Fixing the Title I Comparability Requirement

• By Michael Fickes
• 12/01/11

School districts seeking Title I federal funding for district schools must demonstrate that services funded with state and local money in those schools are “at least comparable” to non-Title I schools in the district.

The requirement appeared in the original Elementary and Secondary Education Act of 1965 (ESEA) and in each of its reauthorizations up through the No Child Left Behind reauthorization in 2007.

But It Doesn’t Work That Way

The next ESEA reauthorization, due this year, will likely contain language designed to make this provision work the way it was originally intended. Right now, it doesn’t.

The idea is that state and local money should enable all schools to provide equivalent services. Federal funding would then provide poorer schools with the extra resources needed to boost their performance up to the level of non-Title I schools.

Last November, the U.S. Department of Education issued a report entitled Comparability of State and Local Expenditures Among Schools Within Districts: A Report From the Study of School-Level Expenditures. The report analyzed school-level spending and teacher salary data from more than 13,000 school districts and found that more than 40 percent of low income schools do not receive sufficient state and local funds to provide services comparable to non-Title I schools in their district.

ESEA became law in 1965. Why is this only just coming out?

Services Vs. Expenditures

The existing law frames several methods districts can use to satisfy the comparability requirement. All focus on comparable services and not school level expenditures, and that leads to the inequities.

For instance, districts can satisfy the comparability rule by maintaining a district-wide salary schedule and policies ensuring equivalence among teachers, administrators, staff, curriculum materials and other supplies. A district-wide salary schedule implies comparable services, but doesn’t prove it.

Several reports have analyzed this problem in detail. In 2010, The Washington, D.C.-based Education Trust published Close the Hidden Funding Gaps in Our Schools by Daria Hall and Natasha Ushomirsky.

In discussing comparability, Hall and Ushomirsky noted that a district-wide salary schedule does not account for the fact that young teachers with less experience and lower salaries typically receive assignments in higher poverty schools. Experienced, more highly paid teachers usually work in more affluent schools.

Their report identifies similar problems with each of the methods cited in the law for establishing comparability.

The report also offers examples of schools that receive federal funds under Title I yet fail to provide students with services comparable to non-Title I schools.

The Solution: School-Level Expenditures

Hall and Ushomirsky — and others — recommend that the law adopt a standard based on per pupil expenditures and teacher salaries at individual schools to enable accurate comparisons among schools.

According to the Education Department’s Comparability study, districts have not generally made school-level comparisons because “most school districts have not designed their accounting systems to track revenues and expenditures at the school level.”

However, continues the report, the American Recovery and Reinvestment Act of 2009 (ARRA) did require schools receiving Title I, Part A, ARRA funds to report per pupil expenditures at the school level.

The ARRA requirement enabled the Department of Education to confirm the flaw in the system in its Comparability report.

“In far too many places, Title I money is filling budget gaps rather than being used to close achievement gaps,” said Secretary of Education Arne Duncan in a statement issued with the Comparability report. “The Title I program is designed to provide extra resources to high poverty schools to help them meet the greater challenges of educating at risk students, and that’s why Title I requires districts to provide a comparable level of services to all schools before they can receive Title I funding for their low income schools.”

In a plan for this year’s reauthorization of No Child Left Behind, the Obama administration proposes closing the loopholes in the current comparability methodologies and requiring school-level comparisons. The Senate version of USEA reauthorization also requires school-level comparisons.

What Will School-Level Comparisons Mean to You?

It appears that the law will change, and many school districts will have to increase per pupil state and local expenditures in schools hoping to receive Title I federal funding.

The Potential Impact of Revising the Title I Comparability Requirement to Focus on School-Level Expenditures, a policy brief from the Department of Education analyzes the impact of the change on school district budgets.

Simulations used to develop the policy brief indicated “on average, the estimated cost of complying with an expenditures-based comparability requirement amounts to just 1 to 4 percent of school-level expenditures in affected districts.”

According to Secretary Duncan:, “With these minor changes across many schools, low spending, low funded Title I schools today can see their expenditures increase by 4 percent to 15 percent, which is very significant.”