Title I, Part A: Eligibility, Fiscal Rules, and Accountability

Title I, Part A funding is the federal government’s largest K–12 program, sending roughly $18.4 billion in fiscal year 2026 to state education agencies, which pass it to school districts serving concentrations of children from low-income families.¹ The program dates to the 1965 Elementary and Secondary Education Act and was most recently reshaped by the Every Student Succeeds Act in 2015. Every dollar comes with rules attached: how districts pick eligible schools, how those schools structure their programs, how the money can be spent, and how outcomes get measured.

How the Money Flows to Districts

Title I, Part A funding runs through four separate grant formulas: Basic Grants, Concentration Grants, Targeted Grants, and Education Finance Incentive Grants. Three of them start with a district-level calculation using Census poverty data and per-pupil education spending, then aggregate up to the state total. The Education Finance Incentive Grant adds a wrinkle by factoring in how equitably a state distributes its own education dollars and how much fiscal effort it puts in. A state’s total allocation is the sum across all four formulas.

State educational agencies pass the money down to local educational agencies. From there, federal law dictates which schools inside the district actually get served.

Which Schools Qualify Inside a District

A district must rank its school attendance areas from highest to lowest poverty percentage and serve the neediest first. Schools where more than 75 percent of children come from low-income families must be funded before any others, regardless of grade level.² High schools get some relief: a district may lower that mandatory threshold to 50 percent for its high schools. If money remains after clearing those buildings, the district moves down the ranked list to serve schools whose poverty rates exceed the district-wide average.

Districts also have discretion to fund any school with a poverty rate of at least 35 percent, even if that school sits below the district average.² Poverty counts typically pull from free and reduced-price lunch data, Census information, or Medicaid enrollment. The ranking rule keeps districts from spreading funds thinly across every campus or steering them toward favored schools.

Schoolwide vs. Targeted Assistance Programs

Every Title I school operates under one of two program models. The choice shapes how broadly the school can use its funds and what planning it must do first.

Schoolwide Programs

A school qualifies for a schoolwide program when at least 40 percent of its students come from low-income families.³ Under this model, the school can blend Title I money with other federal, state, and local resources to upgrade the entire educational program rather than tracking funds student by student. That flexibility is the whole point. A schoolwide campus can hire reading specialists, invest in new technology, or restructure schedules in ways that reach every child.

The trade-off is planning. Before launching, the school must conduct a comprehensive needs assessment covering the whole campus, focused on students failing or at risk of failing to meet state standards.³ The assessment feeds a written schoolwide plan developed with parents, teachers, administrators, and community members. The plan gets updated as student needs shift, made public, and coordinated with related programs like Head Start and career and technical education where relevant.

Targeted Assistance Programs

Schools below the 40 percent poverty threshold, or eligible schools that prefer a narrower approach, must run a targeted assistance program.⁴ Only students who are failing or most at risk of failing state standards may receive services paid for with Title I funds. Staff paid from those funds work exclusively with identified students through small-group instruction, tutoring, or other interventions.

Identification relies on multiple measures: test scores, teacher recommendations, and other objective criteria. The school must keep records showing that every dollar went to the eligible group. It is a more restrictive model, but it gives lower-poverty schools a structured way to reach their most struggling learners.

Reservation for Homeless Students

Whichever program model a school uses, its district must reserve enough Title I funds to serve children and youth experiencing homelessness. That reservation happens before any other expenditures or transfers from the district’s Title I allocation.⁵ There is no fixed federal percentage. The district sets the amount based on the number and needs of homeless students in the community. These funds can support homeless children who attend non-Title I schools, pay for transportation to a student’s school of origin, and fund the district’s homeless education liaison.

Services for Private School Students

Title I follows low-income children, not public school buildings. When eligible children living in a participating public school attendance area attend private schools, the district must provide them with equitable educational services.⁶ Private schools never receive Title I funds directly. The district designs and delivers the services — tutoring, counseling, mentoring, instructional technology — and pays for them out of its Title I allocation.

The spending amount is proportional. It is calculated from the share of low-income children in participating attendance areas who attend private schools, relative to the total count, and it comes off the top before the district earmarks money for other purposes.⁶ Before designing the program, the district must consult with private school officials on how children’s needs will be identified, what services will be offered, and how those services will be delivered and evaluated. Each state designates an ombudsman to monitor and enforce these equitable-services obligations and to resolve disputes.

What Schools Can Actually Spend the Money On

Title I gives schools real flexibility, as long as spending connects to improving achievement for students in poverty. Common uses include hiring reading specialists, math coaches, or counselors addressing non-academic barriers to learning. Districts also fund before-school and after-school tutoring, summer programs to prevent learning loss, and updated curriculum materials or classroom technology.

One constraint sits above all the others: interventions and instructional strategies purchased with Title I funds should be evidence-based. Under ESSA, that means the strategy is backed by research at one of four tiers, ranging from strong evidence supported by well-designed experimental studies down to approaches with a sound rationale that are being studied for the first time. Schools identified for improvement face stricter expectations about which tier of evidence they must use.

The Three Fiscal Rules Districts Have to Meet

Supplement, Not Supplant

Federal Title I dollars must add to what schools already receive from state and local sources, not replace them.⁷ If a district normally staffs one math teacher per grade, Title I funds can pay for a second teacher to reduce class sizes. They cannot cover the salary of a teacher the district would have hired anyway.

ESSA changed how districts prove compliance. Instead of tracing individual costs, a district shows that its methodology for allocating state and local funds gives each Title I school every dollar it would have received without federal help.⁷ The Secretary of Education cannot prescribe the specific methodology, which leaves local leaders room to build one that fits their budget structure.

Comparability of Services

Before receiving Title I funds, a district must show that the state and local resources it provides to Title I schools are at least comparable to what non-Title I schools get.⁸ If every school in the district receives Title I funding, the standard becomes “substantially comparable” services across all buildings. Districts can demonstrate this on a school-by-school or grade-span basis.

Most districts satisfy the rule by filing a written assurance with the state that they maintain a district-wide salary schedule, equivalent staffing policies, and equivalent distribution of curriculum materials and instructional supplies.⁸ Salary differences based only on years of experience are excluded from the calculation, and districts do not have to account for unpredictable enrollment or staffing shifts mid-year.

Maintenance of Effort

A district’s combined state and local spending on education must reach at least 90 percent of what it spent the prior year, measured either per pupil or in the aggregate.⁹ Falling below that threshold triggers a proportional reduction in the district’s Title I allocation and applies across all ESEA-funded programs. Miss the 90 percent mark by five percentage points and federal funding drops by roughly the same proportion.

The Secretary can waive the requirement for exceptional or uncontrollable circumstances such as a natural disaster or a sudden collapse in a district’s financial resources. Outside those narrow situations, there is no relief. Districts making budget cuts have to track this closely, because layering a federal reduction on top of local cuts compounds the shortfall fast.

Parent and Family Engagement Obligations

Every school receiving Title I funds must develop a written parent and family engagement policy jointly with the families it serves.¹⁰ The policy explains how the school will involve parents in planning and improving the Title I program. Schools must hold at least one annual meeting at a convenient time to walk parents through what Title I requires and what rights they have. The policy is distributed in a format parents can understand and, where practicable, in their home language.

The relationship is formalized in a school-parent compact, a written agreement listing what the school commits to (high-quality instruction, regular progress updates) and what families commit to (supporting learning at home, attending conferences). It structures ongoing communication between teachers and households.

The One Percent Set-Aside

Districts receiving more than $500,000 in Title I funds must reserve at least 1 percent of their allocation for parent and family engagement.¹⁰ These funds can cover transportation to school events, childcare during meetings, home visit programs, or literacy training for parents.

Right to Know Teacher Qualifications

At the start of each school year, districts must notify parents in Title I schools that they can request information about their child’s teacher.¹¹ Parents can ask whether the teacher meets state licensing requirements for the grade and subject, whether the teacher is working under an emergency or provisional credential, whether the teacher is teaching within their certified field, and whether paraprofessionals provide services to their child. Districts are legally required to respond promptly.

Accountability and Identified Schools

States receiving Title I funds must adopt challenging academic standards in reading, math, and science, and administer annual assessments in certain grades to measure student progress.¹² The resulting data drives the accountability system that flags which schools need intervention.

Report Cards

Every state publishes an annual report card covering achievement, graduation rates, teacher qualifications, and the accountability system itself. Data must be disaggregated by race, disability, economic disadvantage, English-learner status, homelessness, and foster care status.¹² District and school report cards must be published and made accessible on a single state agency webpage. The disaggregation is what prevents a school from hiding weak outcomes for one subgroup behind strong results overall.

Comprehensive and Targeted Support

States must identify schools for two intervention categories. Comprehensive Support and Improvement (CSI) is the more serious designation. It captures the lowest-performing 5 percent of all Title I schools in the state, any public high school that fails to graduate at least two-thirds of its students, and certain schools where a subgroup’s performance alone would put it in the bottom 5 percent.¹³ CSI schools must develop and implement an evidence-based improvement plan and meet statewide exit criteria within a state-determined period of no more than four years.

Targeted Support and Improvement (TSI) applies where any student subgroup is consistently underperforming based on the state’s indicator system.¹² Schools receiving a TSI notification must develop a plan addressing the underperforming subgroup. When a subgroup’s performance is so low that it alone would trigger CSI identification, the school faces additional requirements, including identifying and addressing resource inequities in its budget.

1
U.S. Department of Education. Fiscal Year 2026 Budget Summary
2
Office of the Law Revision Counsel. 20 USC 6313 – Eligible School Attendance Areas
3
Office of the Law Revision Counsel. 20 USC 6314 – Schoolwide Programs
4
Office of the Law Revision Counsel. 20 USC 6315 – Targeted Assistance Schools
5
National Center for Homeless Education. Serving Children and Youth Experiencing Homelessness Under Title I Part A
6
Office of the Law Revision Counsel. 20 USC 6320 – Participation of Children Enrolled in Private Schools
7
Office of the Law Revision Counsel. 20 USC 6321 – Fiscal Requirements
8
Office of the Law Revision Counsel. 20 USC 6321 – Fiscal Requirements
9
eCFR. 34 CFR 299.5 – Maintenance of Effort Requirements for ESEA Programs
10
Office of the Law Revision Counsel. 20 USC 6318 – Parent and Family Engagement
11
eCFR. 34 CFR 200.61 – Parents Right to Know
12
Office of the Law Revision Counsel. 20 USC 6311 – State Plans
13
U.S. Department of Education. Module 4 – Comprehensive Support and Improvement CSI Schools