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Ed Department Puts Title I and Title III Under Same Administration

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State education officials received an e-mail message from the U.S. Department of Education last week announcing that the administration of Title III—the main conduit for the funding of ELL programs under the No Child Left Behind Act—will soon be carried out by the same office that administers Title I. Title III has been handled by the office of English-language acquisition, while Title I, which provides funds for disadvantaged students and also contains some provisions applying specifically to English-language learners, is administered by the office of elementary and secondary education.

Richard L. Smith, the acting director of the office of English-language acquisition, sent out an e-mail message on June 11 saying that administration of the Title III grant program will be moved from his office to the office of elementary and secondary education, which is headed up by Kerri Briggs, the assistant secretary for elementary and secondary education.* Deputy U.S. Secretary of Education Raymond J. Simon oversees both offices.* The change is effective this fall.

Here's the rationale included in the e-mail:

This change will put the administrative duties, including the monitoring and enforcement responsibilities of the state formula grants under Title I and Title III, in the same office so that the staff can more easily and effectively work together, better coordinate their monitoring and enforcement efforts, and provide more consistent guidance to states regarding Title I and Title III programs for limited-English-proficient (LEP) students.

Mr. Simon has already weighed in heavily on some issues regarding enforcement of NCLB for English-language learners. In 2007, he required Virginia to stop using an English-language-proficiency test instead of the state's regular reading test to assess some ELLs for accountability purposes under Title I.

Kathleen Leos, who resigned as the director of the office of English-language acquisition in September 2007 and is now president and CEO of her own company, said the intent of the Education Department to better coordinate implementation of Title I and Title III could send an important message to states that they need to better align with each other the standards and assessments developed to comply with both sections of the law. But she cautioned that the reorganization will be effective only if it coordinates the policy-making process for the two sections of the law, along with administration.

Mr. Smith's e-mail said the office of English-language acquisition will continue "to focus on national policy and programmatic issues related to LEP students..." For example, the message says that the English-language-acquisition office will continue to handle professional development, discretionary grants, and technical assistance.

Along with Ms. Leos, I'm wondering how much say members of the staff at that office will have over policy decisions regarding ELLs. For example, who will take charge of considering input from the public and putting out a final version of the "interpretation" of Title III proposed May 2 by the Education Department?

Federal education officials have told me they expect to publish the final interpretation by the end of this summer.

*was updated from earlier version

3 Comments

The rationale for making this change in June 2007 does not make sense to me. The opportunity to work together to meet the needs of all children was not diminished during the decades that there were two separate organizations. What will working together look like now that has failed to happen thus far? What is the problem that will be solved?

For decades Title VII and later Title III has been led by highly qualified leaders and staff with expertise in second language acquisition and in the applicable regulations providing equal access. Under a single Title I administration, expert voices are sidelined. The seat at the table that comes with a separate organization diminishes informed policy making that meets the academic needs and performance by ELLs. Some national and state policy makers seem to share a belief that teaching English to native speakers is the same as to non native speakers. Somehow this decision strikes me as an example in a philosophical trend. This decision will do more harm than good and appears to have no merit. I am not satisfied with the expressed rationale.

I agree with Rochelle that this change does not make sense. The email lacks substantive reasons for the change.

I think the main obsession is to disregard the idea that ESOL students are learning English and ignoring that they bring something special to the educational system. They have experience in other languages and cultures something greatly devalued in this country.

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