Comparability Action Plan

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.

Comparability Action Plan

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Purpose:

The purpose of this form is to collect the required information necessary for CDE to verify that each local education agency (LEA) is in compliance with the demonstration requirements regarding Title I, Part A Comparability under the Elementary and Secondary Education Act (ESEA), as reauthorized by the Every Student Succeeds Act of 2015 (ESSA). To ensure the LEA is on-track to meet these requirements, each LEA must submit the following:

  • A list of non-comparable schools and a brief description of the context contributing to non-comparability;
  • A narrative description of the LEA’s plan to meet comparability; and,
  • An action plan and timeline for implementation, including implementation benchmarks and responsible party.


Note: The LEA is required to calculate Title I, Part A Comparability annually and submit demonstration of comparability to CDE biennially.



Instructions:

Complete the form below to describe the steps that will be taken to resolve the non-comparable circumstances. A change in the allocation of staff or instructional resources may be necessary to meet Title I, Part A Comparability requirements.


Upon submitting this form and any supporting documentation, CDE will review the information provided to ensure the LEA is on-track in meeting compliance with the ESSA requirements.

I. Non-Comparable Schools

Please list the schools that were not able to demonstrate comparability in the previous school year.

#1 School Grade Span Served*
Would you like to add another school?*
#2 School Grade Span Served
Would you like to add a third school?
#3 School Grade Span Served
Would you like to add a fourth school?
#4 School Grade Span Served

II. Action Plan: Narrative and Action Steps

Describe the first action step.

What is the timeline for implementation?

What is the benchmark for implementation?

Who will be the person/people responsible for implementation?

Would you like to add another action step?*

Describe the second action step

What is the timeline for implementation?

What is the benchmark for implementation?

Who will be the person/people responsible for implementation?

Would you like to add a third action step?

Describe the third action step

What is the timeline for implementation?

What is the benchmark for implementation?

Who will be the person/people responsible for implementation?

Would you like to add a forth action step?

Describe the fourth action step

What is the timeline for implementation?

What is the benchmark for implementation?

Who will be the person/people responsible for implementation?

III. Assurance

IV. Alternative Comparability Calculator Completed by the LEA (Optional Upload)

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