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Procedures for Demonstrating Title I Comparability Compliance

Last Updated: 10/19/2020 7:37 PM

Demonstrating comparability is a prerequisite for receiving Title I, Part A funds. Because Part A allocations are made annually, comparability is an annual requirement. The LEA must perform comparability calculations every year to demonstrate that all of its Title I schools are in fact comparable and make adjustments if any are not. An LEA must develop procedures for complying with comparability requirements. [ESEA § 1120A(c)(3)]  

1. Responsible Office: It is the responsibility of Robbie Anderson, Director of Accountability and School Improvement, to ensure that the LEA remains in compliance with the Title I comparability requirements. The designated office will oversee the process to ensure all procedures are followed and all deadlines are met.  

2. Deadlines: No later than Nov. 13, the LEA shall annually complete the comparability application supplement and upload to ePlan the required forms to the Tennessee Department of Education (the department) demonstrating comparability. To ensure the Nov. 13 deadline is met, the attached comparability timeline will be followed.  

3. Basis for Demonstrating Comparability: The Johnson City Schools may calculate comparability on an district-wide or grade span basis.  

4. Data Collection: It is the responsibility of Robbie Anderson, Director of Accountability and School Improvement, to collect all data from the appropriate LEA office(s), that are required by the department to demonstrate comparability. The designated office will ensure all required data is submitted to appropriate staff within the defined timeline.  Free and reduced lunch data is collected from Karen McGahey, Johnson City Schools Food Service Director, or designated staff.  Student numbers are collected from Tammy Pearce, Student Services Supervisor.  Accurate lists of certified and classified instructional employees (by school) are prepared by Leia Valley,  Johnson City Schools Finance Director, or designated staff. 

5. Data Verification: It is the responsibility of Robbie Anderson, Director of Accountability and School Improvement, to verify the accuracy of the data used to demonstrate comparability and to ensure the calculations are performed correctly using the method established by the department.  

6. Reallocation: If the initial calculations indicate that a school is not receiving comparable services, a. _ (insert office name and job title of designated staff) will be immediately notified. The LEA will then take immediate steps, as early in the school year as possible and with minimum disruption to the learning environment, that are necessary to demonstrate comparability for all Title I schools. Appropriate steps may include, but need not be limited to, reallocation of funding sources and/or reassignment of personnel. Reallocations must be determined no later than Dec. 1 of the same school year and all corrected comparability forms uploaded to ePlan.  

7. Records: It is the responsibility of Robbie Anderson, Director of Accountability and School Improvement, to ensure that all comparability reports, records, and source documentation of the LEAs comparability analysis and calculations are retained for at least five years for audit purposes. An LEA organizational chart must also be included as part of the records. In addition, the LEA will maintain up-to-date records of having established and implemented an agency- wide salary schedule; policies ensuring equivalence among schools in teachers, administrators, and other staff; equivalence among schools in the provision of curriculum materials and instructional supplies; ensuring the 21 LEA’s hiring practices meet state and federal licensure requirements; teachers are highly qualified; and written LEA comparability procedures.  

8. Complaints: It is the responsibility of Robbie Anderson, Director of Accountability and School Improvement, to handle all complaints from parents, community members or LEA and school staff members, that a school is not receiving comparable services.