Upcoming LEA Deadline: Title I, Part A Comparability of Services Requirement for the 2019–2020 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 the Texas Education Agency (TEA) the CAD survey. LEAs that do not meet one of the defined exemption criteria must also complete and submit to TEA the 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 Reports and Data Collections (GFFC Reports) secure application, accessible through TEAL. 

The deadline for submitting the CAD, and CCF if applicable, is November 22, 2019. 
 

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 maintenance of effort and supplement, not supplant requirements. 

Comparability Computation Form (CCF) Exemption

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

• The LEA has only one campus per grade-span group 
• The LEA has multiple campuses in the grade-span group but no overlap of grade levels
• The LEA has overlap of grade levels but no Title I, Part A campuses in the grade-span group
• The LEA uses exclusion criteria to exclude one or more campuses resulting in no basis for comparison
  (Note: Grade-span groups should match the basic organization of schools in the LEA. For example, an LEA with elementary, middle, and high schools would have three grade-span groups. If there is any overlap in grades, the campuses with the same grades should be tested in the same grade-span group. If there is no overlap in grades, the campuses may be separately tested.)

An exempt LEA is required to complete and submit only 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)

LEAs that do not meet any of the exemption criteria listed above are required to conduct comparability of services testing by completing the CCF. The LEA must use its 2019–2020 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 TEAL application.

November 22, 2019, Deadline

All LEAs that receive Title I, Part A funds must complete and submit the CAD via online survey by November 22, 2019.
LEAs that do not meet any of the allowable exemption criteria must also complete and submit the CCF to GFFC Reports by November 22, 2019.
 

Potential Consequences of Failing to Comply

If you do not submit the appropriate comparability form(s) by the November 22, 2019, deadline, TEA may apply one or more of the following enforcement actions in accordance with Title 2 of the 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.