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Title I Comparability

Title I Comparability

The Elementary and Secondary Education Act (ESEA), reauthorized as the Every Student Succeeds Act (ESSA), states that the purpose of Title I, Part A is to “provide all children significant opportunity to receive a fair, equitable, and high-quality education, and to close educational achievement gaps.”  Section 1118 of the ESSA requires local educational agencies (LEAs) to provide state- and locally-funded services in schools receiving support under Title I, Part A that, taken as a whole, are at least comparable to services provided in schools that do not receive support under Title I, Part A.  This requirement must be met for schools in the same grade spans – elementary, middle, and high school (EMH). 

Title I, Part A funds are intended to provide additional resources for low-performing students from high-poverty neighborhoods, beyond what is provided with State and local funds. The comparability requirement within the ESSA seeks to ensure that Title I, Part A funds are not used to provide services that would otherwise be paid for with State and local funds, thus undermining the supplemental nature of Title I, Part A funds.  Comparability, however, focuses on educational materials and services provided with the State and local funds, as opposed to the supplement, not supplant requirement, which ensures schools receive the funds they would have received if the school had not participated in Title I, Part A. 

Demonstrating Comparability

LEAs must submit demonstration of compliance with the comparability requirements if the LEA has at least one Title I school, with at least 100 students, in a grade span that has two or more schools. 

LEAs are not required to submit demonstration of compliance with the comparability requirements if they do not accept Title I, Part A funds or have:

  • Less than 1000 students,
  • Only one school per grade span, or
  • Two or more schools in the same grade span, but any Title I school(s) has less than 100 students.

Based on stakeholder input and with approval from the Educational Data Advisory Committee (EDAC), LEAs no longer submit current year data through the online comparability platform. Currently, LEAs required to demonstrate comparability will conduct local analyses prior to or at the beginning of the school year and make any necessary adjustments as early in the school year as possible, to create the least disruption for students. CDE has provided Excel calculators that allow LEAs to conduct the analyses based on their specific Title I school configurations:

  • All schools in grade-span receive Title I, Part A funds.
  • Some schools in grade-span accept Title I, Part A funds and others not.
  • Alternative methods: High-low enrollment and poverty bands, per-pupil allocation (PPA).

If unable to determine that the LEA will meet comparability requirements through the traditional FTE method, the LEA may be eligible to use the alternative high-low (enrollment or poverty) methods. LEAs that cannot demonstrate comparability through any of these FTE-based methods may do the PPA alternative analysis, based on state and local funds expended on educational materials and resources (beyond teacher FTE). LEAs operating consolidated schoolwide programs may go directly to the PPA worksheets due to their inability to assign teacher funding sources necessary to calculate comparability based on FTE.

Beginning with the 2019-2020 school year and each year thereafter, LEAs must conduct local analyses and maintain documentation of comparability prior to or early in the school year. CDE will run FTE-based comparability analyses toward the end of each school year for monitoring purposes. If CDE’s analyses do not confirm comparability, the LEA will be notified immediately and must submit data using one of the calculators for other methodology to demonstrate compliance by December 31st. If the LEA cannot demonstrate comparability for a given school year either through CDE’s methodology or by one of the other methods, CDE will work with LEA staff to develop and implement a corrective action plan.

CDE Monitoring 

CDE conducts the calculations that underlie comparability using Student October and HR Snapshot data. HR data consisted of teacher FTE paid with state or local funds (primarily job class code 201). Any federally-funded FTE is eliminated from these analyses. All FTE referenced in these analyses refers only to that paid with state or local funds. LEAs in which not all Title I schools demonstrated comparability through FTE analyses will be notified of potential risk of not meeting comparability and must submit data using one of the calculators to demonstrate compliance by December 31, 2020 based on 2019-20 or 2020-21 data.


The Office of Data, Accountability, Reporting, and Evaluation along with the Office of Data Services, will host webinars to review the comparability requirements, discuss data entry into the HR collection, and demonstrate how to use the Alternative Calculator.

For Additional Information Contact:

Tina Negley 
Program Effectiveness Office

Evita Byrd
ESEA Title I and IV Specialist