Verbatim Mac

Comparability Loophole 1AC

The SQuo leaves effort and comparability standards unchanged by ESSA – means comparability requirement judged based on spending per student not number of teachers per student

Knight, Center for Education Research and Policy Studies, and DeMatthews , Educational Leadership and Foundations, 2016

(David and David “Are ∂ school districts allocating resources equitably? ∂ Implications for Title I funding and the Every Student Succeeds Act” CERPS Working Paper 2016∂ -∂ 2∂ . ∂ University of ∂ Texas at El Paso, El Paso, TX. http://www.utep.edu/education/cerps/_Files/docs/papers/CERPS_Working_Paper_2016_2.pdf accessed 7-6-17 GDI - TM)

The federal government ensures Title I funding reaches the intended students through three requirements: (a) maintenance of effort; (b) comparability; and (c) supplement, not supplant.4 Maintenance of effort implies that no states or districts can decrease total or per-pupil funding by more than 10% from the prior year. ESSA makes no major changes to the maintenance of effort requirement.

Comparability requires districts to staff Title I schools with equal or more instructional staff per pupil compared to non-Title I schools. However, because more experienced teachers typically sort into more advantaged schools within districts (Clotfelter, Ladd, Vigdor & Wheeler, 2006; Goldhaber, Lavery & Theobald, 2015) and more experienced teachers earn higher salaries, comparability in pupil-staff ratios may not imply comparability in spending on instructional staff members (Haxton et al., 2012). Over the past decade, DOE representatives have argued that comparability should be judged based on spending on teachers per student, rather than simply the number of teachers or staff members per student (Government Accountability Office, 2011; Hanna, Marchitello & Brown, 2015; Heuer & Stullich, 2011; National School Board Association, 2013). While the DOE has used the enactment of ESSA to push for equalized spending on teacher salaries between Title I and non-Title I schools, ESSA makes no changes to the statutory language of the comparability requirement and the DOE has not suggested changes to the methods in which districts meet the comparability requirement.

First, comparability loopholes incentivizes teacher funding shenanigans that undermine teacher quality in Title I schools

Knight, Center for Education Research and Policy Studies, and DeMatthews , Educational Leadership and Foundations, 2016

(David and David “Are ∂ school districts allocating resources equitably? ∂ Implications for Title I funding and the Every Student Succeeds Act” CERPS Working Paper 2016∂ -∂ 2∂ . ∂ University of ∂ Texas at El Paso, El Paso, TX. http://www.utep.edu/education/cerps/_Files/docs/papers/CERPS_Working_Paper_2016_2.pdf accessed 7-6-17 GDI - TM)

Over the past four decades, policymakers in the Department to Education (DOE) have enacted various regulations to encourage school districts to allocate funding equitably across schools. Local school districts that meet certain eligibility requirements for receiving Title I funding are required to identify the “Title I schools” that will receive federal funds. Based on those classifications, the DOE currently requires districts to staff Title I schools with at least as many instructional personnel per student as non-Title I schools (the “Comparability Rule”). This policy is meant to ensure that districts will allocate federal funding equitably across schools.

However, in most cases, the highest-poverty schools within each district have higher teacher attrition rates and, as a result, the least experienced teaching staff (Goldhaber, Lavery & Theobald, 2015). Because districts typically use standardized salary schedules that offer higher compensation to more experienced teachers, districts that use equal staffing ratios across schools actually allocate less teacher salary funding per student to the highest-poverty schools. The “comparability loophole” refers to the lack of any requirement that districts spend equal dollars per student across Title I and non-Title I schools (Hanna, Marchitello, & Brown, 2015; McClure, 2008; Roza, 2008; Roza, Miller & Hill, 2008). A controversial policy that the DOE has pushed for, both historically and during the current rulemaking process required to implement ESSA, would mandate districts to equalize spending on teacher salaries between Title I and non-Title I schools.

And teacher quality key - helps disadvantaged students the most and help accumulates over time - studies prove

Goldhaber, University of Washington, Bothell Center for Education Data & Research Director, 16 (Dan, "In Schools, Teacher Quality Matters Most", Education Next, Spring 2016, educationnext.org/in-schools-teacher-quality-matters-most-coleman/, 7-10-17, GDI-EC)

Beyond the headline finding about the impact of schooling overall, the report contains a fair amount of nuance on which school characteristics do (and, importantly, which do not) predict student achievement. The primary analytical technique used involved assessing the proportion of the variation in student achievement explained by different factors. Across grades and different student subgroups, the Coleman study found that most of the variation in student achievement is within rather than between schools, but a larger share of the variation is found between schools in earlier grades and among more disadvantaged subgroups. Regarding teacher quality specifically, one of the key conclusions is that the quality of teachers shows a stronger relationship [than school facilities and curricula] to pupil achievement. Furthermore, it is progressively greater at higher grades, indicating a cumulative impact of the qualities of teachers in a school on the pupil’s achievements. Again, teacher quality seems more important to minority achievement than to that of the majority.

The finding that “teacher quality is one of the few school characteristics that significantly affects student performance” is quite consistent with more-recent research. Also in line with current studies is the report’s finding that “for any groups whether minority or not, the effect of good teachers is greatest upon the children who suffer most educational disadvantage in their background, and that a given investment in upgrading teacher quality will have most effect on achievement in underprivileged areas.” Recent studies, for instance, find that higher funding levels, smaller classes, and more-qualified teachers all have larger effects on disadvantaged students than on other students.

And, this phenomenon impacts racial minority students disproportionately

Resmovits, Senior Education Reporter, The Huffington Post, 2k14 (Joy, “American Schools Are STILL Racist, Government Report Finds”accessed 7/04/17 published 3/21/14 www.huffingtonpost.com/2014/03/21/schools-discrimination_n_5002954.html GDI-XRL)

Black students are suspended or expelled at triple the rate of their white peers, according to the U.S. Education Department’s 2011-2012 Civil Rights Data Collection, a survey conducted every two years. Five percent of white students were suspended annually, compared with 16 percent of black students, according to the report. Black girls were suspended at a rate of 12 percent — far greater than girls of other ethnicities and most categories of boys.

At the same time, minority students have less access to experienced teachers. Most minority students and English language learners are stuck in schools with the most new teachers. Seven percent of black students attend schools where as many as 20 percent of teachers fail to meet license and certification requirements. And one in four school districts pay teachers in less-diverse high schools $5,000 more than teachers in schools with higher black and Latino student enrollment.

Such discrimination lowers academic performance for minority students and puts them at greater risk of dropping out of school, according to previous research. The new research also shows the shortcomings of decades of legal and political moves to ensure equal rights to education. The Supreme Court’s landmark 1954 Brown v. Board of Education ruling banned school segregation and affirmed the right to quality education for all children. The 1964 Civil Rights Act guaranteed equal access to education.

Additionally, minority students have less access to experienced teachers and the coursework necessary to be prepared for college

Cook, Data Editor for U.S. News, 2015

[Lindsey, “U.S. Education: Still Separate and Unequal,” U.S. News, January 28, https://www.usnews.com/news/blogs/data-mine/2015/01/28/us-education-still-separate-and-unequal, GDI –TM]

Separate and Unequal More than 2 million black students attend schools where 90 percent of the student body is made up of minority students. Dozens of school districts have current desegregation orders. Minority students represent 57 percent of the population in “dropout factories” — schools where the senior class has 60 percent or fewer students who entered as freshmen — but only 30 percent of the population in all schools. On average, schools serving more minority populations have less-experienced, lower-paid teachers who are less likely to be certified. A report from the Center for American Progress found that a 10 percentage point increase in students of color at a school is associated with a decrease in per-pupil spending of $75. Disparities in course offerings mean students of color have fewer opportunities to challenge themselves with more difficult courses — the type of courses needed to prepare for a four-year college degree or for a high-paying career in STEM. In seventh and eighth grades, blacks make up 16 percent of students, but account for 10 percent of students taking Algebra 1 and 9 percent of students passing the course. While nearly one in five white students took Calculus in high school, one in 15 black students did. Fewer black students have access to a full range of high school math and science courses — algebra I, geometry, algebra II, calculus, biology, chemistry and physics. They are under-represented in gifted and talented programs. Black students take fewer Advanced Placement classes than white students and score lower on AP tests. While black students disproportionately attend schools with higher minority populations, the teachers, principals and administrators who interact with the students are a different story. When the U.S. Department of Education collected data in the 2007-2008 school year, 80 percent of principals in public schools were white. Meanwhile, only 6.2 percent of high school public school teachers across all subject areas are black — the highest percentage is for health and physical education, where 9.2 percent of teachers are black.

Rejecting modern-day segregation in education perpetuate by the SQuo is a moral imperative—we have a duty to embrace a commitment to racial inclusion

James, a Professor of Law at the University of Miami School of Law where she writes about opportunity and inequality in America’s public schools, 2015

[Osamudia, “Soapbox: Racial segregation in schools, no matter how unintended, should be illegal,” The Miami Herald, February 19, http://www.miamiherald.com/news/local/community/miami-dade/coral-gables/article10679735.html, GDI –TM ]

Failure to commit to substantive racial equality continues to forestall attempts to achieve racial integration in our communities and schools. In Miami, for example, “unintended” residential racial isolation today is actually the product of intentional local, state, and federal policies that broadened access to safe, stable communities for some, while simultaneously denying home ownership, quality education, and public services to others. One need only examine neighborhood maps of Miami during the early 1930s that used racial composition to designate — for investment purposes — areas like Coral Gables as “best,” and certain parts of Coconut Grove as “hazardous,” to get a sense of this intentional government discrimination. Although this sort of blatant racism has long been outlawed, enduring racial and economic segregation in our city is a direct byproduct of intentional decisions to deny access to mortgages and other forms of community investment and development on the basis of race. Moreover, our still-segregated communities have resulted in segregated learning environments. Current debates about controlled choice in the city of Coral Gables implicate this very issue. When asked whether their government has any obligation to counteract school segregation, many parents might respond ‘no’ if it means that they cannot attend their neighborhood school. After all, they might argue, school segregation is an historical artifact no longer in operation. As members, however, of a broader community still impacted today by the intentional racial discrimination of yesterday, we have a duty to consider factors other than convenience, comfort, and our own ideal schooling arrangements when evaluating controlled choice. We have a duty to also consider the value of school integration in helping us achieve our goal of substantive equality. We have a duty to weigh that value just as heavily as we weigh benefits of attending school close to home, and to reject the false dichotomy that the formality of “intent” creates. We have a moral imperative to actively embrace a commitment to racial inclusion in our schools and neighborhoods, and to reject school assignment plans that result, intentionally or unintentionally, in racial exclusion and segregation instead.

Teacher quality also impact graduation rates - increasing the graduation rate boosts the economy- data shows

Amos, Alliance for Excellent Education Vice President of Communications, 16 (Jason, "THE GRADUATION EFFECT: Increasing National High School Graduation Rate Key to Job Creation and Economic Growth, New Alliance Analysis Finds", Alliance for Excellent Education, 1-12-16, all4ed.org/articles/the-graduation-effect-increasing-national-high-school-graduation-rate-key-to-job-creation-and-economic-growth-new-alliance-analysis-finds/, 7-14-17, GDI-EC)

New data from the Alliance for Excellent Education demonstrates how graduating more students from high school creates new jobs, increases consumer spending, boosts tax revenues, and increases the gross domestic product. This “Graduation Effect” data is available for the United States as a whole, all fifty states and the District of Columbia, and more than 200 metro areas nationwide at impact.all4ed.org.

“The two areas of rising rates getting major attention are the Federal Reserve and the high school graduation rates,” said Bob Wise, president of the Alliance and former governor of West Virginia. “For the short-term impact on the nation’s economy, the Federal Reserve’s raising of interest rates has generated a lot of attention, but over the long term, rising graduation rates are much more important for the nation’s economy.”

The national high school graduation rate is at an all-time high, but one in five students still fails to earn a diploma on time. Increasing the national high school graduation rate to 90 percent would likely have the following positive effects on the national economy:

Create 65,150 new jobs

Boost gross domestic product by $11.5 billion annually

Increase annual earnings by $7.2 billion

Increase annual spending by $5.3 billion

Increase federal tax revenue by $1.1 billion

And, Improving education key to competitiveness and economic prosperity

Jennings, founder and former CEO, Center on Education Policy, Washington, D.C., and former General Counsel, U.S. House of Representatives' Committee on Education and Labor, 2015

(Jack, “ESEA at 50”, Kappan Magazine, April 2015, Volume 96, Number 7, accessed 7/6/17, GDI-JG)

A worldwide job market exists today in which U.S. students will have to compete for jobs with Korean students, among many others, once they leave school. We ignore at our peril the economic and technological changes that have led to higher educational demands.∂ As Marshall S. Smith, a former professor and high- ranking official in the Carter and Clinton adminis- trations, has noted:∂ . . . the challenges of a global economy, a complex and changing international environment, and the tech- nology and communication revolutions have dra- matically increased our collective national need to ensure our future prosperity. As a nation, we are ever more dependent on the quality of our human capital to carry us into a productive and safe future. Our schools are better than many think, but we must ask them to change and become smarter (2011, p. 233).

US economic growth good – solves laundry list of impacts

Noell, Professor of Economic and Business at Westmont College and Ph.D. in Economic from Lousiana State University and Smith, Professor of Economic and Business at Gordon College and Ph.D. in Economic from Stanford University, 13

(Edd S. and Stephen L.S., “Want A Better World? Let's Work On Boosting Economic Growth,” Forbes, April 23, 2014, http://www.forbes.com/sites/realspin/2013/04/23/want-a-better-world-lets-work-on-boosting-economic-growth/, GDI – TM)

If we as a society want to live in a better world, we must start taking economic growth seriously. It’s easy for economists to understand why growth is so important—but too often, economists fail to explain why it matters. With increased economic growth, the lives of millions of people around the world—in countries both rich and poor—can be transformed. Both authors of this column have witnessed growth’s power in person. One grew up in 1960s Hong Kong. While today Hong Kong is a wealthy financial capital, in the early 1960s it was engulfed in poverty. His earliest memories include images of the flood of over one million refugees into his city from Mao’s China. But by the time he reached high school much had changed. Children born in shanty towns now lived in apartments with electricity and running water. Each morning, crossing Victoria Harbor with its glittering view of Hong Kong’s burgeoning skyline, he could see the trade, construction, and growth that provided jobs, increased wealth, and lifted families out of poverty. Since then, in our frequent professional travel to Asia, we have both seen first-hand the fantastic poverty reduction triggered by growth in Korea, China, and much of Southeast Asia. The immense power of economic growth is easy to see in dramatic surges like Hong Kong’s, but the transformative power of growth is not limited to poor countries. In wealthy countries like the United States growth and the prosperity that it brings allow us, as a society, to afford to do many good things. It is quite remarkable that someone such as the climate activist Bill McKibbin argues that growth is “the one big habit we finally must break.” When he looks at growth, he sees a malevolent force driving our desires to consume ever more fossil fuels. We could not disagree more. With greater growth our economy can afford to buy green products, offset our carbon footprint, and conserve and replenish the renewable natural resources we consume. Growth means, literally, the increase in the production of goods and services in an economy. Since production of goods and services requires that workers and firms’ owners be paid, the value of production is basically the same as the value of households’ income. So growth measures the increases in a country’s ability to take care of itself. With growth, families are better able to purchase goods and services. A cynic may only think of the purchase of another 80” TV, but economists understand that the “goods” a society gets from growth go far beyond the ones you can pick up at Best Buy. With greater growth we could invest even more in basic research to help find cures for diseases like Alzheimer’s and Parkinson’s. Greater growth would allow us to avert the coming intergenerational fight over how to pay for trillions of dollars of entitlement promises we have made to the needy among us, and to our parents and grandparents in the form of Social Security, Medicare, and Medicaid. These are profoundly moral concerns. In short, the supporters of growth—who usually make their case in economic terms, about tax and spending policies—are on to something. They understand growth’s potential to ease economic problems. Right now the United States is growing at about two percent per year—but to get the U.S. unemployment rate down to a healthy level (under six percent) within four years will take approximately four percent growth per year. That is not just a number on a press release—it’s the dignity of a paycheck and the security of an income for millions of families across America. So if you care about long-term human wellbeing—in rich and poor countries alike—you must care about economic growth. Before we as a society can consider how to achieve such growth, we must recognize that getting growth right matters. Not every instance of economic growth in every country is beneficial. But time and again, hard data documents its positive impact on the things that ultimately matter: education, environmental care, physical health, political freedom, and healthy culture. Failure to realize the transformative power of growth would be a failure of our moral imaginations. We would risk leaving a world for our children in which diseases persist, rivers remain polluted, and the elderly and sick receive inadequate care. Growth must not be sold short. Growth is not just morally defensible; it is a moral imperative for achieving lasting human flourishing.

Comparability Solvency

Option 1

Plan: The United States federal government should increases its regulation of elementary and secondary education by closing the comparability loophole by requiring that districts fund their Title I schools at the same level as or higher than their other schools based on actual spending

Option 2

Plan: The United States federal government should increases its regulation of elementary and secondary education through the closure of comparability loophole in Title I.

Option 3

Plan: The United States federal government should close the comparability loophole in Title I compliance.

We solve -

Comparability loophole perpetuates unequal funding structures – closing the loophole increases funding for schools

Hanna, Center for American Progress Senior Policy Analyst et al. 15

(Robert Hanna, Max Marchitello, and Catherine Brown, “Comparable but Unequal: School Funding Disparities” Center For Amerian Progress, 3-11-15, https://www.americanprogress.org/issues/education/reports/2015/03/11/107985/comparable-but-unequal/ 7-6-17, GDI-JIJD)

Due to the loophole in federal law, more than 4.5 million low-income students attend inequitably funded Title I schools. In most states, there are tens of thousands of students from low-income households who attend Title I schools that are not funded equitably relative to other schools in their district. See the appendix for state-by-state results.¶ These inequitably funded schools receive around $1,200 less per student than comparison schools in their districts. Overall,these schools receive around $668,900 less per year than comparison schools. In Fort Worth, Texas, for example, inequitably funded Title I schools receive around $2,600 less per student.In some districts, the disparities are even wider. In Santa Fe, New Mexico, inequitably funded Title I schools receive around $4,900 less than other schools. These disparities can add up to millions of dollars at the state level. If these gaps were closed, inequitably funded schools in Texas would receive another $1.6 billion annually, and in New Mexico, they would have an additional $65 million. See the appendix for state-by-state results.¶ If the federal loophole were closed, high-poverty schools would receive around $8.5 billion in new funds each year. This estimate is similar to findings reported in a previous study that used 2008-09 school finance data, also based on information collected by DOE. This amount is equivalent to around 1.5 percent of total state and local revenues, which were more than $500 billion in the 2011-12 school year. For inequitably funded Title I schools, these dollars could add real value. See appendix for state-by-state results.¶ As Congress works to reauthorize the No Child Left Behind Act, improving school funding has been a key focus. Sen. Lamar Alexander (R-TN), chairman of the Senate Health, Education, Labor and Pensions Committee, and Rep. John Kline (R-MN), chairman of the House Education and Workforce Committee, both proposed changing the distribution of Title I funds. This would allow states the option of distributing funds solely on the basis of the number of low-income students, rather than continuing to use the four formulas that target the funds to concentrations of poor students. Moreover, both of their proposals fail to address the comparability loophole and would continue to allow districts to demonstrate comparability in ways that mask real inequities in school resources. Members of the House Education and the Workforce Committee recently approved Rep. Kline’s proposal.¶ What could $668,900 buy?¶ Comparability is about a broad range of resources. Title I schools should at least have the same amount of resources—to invest as school leaders see fit—as other schools. They may choose to hire more experienced, and thus more costly, teachers, or they may choose to invest in technology, a new curriculum, an after-school program, or teaching supplies. If shortchanged schools received an additional $668,000, they could do one of the following:¶ Purchase new MacBook Pro computers for more than 550 students¶ Construct six new libraries¶ Implement a new music education program that serves more than 3,500 students¶ Institute a new arts program covering more than 190 classrooms¶ Hire 12 new guidance counselors with an average salary of nearly $54,000¶ Give a $10,000 bonus to more than 60 teachers¶ This paper is not the first to point out this issue of comparability. The fiscal inequities perpetuated by the comparability loophole are well documented. In a DOE national study of school finance during the 2008-09 school year, the department looked at differences in spending between schools in the same districts and found that about 40 percent of Title I schools were underfunded relative to non-Title I schools. In 2012, the Center for American Progress issued its “Unequal Education” report, which analyzed the first wave of DOE per-school expenditure data that included actual teacher salaries. It found that children of color are routinely being shortchanged. CAP has long argued that the loophole is one of the most significant barriers to educational equity. Other groups such as The Education Trust and the New America Foundation have also analyzed the impact of the loophole and found that districts claiming comparability significantly underfund higher-poverty schools.

Closing the Comparability Loophole Solves Educational Inequality – stimulates state and local funding

Hanna, Center for American Progress Senior Policy Analyst et al. 15 (Robert Hanna, Max Marchitello, and Catherine Brown, “Comparable but Unequal: School Funding Disparities” Center For Amerian Progress, 3-11-15, https://www.americanprogress.org/issues/education/reports/2015/03/11/107985/comparable-but-unequal/ 7-6-17, GDI-JIJD)

Students from economically disadvantaged backgrounds deserve the same opportunities at their peers from higher-income families. Notwithstanding the fact that comparability is the law of the land, the way districts comply with the provision undermines its true intent. Under the current fiscal policy, districts can spend less of their own state and local dollars on the schools with the highest needs, and most do spend millions of dollars less in these schools. Therefore, Congress should close the comparability loophole by requiring that districts fund their Title I schools at the same level as or higher than—based on actual spending—their other schools.

To truly address the problem of fiscal inequity, Congress must seize this opportunity to close the comparability loophole. An improved comparability provision could go a long way toward ensuring that all low-income students get their fair share of state and local funding.

Phased in shift to actual expenditures addresses education gaps and solves

Hanna, Center for American Progress Senior Policy Analyst et al. 15 (Robert Hanna, Max Marchitello, and Catherine Brown, “Comparable but Unequal: School Funding Disparities” Center For Amerian Progress, 3-11-15, https://www.americanprogress.org/issues/education/reports/2015/03/11/107985/comparable-but-unequal/ 7-6-17, GDI-JIJD)

The comparability calculation must be based on actual expenditures, including actual teacher salaries.¶ Districts should be required to achieve comparability between Title I and non-Title I schools only by demonstrating that Title I schools receive state and local funding that is at least equal to the average of the district’s non-Title I schools.¶ Districts that serve only Title I schools must show that higher-poverty schools receive no less than the average total of state and local funds for lower-poverty schools.¶ Under current guidance from the U.S. Department of Education, districts can demonstrate comparability at the 90 percent level. In other words, districts can claim that they spend comparable amounts at Title I schools as long as those schools provide at least 90 percent of services offered in other schools. Districts can interpret that percentage as a ceiling not a floor. The department’s guidance should not allow for this amount of leeway.¶ Some have argued that the only way for districts to close the comparability gap is to force experienced teachers to transfer to high-poverty schools, which typically employ teachers with fewer years of experience and lower salaries. In fact, states and districts could provide a host of additional resources to the high-poverty schools and leave the staffing distribution as is. By purchasing the kind of enrichment activities listed in the “What could $668,900 buy?” text box above, districts would comply with the requirement.¶ In addition, districts could change their compensation systems to reward effectiveness instead of seniority or educational degree attainment. In this way, districts can pay highly effective teachers more, particularly those working in schools serving high concentrations of low-income students. With more highly effective teachers clustered in high-poverty schools, these districts could close the comparability gap through supporting highly effective teachers in these schools rather than forcing teachers to move to high-poverty schools.¶ At the same time, actually achieving comparability given that schools have been inequitably funded throughout history will not be easy. That is why Congress should require meaningful compliance with the comparability provision to be phased in gradually. Priority would first be given to the schools that have been most egregiously shortchanged. Full compliance would be required within five years. The following timetable would serve that end:¶ Year one: All districts must publicly report all expenditures by school level. These facts must be made available in an easy-to-read format that is available to the public. The report must also include the percentage of students eligible to receive free and reduced-price lunches. In each subsequent year, the district continues to report this data.¶ Year two: States and districts begin to fill in funding gaps. States would rank their Title I schools by per-pupil expenditures and ensure that the lowest-spending 25 percent of schools are funded to at least 100 percent of the average level of their districts’ comparison schools. These gaps could be closed through state or local actions or a combination of both.¶ Year three: States ensure that the lowest-spending 50 percent of Title I schools are funded to at least 100 percent of the average level of their districts’ comparison schools.¶ Year four: States ensure that the lowest-spending 75 percent of Title I schools are funded to at least 100 percent of the average level of their districts’ comparison schools.¶ Year five: States ensure that all Title I schools are funded at least to the level of the average of their districts’ comparison schools.¶ Under current law, districts already risk losing their Title I dollars if they fail to comply with comparability requirements. Congress should expand this provision to hold states accountable for the gaps outlined above as well. Here, the guiding principle is that states hold the ultimate responsibility for operating inequitable funding systems. Specifically, states should risk losing their full allocation of Title I dollars each year that they fail to keep on track with the above timeline. This arrangement would be a strong deterrent to states and districts that wish to continue their current approaches to funding their most disadvantaged schools. Nationally, this amounts to a reasonable trade-off. For example, we found that in the second year—the first year of narrowing comparability gaps—states and districts would be responsible for closing gaps by around $2.3 billion in exchange for receiving more than $14.6 billion in federal Title I funds.