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Center for American Progress

What if We Closed the Title I Comparability Loophole?

What if We Closed the Title I Comparability Loophole?

Part 3 of Ensuring Equal Opportunity in Public Education

SOURCE: AP/Jason Hirschfeld

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At its inception over 40 years ago, the flagship Title I program of the Elementary and Secondary Education Act of 1965 was intended as the federal government’s way of giving high-poverty schools a leg up. Early on, federal officials realized if Title I funds were to have their desired effect, they would need to be layered on top of an even distribution of state and local funds across schools.

The reason: Title I wouldn’t serve to boost spending if school districts used the funds in place of basic spending in the high-poverty schools. Thus, shortly after its inception, the program came with a comparability requirement that stipulated that school districts must equalize educational services purchased with state and local funds before Title I funds are brought into the mix (See the first report in this package for a detailed history of Title 1 comparability guidelines).

Today, the “comparability” provision is still the tool federal officials use to ensure that the districts disburse their own funds in ways that are fair to high-poverty schools. But recent evidence on district spending practices suggests that the law’s key comparability provision is not doing its job. The question facing policy makers today is if and how we modify the comparability provision to ensure that districts give high-poverty schools a fair shake.

This paper explores reasons for modifying the comparability provision, considerations in making a change, and the likely effects of proposed changes on high-poverty schools. In the end, this paper suggests that the best way to restore the comparability guidelines of Title I to their original intent is by requiring school districts to equalize per-pupil dollar expenditures before accepting federal funds. But an understanding of why this would work best—and why the reauthorization of the No Child Left Behind Act now before Congress is the perfect vehicle for reform—first requires an examination of why current comparability rules fall so woefully short.

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