Center for American Progress

Closing the Comparability Requirement Loophole in Title I
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Closing the Comparability Requirement Loophole in Title I

Removing the loophole for salary differentials and staff qualifications is the first step toward a more accurate calculation of school resources.

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Congress will have the opportunity this year as it approaches the reauthorization of the Elementary and Secondary Education Act to revise many important features of the law. Much of Congress’s attention will surely be directed at outcome-oriented policies in an effort to improve student achievement. But reauthorization will also allow Congress to focus on the financial resources put into education, particularly for Title I, which directs funds toward schools with high numbers of students in poverty. The comparability requirement is intimately connected to the purpose of Title I funds.

True comparability cannot be achieved unless districts compare actual expenditures at the school level. Language in Appendix A provides a specific option that may be of help to members of Congress concerned with revising the comparability provision to reach this goal.

Removing the loophole for salary differentials and staff qualifications is the first step toward a more accurate calculation of school resources. Using a per pupil expenditure comparison—with categorical reporting for both personnel and nonpersonnel expenditures—will enable districts to see the level of resources offered at each school and equalize spending where necessary. This approach leaves districts and schools free to make their own budgeting decisions while maintaining a focus on fiscal equity.

The law should also provide for a phase-in period where districts can determine the best way to reach comparability with required guidance from state agencies. Following the phase-in period, state agencies should be required to monitor districts’ compliance annually and aggressively assist districts that fail to comply with the law’s demands.

Title I schools must receive at least the same amount of local and state resources as non-Title I schools in order for Title I to have its intended effect of providing additional resources to low-income students. Reauthorization of ESEA always provides Congress with an opportunity to bolster alignment of the law with its purpose. Closing the comparability loophole represents a clear way to doing so in the current reauthorization.

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