Another Voice in the On-going Comparability Discussion

Here at Ed Money Watch, we have written extensively about the Title I comparability provision. This provision seeks to ensure that Title I schools receive equitable state and local resources compared to non-Title I schools. Comparability has been a popular topic lately, from a recent conference at the Center for American Progress and a new bill that would strengthen the provision introduced in the Senate. The Fordham Institute recently added its divergent voice to the chorus of proposals related to comparability in its new ESEA Briefing Book. Instead of suggesting Congress strengthen the provision, Fordham suggests eliminating it entirely.

Current law allows school districts to meet the federal comparability rule through various methods that do not reflect the actual distribution of state and local funds between low- and high- income schools. These include student-teacher ratios and district-wide salary schedules. Even when districts use per pupil expenditures to demonstrate comparability, they can ignore variation in teacher salary due to years of experience, the most significant driver of teacher pay.

More experienced, and therefore higher paid, teachers tend to work in higher-income schools, while low-income, Title I schools tend to employ less experienced, lower-paid teachers. As a result, higher-income schools receive a greater share of state and local funds to pay for their teachers than low-income schools. But the current comparability requirements never show these inequities. This is known as the comparability “loophole.”

Most proposals to improve comparability include requiring districts to use actual per pupil expenditures, including variation in salary due to experience, to demonstrate comparability. They also want to increase the level of required equity from 90 percent to 95 or even 97 percent. These changes would ensure that Title I schools actually receive equal state and local funding as non-Title I schools.

Fordham also believes that current comparability provisions do not work and should be replaced. However, rather than strengthen the provision, Fordham suggests phasing out comparability entirely and instead requiring school districts to annually report school-level financial data including information on actual teacher salaries. This would provide local parents, teachers, and other stakeholders with the information they need to determine existing inequities and fix them. Strengthening comparability, on the other hand, would be an “enormous new federal intrusion into the operations of local school districts” and would be difficult to monitor.

While Ed Money Watch is the first to champion increased transparency in funding for public education, we can’t help but be skeptical about this proposal. Without a policy lever that requires districts to ensure equitable funding, it would likely be difficult to enforce the redistribution of state and local funds that stakeholders might demand as a result of increased transparency. We have long known that resources are not equitably distributed between high- and low-income schools and yet the inequalities remain.

Similarly, it is important to remember that the parents of students in low-income schools often have the least access to data and information, despite increased transparency. If only parents of students in higher-income schools are advocating for funding, how can we ensure that students in low-income schools will be fairly represented?

It is fair to say that the comparability provision – both the current version and any potential strengthened version – represent a federal intrusion into local operations. But sometimes that intrusion is a necessary means to an important end – ensuring that low-income students receive equitable state and local resources. Until we can ensure that, districts across the country will continue to use Title I funds to fill gaps in funding for low-income schools, instead of to provide the additional services their students need.