001Welcome to TEA's Federal Fiscal Compliance and Reporting Division's presentation on the ESSA fiscal compliance requirements for the title one part A comparability of services. This presentation will provide a high-level general overview of the comparability process from start to finish. Let's begin. This is TEA's standard legal disclaimer. It states that this presentation is intended to provide general information and guidance to Texas school systems. It reflects TEA's current understanding of the federal guidance. The content is subject to change with changes in the law and it is not legal advice. This is TEA's AI disclaimer. It states that this presentation is not to be recorded or used to train any AI technologies and such action could result in attendees being banned from attending future trainings. This presentation will cover a number of topics. We will begin with what
002title one part A comparability is and the applicable federal citation. I will explain what an exempt school system is and talk about exemption criteria and show you a few examples. We'll talk about the comparability assurance document that most school systems will be completing. We'll talk about what a non-exempt school system is and how to determine compliance by doing the comparability testing steps, establishing the grade span groupings, completing the CCFs, reviewing your CCF results, and submitting that CCF to TEA. So, we'll be talking about the comparability process from start to finish. and let's begin. Title one part A comparability of services is a federal fiscal requirement that applies to all school systems that receive Title One Part A funds. The fiscal requirement states that all Title One Part A campuses and skip campuses must receive the
003same level of service through state and local funds as those campuses that are not receiving Title One Part A funds. Public Law 115-64 section 1118C outlines the comparability of services requirement for school systems. A few of the highlights from this section of the law are that services provided with state and local funds in title one part A schools must be comparable to services in schools that do not participate in the title one part A program. That all Title One Part A schools must demonstrate comparable services at all campuses on an annual basis. and that you must provide assurance of equivalence and are also required to develop procedures for compliance as well as m maintain and update those records annually. I will go into more detail on each of the requirements in the upcoming slides, but
004please keep in mind that the comparability process is a review of current year data as we go over the next information. So as mentioned in the previous slide, the requirement states that a school system must demonstrate comparable services at all campuses on an annual basis. This means that all services provided with state and local funds in title one part A schools must be comparable to the services in schools that do not participate in the title one part A program. If a school system serves all schools with title one part A funds, services provided with the state and local funds must be substantially comparable in each title one part A school. The way a school system shows they are in compliance with the comparability requirement is by completing and submitting the comparability computation form the CCF
005to tea. The requirements for completing and submitting the CCF can be found on TEA's comparability website. You will find the CCF template, which is an Excel format, a link to the CAD training videos, as well as the comparability instructions and comparability guidance handbook. Reviewing these two documents will assist you in ensuring compliance with this requirement. Moving on, the requirement also states that the school system must annually provide assurance of equivalence. What this means is that all title one part A schools must establish a schoolwide salary schedule. A policy that ensures equivalence among schools with regard to teacher, administrator, and other staff and a policy that ensures equivalence among schools in provision of curriculum materials and instructional supplies. The way a school system proves they are in compliance with this part of the requirement is by
006submitting the comparability assurance document, the CAD, which is an online survey that includes a written assurance that the school system has established these items. Written and thorough guidance on completing and submitting the CAD can be found on TEA's comparability website in the comparability instructions document. The CAD is an online survey that is sent to school systems via a to the administrator address letter which includes a link to the survey. You can also find the link in the GFC application under the responses templates tab or on TEA's comparability web page. Part of the requirement we are going to cover is developing written procedures for compliance. Your procedures must identify a tier clear timeline for your process and who is responsible for the calculations. You will need to describe the process that was used to determine if
007title one part A schools are comparable and how and when the school system makes adjustments in schools that are found to be not comparable. All Title One Part A schools are required to review, update, and maintain their records every year. This includes the schoolwide salary schedule, the policy to ensure equivalence with staff every year, the policy to ensure equivalence and provision of curriculum materials and instructional supplies, and the procedure for complying with the comparability requirement. So, moving on from the recordkeeping part of the requirement, um you will want to determine if your school is a non-exempt school or an exempt school. In order to be an exempt school system, you must meet at least one of the exemption criteria. If your school does not receive any Title One Part A funds, you are an exempt
008school system. If your school has one campus in each grade span, this means one elementary, one middle, one high school, or maybe even less campuses, you are an exempt school system. If your school has multiple campuses in any grade span group, elementary, middle, or high, but there is no overlap in the grade levels like second, third, and fourth, you are an exempt school system. If your school does have an overlap in grade spans, but maybe there are no Title One Part A campuses in the grades span group where the overlap occurs, then again, you'd be an exempt school system. Another scenario would be if your school system excludes a campus and we will talk about excluding campuses in an upcoming slide. Um if excluding a campus results in no basis for comparison, you are an
009exempt school system. And I kind of just want to reiterate or remind everyone that comparability is a comparison among campuses. We group the campuses in a grades span group, create an average, and then compare the campuses serving the same grades spans to each other. That's the way the testing works. If you are an exempt school, you are exempt because there is nothing to compare. Therefore, you're exempt from the testing part of the comparability requirement. Each school school system still is required to submit a CAD that claims their exempt status and ensures they have established their required policies and procedures. Okay. Exemption number two was is one campus per grades span. So in this example here, the school system is exempt from testing because there's only one campus per grades span group. There is only one
010elementary school campus and only one middle school campus and only one high school campus. They are excluding from testing because no campuses are saving serving the same grade level students. So there's nothing to compare it to. Number three is when a school has multiple campuses per grade span group but no overlap in grade levels. As you can see in this example, there are three elementary campuses in the elementary grades group, but each campus serves a different grade level, so there is no basis for comparison. This school system is exempt from comparability testing. Exception number four is when a school system has overlapping grade levels, but those overlapping grade levels are all not title one part A or skipped campuses. So in this example, you see two elementary campuses, two middle school campuses, and one high
011school campus. The middle school grades span group is exempt from testing because both middle school campuses are not title one part A campuses. You'll also notice in this example there are two elementary schools. But because the two elementary campuses do not overlap at a certain grade level, the elementary campuses are exempt from testing and there is only one high school campus. So this is an example of another exempt school system. Okay. An example of exemption number five, which is when a school system excludes a campus that then results in oasis for comparison. So in this example, there's two middle schools with an overlap in grade span cuz middle school 6 has more than twice the enrollment of middle school 5. So both campuses are excluded from comparability testing making the school system an exempt school
012system. So all school systems exempt or non-exempt that receive any title one part a funds are required to submit a comparability assurance document also known as a CAD. The CAD is an online survey where each school system will claim their exempt or non-exempt status and sign an assurance stating that they have prepared and implemented the required policies and procedures, the schoolwide salary schedule and the general asurances. So, if you meet any of the criteria discussed on the previous tabs, you would complete the CAD as an exempt school system. And if you do not meet any of those criteria, you're a non-exempt school system and you'd complete the CAD that way. All school systems who receive Title One Part A funds are required to submit the comparability insurance document, the CAD. However, non-exempt school systems are
013also required to submit the comparability computation form, the CCF. The CAD is an online survey where you claim your status and signs assurances. And the CCF is an Excel template where school systems enter data from their local accounting system to show that they are compliant with the fiscal requirement. The CCF consists of three test options a school system can use to show that their campuses are comparable to the others. Test one is a comparison of state and local expenditures per pupil across campuses in the grades span group. Test two is a comparison of pup per pupil expenditures for state and local base salaries and test three is a comparison of ratio of pupils to non-federally funded instructional staff. In order to be in compliance with the fiscal requirement, a school system has to pass only
014one of the three test options. Campuses that have not been excluded must be included in a gradespan group. You will need to determine your grades span groupings. You will group your elementary campuses together, your middle school campuses together, and your high school campuses together. Keeping in mind when placing campuses in the appropriate group, if your campus overlaps two grades span groups, it is to be placed in the group where the highest number of students are enrolled. Some school systems may be eligible to subdivide a grades span group into a high enrollment subset and a low enrollment grades span group if the highest campus enrollment in the grades span group is more than double the smallest campus enrollment. >> The next thing you want to do is gather the data needed to complete the testing. All
015three tests use the same enrollment data to perform the comparability testing. Test one uses that enrollment data in addition to state and local expenditures per campus. Test two uses the campus enrollment data and campus base salaries for nonfederal instructional staff. And test three uses the campus enrollment data in addition to the campus non-federal instructional staff FTEES. Be sure to determine any exclusions that may apply. An exclusion, not to be confused with an exemption, an exclusion happens at the campus level, and a campus has to meet specific criteria to be exempt. For example, a campus with less than 100 students enrolled can be excluded from testing. You may also exclude certain state and local supplemental funds and any sal staff salary differential for years of employment. As mentioned, it's the base salary. A few things to
016consider in your grades span groupings is subdividing a grades span group into a high and low enrollment split. If a system has a gradespan grouping with a substantial difference in enrollment between the largest and smallest campuses to qualify to use the high low enrollment split, the highest enrollment campus has to have at least twice the enrollment of the lowest enrollment campus. And you can split the group into a high and low enrollment groups, leaving at least two campuses on either side of the split to perform the comparison. And another thing to consider is when a campus overlaps more than one gradespan group. If a campus overlaps more than one gradespan grouping, then the school system should place the campus in the grouping that most accurately represents the makeup of the campus. So what this means
017is if the campus overlaps two grades span groups, you place it in the group where the most students are enrolled. All right. The comparability testing is done on the comparability computation form referred to as the CCF. And the CCF is an autoc calculation Excel form. You enter your test test data and the spreadsheet performs your calculations and does the testing and displays the results. So the CCF includes tabs um for reminders, you know, things to remember when you're completing it. Uh there are testing tabs A through I and this is where you enter your campus data and you'd enter each grade span group on a different tab and then there is an excluded campuses tab where you enter all excluded campuses on this tab including the reason for the exclusion. And then you want to
018enter your campus data on the grades span grouping tabs. So you'll begin by entering the three-digit campus number for all campuses in the grades span group. You're going to enter the name of all campuses. And you're going to indicate whether the campus is a title one or skipped campus. And if so, you would enter a Y in that column indicating yes, it is a title one or skipped campus. And if the campus is not title 1A part A or skipped, then you would leave it blank. You're going to enter the campus enrollment number from a specific date in the current year, making sure that all campuses across all groups must use enrollment data from the same date. And be sure to enter the grades span group in the designated box at the top of the
019CCF. And the last thing you will enter is the appropriate test data for test one, two, or three, keeping in mind that only one test has to meet the compliance standard to pass comparability testing. Once you have entered your data, the last step is to review and analyze the results. If your grades span group consists of a mix of title one part A campuses and non-title one part A campuses, you will review your test results in the green section A test results columns. And you will only see test results for those campuses that are title one part A or skipped campuses. the non-title one campuses uh test results will be blank. So if all the test results say yes, that means you're in compliance with the requirement. If the grades span group contains all title
020one part A skipped campuses, not mix, it's all. You will review your results in the blue B section test results columns. And once again, all yeses uh must be displayed in order to pass the test. So once your CCF is complete and you've entered all your campus data and you're all passing the same test, you'll upload the CCF into the GFFC application in TIL. You'll log on to TIL. You'll select GFC reports and data collections. Once you're in the application, on the top horizontal toolbar, you will select the upload response template option. You'll select comparability computation form from the drop-own menu. You'll put in the current school year. Label it as a response document and upload it into the application. And you are complete with your comp. Thank you for listening to the Title One
021Part A comparability general overview. Be sure to visit our other trainings which provide more detail about the different parts of the comparability process. If you have any questions or need assistance, you can reach us at compliance tea.ex.gov. Thank you.