What if We Closed the Title I Comparability Loophole?

June 2008

Recent evidence on district spending practices suggests that Title I's key comparability provision is not doing its intended job. A key question facing policymakers today is if and how to modify the comparability provision to ensure that districts give high-poverty schools a fair shake.

Marguerite Roza's paper explores why the current Title I program's comparability provision falls so short of what is needed, and the reasons for modifying it. She discusses why federal leadership is important, and outlines budgeting and funding considerations that need to be taken into account in making a change. Roza then explores the likely effects of these proposed changes on high-poverty schools. In the end, she suggests that the best way to restore the comparability guidelines of Title I to their original intent is by requiring school districts to equalize per-pupil dollar expenditures before accepting federal funds. In this way, the federal government can be proactive without micromanaging the budgeting processes of myriad local school districts.

This paper is one of four in a Center for American Progress volume that thoroughly examines the federal and local "comparability" issue.

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