Emerging evidence suggests that early phonological awareness in deaf and hard-of-hearing (DHH) children with functional hearing is significantly related to their reading acquisition, and the assessment of phonological awareness can play a critical role in preventing reading difficulties. Validation of the scores obtained from standardized assessments when used with DHH students is crucial to support the assessments' intended interpretations and implications of test scores. Using archival data sets, the aim of this study was twofold: (a) to establish the factorial validity of the item scores on the Test of Preschool Early Literacy-Phonological Awareness (TOPEL-PA) for DHH children with functional hearing and hearing children and (b) to test measurement invariance across these groups. Our archival data sets included assessments of DHH children, hearing children from low socioeconomic status (SES) backgrounds, and hearing children from a range of SES backgrounds. We hypothesized that a second-order unifying ability, Phonological Awareness, along with four first-order subtest factors would explain inter-item associations among the 27 items on the TOPEL-PA. We further hypothesized that patterns of associations among the item scores would be similar across groups and that the individual items would function similarly across groups. Seven hundred and thirty-three children from three samples participated in the study; 171 were DHH children (Mage = 58.7 months old, SDage = 12.5 months old), 195 were low-SES hearing children (Mage = 55.5 months old, SDage = 3.5 months old), and 367 were diverse-SES hearing children (Mage = 53.4 months old, SDage = 8.9 months old). All DHH children were able to identify the referent of monosyllabic spoken words on the Early Speech Perception Test. Test of confirmatory item factor analyses of the hypothesized second-order factor structure revealed that a second-order unifying ability along with four first-order subtest factors well explained associations among the item scores for all groups. This aligned with the scoring structure of the TOPEL-PA, providing strong evidence for factorial validity of the item scores for DHH children as well as for hearing children groups. The measurement invariance test results provided evidence that the vast majority of TOPEL-PA items functioned similarly for hearing children and DHH children with speech perception abilities, suggesting that the utility of the assessment scores obtained from DHH children is consistent with the scores obtained from hearing children. Results of our study suggest that researchers and practitioners can use the TOPEL-PA to assess DHH children with functional hearing. It also suggests that the two skills measured on the TOPEL-PA (blending and elision) are qualitatively similar for DHH and hearing children, but the latent mean score obtained from the DHH children significantly differed from those of the hearing groups, suggesting a quantitative difference.