Today I am continuing this series of consultation tips by focusing on the Title III program for English Learners and Immigrant Children and Youth. This is a program that does not see a great deal of participation by private school students, yet the English learner population of private schools continues to increase.
Like Title IIA and the new Title IV under ESSA, the rules that govern the equitable participation of private school students is part of Title VIII Uniform Provisions. All of the requirements for the consultation process listed under Title VIII apply to Title III, just as they apply to Title IIA. (Title I has its own consultation section outlining the consultation process, which mirrors Title VIII).
The first issue to address with Title III is the identification of students who are English learners. In order to determine who should be assessed as English learners, many schools send out a PHLOTE survey (primary home language other than English). This will identify a pool that should be assessed. The public school has the responsibility for assessment of English learners. This can be accomplished by the public school conducting the assessment, training private school teacher to conduct the assessment, or allowing the private school to conduct its own approved assessment. The cost of assessing private school students by the public school can be recouped from the funds generated by qualified students under Title III. For this reason, many private schools work to find an alternative to the public school conducted the assessment each year.
Once students are assessed, they generate funds that are used to provide services and benefits to them. This program is more flexible than Title I, and can be used not only for direct services to eligible private school students, but also for professional development, materials, parent and family services, translation services, etc.
In addition to funds that are generated by English learners, funds are also generated by immigrant children and youth, whether or not they are English learners. Through a formula, the counts of English learners and immigrant children and youth generate the funds available for Title III services. It is important to note that the immigration status of students and their families is not relevant to whether or not the students are counted for Title III purposes.
For more information on Title III, visit the U.S. Department of Education Office of Non-Public Education’s website.