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Upcoming LEA Deadline: Title I, Part A Comparability of Services Requirement for 2017–2018

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 October 25, 2017
 
TO THE ADMINISTRATOR ADDRESSED:
 
SUBJECT:      Upcoming LEA Deadline: Title I, Part A Comparability of Services Requirement for the 2017–2018 school year.
 
Each year, local educational agencies (LEAs) that receive Title I, Part A funding are required to document their compliance with the Title I, Part A comparability of services requirement under the Every Student Succeeds Act (ESSA). All LEAs that receive Title I, Part A funding must complete and submit to TEA the Comparability Assurance Document (CAD). LEAs that do not meet one of the defined exemption criteria must also complete and submit to TEA the Comparability Computation Form (CCF).
 
The CAD is now available for completion and submission electronically through an online survey.
The CCF, along with instructions for completing/submitting that form and the instructions for completing/submitting the CAD survey, are available on the Title I, Part A Comparability of Services page of the TEA website and through the Grants and Federal Fiscal Compliance (GFFC) Reports and Data Collections secure application, accessible through TEASE/TEAL.
 
The deadline for submitting the CAD, and CCF if applicable, is November 30, 2017.

Background

Under ESSA, Section 1120A(c), known as the comparability of services requirement, LEAs may receive Title I, Part A funds only if state and local funds will be used in Title I, Part A schools to provide services that are at least comparable to the services provided in non-Title I, Part A schools. If the LEA serves all of its schools with Title I, Part A funds, the LEA must use state and local funds to provide services that, taken as a whole, are substantially comparable in each Title I, Part A school.
 
For more information, refer to the Title I, Part A Comparability of Services Guidance Handbook, available on the Title I, Part A Comparability of Services page.
 
Comparability of services is one of three federal fiscal accountability requirements applicable to LEAs that receive Title I, Part A funding. LEAs that receive Title I, Part A funding are also required to comply with the maintenance of effort and supplement, not supplant requirements.

Comparability Computation Form (CCF) Exemption

An LEA is exempt from completing and submitting the CCF if it meets any of the following criteria:

  • Has only one campus per grade-span group
  • Has multiple campuses in the grade-span group but no overlap of grade levels
  • Has overlap of grade levels but no Title I, Part A campuses in the grade-span group
  • Uses exclusion criteria to exclude one or more campuses resulting in no basis for comparison

An exempt LEA is only required to complete and submit the CAD via online survey.
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, available on the Title I, Part A Comparability of Services page of the TEA website.

Completing the 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 2017–2018 current school year budgeted data to complete the CCF.
Refer to the Title I, Part A Comparability of Services Guidance Handbook, available on the Title I, Part A Comparability of Services page of the TEA website, for instructions on accessing, completing, and submitting the CCF to GFFC Reports within the TEASE/TEAL application.

November 30, 2017, Deadline

All LEAs must complete and submit the CAD via online survey by November 30, 2017.
LEAs that do not meet any of the allowable exemption criteria must also complete and submit the CCF to GFFC Reports by the same deadline, November 30, 2017.

Potential Consequences of Failing to Comply

If you do not submit the appropriate comparability form(s) by the November 30, 2017, deadline, then TEA may apply one or more of the following enforcement actions in accordance with Title 2 of Code of Federal Regulations 200.338:

  • Temporarily withhold cash payments pending correction of the deficiency or more severe enforcement action.
  • Disallow all or part of the cost of an activity or action not in compliance.
  • Wholly or partly suspend or terminate the federal award.
  • Initiate suspension or debarment proceedings.
  • Withhold further federal awards for the program.
  • Take other remedies that may be legally available.

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.
With any further questions, email the Federal Fiscal Compliance and Reporting Division at compliance@tea.texas.gov .
Sincerely,

James Connolly, Senior Director
Federal Fiscal Compliance and Reporting Division

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