Fixing Title I Should Start with Supplement, Not Supplant and Comparability

This post has been updated.

Title I of the Elementary and Secondary Education Act (currently known as No Child Left Behind) is the largest federal K-12 grant program at $14.5 billion annually. The program aims to provide additional funding for services for low-income students, and approximately 17 million children receive Title I services. As Congress prepares to reauthorize the Elementary and Secondary Education Act (ESEA), Title I is likely to play a starring role in the debates over changes to the law. Last week, the Center for American Progress and the American Enterprise Institute hosted an event that explored various issues surrounding Title I including recommendations for improving the existing program. Perhaps most central to the discussion was the panel on the fiscal requirements of Title I, “supplement, not supplant” and “comparability.” Though both requirements are intended to work together to ensure that Title I funds are used properly, the currently over-cautious implementation of supplement, not supplant could undermine attempts to strengthen the comparability provision.

Supplement, not supplant refers to a requirement that districts use Title I funds to add new services rather than replace state and local funding for services. In theory, this requirement makes sense – districts should not be allowed to replace state or local funding for education services with Title I funds. In practice, however, the supplement, not supplant provision, which is enforced through an audit process, prevents districts and schools from implementing new and innovative educational interventions and programs. Essentially, auditors examine school and district budgets to ensure that Title I funds are not used to support expenditures that were previously funded through other sources.

Comparability, on the other hand, is intended to ensure that school districts provide equitable resources to low-income and higher-income schools before the addition of federal Title I funds. However, the methods currently in use to test comparability ignore actual funding by relying on alternative resource measures like student-teacher ratios and teacher salary schedules. Most importantly, comparability currently allows districts to ignore variation in teacher salaries across schools due to years of experience. Because more experienced, and therefore more expensive, teachers tend to work in higher-income schools, low-income schools tend to receive less funding.

Until now, there has been little evidence available on the extent to which the current comparability provision allows for drastic resource inequities between high- and low-income schools. “Sunshine for the Sunshine State: Evidence of fiscal inequity within Florida’s public school districts,” one of the papers presented at Friday’s conference, provides an in-depth look at these inequities in Florida. Specifically, the paper finds that teachers in low-income schools in Florida do indeed have lower salaries than teachers in higher-income schools. For example, an analysis conducted in the paper shows that an average teacher in an average school in Florida with a 70 percent poverty rate would be compensated $1,065 less than an average teacher at a school with a 20 percent poverty rate.

The paper also examines variation in per pupil expenditures in low- and higher-income schools. Although the analysis suggests that schools receive $56 more per pupil, on average, for every 10 percentage point increase in poverty rate, this does not suggest that comparability is actually achieved in these schools. The per pupil expenditure amount includes Title I funding, which means one would expect low-income schools to receive more per pupil than higher-income schools. However, the difference – $56 – is likely not large enough to suggest that state and local funds provided equitable funding before the addition of the Title I dollars.

Based on this evidence, it is clear that the current comparability provision is not rigorous enough to ensure equitable funding for schools. The paper suggests changing the provision to require districts to submit data on actual per pupil expenditures, including variation in teacher salary due to experience, to demonstrate comparability. Districts should also be prohibited from forcing teacher transfers to achieve comparability. Instead, districts and schools should be able to look to other, non-teacher salary related expenditures to provide services to low-income students.

In the end, supplement, not supplant is a major barrier to making these changes. Until schools and districts are able to more freely spend their Title I funds without fear of audit violations, Title I expenditures will remain tied to traditional services like teacher salaries. Though supplement, not supplant is rooted in reasonable fears about district manipulation of federal funds, the lack of flexibility is handcuffing district and school leaders. Congress and the Department of Education need to find a better way to implement the provision. Once that is complete, improvements to comparability and other aspects of Title I will be easier to achieve.