We have that word again – procedures. In federal programs, procedures come up all the time. This time it is in conjunction with comparability.
Comparability is a federally mandated process that requires schools to attest that the Title schools are funded comparably to the non-Title schools, or if all schools are Title, the higher-poverty schools are funded comparably to the lower-poverty schools. The way to do this may vary from state to state, but in Mississippi, we compare the teacher units or the teacher salaries among the schools. Schools are deemed comparable if their student/instructional staff ratio does not exceed 110 percent of the average student/instructional staff ratio of non-Title I schools or Title I comparison schools.
Each district must provide documentation to show it has the following:
- An established LEA-wide salary schedule,
- A policy ensuring there is equivalence among schools in teachers, administrators, and other staff, and
- A policy ensuring there is equivalence among schools in the provision of curriculum materials and instructional supplies.
In addition, the district must have written procedures detailing how comparability is calculated. At a minimum, Mississippi requires the following written procedures.
- Identification of the office and job title of the responsible person for calculating comparability
- A description of how the procedures will be carried out.
- Timelines and/or deadlines
- Who will be responsible for receiving and responding to complaints
- Description of the reallocation process if the LEA has schools that are not comparable
- Identification of the methods and process used for collecting data to demonstrate comparability
- Explicitly identifying the method and grade span (range) that will be used to calculate comparability
- Indicate what data will be used to demonstrate comparability and who will verify the data’s accuracy
- Maintain comparability documentation for a minimum of five (5) years
During a monitoring visit, the auditors will check the procedures against the comparability report to verify the written procedures were followed. For this reason, you will want to review your procedures annually since some of the requirements may vary from year to year based on the data. The method and grade span procedures may vary if you find one method does not prove comparable and you have to use the other method. You may want to write into your procedures something like, “The district will calculate comparability using the student/instructional staff ratio first. The teacher salary method will be used if the student/instructional staff method does not show comparability.”
If you have not completed comparability before, I suggest you follow the guidelines to complete the comparability report and then write your procedures to match what you did. Be sure to include each of the bulleted points in your procedures, and label each procedure with the words from the bullet, so there is no doubt which bullet is being addressed.
To prepare for completing the comparability report, I suggest you make sure the personnel MSIS report is correct with all federally funded employees marked with federal codes. This will make it easier to identify the non-federally funded positions.
I will discuss a little more about comparability next month.