Title III FY 2026-27 RFAs Are Open. Here's What Allowable Use Looks Like For Charter LEAs

California's Title III Request for Applications for the 2026-27 fiscal year is live, and the application window closes before most independent-study charters will finish their Local Control and Accountability Plan revisions. The federal Title III-A appropriation nationally sits at $890 million, flat year over year, at a per-EL rate of $125.64 for FY 2025-26, while English learner enrollment continues to climb across California charter authorizers. That is not a policy problem. It is a math problem. The dollars are supplemental by statute, and they are becoming scarcer per EL student every cycle. A special programs coordinator who treats the RFA as a compliance form instead of a design document is leaving intervention capacity on the table.

What Is Actually Happening With Title III This Cycle

The California Department of Education released the Title III Language Instruction and Title III Immigrant subgrant RFAs on schedule for the 2026-27 fiscal year. Both are formula-driven allocations funneled through the LEA (either a district or a directly funded charter). The Language Instruction subgrant supports supplemental services for English learners. The Immigrant subgrant supports LEAs with meaningful increases in immigrant student enrollment over the past three years.

Two conditions have not changed. First, federal law requires Title III funds to be used to supplement, not supplant the base program a state or LEA is already obligated to provide under Title VI of the Civil Rights Act and California's designated and integrated ELD requirements. Second, the LEA must document that the services it purchases meet at least one of the four ESSA evidence tiers.

What has changed is the arithmetic. The FY 2025-26 per-EL rate published in the CDE Title III apportionment overview is $125.64, applied to California's just over 1 million ELs against a flat national pool. Coordinators who applied in 2023-24 and 2024-25 already watched their per-pupil rate shrink. The 2026-27 cycle continues the trend. Current CDE Title III program guidance now sits at the Title III English Learner program page (the older /sp/el/t3/ path has been retired).

Why This Matters To A Charter Special Programs Coordinator

If you run federal programs for an independent-study charter, the flat allocation forces a design decision, not a funding decision. Base ELD instruction is already the LEA's obligation. Title III money is only defensible when it funds something on top of that baseline: additional weekly instructional minutes on top of the ELD block, targeted intervention identified through ELPAC/MAP screening, and per-session progress monitoring against both.

When was the last time you audited which of your EL intervention line items would survive a supplement-not-supplant review?

For directly funded charters, the RFA is also one of the few federal formulas the LEA controls end to end. There is no district office intermediating the allocation, no shared-services table skimming administrative costs. The trade-off is that the compliance liability sits on the charter itself. Without a session-by-session log tied to a specific evidence tier, a Title III narrative will not survive CDE review. The difference between a clean audit and a repayment demand from CDE is documentation the coordinator can produce on demand.

Eighteen of the California charter LEAs A+ Tutoring has spoken with in the last twelve months have never submitted a Title III application, despite being eligible. In our experience, the most common reason is not ineligibility. The coordinator inherited a template that no one had rebuilt against current allowable-use guidance in three years.

What The Guidance And Research Actually Say

Federal law and CDE guidance converge on a narrow set of allowable uses. According to the U.S. Department of Education's Title III English Learner Toolkit, allowable expenditures include supplemental language instruction educational programs, tutoring and academic support services for ELs, professional development for teachers of ELs, and parent and family engagement activities specific to the EL population. Not allowable: covering the salary of a teacher whose role is required under the base program, or replacing curricular materials the LEA was already obligated to purchase.

The evidence tier requirement is where most applications fall apart. ESSA defines four tiers of evidence (strong, moderate, promising, and demonstrates a rationale), and any activity funded under a competitive federal grant is expected to cite one. High-impact tutoring, defined by the National Student Support Accelerator at Stanford University as at least three sessions per week, delivered by a consistent tutor, with a tutor-to-student ratio of no more than 1:3 (with 1:1 and 1:2 showing the strongest effects), sits comfortably in the strong or moderate tier depending on the study cited. Susanna Loeb and colleagues at Stanford have consistently found effect sizes in the 0.20 to 0.40 standard deviation range for programs meeting the high-dosage threshold.

Flat funding against a growing EL population changes the math of the design, not the standard. In our experience working with charter intervention programs, coordinators who write the evidence tier and dosage directly into the RFA narrative face fewer follow-up questions from CDE reviewers.

What Works, Structurally

The interventions that survive a supplement-not-supplant audit share four features: they are additional to the base program (documented on a separate schedule and roster), they are targeted (identified through ELPAC and MAP screening, not offered universally), they are evidence-tiered (with a specific citation in the RFA narrative), and they are logged at the session level (attendance, tutor, focus skill, minutes).

What passes audit: supplemental small-group tutoring for identified Long-Term English Learners, delivered outside the required ELD block, with per-session attendance and progress data.

What does not: contracting a vendor to deliver the ELD block itself, funding a general-education intervention that happens to include some EL students, or subsidizing curriculum the LEA was already required to purchase.

What A+ Sees In The Field

Five of A+ Tutoring's California charter partners (Ocean Grove Charter School, South Sutter Charter School, Visions In Education, Heartland Charter School, and Pacific Coast Academy) have confirmed Title III receipts for the current or prior fiscal year and route a portion of that allocation into supplemental EL and Tier 3 intervention. In the A+ iLEAD Exploration Charter High School Math Tier 3 cohort, 75% of students (9 of 12) reached MAP Growth benchmarks at 3-6x national norms. In the ELA Tier 3 cohort at iLEAD, 87.5% (7 of 8) did the same. The combined Tier 3 cohort reached 80% (16 of 20).

The pattern coordinators report to us is not that Title III money is hard to spend. The problem is that the intervention design most vendors pitch does not survive supplement-not-supplant scrutiny because dosage, tutor consistency, and session-level logging were not built in from day one.

If your Title III narrative was audited tomorrow, could you produce the session-level roster for every funded student, this week?

What A Special Programs Coordinator Can Do Next

Regardless of whether a Title III application ever ends up in front of A+, five steps make the RFA cycle easier.

1. Pull your current Title III per-pupil rate. Compare it to your rate in 2023-24 and 2024-25. If the trend is down, your intervention design has to become more efficient, not more expensive.
2. Audit your LTEL caseload. Identify the students who have been ELs for six or more years. This is the population the strongest evidence base supports funding under Title III.
3. Rebuild the RFA narrative against current CDE allowable-use guidance. Not the template. The current guidance. Line-item what the intervention adds on top of the base program.
4. Cite a specific evidence tier and study in the narrative. "Meets ESSA Tier 2 (moderate evidence), per [citation]" is the phrase reviewers look for.
5. If you sit on the federal programs side of the budget, pull the Title III Consolidated Application and Reporting for your LEA this month. It is the single most useful document for identifying whether your prior-year spend would survive a supplement-not-supplant review.

About A+ Tutoring

A+ Tutoring is a California K-12 virtual intervention provider working with independent-study charter LEAs on supplemental EL and Tier 3 intervention.

A+ Tutoring holds the NSSA Tutoring Program Design Badge (2024-2026), awarded by the National Student Support Accelerator at Stanford University after an evidence-based review. The Badge signifies the quality of our program design and our alignment to Tutoring Quality Standards, as assessed by researchers and practitioners. It is a review of how the program is designed. It is not a validation by Stanford or NSSA of specific outcomes at partner schools.

Separately, in A+ partner-school implementations, 75% of Math Tier 3 students (9 of 12) and 87.5% of ELA Tier 3 students (7 of 8) reached MAP Growth benchmarks, with the combined Tier 3 cohort at 80% (16 of 20), at 3-6x national MAP Growth norms.

Map Your Title III Allocation With Danielle