BFS Learning Blog

Considerations for the Title I, Part A Comparability Requirement for 2022-2023

Cindy Watson


Annually, Local Education Agencies (LEAs) that receive Title I, Part A Funds are required to complete an Assurance document that the LEA is in compliance with the comparability of services requirements regardless if the LEA is exempt or not exempt from the testing requirement.  The other Comparability requirements include:

        1) An agency-wide salary schedule;

        2) A policy ensuring equivalence among schools in teachers, administrators, and                   other staff; and

        3) A policy ensuring equivalence among schools in the provision of curriculum                        materials and instructional supplies.

Usually, LEAs are not required to submit the support documentation to their State Education Agency (SEA) for these requirements.  LEAs are only required to
provide an assurance that the items are in place unless selected for a Validation/Desk Audit of the information.

In most cases, an agency-wide salary schedule is in place and not an issue during a full compliance review.  However, it is more common for an LEA to have misinterpreted the requirement for the policies ensuring equivalency.  When reviewing various LEA Comparability policies, the equivalency policies are noted as a requirement within the policy; however, there are not actual policies in place that ensure the equivalencies.   


In addition, these equivalency policies should be updated to include the changing environment the students are learning in to ensure ongoing compliance with the equivalency policies. Consider double checking your Comparability Policy to confirm there the appropriate equivalency policies are in place. Below is example of a simple equivalency policy which addresses the issue of students being instructed at home:

“In accordance with federal regulations, the Somewhere ISD will ensure equivalence among district schools in teachers, administrators, and other staff at the district level. In addition, the district will ensure equivalence in the provision of curricular materials and instructional supplies at the district level. The district will follow the Texas Education Agency’s guidelines in determining such equivalence on an annual basis.”

The Somewhere ISD will ensure that children instructed at home due to the pandemic are taught by a competent instructor and receive an education substantially equivalent and comparable to the education offered at the children’s campuses.


With the addition of Elementary and Secondary School Emergency Relief (ESSER) Grant Funds to LEA budgets, funds that are not subject to the supplement not supplant requirement, LEAs should consider the impact any redistribution of funds will have on the Title I, Part A Comparability of Services testing requirement.  ESSER funds are federal funds and cannot be included in the Comparability Calculations.  Any redistribution of funds should be thoroughly considered by the LEA.