What CAN Title III Funds Be Spent On?
At the LEP Partnership meeting last week, several U.S. Department of Education officials spelled out for state education officials what federal Title III funds cannot be spent on. But I came away wondering what the funds CAN be spent on. Title III is the part of the No Child Left Behind Act that authorizes funds for English-language-acquisition programs.
I had asked the Education Department's panelists at the session if they could name some examples of what the money may be spent on. One of them named professional development for teachers. That was it.
But this week, Education Department officials followed up with several more examples, which I pass along to you here in the language that they were given to me:
• English language instruction educational programs provided after school or on Saturday.
• Professional development for regular classroom teachers; teachers of [limited-English-proficient] students, such as [English-as-a-second-language] teachers, and principals, other administrators and educational personnel, and personnel from community-based education organizations in topics such as instructional strategies for LEP students, understanding assessment for LEP students, understanding and implementing [English-language-proficiency] standards, alignment of curricula and state standards, and subject matter knowledge for teachers.
• Parental involvement activities designed to assist parents of LEP students to help them work with their children to improve their children’s achievement.
• Support for parental resource centers so they can address the needs of parents of LEP students.
Notice that none of these examples spells out that funds can be used to pay for teachers who provide instruction for English-language learners DURING the school day. I believe this is an area that the federal government will need to provide more clarification on, judging by state education officials' questions at the meeting.
What's at issue is what the federal government means when it says in new guidance issued Oct. 2 that Title III funds can't be used to pay for "core services" for English-language learners. At the meeting, the federal officials didn't give specific examples of what is "core."
Here's an excerpt on this topic in the Oct. 2 guidance regarding the "supplement, not supplant" provision for Title III.
For example, the Department has encountered numerous Title III subgrantees that, for budgetary reasons, use Title III funds to pay the salaries of their English-as-a-second-language (ESL) teachers. Typically, ESL teachers provide the core language instruction educational program services and their salaries are the responsibility of states and [school districts], not the federal government.
Previous guidance on Title III provides plenty of examples of how Title III funds can be spent but it doesn't, in my mind, provide further enlightenment in defining what is "core" in the education of these students (See sections E-1, F-1, F-3, and J-9 in the guidance). I'm wondering: Are ESL pull-out classes, for example, considered core?
One issue, however, that Education Department officials have made clear both at the LEP Partnership meeting and in the Oct. 2 guidance is that Title III funds cannot be spent on development of English-language-proficiency tests, something that a couple of state officials told me personally they have done.