Chapter 1 was created from its predecessor, Title 1, in order to give more flexibility to states and local school districts. Many of the requirements and criteria of Title 1 were relaxed in 1981 when Chapter 1 began. Districts are now required to submit written plans of their new Chapter 1 organization assuring the comparability of services between Chapter 1 and non-Chapter 1 schools. A majority of the states have now adopted less restrictive means of measuring comparability than allowed under Title 1. Variances between Chapter 1 and non-Chapter 1 schools in the same district have increased. Rules for the retention of comparability documentation have been relaxed, and the widely varying definitions of "instructional staff" among states is causing an imbalance of teachers between Chapter 1 and non-Chapter 1 schools. This document, addressed to the U.S. Secretary of Education, recommends provisions at the federal level to require: (1) the retention of comparability documentation which demonstrates compliance, and (2) the defining of "instructional staff," for use in demonstrating comparability in ratio of pupils to staff. (VM)