What Can Title I Funds Be Used For? A District Leader’s Guide

Estimated reading time: 15 minutes

Every Title I budget conversation starts with the same question: what can Title I funds be used for? The short answer: Title I, Part A (often written Title 1) can pay for any necessary and reasonable cost that carries out a school’s Title I program, including additional teachers and paraprofessionals, tutoring and extended learning time, instructional materials and software, technology, professional development, and parent and family engagement. What a given school may buy depends on its program model. A schoolwide program can use Title I to upgrade instruction for every student, while a targeted assistance program can serve only the students it has identified as most at risk. This guide covers the allowable uses, the limits, how the money reaches schools, and how Title I works alongside Title III for English Learners.

Executive Summary

Title I, Part A of the Elementary and Secondary Education Act (ESEA) is the largest federal K-12 program: about $18.4 billion for grants to districts in fiscal year 2026, roughly 20 times the $890 million provided for Title III. It reaches schools through four federal formulas, then through each district’s ranking of schools by poverty.

Two questions decide whether a purchase is allowable. Does it pass the federal cost principles (necessary, reasonable and allocable) and serve a need the school has documented? And which program model does the school run? A schoolwide school can spend Title I on every student and consolidate funds; a targeted assistance school can spend it only on identified students. In both, Title I must supplement, not supplant, state and local money. The useful question is therefore not only whether an expense is allowable, but whether it adds capacity the school could not otherwise afford.

Key Takeaways

• Title I can pay for supplemental staff, tutoring, extended learning time, instructional software, technology, professional development and family engagement.
• Every cost must be necessary, reasonable and allocable, and tied to the school’s plan or to identified students.
• Schoolwide programs (40 percent or more low-income, or a state waiver) can serve every student.
• Targeted assistance programs serve only identified students; English Learners qualify on the same basis as others.
• Supplement, not supplant: Title I cannot replace the state and local funds for services the law requires for English Learners.
• AI tools are fundable when they serve the Title I program, according to the Department of Education’s July 2025 guidance.

What Can Title I Funds Be Used For?

Quick answer: Title I funds can be used for any supplemental activity that helps students meet challenging state academic standards, with priority on the students most at risk, as long as the cost is necessary, reasonable and part of the school’s Title I program.

State guidance fills in the detail. The New York State Education Department’s allowable expenditures list, for example, names computer-aided instructional software, Title I data management software and technology to upgrade a schoolwide program. Your own state’s guidance governs the final answer.

The Four-Part Test for Any Title I Expense

1. Purpose. The cost helps students meet challenging state academic standards, with priority on those furthest behind.
2. Cost principles. It is necessary, reasonable and allocable under the federal Uniform Guidance (2 CFR 200.403 to 200.405).
3. Plan alignment. It addresses a need in the schoolwide needs assessment and plan, or serves the identified students in a targeted assistance school.
4. Supplement, not supplant. Under ESEA section 1118(b), a district shows that its method for allocating state and local funds gives each Title I school all the state and local money it would otherwise receive, and no district may be required to identify that an individual cost is supplemental.

Quick answer: since the Every Student Succeeds Act (ESSA), Title I supplement-not-supplant is tested on the district’s allocation method, not purchase by purchase. Title III keeps its own requirement (ESEA section 3115(g)).

Schoolwide vs Targeted Assistance: Why the Answer Depends on the School

The same purchase can be allowable in one Title I school and not in the next, because the two models answer “who can Title I serve?” differently. According to NCES, about 63 percent of traditional public schools were eligible for Title I in 2021-22; 42 percent ran schoolwide programs and 9 percent targeted assistance programs.

Schoolwide Programs

Under ESEA section 1114, a school can run a schoolwide program when at least 40 percent of the children in its attendance area or enrollment come from low-income families, or with a state waiver. The plan rests on a comprehensive needs assessment of the entire school, is normally developed over one year, and can include strategies that increase the amount and quality of learning time, counseling, career preparation, tiered behavior supports and professional development.

A schoolwide school does not have to identify particular children as eligible, and when it consolidates funds it does not have to keep separate fiscal records by federal program, as long as its records show the schoolwide program meets the intent and purposes of each consolidated program. A Dear Colleague letter of January 21, 2026 encouraged states to use these flexibilities: consolidated funds can support any activity in the schoolwide plan, and only Title I’s supplement-not-supplant requirement applies. One limit stays: section 1114(a)(2)(B) requires schoolwide funds to supplement the non-federal funds the school would otherwise receive, including funds needed for services the law requires for children with disabilities and English Learners.

Targeted Assistance Programs

Under ESEA section 1115, a targeted assistance school uses Title I only for students identified as failing, or most at risk of failing, to meet state standards, using multiple, educationally related, objective criteria set by the district. Economically disadvantaged children, children with disabilities, migrant children and English Learners are eligible on the same basis as other children. The program can include expanded learning time, before- and after-school and summer programs, and professional development, and it must minimize the removal of children from the regular classroom. In practice, a license or device bought with Title I there should match the number of identified students, not the whole enrollment.

What Title I Funds Cannot Pay For

• Supplanting. Costs that replace the state and local funds a Title I school would otherwise receive.
• Replacing the funds for required services. The state and local money for the base program the law requires for English Learners and students with disabilities must stay in place.
• Non-identified students in targeted assistance schools.
• Construction, remodeling and renovation, and furniture or office equipment not necessary for the Title I program (NYSED).
• Monetary incentives such as gift cards, and field trips for entertainment only (NYSED).
• Food for staff, including working lunches (NYSED).
• Districtwide administration unrelated to the Title I program, such as superintendent salaries (NYSED).

How Title I Funding Reaches Schools

1. Federal to state. Four formulas (Basic, Concentration, Targeted and Education Finance Incentive Grants), all based primarily on district counts of children from the Census Bureau’s Small Area Income and Poverty Estimates (NCES).
2. Reservations off the top. The district reserves funds for required purposes, including parent and family engagement and equitable services for eligible children in participating private schools.
3. District to school. Under ESEA section 1113, areas above 75 percent poverty are served first, in rank order (50 percent is allowed for high schools), and an area with at least 35 percent low-income children can be designated eligible. Each school receives an amount based on its number of children from low-income families.
4. Carryover. Up to 15 percent of an allocation can roll into the next year; a state may waive the limit once every three years, and it does not apply below $50,000 (ESEA section 1127).

Can Title I Funds Pay for Technology and AI Tools?

Yes, when the technology serves the Title I program: a documented need, a reasonable cost and the right students. On artificial intelligence, the Department of Education’s Dear Colleague letter of July 22, 2025 states that formula and discretionary grant funds can support AI-based high-quality instructional materials, AI-enhanced high-impact tutoring, and AI for college and career pathway exploration, provided the use meets the program’s requirements. It also stresses responsible use, user privacy and engaging parents.

State policy adds a second layer. At least 35 states have published K-12 AI guidance (Education Commission of the States, April 2026), and some require district policies. In Florida, amendments to State Board Rule 6A-1.0957, approved in September 2026, require districts to add AI provisions to their internet safety policies by July 1, 2027, with parental opt-in for AI tools students use directly and a comparable non-AI alternative.

Purchasing is a separate step that follows your district’s procurement policy: see how K-12 districts buy edtech and TIPS cooperative purchasing.

Title I and English Learners

English Learners are Title I students like any others: eligible on the same basis in targeted assistance schools, and served by the whole-school plan in schoolwide schools. What Title I cannot do is replace the state and local funds that pay for the core English Learner program the law requires.

That gives a clear division of labor. State and local funds pay for the required English language development program. Title III pays for supplemental language instruction for English Learners (see what Title III funds can be used for). Title I pays for supplemental academic support for the students the school serves, English Learners included. Both grants can share one rollout if each pays for a distinct, documented share (Title I vs Title III).

Funding Options

For how these sources combine in an English Learner rollout, see the funding guide for district leaders.

District Benchmark: A $1 Million Title I Allocation

Consider a district with a $1,000,000 Title I, Part A allocation. Before money reaches schools:

• Parent and family engagement: at least 1 percent, or $10,000, because the allocation is above $500,000; at least 90 percent of it, $9,000, goes to Title I schools (ESEA section 1116).
• Equitable services: a proportional share for eligible children in participating private schools.
• Carryover ceiling: up to $150,000 can roll into the next year; more requires a state waiver.

After these and the other required set-asides (such as services for homeless children), the rest goes to eligible schools: ranked by their percentage of low-income children, each receives an amount based on its number of low-income children. Nationally, Title I is about 20 times larger than Title III, so compare your own two allocations before planning English Learner supports around Title III alone.

Common Mistakes District Leaders Make

1. Asking “is it allowable?” instead of “is it in the plan?” Schoolwide spending has to trace back to the needs assessment.
2. Buying schoolwide licenses in a targeted assistance school. Title I there covers identified students only.
3. Shifting the core English Learner program onto Title I. The state and local funds for required services must stay in place.
4. Tying permanent positions to a school near the cut-off. Rankings change every year.
5. Letting carryover pass 15 percent. The state waiver is available only once every three years.
6. Splitting Title I and Title III costs without records. Each grant needs its own documented share.

Recommended Actions

Immediate (this month): List each Title I school’s program model and current Title I purchases, with the need each addresses.

Medium-term (this school year): In the spring needs assessment, quantify the gaps that matter most, such as individualized practice time for English Learners, and write the strategies into next year’s plans. Coordinate Title I and Title III budgets with the federal programs director.

Long-term (strategy): Build multi-year plans that survive changes in school rankings, use the schoolwide consolidation flexibilities where they fit, and tie Title I spending to outcome measures.

Questions District Leaders Should Ask

• Which of our Title I schools run schoolwide programs, and which run targeted assistance?
• Does every Title I purchase trace back to a need in the school’s needs assessment?
• How much of last year’s Title I allocation was carried over, and why?
• Which English Learner services are paid with state and local funds, and which with Title I or Title III?
• How many minutes of individualized practice does a struggling student get each week?
• Do our AI tools meet our state’s AI guidance and our student data privacy agreements?

Frequently Asked Questions

What can Title 1 funds be used for?

Supplemental staff, tutoring, extended learning time, instructional materials and software, technology, professional development, and parent and family engagement, as long as each cost is necessary and reasonable for the Title I program and supplements state and local funds. Schoolwide programs can use them for the whole school; targeted assistance programs only for identified students.

How are Title One schools funded?

The Department of Education allocates Title I to states through four formulas based mainly on Census estimates of children from low-income families. Districts then rank their schools by poverty and allocate funds based on each school’s number of low-income children, serving schools above 75 percent poverty first.

Can Title 1 funds be used for food?

Only in narrow cases. New York’s guidance, for example, allows nutritious snacks for Title I students and light refreshments at parent and family engagement activities, but not food for staff. Rules vary by state.

Are Title 1 teachers federally funded?

Some are. Title I can pay teachers, interventionists, paraprofessionals and coordinators who carry out the Title I program, in proportion to their Title I work and documented under the federal rules for personnel costs (2 CFR 200.430).

Will Title 1 schools lose funding?

Not for the current year: Congress provided about $18.4 billion for Title I grants to districts in fiscal year 2026, $20 million more than the year before. Full-year fiscal year 2027 levels were still pending in the fall of 2026, with programs running on a continuing resolution through December 11, 2026, so confirm the final appropriation before building next year’s budget. Individual schools can still lose Title I money when their low-income share falls below their district’s cut-off.

What happens when a school loses Title 1 funding?

A school that is no longer eligible can still be served for one additional fiscal year under ESEA section 1113(b)(1)(C). After that, staff and services paid with Title I must be funded another way or end.

How many Title 1 schools are there in the US?

NCES reports that in 2021-22 about 63 percent of traditional public schools and 62 percent of public charter schools were eligible for Title I; 42 percent of traditional public schools ran schoolwide programs and 9 percent targeted assistance programs.

Can Title I funds be used for AI tools?

Yes, when the tool supports the Title I program and meets its requirements. The Department of Education’s July 2025 guidance says federal formula funds can support AI-based instructional materials and AI-enhanced high-impact tutoring. Check your state’s AI guidance and district policy too.

Related Resources

• Funding Guide for District Leaders
• Title III Funding: A Complete Guide for Districts
• Title I vs Title III: Key Differences
• What Can Title III Funds Be Used For?
• Can Title III Pay for AI Tools?
• Sole Source Justification for EdTech
• English Learners in U.S. Schools: The Complete District Guide

Conclusion

What Title I funds can be used for is broad. The constraints sit elsewhere: the program model decides who the money can reach, the needs assessment decides what it should buy, and supplement-not-supplant decides what it cannot replace. Districts that start from the plan rather than the catalog spend the larger federal grant on capacity their schools could not otherwise afford.

Sources: 20 U.S.C. 6313 (ESEA section 1113); 20 U.S.C. 6314 (section 1114); 20 U.S.C. 6315 (section 1115); 20 U.S.C. 6318 (section 1116); 20 U.S.C. 6321 (section 1118); 20 U.S.C. 6339 (section 1127); U.S. Department of Education, Dear Colleague letter on schoolwide program flexibilities, January 21, 2026; U.S. Department of Education, guidance on AI use in schools, July 22, 2025; NAESP, FY26 appropriations; Congressional Research Service, Status of FY2027 Labor-HHS-Education Appropriations; NCES Fast Facts, Title I; NCES, Title I formulas study; NYSED, Title I, Part A allowable expenditures; Education Commission of the States, State AI Guidelines, April 2026; Florida Rule 6A-1.0957.

Turning Title I Dollars Into Practice Time

Walk into a Title I classroom during independent work and the pattern is familiar. The students who most need to talk an idea through, often English Learners, get the fewest turns. We ask a lot of one teacher with 25 students, a pacing guide and a small group waiting at the back table.

The constraint is time, not skill. A schoolwide plan can call for more individualized practice, but the teacher still holds one conversation at a time.

Some districts are writing supplemental, individualized practice into their schoolwide plans, with tools that extend the teacher’s reach. Telo AI is one example: students practice speaking in five-minute sessions, three times a week, on the Chromebooks or tablets a school already has or on a screen-free robot, and the teacher dashboard reports participation, vocabulary growth and speaking progress.

See how Telo AI structures individualized speaking practice

Five minutes three times a week adds up to as much as an hour of extra speaking practice per student each month. A Title I plan is judged by what it changes for the students it was written for, and practice time is one of the few things a budget can add directly.