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 ↓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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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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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%.
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.
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.
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.
The same test, seen by the five people who carry it: what their November looked like, and what it looks like now.
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.
Plans each run, keeps the December 1 clock and routes work to the other agents and to the people who decide.
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.
Computes students per state- and locally funded instructional staff member by grade span, and recalculates after every position change.
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.
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.
Drafts an answer to each fiscal indicator the state monitor reviews, with its evidence, and builds a state copy and a redacted board copy.
Decides every fix and approves the test. The agents propose; a named person decides.
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.
13 screens from the working solution, on its sample data. Pick one to see it large.
The test rules, fund codes and time limits are settings. A change is proposed as a new version, and a second administrator approves it.
| Setting | Default | Choose from |
|---|---|---|
| Method | Students per state- and locally funded instructional staff member | Salary or per-pupil methods, 90–110% |
| Limit | 110% of the non-Title I average | As your state's method sets it |
| Grouping | By grade span: K–5, 6–8, 9–12 | Or by size group |
| Count day | October 1, enrollment and staff on the same day | Set per year |
| Excluded staff | Full salary from federal funds; non-instructional paraprofessionals | Special education excess cost, district choice; a split position counts only its state and local share |
| Recalculate | Daily until submitted, and after every position change | Logged with each run |
| State report due | December 1 | Alerts 30, 14 and 7 days before |
| Time limits | Fund-code correction 2 business days, then the director | Fix decision 2 days, purchase verdict 3 business days, co-signature 2 days |
Every figure is labelled: a target the solution is built to, an estimate, a typical published result, or a proven one.
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.
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.
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.
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.
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.
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.
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.
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.
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.
No uncited sentence reaches the accreditor, and likely findings are answered first.
1-min demoIPEDS ReportingEvery survey cell rebuilt from source, every variance explained before lock.
1-min demoFaculty CredentialingEvery section cleared before the term starts, with every credential tied to its proof.
1-min demoWe'll run Title I Comparability & Supplement-Not-Supplant Review on a copy of your own count-day data and Title I purchase requests.