The Center for Law and Education (CLE) strives to make the right of all students to quality education a reality throughout the nation and to help enable communities to address their own public education problems effectively, with an emphasis on assistance to low-income students and communities. For more than a quarter of a century, the Center for Law and Education has worked to bring about school- and district-wide change across the country in order to improve educational outcomes, particularly for low-income students. As a national support center, CLE has developed enormous expertise about the legal rights and responsibilities of students and school personnel as well as about key education programs and initiatives, including Title I. The Center for Law and Education's National Title I, and School Reform Advocacy Project is a nationwide effort to help communities improve the quality of education for low-income, low-achieving students. The project focuses on the largest elementary and secondary education program -- Title I -- as the a primary vehicle for broad-based school reform. Periodically, the Project publishes longer and shorter pieces analyzing new laws, offering strategic advice for changing educational practice and programs, and providing guidance and tools to parents, educators and advocates working to change schools. This document presents comments submitted by the Center for Law and Education on Title I, "Improving the Academic Achievement of the Disadvantages."