Accounting and Auditing

2007-2008 Comparability Instructions and Forms

MEMORANDUM

As a result of reorganization, School Business Services is now responsible for collecting and reviewing the Title I comparability report. This responsibility includes providing guidance and technical assistance to ensure that school districts are in compliance with the comparability requirement.

Demonstrating comparability is a prerequisite for receiving Title I, Part A funds. Because Part A allocations are determined annually, comparability must be demonstrated annually. Last year all Title 1 districts were required to submit their comparability reports to the Department. That requirement will continue this year.

In an effort to demonstrate comparability, Title I directors/coordinators should have already gathered student enrollment data and instructional staff full time equivalent (FTE) data for personnel funded by state/district funds (not federal funds). This data is necessary to determine that Title I schools are comparable to non-Title I schools. If schools are not comparable, adjustments in staffing in the non-comparable schools should be made promptly.

This year, we are requesting that Title I directors/coordinators review the district comparability report with the district business manager and district supervisory personnel responsible for staffing so that appropriate adjustments can be made if there are non-comparable Title I schools. Page 4 of the instructions spells out actions that will be taken if the comparability requirement is not met.

Please note that in accordance with section 1120A©(3), NCLB, a district must develop procedures for complying with the comparability requirement. These procedures should be in writing and should, at a minimum, include the district's timeline for demonstrating comparability, identification of the office responsible for making comparability calculations, the measure and process used to determine whether schools are comparable, and how and when the district makes adjustments in schools that are not comparable. These procedures should be available before the forms are completed.

This year, we are requiring all Title 1 districts to submit comparability reports to DOE for review by no later than December 14, 2007. Attached are the Title I Comparability instructions and forms for the 2007-2008 school year. The instructions and forms are similar to last year except that a school district with only one school such as a charter school or a regional vocational school does not need to file. The forms are in both Excel and Word format. If you complete the Excel version, the calculations will automatically be totaled for you. The comparability instructions   and forms   will also be posted on the School Finance website under Accounting and Auditing. http://finance1.doe.mass.edu/account

Please submit one copy of your completed report via email to Comparability@doe.mass.edu or via US mail to Tom Chin at: Massachusetts Department of Elementary and Secondary Education, School Business Services 350 Main Street, Malden, MA 02148.

Please notify this office if you need assistance with comparability. Thomas Chin at School Business Services, tchin@doe.mass.edu or 781-338-3592 will provide technical assistance.