Deadline for Meeting the NCLB Title I, Part A Comparability of Services Requirement

Word Version

November 19, 2014

TO THE ADMINISTRATOR ADDRESSED:

SUBJECT:    Deadline for Meeting the NCLB Title I, Part A Comparability of Services Requirement

The purpose of this letter is to inform all local educational agencies (LEAs) of the January 16, 2015, deadline for submitting documentation to meet the No Child Left Behind Act of 2001 (NCLB) Title I, Part A comparability of services requirement.

All LEAs are required to complete and submit the Comparability Assurance Document (CAD).

LEAs that do not meet the exemption criteria are also required to complete and submit the Comparability Computation Form (CCF).

LEAs must access and submit the CAD and CCF through the new Grants and Federal Fiscal Compliance (GFFC) Reports and Data Collection application in TEASE/TEAL, as described on the Title I, Part A Comparability of Services page of the TEA website. Instructions for completing the CAD and CCF are also available on that page.

Background
Per NCLB, Section 1120A(c), the comparability of services provision requires LEAs that receive Title I, Part A dollars to fund campuses equitably with their fair share of state and local resources, regardless of whether a campus is also federally funded.

USDE has provided additional, clarified guidance on the comparability of services requirement. Refer to the Title I, Part A Comparability of Services Guidance Handbook, posted on the Title I, Part A Comparability of Services page of the TEA website, for a detailed description of USDE guidance.

Comparability of services is one of three federal fiscal accountability requirements applicable to LEAs that receive NCLB Title I, Part A funding. LEAs that receive NCLB funding are also required to comply with the maintenance of effort and supplement, not supplant requirements.

Comparability Assurance Document (CAD)
All LEAs, including LEAs that receive no NCLB Title I, Part A funding, are required to complete and submit the CAD by January 16, 2015. The CAD must be accessed and submitted through the GFFC Reports and Data Collection application in TEASE/TEAL .

Refer to the Title I, Part A Comparability of Services page of the TEA website for instructions on how to access, complete, and submit the CAD.

Exemption from Further Documentation Requirements
An LEA is exempt from any further comparability of services documentation requirement if it meets any of the following criteria:
•    No Title I, Part A funding
•    One campus per grade span group
•    Multiple campuses in the grade span group yet no overlap of grade levels
•    Overlap of grade levels but no Title I, Part A campuses in the grade span group
•    Exclusion of campus or campuses results in no basis for comparison

An exempt LEA is required to complete and submit the CAD. Exempt LEAs are not required to complete and submit the CCF.

For a detailed description of the exemption criteria and the basis for excluding campuses, refer to the Title I, Part A Comparability of Services Guidance Handbook, posted on the Title I, Part A Comparability of Services page of the TEA website.

Comparability Computation Form (CCF)
All LEAs that do not meet any of the exemption criteria are required to conduct comparability of services testing by completing the CCF. The LEA must use its current-year budgeted data to complete the CCF.

Refer to the Title I, Part A Comparability of Services Guidance Handbook, posted on the Title I, Part A Comparability of Services page of the TEA website, for a detailed description of how the LEA must conduct its testing.

The CCF must be accessed and submitted through the GFFC Reports and Data Collection application in TEASE/TEAL. Refer to the Title I, Part A Comparability of Services page of the TEA website for instructions on accessing, completing, and submitting the CCF.

January 16, 2015, Deadline
All LEAs must complete and submit the CAD by January 16, 2015.

LEAs that receive Title I, Part A funding and do not meet any of the allowable exemption criteria must also complete and submit the CCF by January 16, 2015.

For Further Information
For information on the comparability of services requirement and detailed instructions on how to complete the CAD and CCF, refer to the resources posted on the Title I, Part A Comparability of Services page of the TEA website.
 
With any further questions, email the Division of Federal Fiscal Compliance and Reporting at compliance@tea.texas.gov.


Sincerely,

Ed Santiago
Senior Director
Division of Federal Fiscal Compliance and Reporting