This brief was prepared for the U.S. 

Department of Education under 

Contract Number ED-04-CO0025/0017 with the American 

Institutes for Research (AIR); 

Courtney Tanenbaum and Lindsay 

Anderson are the authors. 

Liz Eisner, who serves as the 

contracting officer’s representative 

(COR) for the National Evaluation 

of Title III Implementation, also 

served as COR for this brief. The 

views expressed herein do not 

necessarily represent the positions 

or policies of the Department of 

Education. No official endorsement 

by the U.S. Department of 

Education is intended or should be 

inferred. 

Title III Accountability and District 

Improvement Efforts: A Closer Look 

ESEA Evaluation Brief: The English Language Acquisition, Language 

Enhancement, and Academic Achievement Act 

May 2010 

Improving education outcomes for 

English Learners (ELs)1 is a vital policy 

concern due both to the growing 

numbers of EL students nationally 

(4.7 million students in 2007–08)2 and to 

the substantial gaps in achievement 

between EL and non-EL students. (For the 

purposes of this brief, the term EL is used 

to refer to those students who are 

designated as “limited English proficient” 

under Title III of the Elementary and 

Secondary Education Act [ESEA].) 

Title III of the Elementary and Secondary 

Education Act (ESEA) provides funds for 

states, which in turn provide subgrants to 

districts3 to develop standards-based 

programs and strategies for better 

meeting ELs’ needs; Title III then requires 

states to hold recipient districts 

accountable for demonstrating improved 

outcomes for this traditionally 

underserved population. Because almost 

94 percent of ELs in the U.S. attend 

schools in Title III-funded districts,4 the 

district improvement process under Title 

III is a potentially promising federal lever 

for promoting greater achievement 

among ELs. This policy brief reports on 

data from interviews conducted with Title 

III officials in six states and nine districts. 

The purpose of the interviews was to 

Highlights 

In a sample of five states and nine districts, some with a long history of serving ELs, and 

others that have experienced rapid increases in EL enrollments, state and district Title 

III officials reported: 

• Three major benefits associated with Title III implementation and accountability 

that have facilitated district improvement—1) heightened awareness among state 

and district stakeholders of the need to address EL concerns; 2) emphasis on the use 

of data for identifying EL students appropriately and for planning EL programs and 

services; and 3) professional development, technical assistance, and coordinated 

services to better address ELs’ needs. 

• Three major challenges associated with Title III implementation and accountability 

that may hinder district improvement—1) recruiting staff qualified to teach ELs; 

2) promoting a sense of accountability at the school level; and 3) funding 

EL services. 

Another major finding of the data collection indicates: 

• States support the district improvement process under Title III by providing technical 

assistance to districts missing annual measurable achievement objectives (AMAOs), 

professional development on EL strategies and practices, and coordinated services 

with Title I. 
2 

begin to build a deeper understanding of the 

supports states provide to districts and the 

strategies districts are undertaking to improve 

the education outcomes for ELs. The purpose of 

the brief is to explore these improvement 

strategies and to suggest emerging issues for 

further investigation and policy response.5

How are ELs performing? 

As reported in The Biennial Report to Congress 

on the Implementation of the Title III State 

Formula Grant Program, School Years 2004–06, 

National Assessment of Educational Progress 

(NAEP) data indicate that ELs have demonstrated 

improvement in the content areas of 

mathematics and reading or language arts (U.S. 

Department of Education, 2008a). However, 

these NAEP data also indicate that, overall, ELs 

are struggling to succeed in school and that 

there remains a disheartening achievement gap 

between language minority students and their 

non-EL peers. For example: 

♦ Nearly half of fourth-grade ELs (44 percent) 

scored “below basic” in mathematics (the 

lowest level), and nearly three-quarters 

(70 percent) scored below basic in reading. 

♦ More than two-thirds of eighth-grade EL 

students scored below basic in mathematics 

and reading (69 percent and 70 percent, 

respectively). 

♦ Whereas 7 percent of fourth-grade ELs 

scored at or above proficiency in reading in 

English, 36 percent of non-ELs scored at this 

level; in mathematics 5 percent of ELs scored 

at or above proficiency as compared with 

33 percent of English speakers (National 

Center for Education Statistics, 2007, as cited 

in Hakuta, August, and O’Day, 2009). 

Methodology and Data Sources

For this brief, data were collected through state-level and district-level telephone interviews conducted in March–June 2009. The 

state-level interviews were conducted with Title III staff from six states: Arkansas, California, Indiana, Montana, New York, and 

North Carolina. The district-level interviews were conducted with nine district Title III officials in five of the selected states, two in 

each of Arkansas, California, New York and North Carolina, and one in Indiana. 

In selecting the state sample, the study team sought to include states with a long history of serving ELs (i.e., California and New 

York) and states that have experienced a rapid increase in EL enrollments in more recent years (i.e., Arkansas, Indiana, and North 

Carolina). For the district sample, the study team selected districts that missed AMAO targets for 2 to 4 consecutive years (based 

on the most recent AMAO data available for each state),* and included districts that varied in size and urbanicity, percentage of 

the EL population, and composition of the EL population. One consortium of Title III districts was also included in the sample.

The data collection and analysis efforts were guided by six primary questions: 

1. What actions do states require of districts missing AMAOs? 

2. What supports do states provide to foster the district improvement process? 

3. What strategies are districts using to improve EL performance? 

4. What are the reported challenges districts face related to Title III accountability? 

5. What are the reported benefits of Title III accountability? 

6. What is the reported salience of Title III? 

Due to the small sample size, and given that each state and district across the United States faces specific challenges, varying 

contextual issues, and serves a unique EL population, the experiences and perceptions of the state and district officials who were 

interviewed cannot be generalized to the universe of Title III grantees and districts. Rather, the findings from these interviews can 

offer insight into how a sample of states and districts experience the district improvement process under Title III—including the 

benefits and challenges—and provide examples of the strategies some states and districts are using to improve the outcomes of 

ELs served by Title III. 

*During the course of one district interview, the study team learned that the district had missed AMAOs for 2 years, but not 2 consecutive years. 

(The district missed in 2005–06 and then again in 2007–08.) All of the other districts in the sample had missed at least one AMAO for 2 or 

more consecutive years. 
3 

The implications of these data are substantial: 

“Language-minority students who cannot 

read and write proficiently in English cannot 

participate fully in American schools, 

workplaces or society. They face limited job 

opportunities and earning power. 

Inadequate reading and writing proficiency 

in English relegates rapidly increasing 

language-minority populations to the 

sidelines, limiting the nation’s potential for 

economic competitiveness, innovation, 

productivity growth, and quality of life” 

(August and Shanahan, 2006). 

What are the strategies for improving 

ELs’ performance? 

The number of studies targeting EL instruction is 

growing. Emerging research suggests specific 

strategies that may help improve the 

achievement of ELs, and a number of states and 

districts have begun instituting promising 

practices for better meeting the needs of their 

English Learners. (See the text box entitled, 

Emerging Research on Improving Outcomes for 

ELs, on page 4 of this brief for the latest research 

on best practices for ELs.) In addition, Adequate 

Yearly Progress (AYP) targets for this subgroup 

established through Title I and Annual 

Measureable Achievement Objectives (AMAOs) 

established through Title III have heightened 

awareness among key stakeholders at the state, 

district, and school levels about the importance 

of focusing attention and resources on this 

population of students. 

Title III Provisions 

In 2001, as the number of EL enrollments 

continued to rise in U.S. public schools, Congress 

reauthorized the Elementary and Secondary 

Education Act of 1965 (ESEA), replacing Title 

VII (the Bilingual Education Act) with the current 

Title III. The reauthorized law abandoned the 

previous competitive grant-funding structure in 

favor of formula grants to states, and placed 

additional emphasis on providing ELs with the 

academic supports they need to attain English 

proficiency and to meet the same challenging 

and rigorous state academic content and student 

academic achievement standards that are 

required of all students. 

Title III grants are awarded to states, which in 

turn award subgrants to districts for the purpose 

of implementing language instruction programs 

to develop ELs’ English language proficiency 

(ELP) and to help ELs meet achievement 

standards in core subject areas. Although Title 

III states and districts are not required to 

implement a specific program of instruction, 

administer specific assessments, or hire specific 

staff, the reauthorization of ESEA holds them 

accountable for the outcomes their students 

attain. Under Title III law, state and district 

progress is measured against state-established 

annual measurable achievement objectives 

(AMAOs), which every district is responsible for 

meeting annually: 

1. AMAO 1: Annual increases in the number or 

percentage of students showing progress in 

learning English; 

2. AMAO 2: Annual increases in the number or 

percentage of students attaining English 

proficiency; and 

3. AMAO 3: Making adequate yearly progress 

(AYP)6 for limited English proficient children 

as described in Title I, Section 1111(b)(2)(B), 

of ESEA.

States are required to establish consequences or 

actions for districts that have not met AMAOs for 

2 or more consecutive years (under Title III, 

AMAOs only apply to districts or consortia of 

districts, not schools). The underlying purpose 

of these accountability mechanisms is 

ultimately to stimulate activities that better 

support ELs and increase English proficiency and 

content knowledge.
4 

Emerging Research on Improving Outcomes for ELs

As EL populations continue to rise in many states, districts, and schools across the nation, educators are eager to learn and 

implement effective strategies for improving EL outcomes. Although more work is needed in this area and no “silver bullets” have 

been identified, the research on how ELs may best be supported in the classroom and the conditions that increase their chances 

of educational success is emerging. 

• Research suggests the following about promising practices for ELs: 

1. English language and literacy development in ELs can be promoted by initially learning to read in their first language 

(August and Shanahan, 2006; Goldenberg, 2008; Hakuta, August, and O’Day, 2009); and 

2. “Effective academic instruction in English for ELs, while similar in many ways to effective instruction for all students, 

also requires specific adjustments and modifications since students are simultaneously learning academic content as 

they learn the language in which the content is taught” (Hakuta, August, and O’Day, 2009). 

• The Institute of Education Sciences (IES) What Works Clearinghouse practice guide, Effective Literacy and English Language 

Instruction for English Learners in the Elementary Grades, outlines the following five research-based recommendations 

districts can undertake for improving EL student outcomes in literacy: 

1. Establish procedures (and provide training) for schools to screen English Learners and monitor their progress, using the 

data to drive instructional decisions; 

2. Provide intensive, small-group reading interventions for at least 30 minutes daily with EL students identified as at-risk 

for reading failure; 

3. Adopt an evidence-based approach to vocabulary instruction and ensure the provision of extensive and varied 

vocabulary instruction for ELs; 

4. Adopt a plan that helps teachers develop English Learners’ academic English skills; and 

5. Facilitate and schedule regular peer-assisted learning opportunities during which EL students work in structured pair 

activities (U.S. Department of Education, 2008b). 

• The results of a 5-year evaluation of the effects of the implementation of California’s Proposition 227 on the education of 

English Learners demonstrated “no clear evidence to support an argument of the superiority of one EL instructional 

approach over another” (AIR and WestEd, 2006), but did identify key, promising features that lead to successful EL 

programs and services: 

1. Sufficient staff capacity to address ELs’ needs; 

2. A schoolwide focus on English language development and standards-based instruction; 

3. Shared priorities and expectations for educating ELs; and 

4. A commitment to using systematic, ongoing assessment data to inform decision making (AIR and WestEd, 2006). 
5 

Exhibit 1 shows that as of the 2007–08 school 

year, 10 states reported that 50 percent or more 

of their Title III districts had missed AMAOs for 

2 consecutive years. 

In the sample of nine districts selected for this 

brief, one district had missed AMAO 1, one had 

missed AMAO 2, and seven had missed AMAO 

3 in the 2007–08 school year for 2 or more 

consecutive years. Whereas no districts in the 

sample had missed AMAOs 1 or 2 for more than 

2 consecutive years, three had missed AMAO 

3 (AYP) for 4 consecutive years. 

What actions do states require 

of districts missing AMAOs? 

In accordance with the Title III law, the six states 

selected for this brief require Title III districts 

that miss one or more AMAOs for 2 or more 

consecutive years to develop an improvement 

plan. Title III subgrantees must also, in any year 

in which they miss one or more AMAOs, notify 

parents of ELs participating in Title III or 

identified for participation in Title III services of 

the district’s AMAO status. For the states with 

districts that have not met AMAOs for 

4 consecutive years, the accountability actions 

vary slightly but typically become more intensive. 

Actions for missing AMAOs for 

2 consecutive years 

The six states included in the sample require, as 

provided for in Title III, that these improvement 

plans address the AMAOs districts missed. 

Districts must demonstrate how they analyzed 

student English language proficiency test data 

and content test data to identify areas of 

weakness and the specific needs of their ELs. 

They must then describe how the activities 

outlined in their plan will address these issues 

and the specific AMAOs they missed. For 

example, the Title III state director in Arkansas 

explained that Title III improvement plans “have 

to be data-driven, and the activities and the 

Exhibit 1: Percentage of Title III Districts That Missed AMAOs for 2 Consecutive Years, 

2007–08 School Year 

Exhibit Reads: States colored in the darkest shade reported that 100 percent of their Title III subgrantees missed 

AMAOs for at least 2 consecutive years. 

Source: Consolidated State Performance Reports, 2007–08 (n = 50 states and the District of Columbia). 

Percent of Title III Districts that Missed AMAOs for Two Consecutive Years, 2007–08

Percent of Districts

0%

0-25%

25-50%

50-75%

75-100%

100%

No data
6 

budget must be seamless with regard to 

addressing [those] data.” A North Carolina 

district official also described the district’s Title 

III improvement plan as a “working and 

breathing document [that] involves 

administrators, mainstream teachers, curriculum 

developers, principals, etc. Every school creates a 

plan that is really based on data, on using their 

data. Data drives instruction.” The plans are 

submitted to the state for review and state 

administrators have established procedures, 

including on-site 

monitoring, to 

ensure districts’ 

implementation of 

their proposed 

plans. 

In accordance with 

the law, the 

interviewed state 

officials reported 

that they ensure 

districts missing 

AMAOs for 1 or 

more years notify 

parents of students 

who are receiving or 

who are eligible for 

Title III services of 

which AMAOs were 

missed, for every 

year that they are 

missed. To assist districts in this process, the 

states in the sample provide sample notification 

letters in the most commonly represented 

languages in the state. North Carolina also 

provides an AMAO parent resource for districts 

to disseminate that describes what AMAOs are 

and why they are important. At least one district 

official identified parent notification as a salient 

consequence of missing AMAOs, suggesting that 

it can further compel the improvement process. 

She noted that “being put on the list” for not 

meeting AMAOs for the [EL] subgroup is “always 

an issue for districts because then they have 

[public relations] issues in the community.” 

Actions for missing AMAOs for 

4 consecutive years 

Three of the six states included in the sample, 

California, New York, and North Carolina, had 

districts that had missed AMAOs for 4 

consecutive years (Arkansas, Indiana, and 

Montana had not yet had any districts in this 

situation and had not yet developed formal Title 

III accountability plans for missing the AMAOs 

for 4 consecutive years). In these three states, 

districts that miss AMAOs for 4 consecutive years 

are typically subject to more rigorous 

interventions, including the development of an 

action plan and/or potential modification of 

instruction or replacement of staff. Although 

loss of Title III funding is another possible 

consequence, none of the states in the sample 

had implemented this sanction in any of 

their districts. 

In California, districts missing AMAOs for 4 years 

must modify their curriculum or program of 

instruction and develop an action plan for 

improving EL performance that reflects the 

AMAOs that were missed. These plans are 

developed and submitted using an online system 

that allows districts to modify and monitor their 

plans. The online system serves also as a tool 

through which state officials can monitor district 

progress and implementation of the action 

plans. Districts missing AMAOs for 4 years are 

also assigned a county lead. California has 

11 county leads who provide these districts with 

ongoing support, including support in designing 

and implementing action plans. The county leads 

meet with staff from their assigned districts 

monthly to provide guidance and resolve issues 

related to Title III accountability. 

As an example of such support, one of the 

interviewed district officials in California 

described receiving support through intensive 

At least one 

district official 

identified 

parent 

notification as a 

salient 

consequence of 

missing AMAOs, 

suggesting that 

it can further 

compel the 

improvement 

process. 
7 

workshops focused on rewriting the district 

action plan. The district was required to embed 

an evaluation and monitoring component into 

the revised action plan. The district also had to 

develop a system for verifying district EL data 

that would better allow staff to accurately 

identify weaknesses in EL instruction and services 

and propose targeted solutions. Furthermore, a 

state committee provided feedback to the 

district upon reviewing the revised action plan, 

and requested that the district establish a time 

line for submitting detailed written updates 

regarding progress in their activities. According 

to this official, the types of intensive, hands-on 

support the district received from the state 

through the county leads “are pieces [of 

support] that make the development and 

implementation of any plan much 

more effective.” 

Similar to California, New York requires districts 

missing AMAOs for 4 consecutive years to write a 

corrective action plan that details major changes 

the district will implement to help ensure ELs’ 

progress and achievement. Such changes may 

entail modifications to staff, curriculum, and/or 

instructional materials. 

Unlike California and New York, North Carolina 

does not have specific requirements for districts 

missing AMAOs for 4 years that differ from those 

for districts missing for 2 consecutive years. 

According to state officials, rather than relying 

on a pre-established set of actions and 

requirements, the state differentiates support 

and technical assistance based on the AMAOs 

each district missed and based on data analyses. 

Districts missing AMAOs for 2 and 4 consecutive 

years are expected to conduct a needs analysis 

using disaggregated student data (e.g., EL data 

disaggregated by school and grade level). They 

then are required to submit an improvement 

plan to the state that outlines the actions the 

district will take to meet the AMAOs that were 

missed and to address the weaknesses in ELs’ 

achievement as 

revealed through 

the needs analysis. 

What 

supports do 

states 

provide to 

foster the 

district 

improvement 

process? 

A review of the 

six sampled states’ 

strategies for 

supporting the 

district 

improvement 

process under Title 

III revealed three 

commonly 

implemented 

support activities: 

(1) technical 

assistance to help 

districts identify 

areas of weakness 

and strategies for 

improving outcomes 

for ELs; (2) professional development focused on 

strategies for effectively teaching ELs; and 

(3) coordination with Title I to provide services to 

districts that have missed AMAOs and are 

identified for improvement under Title I. 

Although the quality of these supports was not 

examined for this brief, the state and district 

Title III officials who were interviewed offered 

their perceptions of the usefulness of these 

support activities, and of the extent to which 

Title I and Title III services are synchronized. The 

information presented below offers some insight 

Districts that 

miss AMAOs for 

4 consecutive 

years are 

typically subject 

to more rigorous 

interventions 

than districts 

that miss 

AMAOs for only 

2 consecutive 

years. Such 

interventions 

may include the 

development of 

an action plan 

and/or potential 

modification of 

instruction or 

replacement 

of staff. 
8 

into the sorts of actions six states are taking to 

specifically support and build the capacity of 

districts missing AMAOs, as well as the efforts 

they are undertaking to promote best practices 

for ELs in districts statewide, regardless of their 

AMAO status. 

Technical assistance to support the 

district and school improvement 

process 

Interview responses suggest that the states in the 

sample with a long-standing history of serving 

ELs, New York and California for example, have 

established formal systems of support focused on 

improving outcomes for ELs. These states devote 

regional staff and resources toward this effort. 

Arkansas, Indiana, Montana, and North Carolina, 

states that have experienced rapid growth in 

their EL population in more recent years, also 

have begun to establish such support networks. 

New York provides assistance through its 

14 Bilingual Education Technical Assistance 

Centers (BETACs), three of which are languagespecific (Asian, Haitian, and Spanish). These 

centers are linked with local universities and are 

located throughout the state.7 The support they 

provide is available not just to Title III districts 

that have missed AMAOs, but to Title III districts 

that have successfully met AMAOs as well as to 

other local education agencies that may not 

have Title III programs, but serve ELs. Examples 

of the types of assistance the BETACs offer 

include: 

♦ Assistance on policies and regulations, 

educational resources, and implementation 

of higher learning standards related to ELs; 

♦ Assistance with parent and community 

outreach programs and activities that are 

designed to support ELs’ success in schools; 

and 

♦ Facilitation and organization of professional 

development opportunities designed to 

enhance the knowledge and skills of 

EL educators. 

The California Department of Education 

coordinates with the California Comprehensive 

Center at WestEd to offer 2-day forums to Title 

III districts that have missed AMAOs. These 

forums are required and differentiated for 

districts that have missed their AMAOs for 2 and 

4 consecutive years. During these forums district 

officials are provided with information and 

training on using the English Language Learner 

Subgroup Self Assessment (ELLSSA)8 tool to 

identify weaknesses in their current plan, factors 

contributing to missing AMAOs, and activities 

they can implement to help meet AMAOs. 

Additionally, the state organizes an annual 

three-day accountability institute focused on 

ELs that includes several sessions on Title 

III accountability measures, program support, 

and strategies for implementing EL programs 

and services. 

In an effort to coordinate services, California also 

has established a Bilingual Coordinators Network 

comprised of the 11 largest districts in the state 

as well as county offices of education. This 

network meets four times a year and the 

meetings focus on strategies for meeting the 

needs of ELs, including issues surrounding Title III 

implementation and accountability. One district 

official in California reported that she has been 

encouraged by the state’s implementation of 

Title III and with the support her district has 

received. She commented, “The state holds true 

to the intent of Title III so that processes and 

procedures do not get in the way of Title III,” 

and that “overall state support has met the 

district’s needs.” 

Similar to California, Indiana has established 

an English as a Second Language (ESL) 

Advisory Group comprised of administrator 

representatives from urban and rural districts 
9 

“It takes a 

village to 

educate a child. 

One or five [EL] 

teachers can’t 

do it alone—

everyone has to 

be trained who 

is meeting 

these students 

and even people 

who aren’t 

teaching them 

but [who are] in 

the building 

need to be 

involved in the 

effort.” 

—District Title 

III official

across the state. The ESL Advisory Group meets 

throughout the year to share strategies, ideas, 

challenges and 

successes, and to 

develop strategies to 

meet the education 

needs of ELs. The 

district official in 

Indiana indicated 

that the Advisory 

Group has been 

especially helpful in 

guiding the district’s 

implementation of a 

specific program it is 

using to support ELs’ 

literacy 

development. She 

has been able to 

learn from other 

districts’ 

experiences. 

In Arkansas, 

technical assistance 

is focused on 

helping Title III 

district officials use 

data to inform and 

improve their 

practices. The state 

convenes data 

summits designed to help districts analyze and 

interpret their ELP assessment data (pertinent to 

AMAO 1 and AMAO 2) and benchmark data 

(pertinent to AMAO 3) in order to identify trends 

and areas that appear particularly weak. Districts 

then are expected to incorporate these 

observations and to identify strategies for 

addressing areas of weakness in their 

improvement plans. All Title III districts are 

included in these Data Summits, regardless of 

their AMAO status. As indicated earlier, North 

Carolina state officials try to individualize the 

assistance they provide to districts. In addition to 

helping districts that have missed AMAOs write 

their improvement plans, state staff are available 

to all Title III districts on an as-needed and byrequest basis. Officials from two districts in the 

state positively emphasized state staff’s 

accessibility and responsiveness. One district 

official reported, “The state provides wonderful 

support.... [State Title III staff] send good tips 

and strategies, best practices, and latest 

studies.... They are spread thin but they provide 

really wonderful support; we couldn’t ask for 

better support.” 

Professional development focused on 

supporting EL student achievement 

All of the state and district officials who were 

interviewed for this brief reported that Title 

III had heightened stakeholders’ awareness of 

the issues related to instructing ELs. Some 

officials further indicated that this awareness has 

resulted in more professional development for 

educators who serve English Learners. 

Specifically, there has been a greater emphasis 

on ensuring instructional staff have the capacity 

to support not only English Learners’ language 

development, but also students’ content-area 

academic success. As one state official noted, 

“It takes a village to educate a child. One or 

five [EL] teachers can’t do it alone—everyone has 

to be trained who is meeting these students and 

even people who aren’t teaching them, but [who 

are] in the building need to be involved in 

the effort.” 

Interview responses suggest that districts, rather 

than the states, are largely responsible for 

providing ongoing professional development to 

school-level staff. However, some states, 

including New York and North Carolina, offer 

state-wide training on topics specific to teaching 

English Learners, as described in the text 

that follows. 

New York sponsors five 1-day teacher institutes 

throughout the school year, and teachers also 

are provided with tuition assistance to earn their 
10 

“The Title I 

focus and 

perspective is 

on the 

acquisition of 

core academic 

skills, and [Title 

III’s focus] is 

the acquisition 

of English, but 

they go hand in 

hand.” 

—State Title 

III official

English as a second language (ESL) or bilingual 

certification. Bilingual Leadership Academies are 

another form of professional development 

designed to build capacity at the local level. The 

academies aim to develop ESL and bilingual 

teachers into principals and administrators. 

Since 2006, North Carolina has strongly 

encouraged its schools to implement the 

Sheltered Instruction Observation Protocol (SIOP) 

model, which officials believe is one way to 

support high-quality instruction for ELs in all 

content areas. The state holds train-the-trainer 

institutes in an attempt to build capacity at the 

district and school levels for implementing SIOP, 

and also uses technology (e.g., 24-hour 

e-coaching and webinars) to provide ongoing 

technical assistance and training in the model. In 

addition to this professional development, which 

is offered to all districts, North Carolina delivers 

professional development, specifically for 

districts and schools that have not met AMAOs. 

During the 2008–09 school year, this training was 

concentrated on teaching reading and academic 

language, areas that were identified as in need 

of improvement based on data and the AMAOs 

districts missed. 

Although the majority of the district officials 

who were interviewed expressed satisfaction 

with the support and professional development 

offered by their state, district officials in one 

state indicated that the state-level capacity for 

supporting districts with high EL populations was 

under development. They explained that the 

majority of the EL student population is located 

in two counties, relatively far from the state 

capital. Their perception was that state officials’ 

and policymakers’ “distance” from the EL 

population has resulted in a lesser sense of 

urgency for addressing the challenges associated 

with improving English Learners’ outcomes. The 

Title III district officials who were interviewed 

explained that they have had to seek out 

assistance from recognized experts in the field, 

beyond state lines, 

for guidance and 

professional 

development. 

Coordination 

with Title I 

For the six states 

included in the 

sample, the majority 

of their EL 

populations are 

enrolled in Title I 

schools and both 

state and district 

officials indicated 

that schools 

struggling with Title 

I accountability can 

make gains by 

concentrating more attention and resources on 

their English Learners. As one state official 

commented, “The Title I focus and perspective is 

on the acquisition of core academic skills, and 

[Title III’s focus] is the acquisition of English, but 

they go hand in hand.” 

All of the state officials who were interviewed 

also reported that the alignment and 

coordination of Title I and Title III services have 

increased in recent years. Specifically, they 

described efforts to coordinate the Title I and 

Title III improvement processes, particularly for 

districts that have missed AMAOs and also are 

identified for improvement under Title I. As 

one example, California reported that in 

2007–08 the Title III office worked closely with 

the Title I office to better align the notification 

for program improvement status under Title 

I and Title III, and also to better align the 

process for submitting improvement plans for 

the two programs. 

Similarly, Indiana’s Title I office invites district 

administrators to technical assistance and 
11 

training workshops during which Title I and Title 

III staff address issues related to their 

improvement status and to increasing the 

performance of ELs. According to one district 

official in this state, Title I and Title III 

coordination has increased not just at the state 

level but at the district level. She described a 

greater level of “commitment and active 

participation of both programs” toward 

maximizing Title I and Title III resources. For 

example, the offices have collaborated to 

provide professional development in EL 

strategies for teachers districtwide. 

Despite these statements, when state and district 

officials were probed about the extent to which 

Title I and Title III offices coordinate services and 

how often such coordination occurs, Title III 

officials in four of the five states in the sample 

indicated that the majority of Title I and Title III 

coordination is limited to joint or consolidated 

auditing and monitoring, which may occur only 

once or twice a year. Additionally, one state 

official noted that although coordination is 

growing at the state level, districts in his state 

“still see a big disconnect between Title I and 

Title III.” 

What strategies are districts 

using to improve EL 

performance? 

The extent to which Title III has contributed to 

the district improvement process for ELs is an 

important policy issue. Although it may not be 

possible to tease apart whether districts are 

implementing strategies for addressing the 

needs of their ELs as a direct result of Title III or 

whether they would have undertaken such 

activities regardless of Title III’s existence, the 

interviewees’ responses indicate that Title 

III accountability has influenced their decision 

making concerning EL programming. In four 

districts, Title III officials indicated that specific 

strategies were adopted as a result of missing 

specific AMAOs. In the other five districts in the 

sample, Title III officials indicated that the Title 

III improvement process helped them enhance 

and refine their already existing programs 

and services. 

The most common strategies for addressing the 

needs of ELs used across the nine sample 

districts include: 

♦ Using data to identify EL students, providing 

appropriate placements in EL programs, and 

evaluating services provided to the ELs 

(nine districts); 

♦ Establishing instructional supports 

designed to meet the needs of EL students 

(nine districts); 

♦ Incentivizing professional 

development and teacher endorsement 

programs (seven districts); and 

♦ Promoting community involvement and 

family outreach (four districts).

Using data to identify students for EL 

programs and evaluate services 

All of the district and school officials in the 

sample indicated that they rely on student 

assessment data for appropriately identifying 

students for placement into EL services, and 

many use data to target evolving individual 

needs as students receive those services.

Specifically, all nine districts administer newly 

enrolled students a home language survey to 

determine if a language other than English is 

spoken at home. If this is the case, students are 

“flagged” and are administered a more formal 

test to determine English proficiency. These 

results are used to determine the student’s level 

of reading, speaking, and writing of the English 

language and to assign students to an 

appropriately leveled classroom or to place them 

in a targeted instructional program. Data are 

then used to monitor students’ progress and to 

ultimately redesignate EL students as fluent and 
12 

proficient in English. For example, in one district, 

EL students are classified into one of four levels 

based on these data, with Level 1 indicating the 

lowest level of proficiency. Level 1 students are 

provided with the most supports, including a 

greater number of classes taught by English for 

speakers of other languages [ESOL]-endorsed 

teachers. As students graduate to the higher 

levels of proficiency and eventually exit EL 

services, the supports they receive decrease. 

Some of the districts in the sample also are 

beginning to use data to evaluate the outcomes 

of their EL improvement activities and to inform 

future efforts. One district official reported that 

she reviewed language proficiency data and the 

end-of-course scores for EL students. These data 

indicate that EL students, particularly at the high 

school and middle school levels are “stuck” and 

continually receiving low scores on the end-ofcourse writing exam. As a result, the district is 

bringing in an expert in the field of ELs to train a 

team of content-area teachers and will pilot a 

program in one of its high schools designed to 

improve the writing skills of ELs. Similarly, due to 

missing AMAO 3 (specifically high school math) 

for 2 consecutive years, this same district handschedules incoming EL ninth-graders into 

Foundations of Algebra or Algebra I with select 

teachers rather than using automated scheduling 

software. This ensures the students are taught by 

teachers who have been trained in the Sheltered 

Instruction Observation Protocol (SIOP) model. 

As another example of using assessment data to 

evaluate the outcomes of services, another 

district in the sample employs a full-time director 

of research and evaluation who is responsible for 

collecting data, analyzing data, and making 

recommendations about EL programming. 

Having someone devoted to research and 

evaluation has allowed the district to conduct 

comprehensive studies within its English 

language development program and helped 

officials determine which instructional practices 

and programs are best serving their EL 

population. For example, district assessment data 

suggest that ELs placed in dual language 

classrooms, which consists of 50 percent English 

instruction and 50 percent Spanish instruction, 

are the highest-performing ELs by the end of 

sixth grade. The district also has introduced a 

staff development program emphasizing 

systematic English language development, which 

is being implemented with varying degrees of 

fidelity at each school site. Assessment data 

indicate that the teachers, grade-level teams, 

and schools that implement the program with 

greater fidelity (e.g., implement all components 

of the program in compliance with the district’s 

guidelines and as intended) experience larger 

gains in their EL’s academic performance. 

Establishing instructional supports 

for ELs 

All of the nine sample districts have developed 

instructional supports targeted to meeting the 

needs of their ELs. However, these instructional 

supports range considerably across the sample of 

districts. The number, availability, and expertise 

of district- and building-level staff affect how 

instructional supports for ELs are provided, as 

does the structure and nature of the schools and 

the distribution of EL resources, teachers, and 

students within the district. 

Depending on these factors, districts typically 

implemented at least one or a combination of 

the following practices: 

♦ Within-classroom, content-based EL 

instruction; 

♦ Push-in support from a specialist who works 

with ELs within the regular classroom; 

♦ Pull-out support from a specialist who 

provides targeted instruction outside of the 

regular classroom; 

♦ Formal dual language or bi-literacy 

programs; 

♦ Structured English immersion or Sheltered 

English instruction practices; 
13 

In the interest of 

sustainability and 

less reliance on 

outside 

consultants in 

the future, 

several districts 

are looking to 

increase building 

and district 

capacity by 

developing their 

own trainers. 

♦ Out-of-school enrichment programs; and/or 

♦ Newcomer centers and schools to specifically 

support recently arrived students.

Incentivizing professional development 

and teacher endorsement programs 

All of the sample districts require professional 

development for staff working with ELs, and 

many have established incentives and/or have 

required teachers to earn their EL endorsement. 

District officials described partnerships with local 

universities and colleges to encourage all 

teachers, EL and mainstream, to complete 

EL-related coursework. Five of the nine districts 

have partnered with local universities to offer 

coursework for teachers in EL strategies and to 

graduate students with an EL certification or 

endorsement.9 Other strategies include 

providing in-service professional development 

focused on EL 

language acquisition 

and coordinating 

resources with Title I 

to provide 

additional in-service 

training. One district 

in Arkansas also is 

working closely with 

AmeriCorps to 

“grow their own” 

teachers who 

represent the EL 

populations in their 

schools. 

In-service 

professional 

development is 

provided by a wide 

array of individuals. 

Title III district staff, EL teachers, coaches, outside 

consultants, and people from other districts in 

the state were identified as professional 

development providers by district officials. The 

professional development provided by these 

individuals is designed typically to address the 

nature of the district’s EL population and areas 

of weakness identified by assessment results. It is 

also often based on which AMAOs the district 

missed. 

One district in Indiana has developed a system 

for ensuring not only that teachers receive the 

professional development, but that they are 

actually applying what they learned in the 

classroom. According to the district official, this 

system was established initially due to concerns 

about veteran teachers’ lack of buy-in for 

evolving EL instructional practices. In order to 

address this issue, the district established a 

two-tier training system in which teachers are 

first trained in EL strategies and then supervised 

to ensure they are incorporating the approaches 

into their daily classroom instruction. 

Several of the districts in the sample also are 

looking to increase building and district capacity 

by developing their own trainers. By doing so 

they hope to decrease their reliance on outside 

consultants and put themselves in a better 

position to sustain their efforts. 

Promoting community involvement and 

family outreach 

In addition to supporting students through 

targeted classroom instruction, districts are 

reaching out to the families and the greater EL 

community by disseminating information about 

not only school-based supports and activities for 

the families of ELs, but also about various 

community resources and organizations that 

serve their needs. 

One district in particular supports recently 

arrived families through a neighborhood center 

that provides school and community information 

in their native language and serves as a point of 

contact. The district also has Hispanic parent 
14 

“It is an ongoing, 

never-ending, 

don’t-makeassumptions 

battle to make 

sure teachers 

know what to do 

on any given 

day.” 

—District Title 

III official 

liaisons who host a Spanish radio show in order 

to deliver pertinent information that non-English 

speaking individuals may otherwise miss. Longstanding partnerships with local Hispanic 

organizations also help further the district’s 

reach. (See the text box entitled, The District 

Improvement Process: The Efforts of One District 

With Rapid EL Growth, on page 15 of this brief 

for additional strategies this district has 

implemented to support its EL population.) 

What challenges do districts face 

related to Title III accountability? 

The interviewed state and district officials 

reported three challenges associated with Title 

III accountability that have hindered the district 

improvement process, in particular: 

♦ Recruiting and training staff qualified to 

teach ELs; 

♦ Promoting a sense of accountability at the 

school level; and 

♦ Funding EL services. 

Recruiting staff qualified to teach ELs 

Most of the state and district officials who were 

interviewed cited challenges associated with 

recruiting teachers with the knowledge and skills 

for teaching ELs, indicating a need for both 

teachers with the skills to teach English language 

development and content-area teachers with the 

skills and training to support ELs in their 

classrooms. 

In two states, officials noted that teacher 

training and preservice programs do not require 

ESL coursework and teachers who work with ELs 

do not necessarily need to have earned an ESL 

endorsement. As a result, districts with EL 

populations in these states are tasked with 

providing this training, often on a year-to-year 

 basis due to teacher turnover. As one district 

official stated, “It is an ongoing, never-ending, 

don’t-make-assumptions battle to make sure 

teachers know what to do on any given day.” 

In the small sample of nine districts, two rural 

districts in particular appeared to struggle to 

recruit and retain teachers qualified to teach ELs. 

According to one 

district official, dual 

language and 

certified teachers are 

frequently more 

interested in teaching 

in urban centers. 

Another district 

official noted that it 

is difficult to staff 

qualified EL teachers 

at the high school 

level. Her district 

typically hires a 

teacher for four to 

five periods of 

regular core content 

and then encourages 

them to teach EL 

classes to fill their 

course load, with the agreement that they will 

earn their endorsement in 3 years. However, 

within 3 years, most of these teachers have left 

the district. 

Promoting a sense of accountability at 

the building level 

The Title III district-level officials indicated that 

promoting a sense of accountability among 

building-level administrators and teachers for 

their EL students’ performance is another 

challenge they have encountered related to Title 

III accountability, particularly because AMAOs 

only apply to districts, not schools. 
15 

The District Improvement Process: The Efforts of One District With Rapid EL Growth 

The sample included one district that has taken notably proactive steps to improve the outcomes of their rapidly growing English 

Learner population. District officials have taken it upon themselves to research and seek out support and training from experts in 

the field, taken steps to coordinate services for ELs, and established partnerships with community-based organizations, all on their 

own initiative. Although the data collection did not allow for a close examination of the quality of these activities, the information 

provides insight into one district’s response to their changing student demographic. 

In 1993, this district served approximately 8,000 students (95 percent of whom were White). Currently, the student population is 

over 17,000, approximately half of which is EL. This district made concerted efforts to welcome these families and to provide 

services designed to support their successful transition into the education system. 

EL community outreach 

Outreach is a cornerstone of the district’s efforts to meet the needs of ELs. One district official explained, “At first [we] thought 

[we] could meet their needs with just a little extra support in the classrooms, but learned quickly that parent involvement [is] 

necessary.” To help engage parents, the district employs two Hispanic parent liaisons who work with all ELs and their families,

regardless of language, race, or ethnicity. Besides working directly in the community, the liaisons also host a radio show during 

which they disseminate information and answer questions from EL families about the schools. The district also has a center for EL 

families designed specifically for newcomer families and that serves as a point of contact and a source of information and 

support. By coordinating with the local Hispanic women’s organization, the district further remains connected to the community.

Instructional supports 

The district has established a focused instructional design model that emphasizes student-to-student interaction and the use of

academic language to help develop ELs’ proficiency and academic achievement. The district provides bilingual instructional 

assistants, supplemental materials, and ESL programming during the summer months to further support ELs. 

To address the specific needs of adolescent ELs, especially recent immigrants, the district has created a Language Academy. 

Students in grades 9–12 and who are in their first year in the United States attend the Language Academy. It is taught by three, 

highly trained core content area teachers (ELA, math, and science). Instruction is delivered primarily in English and the students 

are immersed in both the language and the content, but in an environment that is safe and nonthreatening. 

The district also recognizes the need to support young ELs and better prepare them for a successful academic career. In 2005, the 

district opened a prekindergarten center specifically targeting families with non-English speaking children. Currently, the center 

serves about 520 students, and the district hopes to increase enrollment to 600. 

Teacher recruitment and training 

Finally, the district has undertaken efforts to build the capacity of their teachers to effectively teach ELs. The district expects all 

teachers to earn their ESL endorsements through a local university or participate in district-sponsored professional development 

focused on culture, language acquisitions, and instructional strategies for ELs. In the 2008–09s school year, the district had about 

400 teachers who had completed the formal coursework, and all 1,230 of the district’s teachers participated in 30 hours of the 

district-sponsored professional development. The district also has hired EL specialists who work specifically with principals and 

teachers to ensure they are adhering to the requirements mandated under Title III and under Title VI. 
16 

“We cannot 

possibly achieve 

what is in Title 

III with the 

funding 

provided. But, is 

it value-added? 

Absolutely.” 

—District Title 

III official 

As one district official explained, “I think when 

you get into a system of improvement [for 

missing AMAOs for consecutive years], our 

difficulty comes in that most of our schools don’t 

have subgroups, so you develop a situation 

where you have building administrators who 

aren’t highly 

motivated to 

implement changes 

because there isn’t 

[Title III] 

accountability at the 

building level.... I 

would appeal to the 

Title III folks to 

develop ways that 

that accountability 

can be transferred 

down to the 

school level.” 

The consortium of 

Title III districts 

included in the 

sample has encountered a similar challenge due 

to the nature of the consortium and the way 

AMAOs are calculated (data are aggregated so 

AMAOs are either met or missed at the 

consortium level not at the individual district 

level). According to the consortium lead, 

member districts sometimes drop out of the 

consortium because they are not willing to face 

the consequences associated with Title III 

accountability. The consortium lead stated, “You 

had these districts, particularly the smaller ones, 

saying it wasn’t worth the money because of the 

implications of the accountability. If they did not 

accept Title III funds then they would not come 

under the scrutiny of the accountability system 

for the LEP [subgroup]. Even a district that was 

eligible for $15,000 did not want the money, 

saying it was not worth it, that it was like 

playing ‘Russian Roulette’.” Moreover, when the 

district officials in the consortium received the 

letter reporting that the consortium missed 

AMAOs, the consortium lead indicated that she 

was on the receiving end of these officials’ 

frustrations. She explained, “Everyone was 

belligerent and blaming every other district. 

They just don’t see it as their problem.” 

Funding EL services 

The interviewed state and district officials 

consistently perceived Title III as only a small 

proportion of their districts’ total budget. 

One district official described Title III funds as 

“just a drop in the bucket.” For the nine districts 

described in this brief, the Title III grants ranged 

from $133,942 for an EL population of 

approximately 1,249 students to $3,670,000 for 

an EL population of approximately 

37,091 students, or $107 per student and $98 per 

student, respectively. These data correspond 

with the findings of the State and Local 

Implementation of the No Child Left Behind Act: 

Targeting and Uses of General Education Funds

report (Chambers, Lam, Mahitivanichcha, Esra, 

and Shambaugh, 2009), which indicate that Title 

III typically provides a supplement of 

approximately $100 per EL served. Despite 

concerns with the amount of funding for ELs, the 

interviewed officials all indicated Title III was 

valuable and served to increase stakeholders’ 

awareness of the needs of English Learners. As 

one district administrator shared, “We cannot 

possibly achieve what is in Title III with the 

funding provided. But, is it value-added? 

Absolutely.” 

Districts officials also reported having access to 

other funding sources for serving EL students. In 

addition to Title III, districts draw on Title I funds 

for EL-related services and programs (especially 

since Title I schools typically serve the greatest 

proportion of ELs in a given district), other state 

funds, and local funds and grants. For example, 

one district was the recipient of a state-sponsored 

Refugee Children School Impact Grant that 

provides some of the costs that local school 

districts incur by educating significant numbers 

of refugee children. The grant provides money 
17 

for activities and support that will lead to 

effective integration, such as school-based 

interpreters and translators and for summer 

camps. Another district takes advantage of city 

funds and migrant funds to support after-school 

programs and tutoring for ELs. In yet another 

district, a $1.5 million grant was awarded to a 

small local college that used the funds to create 

an ESL certification program from which the 

district was able to recruit several ESL teachers. 

Although American Recovery and Reinvestment 

Act of 2009 (ARRA) funds were not directly 

appropriated for the Title III program, district 

officials indicated that the students served under 

Title III would benefit indirectly from the portion 

of ARRA funds that were appropriated for the 

Title I program. District officials reported that 

the majority of their ELs were enrolled in Title 

I schools so that even if the funds were not 

specifically used to target services and programs 

for ELs, ELs would benefit from the other 

student supports that would be implemented for 

all students in the schools. However, two district 

officials in particular were taking a proactive 

approach to working with Title I staff to devote 

some of the Title I ARRA funds to support ELs. 

One district official was in the process of 

negotiating with Title I staff to devote some of 

the ARRA funds to support English classes for 

parents and an 8-week intensive summer 

program for incoming EL kindergarten students 

who did not have previous preschool experience. 

Another had submitted a proposal for a portion 

of ARRA funds to be used to provide in-depth 

professional development for secondary school 

teachers that would include coaching and other 

capacity-building activities targeted toward 

meeting the needs of ELs. 

What are the reported benefits 

of Title III accountability? 

The district officials who were interviewed for 

this brief concur that one of the most valuable 

benefits of Title III accountability is heightened 

awareness of the needs of ELs. As one district 

official in North Carolina stated “[Title III] has 

brought [EL] kids to the front line and opened 

up a lot of eyes.” Not only did the legal 

requirement in ESEA to meet the needs of ELs 

require states to create ELP standards for the 

first time, but additional benefits reported by 

some of the interviewed officials include 

increased awareness among stakeholders for the 

importance of monitoring EL academic 

performance over time (as opposed to measuring 

performance at one point in time), and 

enhanced and refined 

classroom instruction for 

ELs through professional 

development and 

teacher collaboration. 

In an effort to more 

accurately track and 

understand student 

progress, one district has 

developed a data 

management system to 

better organize, 

manipulate, and draw 

meaningful conclusions 

from their EL data. The 

data system allows teachers to track an EL 

student’s achievement longitudinally and 

according to this official, allow educators to 

better diagnose student needs and provide 

parents with important information about how 

their children are doing. Regarding instructional 

practices for ELs, another district official noted 

that since the introduction of Title III her state 

has seen, “more services to [EL] students and 

greater ability of teachers to provide supports in 

the classroom.” 

For the Title III consortium in the sample, the 

Title III grant also enabled opportunities for 

teachers across districts to come together for the 

purpose of sharing EL instructional strategies 

and programs, often through literacy institutes 

and teacher-led presentations. With this 

“[Title III] has 

brought [EL] 

kids to the front 

line and opened 

up a lot of 

eyes.” 

—District Title 

III official
18 

“What’s really 

great is that [Title 

III] has put this 

population on the 

map for 

accountability.” 

—District Title 

III official 

collaboration time, teachers in the one sampled 

consortium of Title III districts developed and 

implemented a large-scale summer literacy 

program for their ELs. The consortium lead 

shared that “[Title III] is a great idea and a good 

opportunity for teachers. As a consortium, we 

were able to bring teachers from great distances 

together to share their experiences.” 

What is the reported salience of 

Title III? 

When asked about the salience, or preeminence 

and “value-added” of Title III, the officials 

included in our sample frequently compared 

Title III with Title I. Overall, respondents 

indicated that Title 

I accountability has 

greater salience than 

Title III accountability, 

but that Title III is valueadded and that 

stakeholders are 

beginning to take the 

legislation more 

seriously. 

According to one state 

official, “In terms of 

districts seeing 

consequences of 

AMAOs, [we] still [have] a long way to go. 

People don’t take it as seriously as AYP. They 

look at AYP as a more important accountability 

system than AMAOs.” On the other hand, many 

of the Title III officials reported that Title III 

accountability bolsters Title I accountability. They 

explained that the overlapping federal 

requirements for the two programs cause 

districts to feel that they will be sanctioned twice 

for the same measure, which provides additional 

motivation for meeting those AMAOs. Districts 

must focus on providing quality programs and 

services in order to attain the level of EL student 

performance needed to meet expectations. 

Furthermore, one state official indicated that the 

Title III accountability system is more meaningful 

in terms of EL performance than Title I’s 

singular focus on content area assessment data. 

Specifically, this individual commented that 

AMAOs 1 and 2 provide a “fairer” picture of 

EL attainment. 

Several officials also indicated that the key 

stakeholders in their districts, including school 

leaders and instructional personnel, had become 

aware of the AMAOs by means of professional 

development and meetings about their district’s 

performance. They explained that this awareness 

helps facilitate the improvement process because 

more individuals are invested in addressing the 

needs of ELs in order to meet their accountability 

targets. Another state official commented, 

“What’s really great is that [Title III] has put this 

population on the map for accountability. 

There’s no question about that. It’s been very 

salubrious to the districts in our state and also 

at the school-building level that these kids 

cannot be hidden, they can’t be shunted aside, 

they can’t be denied services, and the state 

and district [are] held accountable for 

their progress.” 

Summary 

In summary, the interviews with state and district 

Title III officials suggest that Title III has resulted 

in some positive actions designed to support ELs’ 

academic success. States have established 

accountability actions and consequences for 

districts that miss AMAOs, and they provide 

technical assistance and support to these districts 

to facilitate the improvement process. 
19 

Although recruiting qualified teachers of ELs, 

promoting a sense of accountability at the school 

level, and the level of funding for EL services 

were raised as challenges, the officials who were 

interviewed also highlighted several benefits of 

Title III. In particular, officials 

reported that Title III has notably heightened 

awareness of issues related to ELs and focused 

more attention on their instructional needs. It 

also has pushed local education agencies to 

reexamine and reassess their current practices 

and services for this population of students. 

National Evaluation of Title III Implementation 

This brief, Title III Accountability and District Improvement Efforts: A Closer Look, and its two companion briefs, Title III Policy: 

State of the States and Title III Accountability: Behind the Numbers, were written during the early stages of the National 

Evaluation of Title III Implementation, a U.S. Department of Education study being conducted by the American Institutes for 

Research. These three briefs are precursors to the collection and analysis of nationally representative data and in-depth case 

study data of Title III-funded districts to examine state and local implementation of Title III standards, assessments, and 

accountability systems under that evaluation. 

The National Evaluation of Title III Implementation will provide more in-depth explorations of some of the issues presented in 

this brief, including analyses regarding: 

• The quality of the supports states provide to districts related to the district improvement process under Title III; 

• How Title III has affected the district improvement process for ELs; 

• The extent to which states and districts differentiate their responses and improvement activities based on the 

AMAO(s) that were missed;’ 

• The extent to which districts evaluate the effectiveness of their improvement activities on EL outcomes; and 

• The extent to which Title III districts struggle to recruit teachers with the skills to teach English language development 

and content-area teachers with the skills and training to support ELs’ academic learning. 

Acknowledgments 

The members of the study team wish to thank all individuals who contributed their time and efforts throughout data 

collection and drafting the brief. Specifically, we would like to express our appreciation to the state and district Title 

III officials who took time out of their busy schedules to speak with us; to AIR staff and consultants, including Bea 

Birman, Andrea Boyle, Kerstin Carlson Le Floch, Kenji Hakuta, Jennifer O’Day, and James Taylor for their thoughtful 

suggestions, guidance, and contributions; and to the following reviewers at the U.S. Department of Education: Supreet 

Anand, Millie Bentley-Memon, Tom Corwin, Susan Craig, Liz Eisner, Britt Jung, Daphne Kaplan, Isabel Oregon, Ron 

Petracca, Jose Rico, Tracy Rimdzius, Phil Rosenfelt, and Richard Smith. The contributions of these individuals were 

essential for the production of the brief. 
20 

Notes 

1 The term English Learner refers to a student whose 

primary language is a language other than English and 

whose level of English proficiency is insufficient to 

support academic learning in a regular classroom in 

which English is the language of instruction. The 

Elementary and Secondary Education Act (ESEA) uses 

the term limited English proficient (LEP) for such 

students; however, it has since become more common 

to use the English learner term. As such, this brief uses 

English learner to refer to students who require 

additional instructional supports to fully participate in 

all-English classrooms until they achieve the requisite 

level of English proficiency. 

2 This is an EL count based on the Title I definition of 

who constitutes an English Learner. States may count 

ELs differently for Title I and Title III. 

3 The term “district” is used throughout this brief in 

reference to any Title III subgrantee, including 

consortia of districts receiving Title III subgrants. 

4 These data are derived from the 2007–08 

Consolidated Performance Reports (CSPR) submitted 

by states. 

5 This brief is the third in a series of three Title III policy 

briefs. The first, Title III Policy: State of the States

provides an overview of state-level implementation of 

key Title III provisions and highlights emerging issues 

associated with Title III standards, assessments, and 

accountability. The second, Title III Accountability: 

Behind the Numbers, provides the most recent data 

available on the school-age EL population across the 

Notes Spacemaker 

country and states’ and districts’ Title III AMAO status. 

The briefs in this series were written for a policy 

audience but appeal to a range of different 

stakeholders. Each brief has its own focus and features 

key contextual information related to that focus. 

Accordingly, multiple briefs may contain 

similar information. 

6 Adequate yearly progress (AYP) is a target set by 

individual states to determine student achievement at 

the district and school levels regarding achievement of 

academic standards in reading/language arts and 

mathematics. Districts and schools must meet annual 

AYP targets for their student population as a whole as 

well as for individual subgroups of students, including 

one subgroup composed of ELs or LEP students. 

7 The three language-specific centers are located in 

New York City, but offer services statewide. 

8 The ELSSA provides districts with a means for 

analyzing EL outcomes and program services and helps 

them identify areas they need to strengthen to better 

ensure the success of their ELs. The state requires all 

local education agencies that have missed AMAOs for 

two consecutive years and 4 consecutive years to 

complete this tool, as well as those LEAs that have 

been identified for Title I program improvement due 

to the performance of their EL subgroup. The tool is 

available online for other districts’ use as well. 

9 This count does not include the two districts in 

California where EL certification is a requirement for 

teachers with ELs in their class. 
21 

References 

American Institutes for Research & WestEd. (2006). 

Effects of the implementation of Proposition 227 on 

the education of English learners, K–12. 

Sacramento, CA: California Department 

of Education. 

August, D., & Shanahan, T. (Eds.) (2006). Developing 

literacy in second-language learners: Report of the 

National Literacy Panel on Language-Minority 

Children and Youth. Mahwah, NJ: Lawrence 

Erlbaum Associates. 

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