Title III Funding: What EdTech Tools Qualify for ELL Programs

Title III of the Every Student Succeeds Act (ESSA) provides federal funding specifically to help English Learners and immigrant students develop English proficiency and meet content standards. Most administrators know Title III exists. Fewer know exactly what it can pay for — and the ambiguity costs districts real money by either leaving legitimate purchases unfunded or, worse, creating compliance risk from improper purchases.

This is a practical guide for ELL directors, curriculum coordinators, and district administrators on using Title III funds for EdTech. It covers what the statute allows, how to document purchases for compliance, and what questions to ask vendors before committing budget.

What Title III Is Actually For

Title III's statutory purpose (ESSA §3101) is to help English Learners attain English proficiency and develop high levels of academic achievement in English. Programs must be evidence-based (meeting at least Tier IV of the ESSA evidence standards) and supplemental — meaning they supplement, not supplant, state and local program funding.

The "supplement not supplant" requirement is the one administrators most commonly misunderstand. It means Title III funds cannot pay for things your district would otherwise fund with state or local money. If your district pays for all teacher professional development with local funds, you can't shift that cost to Title III. But if you're adding ELL-specific professional development that wouldn't otherwise exist, that's a legitimate Title III expenditure.

What Title III Can Fund (EdTech-Specific)

ESSA §3115(c) lists allowable activities. The relevant ones for EdTech purchases include:

• Developing and implementing new language instructional educational programs for English learners
• Providing high-quality professional development to classroom teachers, principals, and other school leaders to improve instruction for English learners
• Purchasing educational technology that supports English learner instruction
• Developing or using formative assessments aligned to state English language proficiency standards
• Acquiring or developing supplemental curricular materials aligned to English language development standards

The Evidence Requirement

ESSA requires Title III programs and activities to be based on "evidence-based" approaches. The four evidence tiers are:

• Tier I (Strong): At least one well-designed and well-implemented randomized controlled experiment showing positive effects
• Tier II (Moderate): At least one well-designed quasi-experimental study
• Tier III (Promising): At least one well-designed correlational study with statistical controls
• Tier IV (Demonstrates a Rationale): A well-specified logic model supported by related research

Most EdTech tools qualify under Tier IV at minimum — they can point to language acquisition research that supports their instructional approach, even if no RCT has been done specifically on their product. Tier IV is sufficient for most Title III expenditures. When evaluating vendors, ask directly: "What evidence tier do you claim, and what documentation do you provide?"

Vendors who can't answer this question clearly create compliance risk. Document the evidence claim in your purchase records regardless of tier level.

---

What Qualifies and What Doesn't: A Practical Table

Purchase Type	Qualifies?	Notes
ELL-specific instructional software (e.g., Kuliso)	Yes	Purpose-built for EL instruction; cleanest compliance
General adaptive learning platform used by all students	Maybe	Only if ELL-specific usage is documented and supplemental
Professional development specifically on ELL instruction	Yes	ESSA §3115(c)(2) — explicitly allowed
Devices (tablets, Chromebooks) for ELL students	Maybe	Allowed if used for ELL instruction and not replacing local device funding
Google Translate subscription	No	Not an instructional tool; can't be shown to improve EL proficiency
ELL-specific assessment tools aligned to ELPA/ACCESS	Yes	Explicitly supported under §3115(c)(4)
General district curriculum (all students)	No	Supplemental requirement — can't fund district-wide curriculum
Parent and family engagement resources in home language	Yes	ESSA §3115(c)(3) explicitly includes outreach to families of ELs
English language development curriculum (supplemental)	Yes	Core use case for Title III; must be ELL-specific, not general ELA

Documentation Requirements

The most common Title III audit finding isn't inappropriate purchases — it's inadequate documentation of appropriate purchases. For every EdTech purchase, your records should include:

Keep these records for at least five years after the close of the grant period. State audits on Title III can come years after the expenditure.

---

Evaluating EdTech Tools for Title III Compliance

When a vendor approaches you claiming their tool is Title III-eligible, ask these seven questions. Vendors who can't answer clearly are creating compliance risk for your district.

1. What ESSA evidence tier do you claim?

Get it in writing. Ask for the specific studies or logic model documentation. "We have research to support our approach" without specifics doesn't satisfy the evidence requirement.

2. How is your tool specifically designed for English Learners?

Generic tools with ELL features added on are harder to justify. Tools purpose-built for EL instruction — with language proficiency scaffolding, home-language support, or WIDA/ELPA alignment — are cleanest from a compliance standpoint.

3. How do you align to state English language proficiency standards?

Ask specifically about WIDA (if your state uses it) or your state's ELP framework. If the vendor doesn't know what WIDA is, that tells you something about how ELL-specific their product actually is.

4. What data privacy documentation do you provide?

FERPA compliance is required. For K-12 tools involving students under 13, COPPA applies. Ask for the vendor's data processing agreement (DPA) and check whether your state has additional student privacy laws that apply.

5. Can you provide district-level usage reporting for EL students?

You need to demonstrate that EL students specifically are using the tool. Vendors who can't provide student subgroup data by EL status make your documentation harder.

6. Do you have other Title III-funded districts as references?

Not a requirement, but a useful signal. Vendors with experience navigating Title III compliance documentation are less likely to create problems for your audit trail.

7. What is your procurement process for PO or state contract purchasing?

Some districts require vendors to be on state cooperative purchasing contracts (e.g., E-Rate, state DoE preferred vendor lists). Confirm the vendor's procurement pathway before initiating a PO.

Kuliso and Title III

Kuliso is designed specifically for English Learner instruction — native-language instructional scaffolding, WIDA-aligned language proficiency support, and academic content delivery built around ESL pedagogy. It qualifies as supplemental ELL-specific instruction software, with a Tier IV evidence base grounded in translanguaging research (García, 2009; Cummins, 2000) and language acquisition theory.

For districts evaluating Kuliso for Title III purchase, we provide data privacy documentation (FERPA/COPPA compliant, student data stays on-premises), EL subgroup usage reporting, and alignment documentation for WIDA and ELPA21 frameworks. You can request a quote and documentation package through our districts page.