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Arizona English Learner requirements are more prescriptive than almost any other state’s. Arizona does not just say a district must serve English Learners; it names the instructional models a district may choose from, sets a daily minimum of language instruction in statute, requires a specific endorsement of the teachers who deliver it, and fixes the assessment that decides entry and exit. This guide covers each of those obligations, what they cost in practice, and the two places districts most often fall out of compliance without noticing.
Table of contents
Executive Summary
Arizona’s English Learner system rests on Proposition 203, codified at A.R.S. 15-752 through 15-755, which made structured English immersion the default. Since the 2019 reform, districts choose from four state-approved SEI models and must deliver a minimum of 120 minutes of English language development a day in grades K-5 and 100 minutes in grades 6-12. Teachers of English Learners must hold an SEI endorsement, obtainable through three semester hours of coursework or 45 clock hours of professional development. Identification runs through a Home Language Survey and the AZELLA Placement test; exit runs through the AZELLA Spring Reassessment and is followed by two years of monitoring. The requirements are unusually clear. Where districts fall short is rarely the model or the minutes; it is the endorsement coverage and the year-round screening duty.
Key Takeaways
- Four state-approved SEI models: Pull-Out, Two-Hour, Newcomer, and 50-50 Dual Language Immersion.
- The 50-50 DLI model requires a Bilingual Parental Waiver Request Application.
- Minimum ELD: 120 minutes a day in K-5, 100 minutes a day in 6-12.
- The SEI endorsement takes three semester hours of coursework or 45 clock hours of professional development.
- A provisional endorsement exists at one semester hour or 15 clock hours and lasts three years.
- Identification runs through the Home Language Survey, then the AZELLA Placement screener, year-round.
- Exit requires an overall Proficient on AZELLA, then two years of monitoring.
- Title III cannot fund the mandated block. Supplement not supplant applies.
The Legal Frame
Arizona voters passed Proposition 203 in 2000. It is codified at A.R.S. 15-752 through 15-755 and it establishes structured English immersion as the default programme, describing it as a “temporary transition period not normally intended to exceed one year”.
Two things follow from that sentence, and both matter operationally. The first is that bilingual instruction requires a parental waiver rather than being freely available, which is why the dual language model on the state’s list carries an application requirement the other three do not. The second is that the statutory expectation of a one-year transition sits a long way from the measured reality, a gap examined in the benchmark section below.
The 2019 reform replaced the earlier four-hour block, which had been the subject of sustained criticism, with the model-plus-minutes structure now in force. The three decades of litigation that produced all of this, from Flores v. Arizona in 1992 to the Supreme Court in 2009, are covered in English Learners in Arizona, along with what the system currently produces. Districts gained choice over the model. They did not gain discretion over the minutes.
The Four State-Approved SEI Models
Quick answer: a district must implement one of four models approved by the State Board of Education. Three are available directly; the fourth requires parental waivers.
| Model | Shape | Condition |
|---|---|---|
| Pull-Out | Students leave the mainstream classroom for the ELD block | None |
| Two-Hour | A concentrated daily block, the successor to the old four-hour model | None |
| Newcomer | Designed for recently arrived students with limited English | None |
| 50-50 Dual Language Immersion | Instruction split between English and the partner language | Bilingual Parental Waiver Request Application required |
The waiver condition on the fourth model is the practical consequence of Proposition 203, and it is where the compliance risk sits for districts pursuing dual language. The model is permitted, but the paperwork is a precondition rather than a formality, and a programme running without complete waivers is a programme running outside the approved structure. The wider case for and against the immersion model is covered in structured English immersion.
The Mandated ELD Minutes
Quick answer: whichever model a district chooses, the SEI models include a minimum of 120 minutes per day of English language development in grades K-5 and a minimum of 100 minutes per day in grades 6-12.
This is worth stating plainly because it is unusual. Most states describe English language development as something a district must provide without specifying how much. Arizona quantifies it, and the quantity is high. Two hours a day of protected language instruction in elementary school is more than almost any other state requires.
The scheduling consequence in secondary is the one that surprises people. One hundred minutes a day in a six-period high school day is close to two full periods, which means an English Learner’s schedule is substantially determined before elective choice begins. Districts that treat the block as something to fit around a timetable rather than as a fixed constraint on it end up out of compliance by arithmetic.
The SEI Endorsement: Who Must Hold One
Quick answer: the Structured English Immersion endorsement authorises an educator to teach English Learners in the area of their existing certificate. If a teacher has English Learners in their classroom, the endorsement is the credential that covers it.
| Full endorsement | Provisional endorsement | |
|---|---|---|
| Coursework route | Three semester hours | One semester hour |
| Professional development route | 45 clock hours | 15 clock hours |
| Validity | Renews automatically with the underlying certificate | Three years |
| Also required | Valid Arizona DPS fingerprint clearance card, and an application fee | |
The prerequisite is a valid Arizona certificate: Elementary, Secondary, Special Education, Career and Technical Education, Early Childhood, or an administrative certificate. Note that the provisional route exists in regulation but is not always practical, because providers generally offer the full coursework rather than the one semester hour version.
The scope of the requirement is the part districts underestimate. The endorsement covers teaching English Learners “in the area of the educator’s prerequisite certificate”, which means it is not only the ELD teacher who needs it. A secondary mathematics teacher with one English Learner in one section is teaching an English Learner. The staffing audit that follows from that sentence is larger than most districts expect, and it is quantified in the benchmark below.
Identification: The Survey Before the Test
Every student’s route into EL services runs through two steps in a fixed order.
- The Home Language Survey, completed at enrollment. A non-English response sends the student to the placement assessment.
- The AZELLA Placement test, a Dynamic Screener administered year-round as students enroll, which determines whether the student has an EL need.
The compliance failure here is almost never the survey and almost never the test. It is the calendar. Because the screener runs year-round and most districts resource it for August, a student enrolling in late November can wait longer than they should for a decision that determines their whole schedule. Naming the person responsible for December and March, not just for August, closes the most common gap in the whole system. The mechanics of both administrations are covered in what AZELLA is and who takes it.
Annual Assessment and Reclassification
Every identified English Learner takes the AZELLA Spring Reassessment in a fixed window running roughly from the first of February to the middle of March, every year, until they reach Proficient.
Reaching Proficient overall requires a Total Proficiency Scale Score at or above the grade’s cut and a level of Intermediate or Proficient in all four domains. Arizona lowered every cut score for Spring 2026, which means reclassification counts for this year are not comparable with last year’s. The tables and the reasoning are in AZELLA scores explained.
The Two-Year Monitoring Requirement
A reclassified student is monitored for two years. This is the requirement most often misapplied, because California’s equivalent runs for four and much of the available training material is Californian. A district importing a four-year monitoring template into Arizona is not out of compliance, but it is spending staff time on a second and third year of documentation the state does not ask for, and a district applying an Arizona template in a state that requires four is out of compliance. Both errors come from the same assumption.
Title III and What It Can and Cannot Fund
| Funding source | Eligible uses | How to access |
|---|---|---|
| Title III, Part A | Supplemental EL technology, tutoring, professional development | Formula grant through the Arizona Department of Education |
| Title I, Part A | Academic support technology in high-poverty schools | Formula grant through the state |
| Structured English Immersion funding | Direct costs of the mandated ELD time | State allocation, tied to EL counts |
| Purchasing cooperatives | Pre-approved purchasing of qualifying tools | Cooperative contract, often without a separate RFP |
Supplement not supplant is the governing rule, and Arizona is the clearest case of it in the country. Because the state mandates the ELD block by statute, Title III cannot pay for the block. It can pay for what runs alongside it. The full set of boundaries is in the complete guide to Title III funding.
One line item does sit comfortably in Title III: the professional development route to the SEI endorsement. Forty-five clock hours per teacher is supplemental professional development, not the delivery of the mandated block.
A Compliance Calendar
| When | Obligation |
|---|---|
| Year-round | Home Language Survey at enrollment, then AZELLA Placement screening |
| Start of year | Confirm every teacher with an English Learner holds an SEI endorsement |
| Daily | 120 minutes ELD in K-5, 100 minutes in 6-12 |
| Autumn | Bilingual Parental Waiver Request Applications for any 50-50 DLI programme |
| November to January | Confirm testing accommodations, devices and headsets |
| 1 February to mid-March | AZELLA Spring Reassessment |
| Spring | Reclassification decisions; begin two-year monitoring for exiting students |
District Benchmark: What the Endorsement Actually Costs
Take a district with 1,200 English Learners across roughly twenty schools. In elementary the students are concentrated, but in middle and high school they are distributed across timetables, so suppose English Learners appear in the classrooms of 250 teachers across the district.
| Figure | |
|---|---|
| Teachers requiring an SEI endorsement | 250 |
| Clock hours each, professional development route | 45 |
| Total professional development hours | 11,250 |
| Equivalent full working weeks of staff time | About 280 |
The numbers per teacher are modest. The number for the district is not, and it recurs as staff turn over. This is the requirement that quietly consumes the largest share of an Arizona district’s EL compliance budget, and it is the one least likely to appear in a board presentation, because it looks like professional development rather than like a mandate.
Now hold it against the outcome. Arizona’s own Spring 2026 documentation put the EL proficiency rate at 13 percent under the previous cut scores, with a projected 23 percent under the new ones. Against a statute that anticipated a transition “not normally intended to exceed one year”, a 13 percent annual exit rate implies an average closer to seven or eight years, and 23 percent implies something over four. Treat those as illustrations rather than forecasts, since the chance of exiting is not constant across a student’s programme. The size of the gap survives the caveat.
The Speaking Time Gap Inside a Mandated Block
Arizona did the thing every other state is told to do. It legislated the time, funded it, and required the credential to deliver it. And the speaking domain still decides who exits, because AZELLA requires Intermediate or better in every domain before a student can be reclassified.
The Speaking Time Gap is the shortfall between the responsive spoken practice an English Learner needs and what one teacher can supply across a full class. It is a structural constraint rather than a teaching failure.
The arithmetic, run against Arizona’s own mandate. Take the 120-minute K-5 block with 25 English Learners. Give an ambitious third of it, 40 minutes, to spoken interaction with the teacher. Divided across 25 students that is 96 seconds each per day, under five hours of individually attended speech across a 180-day year, inside the most protected language block in the country. Doubling the block to 240 minutes produces just over three minutes each.
The arithmetic barely moves because the divisor is the number of students, not the length of the period. Reading and writing scale with the length of a block, since a whole class can read at once. Speaking does not.
Common Mistakes District Leaders Make
- Endorsing only the ELD teachers. The requirement follows the student, not the job title.
- Running a 50-50 DLI programme with incomplete parental waivers. The waiver is a precondition.
- Staffing the Placement screener for August only. It is a year-round obligation.
- Fitting the ELD block around the timetable. In secondary, 100 minutes constrains the timetable, not the reverse.
- Applying a four-year monitoring window. Arizona requires two.
- Charging the mandated block to Title III. Supplement not supplant forbids it.
- Comparing 2026 reclassification rates to 2025. The cut scores changed.
Recommended Actions
Immediate (this month): Run a report crossing every teacher’s roster against EL flags, and compare the resulting list to your SEI endorsement register. The difference is your exposure, and most districts have never produced this single report.
Medium-term (this year): Name the person responsible for Placement screening in every month of the year, and put the ELD minutes into the master schedule as a fixed constraint before elective allocation.
Long-term (strategy): Audit how many of the mandated minutes reach individual spoken production, and resource that domain in a way that does not divide by class size.
Questions District Leaders Should Ask
- How many of our teachers currently have an English Learner on a roster without holding an SEI endorsement?
- Which of the four models are we running, and is it documented as such with the state?
- If we run 50-50 DLI, are all parental waivers on file and current?
- Who administers the Placement screener for a student enrolling in December?
- How many minutes of individual spoken production does each English Learner actually receive per day?
Frequently Asked Questions
What are Arizona’s four approved SEI models?
Pull-Out, Two-Hour, Newcomer, and 50-50 Dual Language Immersion. The first three are available directly. The 50-50 DLI model requires a Bilingual Parental Waiver Request Application, a consequence of Proposition 203.
How many minutes of ELD does Arizona require?
A minimum of 120 minutes per day in grades K-5 and 100 minutes per day in grades 6-12, under whichever of the four models a district implements. This replaced the earlier four-hour block in the 2019 reform.
What is the SEI endorsement in Arizona?
A credential authorising an educator to teach English Learners in the area of their existing certificate. The full endorsement requires three semester hours of qualifying coursework or 45 clock hours of professional development, plus a valid DPS fingerprint clearance card and an application fee, and it renews with the underlying certificate.
Which teachers need an SEI endorsement?
Any teacher instructing an English Learner within the area of their certificate, not only designated ELD staff. In secondary schools, where English Learners are distributed across subject timetables, this typically covers far more teachers than districts initially assume.
Is there a provisional SEI endorsement?
Yes, at one semester hour or 15 clock hours, valid for three years. In practice providers generally offer the full coursework rather than the shorter route, so the provisional option is less available than the regulation implies.
How long does Arizona monitor reclassified students?
Two years after a student reaches Proficient on AZELLA. This is shorter than California’s four-year period, and applying the Californian window is a common source of wasted documentation effort.
Can Title III pay for the ELD block?
No. Supplement not supplant means Title III cannot fund what the state already obliges a district to provide, and in Arizona the ELD block is a statutory obligation. Title III can fund what extends the programme, including the professional development route to the SEI endorsement.
Related Resources
- English Learners in Arizona: Who They Are, What the Law Requires, and What the Data Shows
- AZELLA: What Arizona’s English Learner Assessment Is and Who Takes It
- AZELLA Scores Explained: Levels, Cut Scores and the 2026 Changes
- AZELLA Practice Test: What Arizona Publishes and Where to Find It
- Structured English Immersion: The Model and the 2019 Arizona Reform
- The Complete Guide to Title III Funding
- Texas English Learner Requirements
- What Is an English Learner?
- English Language Proficiency Assessments by State
Conclusion
Arizona’s English Learner requirements are unusually legible. Four models, two minute-counts, one endorsement, one assessment, two years of monitoring. A district can put all of it on a single page, which is more than most states allow. What that legibility exposes is that compliance and outcome are different things. Arizona is compliant with itself by design, and its own proficiency data still shows students taking several years to exit a transition the statute imagined lasting one.
Sources: ADE OELAS, EL Instructional Services and SEI Models; ADE, Structured English Immersion Endorsement PreK-12; ADE OELAS, EL Handbook; ADE, AZELLA Reassessment Adjustments Spring 2026; Arizona State Law Journal, Educating English Learners in Arizona.
Everything Required, Except the One Thing
Read the requirements together and something stands out. Arizona specifies the model, the minutes, the credential, the assessment and the monitoring period. It is thorough in a way that deserves more credit than it gets, and teachers working inside it are not the problem.
What no requirement can specify is how many children speak at once. A district can be perfectly compliant on every line above and still watch the speaking domain hold its cohort at Intermediate, because the one input the statute cannot legislate is individual attention, and that divides by class size no matter how long the block runs.
So some districts are adding spoken practice that does not queue for a teacher’s attention, running alongside the mandated block rather than competing with it for minutes. Telo AI is one example of that approach, offering adaptive conversation in English plus Spanish and French for dual language programmes.
See how districts add individual speaking practice inside a mandated ELD block: https://mytelo.ai/how-telo-works/
Compliance is the floor Arizona built carefully. What sits above it is still a question about arithmetic.
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