Accounting and Auditing
FY 2010 Title I Comparability Reporting
|To:||Title I Directors|
|From:||Thomas Chin, School Business Services|
|Date:||October 21, 2009|
In accordance with federal law, school districts may receive Title I, Part A funds only if they use 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 do not receive Title I funds. When all schools receive Title I funds, districts must ensure that state and local funds are used to provide services that on the whole are substantially comparable in each school. Demonstrating comparability of services is an annual requirement for each school district receiving Title I funds.
Attached are instructions and forms for demonstrating comparability. The only change to the instructions this year pertains to the instructional personnel to be included on Form D. See page 6 of the instructions for the categories allowed. These forms should be completed by November 15 and if schools are not comparable, adjustments in staffing in the non-comparable schools should be made promptly with the assistance of district supervisory personnel responsible for staffing and the district business manager. These forms must be retained by the Title I Director and be available for outside review. The comparability instructions and forms will also be posted on the School Finance website under Accounting and Auditing.
In previous years, the Department of Elementary and Secondary Education required each Title I district to submit evidence related to comparability of services. This school year the Department will only require those districts undergoing an FY10 program review to submit such evidence. We understand the administrative burdens at the local level to complete and submit evidence related to comparability of services; and we will use EPIMS data to construct an automated comparability reporting to fulfill the annual state monitoring of district comparability.
Please note that federal law requires that a district develop procedures for complying with the comparability requirement. These procedures should be in writing and should, at a minimum, include the district's timeline for demonstrating comparability, identification of the office responsible for making comparability calculations, the measure and process used to determine whether schools are comparable, and how and when the district makes adjustments in schools that are not comparable. These procedures should be available before the forms are completed.
The Department's School Business Services is responsible for providing guidance and technical assistance to ensure that school districts are in compliance with the comparability requirement. Please notify this office if you need assistance with comparability. Alex Lilley at School Improvement Grants, firstname.lastname@example.org or 781-338-6212 will provide technical assistance.
c: Business Manager