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Title I Frequently Asked Questions (FAQ)

Schoolwide Programs
What is a Schoolwide program?
A Title I Schoolwide program is a method of delivering Title I services in eligible schools. It allows the school to address the educational needs of children living in impoverished communities with comprehensive strategies for improving the entire school so every student achieves high levels of academic proficiency.

Schoolwide programs have great latitude to determine how to organize their operations and allocate the multiple funding sources available to them. They do not have to identify particular children as eligible for services or separately track federal dollars. Instead, Schoolwide programs can use all allocated funds to increase the amount and quality of learning time. In this way, they can embrace a high-quality curriculum, according to a comprehensive plan that ensures all children meet the state's challenging academic standards.

Schoolwide programs serve all children in a school. All staff, resources, and classes are part of the overall Schoolwide program. The purpose is to generate high levels of academic achievement in core subject areas for all students, especially those students most in need. This purpose is achieved through:
High quality instruction
Comprehensive reform strategies and methods that are based on the use of scientifically based research
Strategies and methods to improve teacher quality and professional development
Consolidated use of funds
What are the advantages of becoming a Schoolwide program?
When an entire school is the target of change, schools serving the most disadvantaged youth can achieve success.
A Schoolwide program is built upon whole school reform strategies rather than separate, fragmented or add-on services.
The whole school takes responsibility for the success of each student.
Integration and coordination of efforts toward unified goals provide for greater success.
What are the eligibility requirements for Title I Schoolwide programs?
The school's poverty level must be at least 40%.
The school and district together decide the school should become a Schoolwide.  
High-quality assistance and support is available to the school.
The district approves, (with external technical assistance provider recommendations) the school's Schoolwide plan. This plan is developed over a one-year period by a diverse group of stakeholders, including teachers, principals, pupil services personnel, external assistance providers, and parents and community members.
What must be done to develop an acceptable plan?
  1. Conduct a comprehensive needs assessment that identifies specific areas of academic need for all of the various populations of students at the school (including migrant students). As a result of this needs assessment, the resulting plan should reflect:
    Challenging goals
    Identified areas of instructional strengths and weaknesses
    Use of data driven decision-making
    A strong understanding of instructional approaches
  2. Employ reform strategies designed to improve instruction throughout the school so all children can meet the State's proficient and advanced academic levels. Some of the strategies that should be included are:
    Strengthen the core academic program through use of effective methods and strategies that reflect scientifically based research.
    Increase the amount and quality of learning time (such as extended school year, before and after school and summer school programs and opportunities) and help provide an enriched and accelerated curriculum.  
    Include strategies to meet the needs of historically underserved populations, and those students who are most at risk of not meeting the State standards.
  3. Ensure that instruction is provided by highly qualified teachers.
  4. Provide high-quality and ongoing professional development for teachers, principals, paraprofessionals and others as appropriate.
  5. Implement strategies to attract high-quality and qualified teachers to high-needs schools.
  6. Increase parental involvement in student achievement, in accordance with the requirements in section 1118.
  7. Assist children in the transition to the next level, such as from early childhood programs (i.e. Even Start, Head Start) to local elementary school programs.
  8. Include teachers in the decisions regarding the use of academic assessments in order to improve the achievement of individual students and the overall instructional program.
  9. Provide timely and effective assistance for students having difficulty meeting the proficient and advanced levels of academic performance.
  10. Coordinate Title I with other Federal, State and local resources, services and programs.
Where might one look for additional information on Schoolwide programming?
Title I Guidance for Schoolwide Programs
PI 9551: Title I Schoolwide Assurances and Narrative
Title I Schoolwide Federal Guidance
Targeted Assistance Programs
What is a Targeted Assistance program?
A Targeted Assistance program is one in which individual students are targeted to receive Title I services. Students are identified based on multiple, objective, educationally related criteria. Services may be delivered in a number of ways: in-class instruction; pull-out instruction; and/or extended day, week, or year instruction. Title I teacher(s) are responsible for providing extra services to identified children; coordinating with other school personnel involved with the children; and involving parents in the planning, implementation, and evaluation of the Title I program. For more information, visit: Targeted Assistance Guidelines
Charter Schools

Utilizing Title I Paraprofessionals in a Targeted Assistance Program

What are Title I-funded charter schools?
A charter school is a tuition-free public school created on the basis of a contract or "charter" between the school and a local school board or other authorizer. A charter school has more freedom than a traditional public school in return for a commitment to meet higher standards of accountability. The two types of Title I-funded charter schools are:
Instrumentality charters are operated within public schools, and the district employs all charter school personnel.
2R charters receive their charter from nonpublic school district partnerships; in Wisconsin, such charters are currently operated by the Milwaukee Area Technical College, Milwaukee Common Council, University of Wisconsin (UW)-Milwaukee, and UW-Parkside.  
Parent Involvement
How are parents involved in the ESEA consolidated application?
The reauthorized Elementary and Secondary Education Act (ESEA), also known as the No Child Left Behind Act of 2001, requires schools to involve parents in school programs and in the education of their children. The following major ESEA parent-involvement requirements for schools and districts are addressed in DPI bulletin nos. 03.03 and 03.04
Title I - Improving the Academic Achievement of the Disadvantaged
Parent Involvement Policy for Schools and Districts
District Parent Involvement Policy  
School Obligations
School-Parent Compact  
School and District Responsibilities for Building Capacity for Parent Involvement
Parental Information and Resource Centers (PIRCs)
Private Schools
How do private school students and schools participate in the ESEA consolidated plan?
The Elementary and Secondary Education Act (ESEA), provides educational services and benefits to private school students and educational personnel, including those in religiously affiliated schools. These services are targeted for students and educators and not for the private schools. The reauthorized ESEA requires the equitable participation of private school students and educational personnel in some of its major programs. Following are explanations of some of the law's provisions, brief summaries of each program, and questions and answers regarding the participation of private school students and educational personnel in the programs. Information is also provided on the transfer of funds from one program to another. Much of the information in this document has been drawn from federal guidance documents posted on the United States Department of Education website (; also see DPI Bulletin No. 03.01
Response to Intervention (RtI)
Please note: With Title I programs and funding, there are basic tenets upon which the allowability of activities and purchases are determined. However, these basic tenets rely upon the specific Title I program model in a specific school, in the program models of other Title I schools in the district and the funding of activities in schools (Title and non-Title) across the district as a whole. In sum, it is hard to determine if something is an allowable Title I program or expense without knowing the larger context in which the program is taking place. Having said this, the following FAQ attempts to address some of the more general questions regarding the coordination and integration of a school’s RtI and Title I programs.

Targeted Assistance Title I Programs:
In a targeted assistance school, can the Title I teacher participate in RtI?
Yes. Title I services are one piece of the continuum of services available to students. Title I teachers should still be providing supplemental educational support to a select group of students determined as Title I-eligible by a review of multiple measures of academic progress. The school should have explicit criteria for when students enter the Title I program and explicit criteria for when students exit the Title I program. Title I teachers collaborate with regular classroom teachers in identifying Title I students. Title I teachers may consult with regular classroom teachers to design classroom interventions that the teacher would implement before a student is identified as Title I eligible. However, the Title I teacher should not be delivering those interventions as they are designed for non-Title I students. Title I teachers should never be used to deliver the core instruction provided to all students even if that instruction is differentiated. Title I teachers deliver education services over and above the core instruction. Title I services should never reduce a student's access to the core instruction.
What role can Title I instructional paraprofessionals play in the implementation of RtI in a targeted assistance school?
Paraprofessionals work under the direct supervision of a highly qualified teacher whose responsibilities include, but are not limited to, supporting the lesson plan of a properly licensed teacher, providing technical assistance to the teacher, and helping with classroom management. Paraprofessionals hired with Title I funds are specifically assigned to support students receiving Title I services under the direct supervision of a highly qualified teacher. This could include supporting a Title I student's participation in the school's RtI system. Title I paraprofessionals should not provide interventions to general education students. For more information on Title I paraprofessionals, see Bulletin 03.02 ESEA Update: Paraprofessionals-Frequently Asked Questions.
Can Title I funds be used to purchase instructional materials to support the RtI system in a targeted assistance school?
If the district is purchasing particular materials for all schools in the district, those materials must be purchased with state or local funds in both Title I and non-Title I schools. In a targeted assistance school, Title I funds may only be used to purchase instructional materials for Title I students in the Title I program. Title I funds may never be used to purchase instructional materials in non-Title I schools.
How do multi-level systems of support work within the Title I targeted assistance programming? What parameters do we need to be aware of as we implement RtI?
When implementing RtI in a targeted assistance school, staff must ensure that the students served by Title I teachers and the services those teachers provide are consistent with Title I law. In a targeted assistance school, Title I teachers work only with Title I-eligible students and the services they provide are above and beyond what non-title students are receiving and supplemental to the core instructional program. This must be foremost in consideration when determining which level Title I services would best be placed.
In a targeted assistance program, what role can Title I teachers play in the new Specific Learning Disabilities (SLD) rule?
In a targeted assistance program, Title I teachers should continue to serve Title I identified students and provide the necessary supplemental interventions to these students. These documented interventions with the Title I teacher may meet the standards of an intensive intervention required as part of a SLD eligibility decision. For more information on the SLD criteria and its definition of "intensive interventions," see Programs for Students with Specific Learning Disabilities.
Schoolwide Title I Programs:

How may Title I funds be used to support RtI in a schoolwide school?
Schoolwide programs, allowable in buildings with at least 40% poverty upon submitting their schoolwide application, are designed to serve the educational needs of all students within the school. In order for any activity to be allowable in a schoolwide, the activity must be reflected both in the school's comprehensive needs assessment and schoolwide plan. As is the case with all actions and strategies on schoolwide plans, if it is being funded with Title I funds, its effectiveness on increasing student achievement will need to be evaluated annually. For more about schoolwide programming, see Title I Schoolwide Programs.

Title I funds combined with other resources may be used to fund any aspect of RtI in a schoolwide school. In a schoolwide program, the district must take appropriate measures to ensure that they are not supplanting state and local funds with federal Title I funding.

In addition, districts may set aside a portion of their IDEA Part B funds to be used within Title I schoolwide schools to support any part of their schoowide plan. For more information on this option, see IDEA - Title I Schoolwide Set-Aside.

The U.S. Department of Education has an informative power point on this topic titled, Implementing RTI Using Title I, Title III, and CEIS Funds.
Highly Qualified Teachers and Paraprofessionals
Must teachers be highly qualified to teach in a Title I targeted assistance school?
Yes. Title I teachers must be highly qualified at the time of hire.
Must teachers be highly qualified to teach in a Title I Schoolwide school?
Yes. All teachers in a Title I Schoolwide school must be highly qualified. Teachers funded by Title I funds must be highly qualified at the time of hire.
If an individual holds an emergency license or emergency permit, are they highly qualified?
Not necessarily. An emergency license/permit may allow the teacher to hold the position, but whether the teacher is highly qualified depends on the individual's education, preparation, and assignment. For the individual to be funded from Title I or IIA dollars, the teacher must be highly qualified. A teacher who holds an emergency license or permit in core subject(s) is considered highly qualified only if all three of the following criteria are met:
  1. The educator has demonstrated content knowledge in the core subject(s) in which they will be teaching through either a major, minor, or successful completion of Wisconsin's Praxis II test(s). Please note that since a major or minor does not exist in reading and Wisconsin does not currently have an approved content test for reading, the only individuals who meet this requirement for reading are elementary-licensed teachers. Also note that an elementary or middle school teacher who is licensed to teach all core academic areas for regular education would meet this requirement for a special education assignment since the Praxis II exam is dependent upon developmental level and not whether it is regular or special education.
  2. The educator is enrolled in an approved educator preparation program that will be completed in no more than three years.
  3. The district provides high quality professional development before and while teaching and intensive supervision or mentoring while teaching.

What are the licensure requirements for teachers who provide Title I intervention?

Licensure Requirements for Providing Students with Interventions and Additional Challenges

What happens if an elementary teacher serving as a Title I reading teacher does not complete the reading licensure program after three years?
The individual can no longer be counted as a highly qualified reading teacher and cannot be funded from Title I.
When must an elementary-licensed teacher hold a reading teacher license (316)?
A reading teacher license (316) is required for the following assignments:
  • If the individual teaches more than one class of reading per day;
  • If the reading assignment is part of a Title I targeted assistance program;
  • If the reading assignment is part of a reading recovery program (not part of a self-contained classroom).
When must a secondary-licensed teacher hold a reading teacher license (316)?
A reading teacher license (316) is always required for a secondary teacher to teach reading.
What license must a teacher hold in order to teach a program such as READ 180?
A reading teacher license is required for all teachers teaching READ 180.
How does a Title I math teacher meet the highly qualified status?
A teacher who holds an elementary license in regular education can teach the core academic areas of Language Arts, Math, Science, and Social Studies within the grades of the elementary license and is considered highly qualified. Therefore, if the teacher holds a Middle Childhood-Early Adolescence regular education license, the teacher can teach Title I math or serve as a Title I math coach to grades 1-8, There is no separate elementary math license for these assignments. If the individual is teaching high school math, the individual must hold a math license (400) in order to be considered highly qualified.
Must a substitute teacher be highly qualified to hold a Title I position?
A substitute teacher must be highly qualified for the Title I assignment if they teach or work with students for 20 or more consecutive days. It is strongly recommended that shorter term substitute teachers and paraprofessionals meet the highly qualified requirement. Please note that a substitute teacher who is not highly qualified cannot be funded by Title I. For more information on appropriate licensure for assignments, visit What Can I Teach with my License?
Title I Paraprofessional Requirements:
Must all paraprofessionals who work with students in a Title I program be highly qualified?
All paraprofessionals hired after January 8, 2002, who work in a Title I targeted assistance program must be highly qualified at the time of hire. Paraprofessionals hired on or before January 8, 2002, had until January 8, 2006, to meet the highly qualified requirements. For more information on highly qualified requirements for paraprofessionals, see ESEA Update Bulletin No. 02.03 Requirements for Paraprofessionals.
Which paraprofessionals must be highly qualified in a Title I schoolwide school?
All paraprofessionals in a schoolwide school must be highly qualified. This includes special education paraprofessionals.
How does a paraprofessional demonstrate highly qualified status?
In order to be highly qualified, a paraprofessional must hold a high school diploma and have completed two years of post-secondary education (48 credits) or an associate's degree or have met a rigorous standard of quality and demonstrated knowledge of, and ability to assist in instruction in reading, writing or mathematics, or reading, writing or math readiness. Please see our web site for more information on the paraprofessional assessment: Wisconsin Recommended Assessment Guidelines for Local School District Use for Title I Paraprofessionals.
Must a substitute paraprofessional be highly qualified to hold a Title I position?
A substitute paraprofessional must be highly qualified for the Title I assignment if they work with students for 20 or more consecutive days. It is of strongly recommended that shorter term substitute paraprofessionals meet the highly qualified requirement. Please note that a substitute paraprofessional who is not highly qualified cannot be funded by Title I.
Supplement Not Supplant
How can my district avoid supplanting when allocating Title I funds?
To determine if your district is in danger of supplanting when allocating Title I funds, ask the following questions:
Does the district use Title I funds to provide services that the LEA is required to make available under state, local or another federal law?
Does the district use Title I funds to provide services that it provided in the prior year with nonfederal funds?
Does the district use Title I funds to provide services for children participating in a Title I program or in a Title I school that it provides with nonfederal funds to nonparticipating children or children in non-Title I schools?

If you answer yes to any of these questions your district is at risk of supplanting. Consult with your assigned DPI Title I consultant before proceeding.

May Title I Funds be used to hire Pupil Services personnel such as school counselors and social workers?
Yes, with conditions. Title I schoolwide schools must conduct an annual needs assessment to determine the greatest needs of low achieving students. Based on the needs assessment a schoolwide plan is developed, implemented and evaluated annually. The needs assessment results in the identification of schoolwide reform strategies that 1) provide opportunities for all children to meet the State's proficient and advanced levels of student academic achievement, 2) use effective methods and instructional strategies that are based on scientifically based research and, 3) include strategies to address the needs of all children in the school, but particularly the needs of low-achieving children and those at risk of not meeting the State student academic achievement standards. If pupil services personnel are employed to meet one or more of these objectives, they may be funded by Title I funds so long as those funds do not supplant state or local dollars. In a targeted assistance school, pupil services personnel may be considered only under the following conditions:
The school is implementing programs that provide supplemental services only to eligible children identified as having the greatest need for special assistance;
The school provides opportunities for professional development with Title I funds and, to the extent practicable, from other sources, for teachers, principals, and paraprofessionals, including if appropriate, pupil services personnel, parents, and other staff, who work with participating children in programs;
The school provides strategies to increase parental involvement such as family literacy services;
The pupil services personnel paid with Title I funds work only with students receiving Title I services and;
Title I funds do not supplant state or local dollars.

If you answer yes to any of these questions your district is at risk of supplanting. Consult with your assigned DPI Title I consultant before proceeding.

Disposal of Equipment
If a Title I school closes or no longer qualifies for Title I services, what happens to the materials/equipment purchased with Title I funds?

The LEA should first check with their business manager regarding their district's internal policy regarding disposal of property purchased with federal funds. However, the district's policy should at a minimum follow EDGAR 80.32 (e) and 80.33 (b). Both of these EDGAR laws explain that these disposition rules come into play when the property acquired under a grant is no longer needed for the original project/program or for other activities currently or previously supported by a federal agency.  If the LEA still has questions, please contact Al Virnig at or (608) 266-2428.

Transportation for Homeless Students

New Guidance from U.S. Department of Education: Use of Title I funds to provide Services to Homeless Children and Youth.


USDE has issued new guidance regarding the Consolidated Appropriations Act, 2014 which has expanded the allowable uses of Title I, ESEA funds to include transporting homeless children and youth to their school of origin. Additionally, an LEA may now use funds from its FY 2014 Title I grant to fund all or part of the homeless liaison’s salary even if that person has no Title I duties.


It is important to note that while the new authority under the appropriations act now permits an LEA to use Title I funds to support a homeless liaison and to transport homeless children and youth to their school of origin, it does not otherwise change an LEA’s existing obligation under ESEA section 1113(c)(3)(A) to provide comparable Title I services to homeless children and youth who attend non-Title I schools.


LEAs must continue to meet comparable services needs, but may also use reservation funds to pay for transportation to the school of origin and/or homeless liaison.


Letter to State’s from the U.S. Department of Education

For more information on RtI and Title I, see policy guidance provided by the United States Education Department.

For questions about this information, contact Title I and School Support Team (608) 267-3721