Program Audit Tool
Bilingual / English as a
Second Language (ESL)
Bilingual/ESL
Introduction
The Program Audit Tools were developed to assist local education agencies (LEA) with understanding
program requirements, reviewing internal controls, and ensuring that appropriate documentation exists to
support program and funding compliance for various federal and state programs. The tools also assist new
program directors in outlining program requirements.
The indicators outlined in these tools are cited in the following sources:
 Federal and State Statute
 Program Guidelines
 Program-Specific Funding Applications
 Program-Specific Provisions and Assurances
 Performance-Based Monitoring and Interventions
 Texas Education Agency’s State Program Plans
Depending on the program requirements, the tools include the following sections, where applicable:
 Board Policy/Action
 Personnel
 Financial Management
 Program Requirements
 Program Coordination
 Parent Involvement
 Parent Notification
 Public Information
 Data/Reports
 Documentation
 Student Services
 Professional Development
 Program Evaluation
 Private Schools
The tools are designed for program administrators and other key personnel to gather data and internally
identify whether the LEA is meeting the requirements, how the requirements are being met, and potential areas
for improvement. The review should include a team of individuals connected to the program, rather than single
program contacts, to facilitate collaborative involvement in the review and refinement processes. The LEA may
also consider external support to facilitate discussions.
Prior to conducting individual program reviews, staff members should be provided with a copy of their
respective program tools. Sections of the tool may then be assigned to staff members to gather data related to
their indicators. When the team convenes, members work together to review each section, identify the data
that supports compliance, and ultimately use the results of the program audit to refine the effectiveness of the
program in supporting student achievement.
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Board Policy/Action

Comments
The LEA has a clearly articulated mission for Bilingual/ESL education that is consistent with
the Texas Administrative Code (TAC) and Texas Education Code (TEC).
The LEA has a consolidated set of policies and procedures for translating the vision into
action.
The LEA has policies and procedures for ensuring that all allocated funds are expended
each year.
The board policy adopted by the LEA to establish and operate an LPAC provides for the
selection, appointment, and training of committee members and is composed of the
required members.
A school district implementing a dual language immersion program must develop a policy
on enrollment and continuation for students in the program. The policy must address:
1. eligibility criteria;
2. program purpose;
3. grade levels in which the program will be implemented;
4. support of program goals as stated in §89.1603 of this title (relating to Dual Language
Immersion Program Goals); and
5. expectations for students and parents.
General Comments:
Program Coordination
 Note: Additional Program Coordination requirements are cited in the Program Requirements section.
Comments
The LEA uses an effective process to identify LEP students served with Title I, Part A funds
on targeted assistance campuses.
The LEA assures that qualified and highly effective Bilingual/ESL teachers are recruited,
developed and retained and/or proper exceptions/waivers are requested for approval by
October 1.
Bilingual education and English as a second language programs are integral parts of the
total school program. These programs use instructional approaches designed to meet the
special needs of limited English proficient students. The basic curriculum content of the
programs is based on the essential skills and knowledge required by the state.
For LEP students who qualify for services in the special education program, a professional
member of the LPAC serves on the admission, review, and dismissal (ARD) committee.
LPAC and ARD committees work collaboratively to make Bil/ESL entry and exit decisions of
special education students.
SUMMER SCHOOL PROGRAM requirements: An LEA required to offer bilingual education
or ESL offers a summer program that addresses the affective, linguistic, and cognitive
needs of LEP students for children eligible for admission to kindergarten or first grade at the
beginning of the next school year and provides the necessary resources to conduct the
program effectively.
1. Students must be eligible for admission to kindergarten or first grade at the
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beginning of the next school year and must be LEP.
2. The program focuses of language development and the knowledge and skills
appropriate to the level of the student.
3. Enrollment is optional with the parents of the students.
4. The program is operated on a one-half day basis, a minimum of three hours each
day, for eight weeks or the equivalent of 120 hours of instruction.
5. Student/teacher rations district-wide do not exceed 18:1.
6. Teachers in the program possess certification or endorsement.
7. The LEA maintains records of eligibility, attendance, and progress of students in the
program.
General Comments:
Financial Management

Comments
The LEA has a fiscal management system in place for ensuring the proper expenditure and
reporting of Bilingual/ESL funds.
LEAs, with an exception to the bilingual education program and approval to offer an
alternative program or a waiver of certification requirements for the teachers who will
provide instruction in ESL, expend at least 10% of the bilingual education allotment to
improve the skills of the staff assigned to implement the program.
The LEA expends at least 85% of the bilingual education allotment (program code 25) to
supplement the bilingual education/ESL instructional program.
The LEA has the capacity to prepare and submit financial reports that are both accurate and
reliable.
General Comments:
Program Requirements

Comments
The principal of each school campus, with the assistance of the campus SBDM committee,
develops, reviews, and revises the campus improvement plan for the purpose of improving
student performance for LEP students. There is evidence that the goals, objectives,
strategies/activities address this student population.
The LEA (with an exception to the bilingual education program) is addressing their recruiting
practices to meet their needs for bilingually certified teachers.
Each Language Proficiency Assessment Committee (LPAC) for a Bilingual program shall
include a professional bilingual educator, a professional transitional language educator, a
parent of a limited English proficiency student (current student in the program), and a
campus administrator. (A parent serving on an LPAC may be an employee of the LEA.)
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ESL LPAC members consist of one professional personnel and a parent of a LEP student in
the program for ESL.
The LEA provides LPAC training to all members of the committee, including parents. There
is evidence of training, including agendas and sign-in sheets.
Upon initial enrollment and at the end of the school year, the LPAC reviews all pertinent
information on LEP students. THE LPAC reviews pertinent information and meets during the year,
as needed.
Before the administration of state assessments, the LPAC determines the appropriate assessment
option for each LEP student. There is evidence that the LPAC considered the following:
1. academic program participation (Bilingual or ESL) and language of instruction;
2. language proficiency, including literacy, in English and/or Spanish;
3. number of years enrolled in U.S. schools;
4. previous testing history;
5. level achieved on the state English language proficiency assessment in reading;
6. consecutive years of residence outside of the 50 U.S. states; and
7. schooling outside the U.S.
The LEA administers an Agency-approved oral language proficiency test (OLPT) to identify
LEP students for whom a language other than English is indicated on the Home Language
Survey in Grades PK-12 for identification purposes.
All oral language proficiency testing is administered by professionals or
paraprofessionals who are proficient in the language of the test and trained in
language proficiency testing. The LEA has evidence of training for staff, including
agendas and sign-in sheets.
The oral language proficiency test is administered within four weeks of a student’s
enrollment.
The LEA administers the TELPAS Reading, in Grades 2-12, and TELPAS Listening,
Speaking and Writing to Grades K-12 to all LEP students enrolled, including students with
parental denials.
The LEA has administered the English reading and language arts sections of an Agency
approved norm-referenced standardized achievement test for Grades 2-12 for all students
with a language other than English indicated on the Home Language Survey for
identification purposes.
The LEA has an enrollment of 20 or more LEP students in any language
classification in the same grade level district wide and offers dual language
instruction in a bilingual program for LEP students in PK through the elementary
grades.
The LEA has an enrollment of less than 20 LEP students in any language
classification in the same grade level district wide and offers an English as a second
language (ESL) program for all LEP students enrolled.
The LEA provides written notice to the student’s parent advising that the student has
been classified as limited English proficient and requests approval to place the student in
the required program, bilingual education or ESL.
Parental Permissions are filed in the students’ permanent record folders.
The students’ permanent records contain the following documentation:
1. Home Language Survey
2. the identification of the student as LEP;
3. the designation of the student’s level of language proficiency;
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4.
5.
6.
7.
the recommendation of program placement;
parental approval of entry or placement in into the program;
the dates of entry into, and placement within, the program;
the dates of exemptions from the criterion-referenced test, criteria used for this
determination, and additional interventions provided to ensure adequate yearly
progress;
8. the dates of exit from the program and parent notification; and
9. the results of monitoring for academic success, including students formerly classified
as LEP, as required under TEC.
The LEA addresses all required elements in its bilingual education program provided to LEP
students in PK through the elementary grades.
The district has designed ESL instruction to be an intensive program to develop proficiency
in the comprehension, listening, speaking, reading, and writing of the English language.
The LEA uses state-adopted textbooks in the bilingual education and special language
programs.
The LEA shall at least annually report to parents the progress of their child as a result of
participating in the program offered to LEP students.
Prekindergarten and kindergarten students are not exited from the Bilingual or ESL
program.
The LPAC uses required criteria to exit LEP students from the bilingual education or ESL
program.
The LPAC promptly notifies the parent of the student’s reclassification as English proficient
and exit from the bilingual education/ESL program and acquires approval.
The LPAC monitors the academic progress of each student who has exited from a bilingual
education or ESL program within two years of exiting to determine whether the student is
academically successful. Instructional staff is aware of M1 and M2 students.
A district that is unable to provide a bilingual education program or an ESL program as
required by statute, shall request an exception by October 1st that includes the required
components.
n/a
Bilingual and ESL programs are located in the regular public schools, rather than separate
facilities; AND enrollment of LEP students in schools does not exceed 60% of the total
student enrollment for that school.
General Comments:
Dual Language Program Requirements
 Note: Applicable for LEAs with Dual Language programs.
Comments
A dual language immersion program must fully disclose candidate selection criteria and
ensure that access to the program is not based on race, creed, color, religious affiliation,
age, or handicapping condition.
A school district must obtain written parental approval for student participation in the
program sequence and model established by the district.
A dual language immersion program shall be developmentally appropriate and based on
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current best practices research.
A dual language immersion program shall be a full-time program of academic instruction in
English and another language.
A minimum of 50% of instructional time must be provided in the language other than
English.
The minimum enrollment requirement of limited English proficient (LEP) students in a dual
language immersion program should be the lesser of 30% of the students in the class, or all
LEP students served in that grade at that campus.
Program implementation should:
(1) begin at prekindergarten, kindergarten, or Grade 1, as applicable;
(2) continue without interruption incrementally through the elementary grades; and
(3) consider expansion to middle school and high school whenever possible.
If the LEA is implementing a dual language immersion program, it must conduct annual
formative and summative evaluations collecting a full range of data to determine program
impact on student academic success.
General Comments:
Data

Comments
The Home Language Survey contains, at a minimum, the following required questions:
1. "What language is spoken in your home most of the time?"
2. "What language does your child (do you) speak most of the time?"
All students have a Home Language Survey in their permanent record folders (original
copy) signed by their parents (for students in Grades PK-8) or by the student (Grades 9-12).
The LEA effectively uses automated processes for the submission of PEIMS data.
The LEA has a valid and reliable method for reporting accurate PEIMS data on the LEP,
Bilingual and ESL coding as well as attendance that affect funding allocations.
The LEA uses completion/graduation rates to assess academic attainment of Bilingual/ESL
students including tracking student performance data two years after exiting the
Bilingual/ESL program.
The LEA uses follow-up data to assess Bilingual/ESL student participation (including
placement, retention, and completion) in postsecondary education and/or work.
The LEA complements AEIS data with PBM, OCR, and other quantitative and qualitative
data to assess student performance and make informed decisions.
Records relating to the identification of LEP students that impact their educational programs
are properly maintained.
The LEA ensures that LEP students are not overrepresented in special education or
underrepresented in gifted/talented (G/T) education.
The LEA evaluates demographic data from year-to-year, with a focus on eliminating
achievement gaps.
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General Comments:
Parent Involvement & Parent Notification Requirements

Comments
Parents are provided notice about LPAC meetings, including meeting time and location, well
in advance. Meeting times should be convenient for parents and accommodate their work
schedules. Meeting agendas, minutes and other materials are presented in a language and
format that parents understand.
The LEA provides information to parents describing the bilingual education program, its
benefits to the student, and its being an integral part of the school program to ensure that
parents understand the purpose and content of the program.
General Comments:
Professional Development

Comments
The LEA plays a significant role in building the capacity of staff through professional
development and technical assistance activities. The LEA must offer professional
development programs for dual language immersion teachers that incorporate second
language acquisition methods that are developmentally, affectively, linguistically, and
cognitively appropriate.
Program Evaluation

Comments
The LEA has developed a comprehensive strategy for annual Bilingual/ESL program
evaluations.
The LEA annually evaluates its student performance data and provides ongoing,
systematic, objective, evaluation of Bilingual/ESL programs.
The annual evaluation report developed by the LEA includes information on student
academic progress and other information necessary to evaluate the quality of the
program. The report, as a minimum, should include:
1. academic progress of LEP students in either language;
2. the extent to which they are becoming proficient;
3. the number of students exited from the Bilingual and ELS programs;
4. the number of teachers and paraprofessionals trained and the frequency, scope and
result of the training.
This evaluation is maintained at the LEA level.
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The LEA conducts periodic assessments and continuous diagnosis in the languages of
instruction to determine program impact and student outcomes in all subject areas.
The LEA evaluates demographic data from year-to-year, with a focus on eliminating
achievement gaps.
General Comments:
Private School Requirements

Comments
N/A – No Private Schools
N/A – Charter School
NOTE: The State Bilingual/ESL program does not include private school requirements;
however, if the LEA participates in the Title III, Part A program, private school requirements
apply under this funding source. See the Title III, Part A Audit Tool.
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Bilingual/ESL Program Audit Review Summary
District:
Date:
Board Policy/Action
Recommendations:
Clearly Evident
Somewhat Evident
Not Evident
Comments:
Program Coordination
Recommendations:
Clearly Evident
Somewhat Evident
Not Evident
Comments:
Financial Management
Recommendations:
Clearly Evident
Somewhat Evident
Not Evident
Comments:
Program Requirements
Recommendations:
Clearly Evident
Somewhat Evident
Not Evident
Comments:
Dual Language Program
Requirements
Recommendations:
Clearly Evident
Somewhat Evident
Not Evident
Comments:
Data
Recommendations:
Clearly Evident
Somewhat Evident
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Not Evident
Comments:
Parent Involvement &
Parent Notification
Requirements
Recommendations:
Clearly Evident
Somewhat Evident
Not Evident
Comments:
Professional Development
Recommendations:
Clearly Evident
Somewhat Evident
Not Evident
Comments:
Program Evaluation
N/A
Recommendations:
Clearly Evident
Somewhat Evident
Not Evident
Comments:
Audit Review Team
Name
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