Dear Title III Directors,

It was wonderful to see so many of you at the meeting last week.  We want to thank the NCSTIIID Board for all of their hard work in putting together an array of presentations that highlighted how different policies at ED and beyond may impact your work at the SEA.  We did want to offer one point of clarification, based on the discussion that occurred at the end of the sessions with the Office of Civil Rights (OCR) and the Department of Justice (DOJ) regarding your obligation to comply with Title VI, EEOA, and other requirements monitored and enforced by those teams.

Title III is intended to be a supplemental program that supports the basic English language assistance program in your State. An SEA or LEA has the obligation to provide services to ELs and to comply with Title VI and EEOA requirements, whether it receives Title III funds or not.  Because of this, a Title III Director or program at the SEA might run into supplanting issues if Title III staff who are funded only out of Title III are also tasked with the oversight of these other requirements.  The work supporting these broader requirements should come from State or local funds, either in paying for a portion of the Director's salary to do such work or in providing additional personnel to support general programming for ELs across the SEA or LEA.  Our goal is to clarify the intended purpose and ensure that funds are used to supplement local, state and other federal funds. 

Supreet Anand