SystemAccreditation, Institutional Research & Accountability

Title I Comparability & Supplement-Not-Supplant Review

Title I comparability tested on every school and every position, and each Title I purchase checked against your district's own method, before the state report

Every Title I school inside the 110% band before the state report, every purchase checked.

See one case, screen by screen ↓
demo115.8%Harrow Glen Elementary's share of the non-Title I average, before the agents found two teachers coded to the wrong fund
target6,100positionschecked against payroll and the Title I budget on every run
target812requestsTitle I purchase requests checked against the district's method since July 1, each with its citation
target27daysbefore the December 1 state deadline, with 37 of 37 Title I schools inside the 110% band
In short

What is Title I Comparability & Supplement-Not-Supplant Review?

Title I Comparability & Supplement-Not-Supplant Review is a solution that runs a district's Title I comparability test and checks every Title I purchase before state monitoring. Six agents read October 1 enrollment, every position and the payroll, line every school up against its grade span's non-Title I average and the 110% limit, model fixes for the schools outside, and cite the district's method on each purchase request. The Federal Programs Director approves and the Chief Business Officer co-signs before the report goes to the state.

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Updated

The problem

Why the Title I comparability test is slow and risky today

Title I comparability is the condition behind every Title I, Part A dollar: under ESSA section 1118(c), state and local money must give a district's Title I schools services at least comparable to its other schools, and under section 1118(b) Title I may not pay for what state and local funds would otherwise provide. In the common method, a Title I school is comparable if its students per state- and locally funded instructional staff member does not exceed 110% of the non-Title I average for its grade span, counted on the same day, usually October 1.

Each fall the federal programs office rebuilds that test by hand: two exports from the student information system and HR, federally funded staff stripped out by fund code, ratios typed into the state workbook, then weeks of email to fix the outliers before the deadline. A position coded to the wrong fund silently takes a teacher out of a Title I school, staffing changes after October go unchecked, and Title I purchase requests are screened one at a time, rarely with a citation to the district's own method. Title I Comparability & Supplement-Not-Supplant Review puts six agents in front of that work, so the director spends November deciding, not rebuilding.

typical18billion dollarsa year in Title I, Part A funds go to districts that must show comparability
typical110%of the non-Title I average is the most a Title I school's students per staff member may reach in the common method
typical3yearsafter the grant period, or after findings resolve, the staff lists and calculations must be kept
Where a district's comparability working days goestimated
By hand27 days
With the solution2.1 days
  • Pulling same-day enrollment and staff counts from two systems3 → 0.1 d
  • Stripping federally funded staff by fund code4 → 0.2 d
  • Filling the state workbook by grade span3 → 0.1 d
  • Finding and fixing the schools outside the band10 → 1 d
  • Approval, co-signature and submission to the state2 → 0.2 d
  • Gathering the evidence a state monitor asks for5 → 0.5 d

Estimated split of a mid-sized district's working days on one year's comparability test, by hand and with the agents. Our arithmetic, kept modest; the fixes still wait on people.

How it works

How the comparability test runs each fall

Six agents read every position, line up every school and check every Title I purchase; HR corrects, the director decides, the business officer co-signs.

What comes in
What arrives5 sources · enrollment, positions, payroll, grants and the district method
Agents at work
Staff agentfund codes against payroll
Then
Comparability agentratios by grade span
Supplant agentpurchases against the method
Then
Fix agentoptions, cost and ripple
Then
Monitoring pack agentevidence for the state
A person decides
HR corrects, the director decides, the business officer co-signsmaker and checker on every change
What comes out
Every school inside the band
Report sent to the state
Monitoring pack
One case, step by step

One year's Title I comparability test, from count day to the state report

Marlow Bay Unified School District has 62 schools, 38 of them Title I, about 48,000 students and 6,100 positions. It is Wednesday, November 4, 2026; the count day was October 1 and the state report is due December 1. Here is the morning, screen by screen, in the working solution.

  1. 016:10 AM

    Every school on one line before the office opens

    Six agents

    The agents read 48,000 October 1 enrollments, 6,100 positions and the October 15 payroll, and line up 61 tested schools against their grade span's non-Title I average: elementary 17.1, middle 19.4, high 21.2 students per staff member. Bayside Alternative High School, 74 students, is left out under the 100-student floor.

    35 of 37 tested Title I schools are inside the band; 2 are outside.

  2. 02First look

    Harrow Glen Elementary, at 115.8%

    Teresa Vance · Federal Programs Director

    Harrow Glen is a Title I schoolwide program where 81% of students come from low-income families. Its file shows 517 students on October 1 and 26.1 FTE of state and local instructional staff: 19.8 students per staff member against 17.1. Every staff group is marked counted or excluded, with the reason, and two classroom teachers are excluded with their fund code under review.

  3. 03Behind the number

    Every position checked three ways

    Staff agent

    The Staff agent read 31 instructional positions at Harrow Glen and matched each to the October 15 payroll. Two disagree: POS-40217 (grade 3) and POS-40218 (grade 4) are coded to Fund 211, Title I, in position control, but payroll pays both from the general fund. Budget revision BR-26-14 canceled those Title I class-size lines in June, and position control was never updated.

    Checked the Title I budget: no class-size teachers at Harrow Glen. Confidence 0.97.

  4. 04One click

    The payroll record behind the flag

    Teresa Vance

    Clicking Fund 101 in the positions table opens the ERP payroll distribution for the pay period ending October 15: POS-40217's gross pay charged 100% to 101-1110-100-118, General Fund, regular instruction, Harrow Glen, the same account every pay period since August 1. The copy is kept with this year's test, and the opening is logged.

  5. 059:14 to 9:15 AM

    HR recodes, the budget analyst checks

    Dana Whitlock · HR Position Control Manager

    Dana recodes both positions from Fund 211 to Fund 101 in position control; the agents never change a position record. Priya Natarajan, the Budget Analyst, checks the change against payroll, because the maker cannot check her own change. The school recalculates at 28.1 FTE and 18.4 students per staff member, and Teresa accepts it with reason C1.

    Harrow Glen: 115.8% to 107.6%, inside the band. These two are the only disagreements among all 6,100 positions this year.

  6. 0627 days to go

    Three ways back inside the band at Linden Park

    Fix agent

    Linden Park Middle School sits at 112.4%; its codes are right, but two locally funded positions have been vacant since August. The Fix agent models three options with the ratio after, the cost, the certainty before December 1 and its confidence. Filling the vacancies has low certainty (0.41); moving two teachers from Sterling Knoll Middle School reaches 107.3% but moves the middle-school average from 19.4 to 19.5 and changes teachers for 54 students.

    Recommended: pay two Title I reading interventionists from the general fund from the November 15 payroll. 108.1%, $171,800, confidence 0.93.

  7. 079:18 AM

    The director decides; the business officer co-signs the money

    Malcolm Reyes · Chief Business Officer

    Teresa decides option B with reason F2, add or re-fund with local funds; the system refuses a decision without a reason code. Because it moves general fund dollars, Malcolm co-signs the $171,800, which frees the same amount of Title I for the school plan's tutoring. Linden Park recalculates at 108.1%.

  8. 08Next in the queue

    A Title I purchase that would supplant, with the paragraph

    Supplant agent

    REQ-27-0814 asks Title I to pay $38,400 for core reading program consumables, K to 2, at Harrow Glen. The Supplant agent checked the district's method, state requirements and the school plan: the method buys the adopted core reading program for every school from the general fund (section 3.2). Teresa accepts the verdict with reason S3, and Priya confirms the account change in the ERP.

    Would supplant, confidence 0.94: Title I would pay for what Harrow Glen gets anyway.

  9. 099:22 AM

    Approved, co-signed and sent to the state

    Teresa Vance and Malcolm Reyes

    The report preview shows every grade span inside: elementary 26 of 26, middle 7 of 7, high 4 of 4, with three adjustments documented and the assurances attached. Priya built the test, Teresa approves with reason A1, Malcolm co-signs, and Teresa submits to the state reporting portal: confirmation SRP-2026-118734.

    37 of 37 Title I schools inside, 27 days before December 1.

  10. 10Audit-ready

    Who did what, when, why and on which evidence

    Leon Park · Internal Auditor

    Every step of the morning is on a trail that cannot be edited: the recode, the check, each recalculation, the fix and its ERP budget transfer BT-27-0093, the co-signatures and the submission, each with its reason code. Leon reads everything, exports the trail as CSV, and changes nothing.

Who it’s for

Built for everyone who signs the comparability report.

The same test, seen by the five people who carry it: what their November looked like, and what it looks like now.

TV
Teresa VanceFederal Programs Director · owns the test and the December 1 report
Federal Programs Director
Before
Signs that every Title I school is comparable from a workbook she cannot trace back to a position.
Now
Sees every school on one line, opens the position and payroll record behind any number, and decides every fix and purchase verdict with a reason code.
MR
Malcolm ReyesChief Business Officer · co-signs the report and every fix that moves money
Chief Business Officer
Before
Is asked to approve general fund moves late in November, with the cost and the reason in separate emails.
Now
Sees each option's cost to the general fund, its certainty and its effect on the comparison average before he co-signs.
PN
Priya NatarajanBudget Analyst · builds the test and checks every position change
Budget Analyst
Before
Strips federally funded staff out of an export by fund code, by hand, and finds a stale code only when a ratio looks wrong.
Now
Gets the disagreement between position control and payroll first, with the reason, and checks every change HR makes before the school recalculates.
DW
Dana WhitlockHR Position Control Manager · corrects position records at the source
HR Position Control Manager
Before
Hears that a position is miscoded without being told which field is wrong or what payroll says.
Now
Receives a correction that names the positions, the fund, the effective date and the payroll evidence, and fixes it in position control.
LP
Leon ParkInternal Auditor · reads everything, changes nothing
Internal Auditor
Before
Rebuilds who changed what, and why, from emails and workbook versions when the state monitor asks.
Now
Filters the trail by people or agents and exports it, with each decision's reason code and evidence.
Built on the engine

6 agents. Each with one job, and hard limits.

Six agents read every position, line up every school and check every Title I purchase; HR corrects, the director decides, the business officer co-signs.

Comparability coordinator

Plans each run, keeps the December 1 clock and routes work to the other agents and to the people who decide.

  • Never approves or submits
Staff agent

Reads every position from HR and position control, matches it to the ERP payroll and the Title I budget, excludes federally funded staff by fund code, and flags any disagreement with its reason.

  • Never writes a position record
  • Below 0.90 confidence, a person decides
  • Staff names only in restricted views
Comparability agent

Computes students per state- and locally funded instructional staff member by grade span, and recalculates after every position change.

  • Same-day enrollment and staff only
  • Below 0.95 confidence, a person decides
Fix agent

Models staff moves and local fund changes for any school outside the band, with the ratio after, the cost, the certainty before the deadline and the effect on the comparison average.

  • Proposes only; a person always decides
  • Any fix that moves money needs the business officer's co-signature
Supplant agent

Reads each Title I purchase request against the district's method for state and local funds, state requirements and the school plan, and drafts a question to the school when a fact is missing.

  • Cites the paragraph for every verdict
  • Below 0.85 confidence, a person decides
  • Never approves a request
Monitoring pack agent

Drafts an answer to each fiscal indicator the state monitor reviews, with its evidence, and builds a state copy and a redacted board copy.

  • A person accepts every answer
  • The board copy redacts staff names
Federal Programs Director

Decides every fix and approves the test. The agents propose; a named person decides.

Ask in plain words

Ask about any school, position or purchase

Ask in plain words. Every answer cites its source, and the assistant can take you to the screen where you act.

Why is Harrow Glen outside the band?

Position control codes two Harrow Glen teachers, POS-40217 and POS-40218, to Title I, so the test leaves them out. Payroll pays both from the general fund, because the June budget revision canceled those Title I lines. Corrected, Harrow Glen sits at 107.6%.

Which Title I purchases does the district already fund?

Three waiting requests pay for what the method gives every school: core reading consumables at Harrow Glen ($38,400), literacy screener licenses at Seacliff ($6,950) and lab safety equipment at Coral Ridge ($9,800).

What if we move two teachers from Sterling Knoll to Linden Park?

Linden Park would reach about 107%, but the middle-school comparison average also moves, from 19.4 to 19.5, and 54 students change teachers in November. Paying two Title I interventionists from the general fund gets to 108.1% from the next payroll.

Build the state monitoring pack

Six sections: the calculation, staff lists, adjustments, procedures and the method, purchase decisions and the audit trail. Each page cites its source.

Every screen

The working solution, as it ships.

13 screens from the working solution, on its sample data. Pick one to see it large.

Every school on one line against the 110% comparability limitMarlow Bay Unified's 61 tested schools as dots on one axis of students per state- and locally funded instructional staff member, as a share of the non-Title I average for each grade span. A dark line marks the average, a shaded band runs to the 110% limit, Harrow Glen (115.8%) and Linden Park (112.4%) sit outside it, and the supplement-not-supplant check runs down the right.
One school's file: who is counted, the ratio and what the agents foundHarrow Glen Elementary, a Title I schoolwide program: 517 students, 26.1 FTE, 19.8 students per staff member against 17.1. Every staff group is marked counted or excluded with the reason, beside three years of history and a box to ask the agents.
Every position checked three ways: position control, payroll and the Title I budgetThe Staff agent's run for Harrow Glen, step by step. Two classroom teachers show Fund 211 (Title I) in position control but Fund 101 (general fund) in the October 15 payroll, and the proposed correction waits for HR, the budget analyst and the director.
Click any value to see the source passageThe payroll record behind the flag: the pay period ending October 15 charges POS-40217 entirely to the general fund account for regular instruction at Harrow Glen, the same account every pay period since August 1.
Maker and checker: HR recodes, the budget analyst checks, the director acceptsAfter Dana Whitlock recodes the two positions and Priya Natarajan checks them against payroll, Harrow Glen recalculates at 107.6%, inside the band. The Staff agent checked all 6,100 positions the same way, and these two are the only disagreements this year.
Three modeled ways back inside the band, with cost, certainty and rippleLinden Park Middle School at 112.4% of the middle-school non-Title I average of 19.4. Fill the vacancies, pay two Title I interventionists from the general fund, or move teachers from a non-Title I school, which would raise the comparison average itself.
The director decides with a reason code; the business officer co-signs the moneyOption B decided by the Federal Programs Director with reason F2 and co-signed by the Chief Business Officer, because it moves $171,800 of general fund dollars. Linden Park recalculates at 108.1%.
The supplement-not-supplant review of every Title I purchase request812 requests checked since July 1: 741 supplemental, 52 needed evidence and 19 moved to state or local funds. Each waiting request shows the Supplant agent's verdict, its reason in one line, the confidence and a citation, with filters, search and bulk decisions for the 46 still waiting.
One request, the agent's reasoning and the decisionREQ-27-0814, core reading program consumables K–2 at Harrow Glen, $38,400 on a Title I account. The agent's four checks end in Would supplant, confidence 0.94, citing section 3.2 of the district's method, beside Ask the school, Override and Accept verdict.
Approved, co-signed and submitted to the state reporting portalThe comparability report previewed by grade span with the assurances attached, and four steps signed in order by different people: the budget analyst built it, the director approved it, the business officer co-signed it, and it went to the state with confirmation SRP-2026-118734.
Each state monitoring indicator answered, with its evidenceEight fiscal indicators, from written comparability procedures to records kept three years, each with an answer drafted by the agent, its evidence marked complete, and an Accept button for the director.
An audit trail of who did what, when, why and on which evidenceEvery action by a person or an agent, newest first, each with its reason code and evidence: the recode, the check, the recalculations, the fix, the co-signatures and the submission. Filter by people or agents and export as CSV.
Roles and separation of duties, set by the districtWho can do what, and what each role can never do: the maker of a change can never be its checker. Tabs hold the test rules, fund codes, time limits and alerts, privacy and retention, and the agents' versions and confidence thresholds.
Governance

Built for Title I monitoring: cited, checked, co-signed.

Seven roles, separated by dutyHR corrects position records; the Budget Analyst builds the test and checks every change; the Federal Programs Director decides fixes and purchase verdicts and approves; the Chief Business Officer co-signs; principals request purchases and see only their own school; the internal auditor reads and exports; the administrator runs settings and makes no decisions.
A second person on every change that mattersA recode is checked by someone other than the person who made it, every fix and ERP account change that moves money is co-signed, and the report needs two different people to approve and co-sign. The test stays blocked while any Title I school is outside the band.
Every number cites its sourceClick any value, from a school's 517 students to a payroll account, and the source opens with its system, date and highlighted passage. Every purchase verdict names the paragraph of the district's method it rests on.
Staff and student privacy by defaultStaff names and salaries are visible only to HR, Budget and the Chief Business Officer, and every view of a staff record is logged. Student records stay in the student information system: the test uses school-level counts only, under FERPA, and the board copy redacts staff names.
Agents read, people decideThe agents read the systems of record and never write to them. Every verdict carries a confidence, anything below the agent's threshold goes to a person, and an override needs a reason code. New instruction versions run on last year's test first and must match its approved result.
An audit trail a state monitor can testWho, what, when, why and which evidence, for people and agents alike, exported as CSV or as a monitoring pack: a state copy with names and a redacted board copy. Records are kept three years after the grant closes or findings resolve, with legal hold available.
Configuration

Your district's comparability method, not ours

The test rules, fund codes and time limits are settings. A change is proposed as a new version, and a second administrator approves it.

SettingDefaultChoose from
MethodStudents per state- and locally funded instructional staff memberSalary or per-pupil methods, 90–110%
Limit110% of the non-Title I averageAs your state's method sets it
GroupingBy grade span: K–5, 6–8, 9–12Or by size group
Count dayOctober 1, enrollment and staff on the same daySet per year
Excluded staffFull salary from federal funds; non-instructional paraprofessionalsSpecial education excess cost, district choice; a split position counts only its state and local share
RecalculateDaily until submitted, and after every position changeLogged with each run
State report dueDecember 1Alerts 30, 14 and 7 days before
Time limitsFund-code correction 2 business days, then the directorFix decision 2 days, purchase verdict 3 business days, co-signature 2 days
Connections

Works with the systems a federal programs office already runs on

Student information systemOctober 1 enrollment, by school and grade
HR system and position controlstaff, assignments, each position's school, FTE and fund code
ERPpayroll distribution and budget accounts
Grants management systemthe Title I budget and purchase requests
Document managementboard policies, the allocation method and school plans
State reporting portalthe comparability report form and its receipts
What it changes

The difference, in numbers.

Every figure is labelled: a target the solution is built to, an estimate, a typical published result, or a proven one.

target
27days
before the state deadline, the test approved with every Title I school inside
TodayThe last week
With agentsNov 4, for Dec 1
target
6,100positions
checked against payroll and the Title I budget on every run
Every position
three records each
target
812of 812
Title I purchase requests checked against the district's method, each cited
Every request this year
19 moved to state or local funds

Sources: ESSA sections 1118(b) and 1118(c) (20 U.S.C. 6321) · state comparability guidance (110% test, same-day counts, federally funded staff excluded, schools under 100 students excluded, report due December 1, funds may be held, records kept three years) · U.S. Department of Education, Supplement not Supplant under Title I, Part A (June 2019) · U.S. Department of Education, Title I, Part A appropriation, about $18 billion a year · "demo" = seen in the working solution, on its sample data · "target" = design goal, measured in the live solution · "typical" = published figures and rules · "estimated" = our arithmetic, kept modest. Marlow Bay Unified School District, its schools and the people named on this page are fictional: characters and sample data in the working solution.

Questions

What federal programs offices ask us.

What is Title I Comparability & Supplement-Not-Supplant Review?

Title I Comparability & Supplement-Not-Supplant Review is a solution that runs a district's Title I comparability test and checks every Title I purchase before state monitoring. Six agents read October 1 enrollment, every position and the payroll, line every school up against its grade span's non-Title I average and the 110% limit, model fixes for the schools outside, and cite the district's method on each purchase request. The Federal Programs Director approves and the Chief Business Officer co-signs before the report goes to the state.

What is a Title I comparability report?

It is the report a district sends its state showing that, under ESSA section 1118(c), state and local money gives its Title I schools services at least comparable to its other schools. In the common method, each Title I school's students per state- and locally funded instructional staff member may not exceed 110% of the non-Title I average for its grade span, with enrollment and staff counted on the same day. Several states require it every year, some by December 1.

What does supplement not supplant mean for Title I?

Under ESSA section 1118(b), Title I funds must add to what state and local money provides, not replace it. A district shows this through a Title I-neutral method for allocating state and local funds, as the Department of Education's 2019 guidance describes. The Supplant agent reads each purchase request against that method, state requirements and the school plan, and cites the section its verdict rests on.

What are examples of supplement vs supplant?

In the working solution, after-school math tutoring and family literacy nights are supplemental, because the district's method funds neither at any school. Core reading program consumables would supplant, because the method buys the adopted core reading program for every school from the general fund, and so would literacy screener licenses that state law requires for every school. Laptops are marked needs evidence until the school shows they are beyond its regular refresh.

What happens if a school is outside the 110% band?

If a district cannot show comparability, its Title I funds may be held until it does, and a supplanting finding can force repayment. The Fix agent models each way back inside the band with its ratio, cost, certainty before the deadline and its effect on the comparison average, and the report stays blocked until every Title I school is inside.

How does it handle staff paid from federal funds?

The district's fund code map decides which staff count: in the working solution the general fund and state class-size funds count, and Title I, Title II, Title III and IDEA funds are excluded. A position split across funds counts only its state and local share, and the Staff agent checks every position's fund code against payroll and the Title I budget, so a stale code is caught before it moves a ratio.

Do people stay in control of the decisions?

Yes. The agents read, compute, model and draft; they never change a position record, approve a purchase or submit the report. HR makes every correction and the Budget Analyst checks it, the director decides with a reason code, the business officer co-signs anything that moves money, and an override of an agent needs its own reason code.

How long does it take to go live?

The Agentic Solution Engine builds and deploys it from your requirements and documents, such as your state's comparability guidance, your written procedures and your allocation method, and it goes live once every quality gate has passed. We will walk you through it on a copy of your own count-day data first.

See it on
your October 1 data.

We'll run Title I Comparability & Supplement-Not-Supplant Review on a copy of your own count-day data and Title I purchase requests.