Quick Answer
Title I family engagement funds pay for activities consistent with the district's engagement policy, and must include at least one of five uses in Section 1116, such as programs that reach families "at home, in the community, and at school." Costs must be necessary and reasonable. Overall, the funds must add to state and local money, not replace it.
TL;DR
Districts with more than $500,000 in Title I, Part A funds must set aside at least 1% for parent and family engagement. Most of it goes to Title I schools, and parents help decide how it's split. The spending has to fit the district's engagement policy, and taken together it must include at least one of five uses in the law. The supplement-not-supplant rule also applies, and since the Every Student Succeeds Act it's checked against the district's overall funding formula, not purchase by purchase. Every source is linked below, so a coordinator can check the text rather than take a blog's word for it.
What this is: KudoKids sells a family app that a school can pay for, so read this page the way you'd read any vendor writing about a funding stream — as a plain-English summary of the public sources, each one linked, and not as funding or legal advice. Whether anything is an allowable use in your plan is your coordinator's call, not ours.
Where Does Title I Family Engagement Money Come From?
Title I family engagement money comes from a required set-aside inside the district's Title I, Part A allocation. Section 1116 of the Elementary and Secondary Education Act (codified at 20 U.S.C. § 6318) requires each district to "reserve at least 1 percent of its allocation" to carry out family engagement activities. Small districts are exempt. The statute says the set-aside isn't required where 1% of the allocation would be $5,000 or less, and the U.S. Department of Education's (ED's) January 2025 non-regulatory guidance states the same rule from the other side: districts allocated more than $500,000 must reserve at least 1%.
Three rules come with the set-aside:
- At least 90% goes to schools. "Not less than 90 percent of the funds reserved... shall be distributed to schools served under this part, with priority given to high-need schools" — and per the 2025 guidance, each district defines "high need" for itself. The same guidance (C-14 and C-15) figures the 1% for families of participating private-school students separately. The 90% applies to the public-school share.
- Parents help decide the allotment. The statute requires that parents and family members of children receiving Title I services "shall be involved in the decisions regarding how funds reserved... are allotted for parental involvement activities."
- Districts may reserve more than 1% — and per the 2025 guidance, the amount above the required 1% can be kept for district-wide engagement activities rather than distributed to schools.
Smaller districts still have the duties. The 2025 guidance (question C-13) says districts at or under the $500,000 line must carry out Section 1116; they just don't have to set aside 1% to do it.
What Are the Allowable Uses of Title I Parent and Family Engagement Funds?
Title I family engagement funds must pass two tests in the statute: they must be spent on activities "consistent with the local educational agency's parent and family engagement policy" — the written policy the district developed jointly with parents — and the spending must include at least one of five listed categories (Section 1116(a)(3)(D)):
- Professional development on family engagement strategies for school staff, which the statute says "may be provided jointly" with parents and family members.
- "Supporting programs that reach parents and family members at home, in the community, and at school." That's the statute's own wording: home-based programs sit in the list on equal footing with school-based ones.
- Disseminating best practices, "especially best practices for increasing the engagement of economically disadvantaged parents and family members."
- Collaborating with community organizations or employers with a record of success in improving family engagement, including through subgrants to schools.
- "Any other activities and strategies" the district determines are appropriate and consistent with its engagement policy.
The fifth category leaves the list open, so the district's own policy sets the limit on activities, while federal cost rules and state guides (below) set the limit on costs. The whole frame also sits on a statutory definition: Section 8101(39) defines "parental involvement" as "the participation of parents in regular, two-way, and meaningful communication involving student academic learning and other school activities." ED's 2025 guidance (question A-2) says this definition "sets the parameters, in conjunction with other sections of the law," for how states, districts and schools involve parents.
What Does "Supplement, Not Supplant" Mean in Plain English?
Federal money must add to what state and local dollars already pay for, not replace it. The rule lives in Section 1118(b) of the ESEA (20 U.S.C. § 6321(b)): districts "shall use Federal funds received under this part only to supplement the funds that would, in the absence of such Federal funds, be made available from State and local sources... and not to supplant such funds."
What changed under the Every Student Succeeds Act is how a district demonstrates it. Before ESSA, ED used three "presumptions" that tested individual costs. The current statute replaces that with a methodology test: a district shows that the formula it uses to allocate state and local money to schools gives each Title I school everything it would receive if it weren't a Title I school. The Department of Education's 2019 supplement-not-supplant guidance — which supersedes all of ED's earlier guidance on the topic — puts it flatly: "An LEA can no longer be required to identify that any individual cost or service supported with Title I, Part A funds is supplemental," and the district's methodology must be "'Title I neutral' in that it allocates State and local funds to schools without regard for Title I status."
In plain terms: federal law checks supplanting at the level of the district's funding formula, not line by line. A district's own written procedures may still ask more of a purchase, which is why the call stays local.
What Questions Does a Coordinator Actually Ask About a Family-Engagement Purchase?
A coordinator's check on a family-engagement purchase can be built from seven questions in the statute, ED's guidance and the federal cost rules, and each one is the district's to answer:
| # | The question | Where it comes from |
|---|---|---|
| 1 | Does it fit our written parent and family engagement policy — the one developed with parents? | Section 1116(a)(2), (b)(1) |
| 2 | Does our reserved-fund spending, taken together, include at least one of the five activity categories? | Section 1116(a)(3)(D) |
| 3 | Were parents involved in deciding how the reserved funds are allotted? | Section 1116(a)(3)(B) |
| 4 | Does it hold up against the definition of parental involvement — regular, two-way, meaningful? | Section 8101(39) |
| 5 | Is our state and local allocation methodology Title I neutral? | Section 1118(b); ED 2019 guidance |
| 6 | Is the cost necessary, reasonable and allocable to the program? | Uniform Guidance, 2 CFR 200.403–200.405 |
| 7 | What will we have on file: the policy fit, the invoice, and whatever the program reports back? | District's own procedures |
States add their own tests on top of the federal frame, and a state guide can be more concrete. New York's allowable-expenditures guidance, for example, says a family-engagement expenditure must:
- fit Title I's purpose
- meet needs named in the engagement policy
- be reasonable in cost and reach
- serve all students, including students with disabilities and English learners
- pay for activities with evidence behind them
Its columns are specific enough to name door prizes and gift cards as out. Behind the state guides sit the federal cost rules in the Uniform Guidance (2 CFR Part 200): a cost must be necessary, reasonable and allocable (fairly chargeable to this program). Business offices apply those rules to federal purchases generally. Before any purchase conversation, pull your own state's guide. Here is how two state guides treat common costs:
| Cost | New York (NYSED) | Washington (OSPI) |
|---|---|---|
| Transportation and child care so parents can attend | Allowable | Allowable |
| Materials that help parents work with their children | Allowable | Allowable (instructional kits, workbooks, books for loan) |
| Home visits for parents who can't attend meetings | Allowable | Not listed |
| Translation and interpretation | Allowable | Allowable |
| Light refreshments for parents | Allowable | Allowable when meetings clash with family meals or schedules |
| Stipends for parents | Unallowable | Not listed |
| Door prizes, gift cards, promotional items | Unallowable | Unallowable (gifts and promotional items) |
Row 7 of the coordinator's checklist, what goes on file, is where a vendor can help. A vendor can hand a district accurate documentation of what happened — for an at-home program, that can be a count of how many families started, and when. A vendor cannot hand a district a compliance conclusion, and one who tries is answering a question that was never theirs.
Who Decides Whether a Specific Purchase Fits?
The district's coordinator and business office decide whether a specific purchase fits, and the state reviews their work: Section 1116(h) directs each state educational agency to review district engagement policies and practices. A vendor's legitimate role in that process is narrow: describe the program accurately, answer the district's questions in writing, and send whatever documentation the district asks for.
Common Mix-Ups When Reading About Title I Family Engagement
Four pairs of terms get confused when reading about this fund: Title I and Title 1, Section 1116 and Section 1118, $500,000 and $5,000, and parental involvement and family engagement.
- Title I vs. Title 1. Same fund — schools often write it with the numeral, federal documents with the Roman numeral. Search both when you're looking for guidance.
- Section 1116 vs. Section 1118. ESSA renumbered the law. Parent and family engagement was Section 1118 under No Child Left Behind and is Section 1116 now; Section 1118 is now the fiscal section where supplement-not-supplant lives. Older articles — and some state pages — still use the old numbers. The U.S. Code citations (§ 6318 and § 6321) never changed.
- $500,000 vs. $5,000. Both are real: the statute exempts districts where 1% of the allocation is $5,000 or less; ED's guidance (question C-12) says a district with "a Title I, Part A allocation of greater than $500,000 must reserve at least one percent." Two framings of one rule.
- "Parental involvement" vs. "parent and family engagement." The section heading says engagement; the defined statutory term is parental involvement. ED's 2025 guidance says the definition "sets the parameters" for how states, districts and schools involve parents.
What KudoKids Is — and Whose Call the Rest Is
KudoKids (kudokids.org) is a family app a school can fund for every family, one year at a time: parents enroll directly on their own phones, kids earn screen time at home by finishing real routines, teachers run nothing, and the core app stays free to families either way. It never asks a parent to come to the building — which, if your problem is reaching the families who never come to events, is the point.
The funding section of the schools page describes how a school can pay for it and what a school receives. We'll answer whatever your coordinator or business office asks, in writing. What we won't do is apply the tests above to our own product; those determinations are yours. If the next question is privacy review, see does a parent app need a student data privacy agreement?
Frequently Asked Questions
Does every district have to reserve 1% for family engagement?
No. The reservation requirement applies to districts allocated more than $500,000 in Title I, Part A funds (the statute frames the same exemption as "1 percent... is $5,000 or less"). Districts under the line still carry Section 1116's engagement duties (a written policy, a school-parent compact, an annual Title I meeting at each school, capacity-building) without the mandatory reservation.
Can a district keep the reserved money at the district level?
At least 90% of the required 1% for public-school families must be distributed to Title I schools, with priority to high-need schools as the district defines them. Anything a district reserves above the required 1% may, per ED's 2025 guidance, be retained for district-wide family engagement activities.
What is the definition of parental involvement under federal law?
Section 8101(39) defines parental involvement as "the participation of parents in regular, two-way, and meaningful communication involving student academic learning and other school activities," including ensuring "that parents play an integral role in assisting their child's learning," that they are "encouraged to be actively involved in their child's education at school," and that they are "full partners in their child's education." The statute's separate definition of "parent" is broad — it includes a grandparent or stepparent the child lives with.
Can a vendor say its product is an allowable use of family engagement funds?
A vendor can describe what its program does and answer a district's questions in writing. The determination itself — policy fit, category fit, supplement-not-supplant — belongs to the district's coordinator and business office, applying the district's own plan. Treat any vendor's self-certification as a red flag, ours included.
Where are the actual source documents?
The statute: Section 1116 and Section 1118(b) at govinfo.gov. The guidance: ED's Parent and Family Engagement guidance (January 2025) and Supplement Not Supplant guidance (June 2019). If you only read one, read the 2025 guidance — it's ED's own Q&A on everything above.
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Last updated: September 24, 2026
This article is for informational purposes only and does not constitute legal or funding advice. Every determination about a district's Title I plan, policy, and spending belongs to the district, its coordinator, its business office, and its state educational agency.
