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Why is Demonstrating Comparability Necessary?
2015 ESEA Directors Institute
August 27, 2015
Claudio Sanchez, NPR Education Correspondent: Frozen In Time, Remembering The Students Who Changed A Teacher's LifeJonathan 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
Illustrating Comparability
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.
Schools in the LEA
Each Table in the Room Represents a School
Title I Title I Title I
Non-Title Non-Title Non-Title
Allocating State & Local Funds to Schools
Comparable State & Local Funds at Title I Schools
Title I Title I Title I
Non-Title Non-Title Non-Title
Allocating Title I Funds to Title I Schools
SUPPLEMENTAL Title I Fundsare Like the Cherry On Top of State & Local
Funds
Title I Title I Title I
Non-Title Non-Title Non-Title
Are Title I Schools Comparable?
State & Local Funds Cannot be Limited at Title I Schools and Increased at Non-Title I Schools
Title I Title I Title I
Non-Title I
Non-Title I
Non-Title I
What is SUPPLANTING?
Title I Title I Title I
Non-Title I
Non-Title I
Non-Title I
If Title I Funds are used In Place of State & Local Funds,
THIS IS SUPPLANTING
Comparability Overview
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.
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.
TDOE Standard Method for Comparability
– Non-Title SchoolsStudent/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
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.
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.
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.
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.
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
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.
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.
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
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.
Clarifications
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.
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.
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.
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.
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.
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.
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.
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.
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
OR MAYBE
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
OR MAYBE
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
OR MAYBE
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.
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.
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.
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.
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.
Comparability Support
CPM Comparability Support
• CPM Regional Consultants – Map of District Assignments1) Corey Currie
[email protected](731) 234-5417
2) Janet (Michelle) [email protected](731) 225-3627
3) Bridgett [email protected](615) 626-3466
4) Courtney [email protected](615) 864-5471
5) Deborah [email protected](615) 864-5162
6) Jacki [email protected](423) 262-3296
CPM & Finance Regional Consultant District Map
LAKE
OBION WEAKLEY
DYER GIBSON
LAUDERDALE
HAYWOOD
FAYETTE
CROCKETT
BENTON
SHELBY
TIPTON
HENRY
CARROLL HUMPHREYS
HENDERSONMADISON
HARDEMAN McNAIRY HARDIN
HOUSTON
STEWARTROBERTSON
MONTGOMERY
DICKSON
CHEA
THAM
PERRY
HICKMANWILLIAMSON
DAVIDSON
MAURY
LEWIS
WAYNE LAWRENCE
MARSH
AL
L
GILES
SUMNERMACO
NTROUSDA
LE
WILSON
RUTHERFOR
D
BEDFORD
LINCOLN
SMITH
DEKALB
WHITE
PUTNAM
JACKSON
CLAY
CANNON
COFFEE
FRANKLIN
MO
OR
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PICKETT
OVERTON
FENTRESS
CUMBERLAND
BLEDSO
E
WARREN
VAN
BUREN
GRUNDY
SEQUATCH
IE
MARION
SCOTT
MORGAN
CAMPBELL
ROANE
LOUDON
RHEA
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N BRADLE
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McMINN
POLK
MEI
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MONROE
BLOUNT
SEVIER
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SULLIVAN
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UNICOIHAMBLE
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WASHIN
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Corey Currie, CPMCindy Smith, Fiscal
Michelle Mansfield, CPMBrad Davis, Fiscal
Bridgett Carwile, CPMRob Mynhier, Fiscal
Courtney Woods, CPMBrian Runion, Fiscal
Deborah Thompson, CPMDustin Winstead, Fiscal
Jacki Wolfe, CPMJackie Broyles, Fiscal
120 Chester200 Decatur240 Fayette350 Hardeman360 Hardin380 Haywood390 Henderson
391 Lexington (PK-8)
490 Lauderdale550 McNairy570 Madison 680 Perry792 Shelby
793 Arlington796 Germantown794 Bartlett798 Millington795 Collierville797 Lakeland
840 Tipton
960 West TN School for Deaf
030 Benton090 Carroll
092 Hollow Rock- Bruceton
093 Huntingdon094 McKenzie 095 South Carroll097 West Carroll
170 Crockett171 Alamo (PK-6)
172 Bells (PK-5)
230 Dyer231 Dyersburg City
275 Gibson271 Humboldt City272 Milan SSD273 Trenton274 Bradford SSD
400 Henry401 Paris SSD (K-8)
420 Houston430 Humphreys480 Lake660 Obion
661 Union City810 Stewart920 Weakley
985 ASD
110 Cheatham140 Clay180 Cumberland190 Davidson 210 DeKalb220 Dickson250 Fentress440 Jackson560 Macon630 Montgomery670 Overton 690 Pickett710 Putnam740 Robertson800 Smith830 Sumner850 Trousdale930 White950 Wilson
951 Lebanon SSD (PK-8)
970 Dept of Children’s Serv.971 Dept of Corrections963 TN School for the Blind961 York Institute (9-12)
020 Bedford040 Bledsoe080 Cannon160 Coffee
161 Manchester (PK-8)
162 Tullahoma260 Franklin280 Giles310 Grundy410 Hickman500 Lawrence 510 Lewis520 Lincoln
521 Fayetteville 580 Marion
581 Richard City 590 Marshall600 Maury640 Moore750 Rutherford
751 Murfreesboro (PK-6)
770 Sequatchie880 Van Buren890 Warren910 Wayne940 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 Cleveland070 Campbell330 Hamilton530 Loudon
531 Lenoir City
540 McMinn541
Athens City (PK-9)
542 Etowah City (K-8)
610 Meigs620 Monroe
621 Sweetwater (PK-8)
650 Morgan700 Polk720 Rhea
721 Dayton City (PK-8)
730 Roane760 Scott
761 Onieda
100 Carter 101 Elizabethton
130 Claiborne150 Cocke
151 Newport City (K-8)
290 Grainger300 Greene
301 Greeneville
320 Hamblen340 Hancock370 Hawkins
371 Rogersville (K-8)
450 Jefferson460 Johnson County470 Knox
780 Sevier 820 Sullivan
821 Bristol 822 Kingsport
860 Unicoi Co870 Union Co900 Washington 901 Johnson City
964 East TN School for Deaf
Central Time Zone Eastern Time Zone
Revised 8/17/2015
CHESTER DEC
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