Yes, Title III funds can pay for English learner materials, as long as the materials are supplemental. The California Department of Education (CDE) lists "identifying, acquiring, and upgrading curricula, instructional materials, educational software, and assessment procedures" among authorized Title III activities, but says the funds cannot buy materials used as primary instructional materials. Your district or charter, as the Title III subgrantee, decides whether a specific purchase is allowable.
Below is what CDE's public Title III pages say, and how a purchase usually moves through a district.
What is Title III Part A for?
Title III, Part A of the Every Student Succeeds Act (ESSA) funds the English Learner Student Program (and a separate Immigrant Student Program). The CDE's Title III Authorized Costs page says the purpose is to ensure that all English learners attain English language proficiency and meet the same challenging state academic standards as other students.
The money goes to local educational agencies (LEAs), such as districts, county offices and charters, as subgrants. The LEA plans and spends it, not individual schools.
What activities are required under ESSA Section 3115?
As summarized by the CDE, every LEA that receives an English learner subgrant must use the funds to:
- Increase the English proficiency of English learners through effective language instruction educational programs.
- Provide effective professional development to teachers, principals and other school staff.
- Provide activities and strategies that enhance or supplement language instruction programs, including parent, family and community engagement.
What activities are authorized?
Section 3115(d) then lists activities LEAs may fund. The CDE's summary includes:
- Improving instruction by identifying, acquiring and upgrading curricula, instructional materials, educational software and assessment procedures.
- Tutorials and intensified instruction for English learners.
- Community participation programs, family literacy services, and parent and family outreach and training.
Direct administrative costs are capped: the CDE's Consolidated Application guide quotes Section 3115(b) that LEAs "may use no more than 2 percent of the EL program subgrant for direct administrative costs."
What does supplement not supplant mean for Title III?
The CDE quotes ESSA Section 3115(g): federal funds under Title III "shall be used so as to supplement the level of federal, state, and local public funds" that would otherwise be spent on English learner and immigrant programs, "and in no case to supplant such federal, state, and local public funds."
The CDE's Plan Development FAQs add: "An LEA must use Title III funds to supplement state language instruction educational programs," and "When Title III funds are used in place of state investments, it is supplanting." Among the examples of supplanting, the FAQ lists "Using Title III funds to purchase materials used as primary instructional materials."
In practice, California requires every English learner program to include designated and integrated ELD (see our guide Designated vs. Integrated ELD in California). That core ELD program, and the core materials for it, are the LEA's obligation. In its Authorized Use Scenarios, the CDE marks replacing worn-out teacher manuals and textbooks for the current core ELD curriculum as not authorized, explaining: "The LEA is obligated to provide the core educational program and materials for all students and teachers."
The CDE's practical test: do all students already receive it through another funding source? If so, Title III cannot pay.
Can Title III pay for supplemental ELD materials?
Often, yes. The CDE's examples draw the line between core and supplemental:
- Authorized: developing supplemental ELD curriculum that is not required for core instruction.
- Authorized: Title I paying for core English book sets while Title III pays for supplemental Spanish sets in each classroom.
- Not authorized: textbooks that serve as an English learner's core math or language arts text.
The pattern: extras for English learners can qualify; what every student must already receive cannot.
Can Title III pay for professional learning?
Professional development is required, but must still be supplemental. The CDE's scenarios authorize paying substitutes so teachers can attend Title III professional development that goes beyond ELD Standards training and any state- or locally required training. A one-time session on general technology for all classrooms is marked not authorized.
What about Title III parent engagement funds?
Parent, family and community engagement is one of the three required activities, and family literacy and parent outreach are authorized. The FAQ says parent programs must be Title III-specific: translating materials already given to English-only parents is not an acceptable use.
One common misunderstanding is the English Learner Advisory Committee. In the CDE's scenarios, sending parents of English learners to a bilingual education conference is authorized, but paying for ELAC flyers, speaker fees and meeting costs is not, because ELAC is state-mandated: "Federal funds can't be used for activities required by the State." If you are planning ELAC meetings with something like our ELAC Meeting Kit (English & Spanish), ask your district which funds apply rather than assuming Title III.
Translation follows the same logic. Title III can translate Title III program communications sent only to parents of Title III-served English learners, but not a general district newsletter. Ask the same way about family letters on ELPAC results, such as our ELPAC Results & Reclassification Family Kit (background: AB 2555 and ELPAC Reclassification).
How does a Title III purchase typically work?
Details vary, but the path usually looks like this:
- The LEA plan. Title III activities are described in the LEA's LCAP Federal Addendum. The CDE's LCAP Addendum guidance asks LEAs to describe their Title III professional development and programs and activities, and to show they are "supplemental to all other funding sources for which the LEA is eligible."
- A request. A teacher or principal asks the EL program office whether a need fits the plan.
- A quote and approval. The program office confirms the funding source; the business office checks budget and vendor paperwork, such as a W-9.
- A purchase order. The district issues a PO and pays the invoice, keeping records that show the cost was supplemental.
Why does the district decide?
The LEA is the subgrantee. It knows what its core program and other funds already cover and what is in its plan, so the same product can be supplemental in one district and supplanting in another. No vendor, including us, can tell you a product is "Title III approved."
Questions to ask your Title III coordinator
- Is this in our LCAP Federal Addendum or Title III plan?
- Is it supplemental, or part of our core ELD program and materials?
- Do all students already get this, or is it paid for by another fund?
- Will it serve only English learners, in addition to what they already receive?
- Which funding period and deadline apply?
- What paperwork do you need: quote, W-9, sole-source letter?
Frequently asked questions
Can Title III funds pay for English learner materials?
They can pay for supplemental materials. The CDE lists acquiring and upgrading curricula, instructional materials, educational software and assessment procedures as an authorized Title III activity, but says Title III cannot buy materials used as primary instructional materials. Your LEA decides whether a specific purchase is allowable.
What does supplement not supplant mean for Title III?
Under ESSA Section 3115(g), as quoted by the CDE, Title III funds must be used to supplement federal, state and local public funds for English learner programs, and in no case to supplant them. In the CDE's words, when Title III funds are used in place of state investments, it is supplanting.
Can Title III pay for core ELD materials?
No, according to the CDE's Title III Authorized Use Scenarios. Replacing worn-out teacher manuals and textbooks for the current core ELD curriculum is listed as not authorized, because the LEA is obligated to provide the core educational program and materials for all students and teachers.
Can Title III funds pay for parent engagement?
Yes, for activities that are specific to the Title III program and go beyond what is required. The CDE lists parent and family outreach and family literacy services as authorized, but says Title III cannot pay ELAC costs, because ELAC is required by the state.
Can Title III pay for translation?
The CDE says Title III can pay to translate Title III program communications sent only to parents of Title III-served English learners, but not general district communications such as an events newsletter.
Who decides whether a Title III purchase is allowable?
The local educational agency (your district or charter) that receives the Title III subgrant. It describes its program in the LCAP Federal Addendum and must show each cost is supplemental.
Sources
- CDE: Title III Authorized Costs
- CDE: Title III Authorized Use Scenarios
- CDE: Title III Plan Development FAQs
- CDE: Title III, LCAP Addendum Criteria and Guidance
- CDE: Consolidated Application Guide, Title III English Learner Program
This article summarizes public CDE guidance as of October 2026. It is not legal or fiscal advice; your LEA decides what is allowable.
Written by Isaac, U.S. Navy veteran and founder of Creator Supply Co.