Fixing the Title I Comparability Requirement
- By Michael Fickes
- December 1st, 2011
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
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
“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
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