English Learner Program Compliance Review for School Districts with Afghan Students

An English learner (EL) program compliance review is an independent evaluation of how a school district identifies, places, teaches, monitors and communicates with English learners and their families. It measures each part of the program against Title VI, the Equal Educational Opportunities Act, Title III, IDEA where students also have disabilities, and state law, and ends with findings and a corrective action plan.

Yes. The Department of Education withdrew its 2015 English learner guidance in August 2025, closed its Office of English Language Acquisition in May 2026 and removed the disparate-impact provisions from its Title VI regulations in July 2026. Those changes narrow federal enforcement, but the statutes stand: Title VI, the Equal Educational Opportunities Act and the Title I and Title III requirements of ESSA. The EEOA still requires appropriate action to overcome language barriers, courts still judge that duty under the Castañeda test, and families can sue a district directly.

Title VI of the Civil Rights Act of 1964; the Equal Educational Opportunities Act, 20 U.S.C. 1703(f); Lau v. Nichols and the Castañeda three-part test; ESSA requirements for identification, parent notice, yearly English proficiency testing, exit and four years of monitoring; IDEA and Section 504 for English learners with disabilities; FERPA; Plyler v. Doe for enrollment; and your state’s English learner rules and monitoring instrument.

Castañeda v. Pickard (1981) is the federal appeals court test used to judge whether a district has taken appropriate action under the EEOA. The program must rest on a sound educational theory, be implemented with adequate staff and resources, and be evaluated and changed if it does not produce results. Our findings are organized against all three prongs.

A rapid diagnostic takes three to four weeks. A full compliance review takes 10 to 14 weeks from the data agreement to the board briefing, depending on district size and the school calendar. Follow-up checks run at 90, 180 and 365 days.

We quote a fixed fee, travel included, after a scoping call, because scope depends on enrollment, the number of schools and the areas under review. For reference, public records show a Northern Virginia district’s contract for a multi-year English learner program evaluation, covering 2018 and 2019, priced at $199,624.

A signed data agreement, one named contact and the items on our evidence request: policies and procedures, home language survey forms, enrollment and English proficiency data, program and staffing rosters, sample parent notices, Title III budgets, and access to schools for interviews and observations. We draw the student-file sample ourselves.

We work as a school official under the district’s direct control, sign your data privacy agreement, use de-identified data wherever possible and open named records only for the file sample. Data stays in an encrypted, access-controlled, U.S.-hosted environment and is returned or destroyed at the end with a written certificate. We do not collect immigration status.

Your counsel can engage and direct us, so that findings reach counsel first; whether privilege applies is for your counsel to decide. Ariana Nexus is not a law firm and does not give legal advice; we supply the evidence, analysis and corrective plan your counsel relies on.

Yes, with consent. Family interviews and focus groups run in Pashto, Dari or the family’s own Afghan language, with a woman interviewer for mothers on request and trauma-informed protocols. Students are interviewed only where appropriate and with a parent’s permission.

Pashto, Dari and 22 more Afghan languages: Uzbeki, Turkmeni, Balochi, Pashayi, Aimaq, Kyrgyz, Brahui, Ormuri, Parachi, Wakhi, Shughni, Sanglechi, Ishkashimi, Munji, Yidgha, Gawarbati, Tirahi, Nuristani (Ashkun group), Kati, Prasun, Waigali and Tregami. Reports are in English, and family materials can also be prepared in French, German, Spanish, Italian, Hebrew, Urdu, Arabic, Hindi, Portuguese, Chinese, Russian, Turkish and Swedish.

As separate languages, never folded into “Farsi” or “Persian.” Pashto is a different language altogether, and Afghan Dari and Iranian Persian differ in the words families use with schools. The survey should also record which language each parent prefers for meetings and whether they read it, so the district can choose written, audio or interpreted communication.

We check whether screening asks about years of schooling in Afghanistan and in transit countries, not just age. Since 2021, girls in Afghanistan have been barred from school after sixth grade, so many girls arrive years behind the grade their age suggests. Placement should not wait for transcripts that may not exist.

Sometimes, in part. Title III must supplement, not supplant, other funds, and it generally cannot pay for what civil rights law already requires. Evaluating services that Title III funds may be allowable. Our funding map separates the parts for your federal programs director and your state Title III office to confirm.

Yes. We review English as an additional language (EAL) provision in the United Kingdom, ELL and ESL programs in Canada, EAL/D programs in Australia, and newcomer language programs in Europe, including German DaZ and French UPE2A settings, depending on the type and scale of the project.

No. This review evaluates your whole English learner program and tells you what to fix. If a finding concerns interpreting or translation, you can use any qualified provider. Our school interpreting and document translation services are separate engagements, and we disclose that interest in the report.