Answer: No. The Title I homeless set-aside requires the provision of comparable services. 20 U.S.C. 6313(c)(3) The homeless set-aside is required of all LEAs that get Title IA funds. Comparable services are required as part of that set-aside. Additional set-aside funds can be used for a variety of other services, including for transportation and the liaison.
The Department of Education’s Guidance helps address this:
“M-5. In an LEA with Title I and non-Title I schools, are homeless children and youths who attend non-Title I schools eligible to receive Title I, Part A services?
Yes. Under section 1113(c)(3)(A) of the ESEA, an LEA must reserve sufficient Title I funds to provide services to homeless students who attend non-Title I schools that are comparable to those provided to students in Title I schools.
These services may include providing educationally related support services to children in shelters and other locations where homeless children live. Services should be provided to assist homeless students to effectively take advantage of educational opportunities.
In addition to serving homeless children and youths who attend non-Title I schools, as described in question M-4, the homeless set-aside may be used to provide services to homeless students in Title I schools that are not ordinarily provided to other Title I students.”