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"The difference between compliance and commitment is the difference between a job and a mission."
― Stephen R. Covey
Title I programs are often seen as a compliance checklist – an obligation to fulfill the requirements set forth by the Every Student Succeeds Act (ESSA). However, when we reduce efforts to mere box-checking, we miss the deeper intent of the law: to ensure that all students, regardless of their background, receive an equitable education and meet challenging state academic standards.
Whether it’s completing your district’s Grant Management Application and Planning (GMAP) system application or comparability report, making decisions on uses of funds or using the school-family compact, required activities are in place for a reason. This month’s newsletter is designed to explore some common compliance activities and their purpose.
2025-2026 Title I, Part A Comparability Report Due Nov. 3
ESSA 1118(c) requires districts to provide services using state and local funds to Title I schools that, taken as a whole, are at least comparable to services in schools that are not receiving Title I funds. Districts demonstrate the comparability of services by submitting the required comparability report in each of its schools using general funds.
The window for gathering data for the comparability report is between the last day of the second month of school (a school month is 20 teaching days) and Oct. 31 of the current school year. Often this timeframe will be Sept. 30-Oct. 31, inclusive, but this may depend on district calendars.
The 2025-2026 comparability report checklist, the comparability report guide and the tutorial video can be found on KDE's Title I, Part A Documents and Resources webpage. The comparability report workbook is in the GMAP district document library. Districts must submit the report for approval in GMAP by Nov. 3.
This article focuses on the student enrollment and staff full-time equivalency data to be included in the comparability report, as well as some common errors when completing the report.
Student Enrollment Reports
Enrollment Summary Reports from Infinite Campus (IC) must be run on the selected date for each individual school that must be compared. Be sure to exclude preschool students at all locations.
If schools have half-day kindergarten, those enrollments should only be considered as half-time students. For example, 50 half-day kindergarten students would be documented as an enrollment of 25. It may be necessary to manually handwrite those calculations in your report for documentation purposes.
Save a PDF of each report at the time it’s run. If your district is selected for monitoring, Kentucky Department of Education (KDE) consultants will check that the enrollment numbers provided on the comparability report match the data on the IC report.
Staff Counts
Full-time equivalency (FTE) refers to the percentage of an employee’s salary and is reported in decimal form.
The comparability report looks at the FTE for instructional staff paid with state and local funds. Salaries or portions of salaries paid from any federal funds (Title programs, Individuals with Disabilities Education Act, etc.) are not included in the report.
For the purpose of comparability, the FTE for a full-time staff member paid entirely from state and local funds would be 1.0, whereas a staff member paid 50% from state and local funds and 50% from federal funds would be 0.50. FTE information for instructional staff members assigned to the school who provide direct instructional services to children or who assist or supervise those staff members who provide instruction must be included on the comparability report. This includes, but is not limited to, teachers, principals, librarians, guidance personnel and paraprofessionals.
Preschool teachers should be excluded from the total staff FTE, as the comparability report focuses on grades K-12.
Non-instructional staff – such as administrative assistants, clerical personnel and cafeteria workers – are not included in the report. Refer to pages 10 and 11 of the Title I Comparability Guide for a more detailed list of staff to include and exclude on your report.
It is recommended to create a worksheet that can be used to quickly determine each school’s staffing counts. Refer to the “Comparability Report Instructional Staff FTE Documentation” resource available in the Fiscal Management section of the Title I Sample Documents folder for suggested methods of documentation and templates the districts may use. No matter how you choose to document your staff counts, be sure to maintain that documentation in the event that you are monitored, as it will be used to corroborate the FTEs provided in your comparability report.
Common Errors
Reports will be sent back for correction regarding some of these common errors:
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Date Range: The date reported is outside of the allowable date range. Student enrollment data must be pulled on either the last day of the second school month, or any date earlier than the report deadline. Typically, this is anywhere from Sept. 30-Oct. 31.
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Grade Spans: Grade spans don’t match what is reported in GMAP. Note: the grade span groupings listed on the comparability report are only an example and should be changed, if necessary, to reflect your district’s actual breakdown of grade spans.
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Size Grouping: Size groupings have been used unnecessarily. If there is a significant difference in the enrollments of schools within a grade span – for example, the largest school in the grade span has an enrollment that is two times the enrollment of the smallest school in the grade span – the district may divide grade spans into a smaller size grouping and a larger size grouping. Any school whose enrollment falls between the two can be placed in the size grouping deemed most appropriate.
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Comparison Schools: The wrong schools are listed as comparison schools. For example, not all non-Title I schools in the grade span and group size are listed, or a Title I school that belongs in the high-poverty category is listed for comparison. Reports may get sent back if too many schools are listed as comparison schools. Up to one-half of the lowest poverty Title I schools may be used. It’s possible to use only one Title I school in the grade span for comparison. Instructions and examples of comparison schools are on pages 11-13 of The Comparability Guide.
The final determination from the workbook shows my schools aren't comparable
Don’t panic! Try these possible quick fixes:
- Double check your student enrollment and staff FTEs. Does your math add up? Did you include and exclude the correct students and staff consistently at each location?
- Review your grade span and size groupings. Is there another way to group your schools that makes sense and meets requirements?
- Look at your comparison school(s). Did you list the non-Title I schools or the Title I school(s) with the lowest poverty? Did you list half or fewer comparison schools?
- Run enrollment data from a different day within the date range.
If you still can’t reach comparability, contact your Title I consultant who can walk you through the steps of salary comparison. If, after completing a salary comparison, the district still cannot achieve comparability, adjustments will need to be made in staffing assignments to rectify the inequity.
Exemptions
Districts that have only one school per grade span (or single school districts) do not have to complete comparability for that grade span. This means that some districts in Kentucky may not have to show comparability for any school. A comparability worksheet is still required by the due date, showing that the district is exempt, but the district will not need to maintain staff FTE counts or student enrollment reports.
If no schools within a grade span or size grouping receive Title I funds, the district is not required to calculate comparability for that grade span or size grouping. As the district enters the number of schools in each grade span and size group on the “CR Worksheet” tab, additional tabs will automatically generate if the district is required to calculate comparability for that group.
Principal's Perspective: Compacts at Conferences – Train Your Teachers
Submitted by Denise Harover, Title I, Part A consultant
This section of our newsletter is often dedicated to meaningful parent and family engagement, and rightly so! It is a powerful tool for boosting student achievement. Involving parents as partners in education positively impacts academic performance, behavior and social-emotional skills. This collaboration is essential and required for school success.
ESSA Section 1116 requires schools receiving Title I allocations to develop, in collaboration with parents, a learning compact that outlines how parents, school staff and students share the responsibility for improving academic success. Further, ESSA 1116(d)(2)(A) requires elementary schools to hold at least one parent-teacher conference annually, which must include a discussion of the parent and family engagement compact in relation to the individual child’s achievement.
As a former teacher in a Title I school, I was unaware of the requirement to discuss the compact with parents at a conference, so I never did. The compacts were one more thing to check off my “to-do list” at the beginning of the year. I made sure all parents signed them; then I turned them in and never looked at them again. When I came to KDE, I became aware of this requirement and realized that I had missed the opportunity to use this powerful collaboration tool.
The responsibility of educating children and closing the achievement gap is a heavy load. The school-family compact allows us to share this load with families in a meaningful way. When you go back to review what the compact says and what everyone has agreed they will do, it can be eye-opening to all parties.
Has everyone been doing what they said they would do and fulfilling their part of the agreement? Discussion of the compact allows all parties, including the students, to remain focused on the agreement we all made to put forth our best effort in making sure school is a priority.
As you get into the school year, do not overlook the opportunities the school-family compact can offer. It has the potential to strengthen the relationship between schools and families and increase student achievement. When used as a living document and not just one more piece of required paperwork, it is a support for success.
To ensure that teachers are prepared in advance to effectively use the compact, provide some brief training and clear expectations about how and why to use the compact during parent-teacher conferences. Use the “School-Family Compact Discussion Documentation” in the Parent and Family Engagement folder of the Title I, Part A Sample Documents folder on the Title I Documents and Resources webpage. This resource provides tips on conference invitations, guidance for teachers, creating conference agendas or talking points, and sign-in sheets to document compliance on compact discussions.
Accepting Applications for Diagnostic Review Team Members
The Kentucky Department of Education (KDE) and Cognia are accepting applications for diagnostic review team members to serve during the 2025-2026 school year.
The Cognia diagnostic review process is a performance-driven approach that relies on data from student performance, stakeholder feedback, classroom observations and a review of documents, artifacts and school practices.
Diagnostic reviews yield a comprehensive analysis of an institution in an extensive report intended to energize and guide continuous improvement planning for underperforming schools and districts.
All diagnostic review team members must have experience or expertise in the following areas:
- School or system administration, with a specific emphasis on instructional leadership such as superintendent, principal, instructional supervisor, director of curriculum and instruction, assessment, special education, etc.
- Leading or supporting turnaround/improvement initiatives at the school, system or state department levels.
- Familiarity with the analysis and use of data as a driver for improvement.
Diagnostic review team members are required to complete specialized training. While there is no compensation for participating as a diagnostic review team member, all expenses associated with travel for an onsite visit will be reimbursed by Cognia.
If you are interested in serving in this capacity, please begin by submitting your contact information on the diagnostic review team member interest form.
We will send next step information to support you through the training process. There will be multiple training options available throughout the next few months in preparation for reviews scheduled for the 2025-2026 school year.
If you have questions, please email the Cognia team.
Open Title I, Part A Projects and Associated Deadlines
Please review the table below and make note of the approaching deadlines regarding the obligation and expenditure of funds from all open Title I, Part A projects.
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Fiscal Year (FY)
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Period of Award
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85% Obligation
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All Funds Spent or Encumbered
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Final Federal Cash Request
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FY2024
(Project 310K)
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July 1, 2023 - June 30, 2026
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Sept. 30, 2024
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June 30, 2026
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Aug. 31, 2026
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FY2025
(Project 310L)
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July 1, 2024 - Sept. 30, 2026
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Sept. 30, 2025
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Sept. 30, 2026
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Nov. 13, 2026
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FY2026 (Project 310M)
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July 1, 2025 - Sept. 30, 2027
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Sept. 30, 2026
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Sept. 30, 2027
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Nov. 12, 2027
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