How Should Title I & Title III Directors Work Together to Prepare for ESSA’s Shift in EL Requirements?


How should Title I & Title III Directors work togetherWhen it comes to requirements for English Learners (ELs) in ESSA (Every Student Succeeds Act), one of the biggest shifts in responsibility is the move of accountability for ELs progress toward English proficiency from Title III to Title I. Under ESSA (as compared to NCLB) it is more clearly noted that Title I funds can be used for programs to help ELs attain English proficiency. In addition to the accountability
measures, the following two requirements have also been moved to Title I (and must be implemented for ELs in programs funded by either or both Title I and Title III):

  1. The requirement to notify parents of the identification and placement of a student in an EL program, and
  2. Scheduling regular meetings for parents of ELs to receive feedback and recommendations.

And finally, school improvement under ESSA (called either Comprehensive or Targeted Support and Improvement) requires that improvement plans include interventions for ELs if they are wholly or partly the reason for the school being identified for “Support and Improvement”.

This information, and more, is covered in our free eBook "Working together for successful EL Programs Under ESSA". Download it here.

What does this mean for Title I and Title III Directors?

Since attainment of English proficiency is new to Title I, it means that Title I staff at the State and district level may not have the knowledge, skills, or capacity to meet the shifted requirements, but Title III staff should have that capacity. Accountability for ELs progress toward and attainment of English proficiency is not new to Title III. Thus, cooperation and collaboration between Title I and Title III directors at both the State and district level will be essential for a smooth implementation of EL requirements under ESSA.

Title III programs still require that funds be spent to help ELs attain English proficiency and access academic content (acquire content knowledge). Also, Title III is required to implement programs that help ELs meet the long-term goals and interim measures set for ELs under Title I.

What does collaboration look like?

Suggestions for collaboration between state and district staff to meet ESSA’s EL requirement’s include:

  • Title I (accountability) staff at the state level should include Title III staff in the development of goals for ELs as well as the development of accountability indicators for measures of progress toward English proficiency;
  • Title I has parent notification requirements for ELs that participate in EL programs funded by either Title I or Title III or both, therefore, it is essential that Title I and Title III staff cooperation in the identification of students that participate in these programs in order for Title I to meet this requirement;
  • Because Title I accountability also includes academic progress in the content areas, district Title I and Title III staff could work together in the identification of accommodations for ELs and in the design of programs that help ELs acquire content knowledge;
  • Because Title III requires the use of funds for professional development for staff working with ELs, and Title I funds may also be used for this, Title I and Title III staff could work together to identify:
    • the type of professional development that would have the greatest impact on ELs in the provision of services by EL teachers that help ELs attain English proficiency, and
    • the type of professional development for content teachers that will help them help ELs acquire content knowledge;
  • In planning for the expenditure of Title I and Title III funds for ELs, it is allowable to use both funds for the same activities (September 23, 2016 Non-Regulatory Guidance: English Learners and Title III . . . question A-12), therefore Title I and Title III staff could jointly plan programs that meet the needs of ELs in the schools and district (note: supplement not supplant requirements, which are very context specific, must be met);
  • Under ESSA, the Title I requirement of scheduling regular meetings for the parents of ELs could be coordinated with similar requirements under Title III and these meetings could meet the requirements and goals of both titles; and
  • Title I and Title III staff should work together in the develop of interventions for ELs in school Support and Improvement

There are many other ways that Title I and Title III staff can collaborate, and you may also want to consider other areas, like accountability, depending on the structure of your particular education agency. The list above is not intended to be comprehensive. If you have good examples of this type of collaboration, we would love to hear about it. Please send us information about your successes and we’ll post them in an upcoming blog that focuses on examples of best practices for collaboration between Title I and Title III. Email your success stories to

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Dr. David Holbrook

About The Author

Dr. David Holbrook is a nationally recognized leader in federal programs administration and monitoring with expertise in Title I, Title III, Native American Education, and Federal Programs. Dr. Holbrook has also worked as a consultant with Title III of the US Department of Education and now serves as Executive Director, Federal Compliance and State Relationships with TransAct.