WAIVERS (“Flexibility,” frequently used by the Bush-Chaney-Spellings administration to override congressional legislation) open the floodgates politically, and subsequently legislatively, to erode these venerable safeguards for assuring equality of educational opportunity.  Poor children don't have effective means at the local level to enforce Title I Comparability, and other NLCB standards. “Waivers” and “Flexibility” in this area has the potential to gut the Congressional intent and mandate that high-poverty school children be educated on an equitable basis, assuring that “ . . . a rich curriculum serves the poor as well as it does the well to do.” The American Recovery and Reinvestment Act is intended to hold the line and launch innovative educational improvements.  The Secretary's "invitation" for waivers does neither.

In that Title I funding is a major a component of the No Child Left Behind Act, Citizens for Better Schools www.cfbsedu.org find it fundamentally inconsistent to allow school districts, many of whom have not done a good job presently, to lessen Title I Comparability (and other NCLB) standards.  How will these poor students make up two years of incomparable education?  Would you want your child to labor under this yoke.  While it appears the Secretary is set on inviting “waivers” in Comparability, we should oppose them as not educationally sound, unnecessary, and inconsistent with the President’s ARRA core principals:  1) "Making progress toward rigorous college- and career-ready standards and high-quality assessments that are valid and reliable for all students . . . 3) Making improvements in teacher effectiveness and in the equitable distribution of qualified teachers for all students, particularly students who are most in need, 4) Providing intensive support and effective interventions for the lowest-performing schools."  Congress recognized soon after passage of the original Title I legislation that the “supplemental” federal help would not be effective unless “the program came with a comparability requirement that stipulated that school districts must equalize educational services purchased with state and local funds before Title I funds are brought into the mix.”   It is Citizens for Better Schools experience that conditions in the states educational programs have not changed to such extent as to justify abandoning, temporarily waving, or weakening the congressional intent and mandate for school comparability as a condition precedent to receipt of federal Title I education funding.      Equity and Equality was the essential civil rights function of the comparability requirement.  Congress fully understood that without this standard SEAs and LEAs could simply take federal funds to supplant state funds without ever improving the educational conditions of poor students.    We firmly believe that education advocates and civil rights organizations should immediately bring our concerns to the attention of the President, the Secretary of Education, and Congress.  Our children don't have two years to waste without maintenance of comparability standards.    Education researchers have detailed how difficult and expensive it is to “bring children up” in grade who have previously received a less than adequate education.    Lifting SEAs and LEAs mandated title I comparability will leave our children “further behind.” As congress intended, Title I Comparability should remain rigid and unyielding. In sum, the Secretary’s “Request for Waivers” on comparability is a false economy and a wasteful educational practice.  Fiscal assistance to the states and LEAs can be obtained without sacrificing comparability of educational services for children of poverty.    Citizens for Better Schools invite your support and assistance in advancing our position and opposing Comparability Waivers, and weakening of NCLB, as part of the ARRA.   We welcome your comment and suggestions and urge that you act swiftly as time is of the essence in this matter.  I look forward to hearing from you soon, and will greatly appreciate your support in this effort to preserve Title I comparability.   Sincerely, Yours in "The Struggle"/LS/Ronald E. JacksonExecutive DirectorCitizens for Better Schools1-888-316-2325www.cfbsedu.orgrejacksumc@aol.comcfbsedu@aol.com

NOTE:What if We Closed the Title I Comparability Loophole? http://www.americanprogress.org/issues/2008/06/comparability_part3.html