

September 2011

Comparability Requirements

• Written Procedures Written Procedures (Sec. 1120A(C)(3)(A))– Timelines– Position of responsibility (who is responsible?)– Process used to determine comparability

• Source data• Comparability method• When adjustments are made to non-comparable

schools

• Charter or Special SchoolsCharter or Special Schools– Use a separate comparison method

• Non-Comparable SchoolsNon-Comparable Schools

– Correct the imbalance immediately.

– Submit corrected forms to ISBE by 11/30/11.

• Non-compliance: Funds Frozen 1/1/2012

– Funds will be withheld and/or repaid to ISBE

for non-compliance.

Comparability Requirements

• LEAs on a district wide or grade-span basis must use state and local funds to provide services in project areas that, taken as a whole, are at least comparable to services being provided in school attendance areas that are not receiving Title I funds.

• If the LEA selects all of its attendance areas in the district or in a grade-span group or enrollment-size range as project areas, the LEA must use state and local funds to provide services that, taken as a whole, are substantially comparable in each project area.

Comparability Requirements

• LEAs must exclude any federal funding from their calculations. Salaries paid from federal funds must be excluded from a comparison using pupil/salary a ratio or pupil/expenditure ratio. Vacant positions can not be used to calculate the pupil/staff ratio. Salaries can not include longevity.

• If a school is not comparable the district will implement their written procedures for correcting the imbalance. A district will not be able to submit the comparability document where schools are not comparable.

Comparability Requirements

• Schools have until November 30th to correct non-comparable situations in their schools using their written procedures or their Title I funding will be frozen and will remain frozen until corrections are made and must be demonstrated through their submittal of corrected documentation.

• Should a district demonstrate an inability to achieve a comparable level of expenditures throughout the district the district's eligibility to receive future allocation of Title I funding will be in question and a process will be employed to retrieve the Title I funding allocated for the affected schools.

Comparability Requirements

Note: If a district is a single school building, or, has unique grade spans in each building, the district is in most cases exempt. Check the User Guide for more scenarios to determine an exempt status. Exempt districts will select the "district is exempt" option on the Information Page, then navigate to the Main Menu and select the "submit" link. That is all that is required.

Comparability Requirements

Comparability Requirements

A district is exempt if:• They have only one attendance center in the district. • All the attendance centers are unique grade spans (for example, the

district has a K-5 for one, 6-8 for another, 9-12, etc.)• The two attendance centers with the same grade span have

enrollments where one center is twice the size of the other (for example, one of the district’s two K-5 schools has 250 and 560 for the other).

• The attendance centers have enrollment of less than 100.

A district is not exempt if:• They have multiple attendance centers with similar grade spans and

similar student enrollments. This includes districts with less than 1000 students. (For example, if a district with less than 1000 students but has several attendance centers with the same grade spans and enrollments of 100 or more they must compare their schools.)

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Sample TimelinesJanuary – April

• Engage in district-level budget (State and local funds) discussions concerning staff, distribution of equipment and materials to ensure compliance with Title I comparability for the upcoming school year.

May – July

• Conduct meetings with appropriate LEA representatives to discuss the requirements for completing the annual comparability calculations.

• Establish participant roles and responsibilities.

• Establish specific timelines for completion of the calculations.

• Decide which calculation methodology to use.

August

• Obtain preliminary information from appropriate LEA staff.

• Identify LEA Title I and non-Title I schools.

September• Identify date and collection methodologies for gathering data needed to

complete calculations.October• Collect data.• Meet with appropriate staff and calculate comparability.• Make corrections to Title I schools shown not to be comparable.November• Reconvene appropriate LEA staff to address any outstanding issues.• Maintain all required documentation supporting the comparability

calculations and any corrections made to ensure that all Title I schools are comparable.

Due November 30, 2011

Sample Timelines

Questions