Comparability Overview:

Section 1118 of ESSA requires that local educational agencies (LEAs) provide state- and locally-funded services in Title I, Part A schools that, taken as a whole, are at least comparable to services provided in schools that are not Title I, Part A. This comparability requirement ensures that Federal Title I, Part A funds are not spent on resources that non-Title I, Part A schools obtain with state and local funds. Statute requires that LEAs provide services that meet comparability requirements each year and maintain documentation to demonstrate compliance biennially. However, statute also stipulates that LEAs must annually provide services in Title I schools that are, in fact, comparable to those in non-Title I schools.

Therefore, LEAs must annually conduct local analyses to ensure comparable services are being provided. In order to reduce burden on LEAs, as a first step, CDE conducts calculations that underlie comparability using Student October and HR Snapshot data, analyzing teacher FTE paid with state or local funds (primarily job class code 201) and excluding any federally funded FTE. If CDE is able to demonstrate comparability on behalf of the LEA, the LEA is not required to submit any additional analyses or evidence to CDE. If CDE is not able to demonstrate comparability on behalf of the LEA, the LEA must provide evidence of comparability using local analyses. An Excel alternative calculator is available for LEAs that were unable to meet comparability requirements through the traditional FTE method, as calculated by CDE.

More information can be found on the CDE Comparability webpage.

Comparability Action Plan Purpose:

LEAs that are unable to demonstrate comparability for the previous school year must complete the Comparability Action Plan that describes the LEA’s plan to resolve non-comparable circumstances within the current school year. This plan should include action steps and a timeline for implementation, as well as the party responsible for implementation.