ADE Director's Communication Memo Form

Memo Number : FIN-07-015

Date Created : 08/10/2006


Co-op Directors
other: Title 1 Coordinators

Type of Memo: Regulatory
Response Required: Yes
Section:   Fiscal and Administrative Services - William J. Goff, Assistant Commissioner
Title 1 Comparability Report

Regulatory Authority:
No Child Left Behind Act of 2001 (Public Law 107-110)

Contact Person:
Patsy Hammond

Phone Number:


Section 1120A(c) of No Child Left Behind states that local educational agencies (LEAs) may receive Title I funds only if state and local funds will be used in schools served under Title I Part A to provide services that, taken as a whole, are at least comparable to services in schools that are not receiving funds under Title I Part A. If all the LEA's schools receive Title I services, the LEA may receive Title I funds only if state and local funds are used to provide services, that taken as a whole, are substantially comparable in each school.

To prove comparability, a district needs to examine the state and locally paid instructional staff in all schools being compared. The calculation of comparability is determined by examining the total Full Time Equivalent (FTE) of instructional staff in all schools being compared. Instructional staff includes teachers and other personnel assigned to schools who provide direct instructional services such as music, art, and physical education teachers, guidance counselors, speech therapists and librarians, as well as other personnel who provide services that support instruction, such as school social workers and psychologists. Paraprofessionals and principals are not included as instructional staff when calculating FTEs. When demonstrating compliance for comparability, a district may exclude staff paid with state and local funds -- in supplemental programs that meet the intent and purposes of Title I, in language instruction education programs, and the excess costs in programs providing assistance to students with disabilities as determined by the LEA. Districts must keep the data used to make the Title I Comparability Report calculations in the district audit file.

Neither the Title I Comparability Report Form nor the requirements of comparability have changed from the 2005-2006 school year. However, a definition of instructional staff has been included which omits paraprofessional staff and the principal from inclusion in the comparability calculations and clearly outlines the penalty for schools that are not comparable.


Because the purpose of the comparability requirement is to ensure that Title I schools receive the same level of services from State and local funds as other schools, determinations must be made as early as possible in the school year. The deadline for submission is November 1, 2006. Data used to complete the original Comparability Report is October 1, 2006. District officials should complete preliminary reports prior to October 1 to insure any required staff adjustments are made as early as possible in the school year.

The attached report form is in Excel format. To move between the different pages of the report, the district will use the tabs at the bottom of the page. The district must copy the report to a district computer. When completed, the district must print the report, have the person responsible for completing the report sign it, and submit to:

Ms. Patsy Hammond, Federal Programs Analyst
Arkansas Department of Education
No. 4 Capitol Mall, Room 102-A
Little Rock, Arkansas 72201-1071

For assistance, contact Ms. Hammond at 501-682-4275.


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