Office of Accountability

Title I Comparability Report

Consolidated Application Update


Due November 30, 2012


General Instructions

The following information is meant to assist LEAs/Charter School LEAs in documenting the effectiveness of assurances for meeting Title I requirements for "comparability" and for allocating local funds between NCLB Title I schools and non-Title I schools.

Note: For purposes of these NCLB Title I funds, a Charter School LEA will be considered as a local educational agency (LEA).

Sections 1120A(c)(3)}, Procedures and Records - "Each local educational agency assisted under this part shall - (A) develop procedures for compliance with this subsection and (B) maintain records that are updated biennially documenting such agency's compliance with this subsection."

Therefore, if a Local Educational Agency (LEA) files written assurances in the Consolidated Application or the LEA Comprehensive Educational Plan that it has established and implemented: a.) an LEA-wide salary schedule and b.) policies to ensure equivalence among schools in staffing and in the provision of materials and supplies, it must keep records to document implementation of such salary schedule and equivalence policy.

If the LEA established and implemented other measures for determining compliance with comparability, such as student/instructional staff ratios, it must maintain source documentation to support the calculations and demonstrate that any needed adjustments to staff assignments were made.


General Information

Fiscal Year

Select the data year used for this report (the current school year)


Find your LEA and BEDS code in the drop-down list

E-Mail Address:

Enter the e-mail address of the contact person for questions

Section 1:
Check if the LEA is applying for an EXEMPTION because it has:

  • An enrollment of less than 1,000 pupils (Part A, Section 1120 A); or
  • Only one school building for each non-overlapping grade span grouping in the LEA. (Part A, Section 1120A).
  • None of the Above

If neither of these options apply, C. None of the above should be selected.
Verification of the Section 1 selection will be requested.
If option A or B was selected and verified a thank you message should appear which confirms that the process is complete.

If option C is selected and verified, Sections 2 and 3 will appear.

Section 2: Check the applicable exclusions. (Part A, Section 1120 A)

An LEA may only exclude those English Language Learners (ELL) and Special Education programs approved by the State Education Department and State or locally funded compensatory education programs that meet the intent and purposes of Title I, Part A.

If any of the items in Section 2 are checked, a description of the program(s) to be excluded including implementing rules and guidelines, the number of pupils enrolled, the FTE assignment of staff, and how the program will be supplemental must be submitted.  Please e-mail these materials as an attachment to CONAPPTA@MAIL.NYSED.GOV, with the Subject line reading: "Comparability Exclusion Documentation". The LEA must also provide assurances that children served are educationally disadvantaged, and that their progress will be evaluated against the same performance objectives as the Title I funded programs and reported on the Local Educational Agency Program (LEAP) evaluation report.

Please note: An LEA may exclude approved programs only if it does so in all project and non-project schools in which the program operates.  An LEA may choose to calculate comparability by grade span group comparisons or by LEA-wide Title I/Non-Title I comparisons.

Section 3a.: Check the grade span group being reported.  Report only groupings with more than one building.  The LEA-wide comparison (all buildings in a single Comparability Report) may be used instead if an LEA chooses to include all buildings in the Title I/non-Title I comparison. 

Four typical grade span groupings are listed for comparability reporting:  primary, elementary, junior high/middle school, and high school. Each school building should be listed with the grade span group where it has the most grades in common and matches the basic organization of schools in the LEA. If there are an equal number of grades in each grouping, report the buildings in the higher grouping (e.g., for buildings with Grades 3 and 4, use "elementary", rather than "primary").  Use "Other" only if your LEA's grade spans do not fit the four categories listed.  Select "LEA-wide" if you are reporting all your buildings on one report.

  • An LEA with a K-3, Pre-K-2, and K-2 buildings would probably choose to group them in the primary grade span group.
  • An LEA with K-6, 3-5, and 4-6 buildings would most likely include them in the elementary grade span group.

If an LEA has two or more elementary buildings, but only one middle school and high school, only the elementary schools would be reported for comparability purposes.  Likewise, if there are two or more middle/junior high or high schools, these groups must also be reported.

Section 3b:
If an LEA has both Title I and non-title I buildings in a particular grade span grouping, the non-Title I screen will appear first. If only Title I buildings are in the particular grade span grouping the Title I screen will appear.

Section 4:   (same for both grade-span grouping and LEA-wide reporting)

(a) Non-Title I Schools:

List all public schools where no Title I funds are expended. For purposes of this report, a school is an administrative entity assigned a building code by the State Education Department. Do not include private schools.
(b) Building Grade Span:
Select the building grade span range.
(c) Total # Pupils Enrolled:

Enter the FTE (to the nearest whole number) student enrollment in each non-project school. A half-day kindergarten child should be counted as a .5 FTE, but the total number needs to be a whole number. Report all enrolled pupils regardless of program status. For example, include students receiving services for ELL and disabilities.  Use 2012-2013 data.
(d) Total FTE Instructional Staff:
Enter the total FTE (to the nearest tenth) for all instructional staff assigned to each non-Title I school building.  Use 2012-2013 data.

Indicate whether or not more non-title I buildings need to be submitted.

A full-time equivalent is defined as a person hired on a full-time basis for the entire school year. A person hired on a full-time basis for a portion of the school year should be entered as that percentage of a full-time equivalent. All other personnel should be apportioned accordingly. For example a person hired on a full-time basis for 1/2 of the school year should be entered as .50 FTE; a person hired on a half-time basis for 1/2 of the school year should be entered as .25 FTE. Staff assigned to more than one building should be prorated across building assignments.

Instructional staff include (except if items A-C are checked in section 2) those who:

  • are paid with State aid and/or local tax levy funds (do not include staff paid under other federal Titles such as Class-size Reduction (Title II-A), Reading First, IDEA, etc.) and
  • provide direct instruction to students or provide services which support direct instruction.

Direct instructional staff include classroom teachers, other subject/special area teachers and teaching assistants who meet with and instruct students on a regular basis, hold appropriate certification and/or license to teach and are represented by a teachers' bargaining unit or bargaining unit for teaching assistants.

Staff who support direct instruction include psychologists, guidance counselors, school social workers, librarians, media specialists, and administrators.

Note: Administrators are persons who have no direct instructional assignment and/or who are represented by an administrators' bargaining unit rather than a teachers' bargaining unit.
LEAs should not include in this calculation teacher aides, clerks, secretaries, school nurses, bus drivers, custodians, play ground attendants, security personnel, LEA business officers, and other such staff.

When all the non-Title I buildings have been submitted Section 6 (Title I Buildings) will appear.

Section 5 intentionally left blank

Section 6: (Use for both grade span and LEA-wide groups)

(a) Title I Schools:

List all public schools where Title I funds are budgeted to provide instructional services.

(b) Building Grade Span:

Select the building grade span range.

(c) Total # Pupils Enrolled:

See Section 4.

(d) Total FTE Instructional Staff:

Enter the total FTE for all instructional staff assigned to each Title I building who:
·  Are paid with State Aid and/or local tax levy funds and
·  Provide direct instruction to students or services which support direct instruction.
(See Section 4 for examples of direct instructional staff and those who support direct instruction.)
Use 2012-2013 data.

When information for all buildings have been submitted a summary page will appear which will permit editing. When ready to submit form, please print the page for your records and then click the complete form button.

If you have any problems or questions, please contact the Title I School & Community Services office at or (518) 473-0295.

Last Updated: September 4, 2013