Assessment/Accountability No Child Left Behind
Title I

Fiscal Information

• How the Federal Government Allocates Funds to States and Districts
• How Districts Allocate Funds to Schools
• Maintenance of Effort, Comparability of Services and Supplement, Not Supplant
• Time and Effort Reporting
• Transferability, Flexibility, and Program Coordination
• Ed-Flex Waivers
• Reservations / Set-Asides
• Carryover Funds
• Show All

Maintenance of Effort, Comparability of Services and Supplement, Not Supplant

Title I funds are intended to provide supplemental funds for targeted services for needy students that add to the resources already available for such students; as such, federal funds must not replace local and state funds for these purposes. As part of a state or federal audit, local officials may be required to provide evidence that Title I funds are provided over and above the resources that would normally be provided. Districts must therefore (1) maintain state and local effort; (2) provide services in areas with state and local funds that are at least comparable to services provided in areas not receiving Title I Part A services; and (3) use Title I Part A funds to supplement, not supplant regular non-federal funds.

   Federal Non-Regulatory Guidance on Fiscal Issues: Maintenance of Effort; Comparability; Supplement, not Supplant; Carryover; Consolidating Funds in Schoolwide Programs Grantback Requirements (Updated February 2008)

   Sample Supplement, Not Supplant Policy and Procedure

Maintenance of Effort: Districts are required to demonstrate that the level of state and local funding remains relatively constant from year to year in order to receive the district's full Title I allocation. A district's education expenditures from non-federal funding sources must be at least 90% of the prior year amounts. It is the State's responsibility to determine annually whether a district has maintained effort. Because data from the prior year are not available in time to make this determination, the calculation is based on a comparison of district expenditures between the third and second preceding school years. For example, in calculating maintenance of effort requirements for FY08, the Department's School Finance office analyzes district expenditures from state and local funds for public education from FY05-FY06.

Comparability of Services: Districts are required to use district funds to provide educational services in Title I schools that are comparable to the services provided in non-Title I schools. Districts must ensure compliance with all comparability requirements, including establishing and implementing: (a) a local educational agency-wide salary schedule; (b) a policy to ensure equivalence among schools in teachers, administrators, and other staff; and (c) a policy to ensure equivalence among schools in the provision of curriculum materials and instructional supplies.

Supplement, Not Supplant: To ensure that funds made available under Title I Part A are used to provide services that are in addition to the regular services normally provided by a school district for participating children, the district must use these funds to supplement, not supplant regular non-Federal funds.

• In Targeted Assistance schools, a school district may use Title I funds only to supplement and, to the extent practical, increase the level of funds that would, in the absence of Title I funds, be made available from non-Federal sources for the education of students participating in Title I programs. In no case may Title I funds be used to supplant (e.g., take the place of) funds from non-Federal sources. To meet this requirement, a district is not required to provide Title I services using a particular instructional method or in a particular instructional setting..

• Unlike a Targeted Assistance program, a Schoolwide program school is not required to select and provide supplemental services to specific children identified as in need of services. A school operating a schoolwide program does not have to: (1) show that Federal funds used with the school are paying for additional services that would not otherwise be provided; (2) demonstrate that Federal funds are used only for specific target populations; or (3) separately track Federal program funds once they reach the school. A Schoolwide program school, however, must use Title I funds only to supplement the amount of funds that would, in the absence of the Title I funds, be made available from non-Federal sources for that school, including funds needed to provide services that are required by law for children with disabilities and children with limited English proficiency.