Title III requires that funds available under a subgrant be used to supplement the level of federal, state, and local funds that, in the absence of such availability, would have been expended for programs for English Learner (EL) students and immigrant students and in no case to supplant such federal, state, and local funds. That is, supplement means “to add to” and supplant means “to take the place of” or “instead of”. For example, if a particular activity was paid for using non-federal funds, or other federal funding such as Title II, then the same activity this year cannot be paid for using Title III federal funds. State-mandated activities must be paid for using state funds first. Can Title III funds be used to support sending personnel to English Learner-specific professional development (PD) by paying for substitute teachers or extra-pay if the training is held outside the hours specified in the employment contract? Maybe. The PD must be supplemental and should not violate the “Supplement, not Supplant” provision of Title III, Section 3115 (g). Also, see Title III, Section 3115 (c)(2)(D) to ensure PD is of “sufficient intensity and duration”.