Management Bulletin 25-07

Early Education Division

Subject: Revised Guidance on Identification of Dual Language Learners

Number: 25-07

Date: July 2025

Expires: Until rescinded or superseded by regulations

Authority: California Education Code (EC) Section 8241.5; Assembly Bill (AB) 2268 (Chapter 15, Statutes of 2024)

Attention:  Executive Directors and Program Directors of all California State Preschool Programs

Note: This Management Bulletin (MB) rescinds and replaces MB 23-03.

Purpose

The purpose of this MB is to notify and provide guidance to California State Preschool Program (CSPP) contractors regarding the requirements for identifying and collecting data on dual language learners (DLL) including multilingual learners, language characteristics of preschool programs, and language composition of program staff.

This MB provides guidance to contractors regarding the following:

• Designating CSPP children as DLLs, including children who are dually enrolled in transitional kindergarten (TK) or kindergarten and CSPP;
  
  
• Conducting the Family Language Instrument and Family Language and Interest Interview;
  
  
• Teacher Designation of a DLL;
  
  
• Determining DLL status from kindergarten through twelfth grade (K-12) English learner (EL) status;
  
  
• Reporting data on DLLs; and
  
  
• Defining “enrollment date” for the purposes of all guidance related to DLL designation.

Policy

CSPP contractors are required to use the Family Language Instrument and the directives in this MB for all children, including those children dually enrolled in TK and CSPP, to identify DLLs in CSPP, except as provided below.

For children that are dually enrolled in kindergarten and CSPP for Extended Learning and Care (under the provisions of Education Code [EC] 48000[l]), contractors may do either of the following for the purposes of determining DLL status in CSPP:

• Conduct the Family Language Instrument to determine the DLL status of the child, or
  
  
• Use the child’s designation as an EL student through the state assessment for English Language Proficiency, as provided in the “Determining DLL Status” directive below.
  

For any child in CSPP, if the contractor determines that the child is a DLL as described above, the contractor must conduct the Family Language and Interest Interview following the procedures listed in the Family Language and Interest Interview section below.

Contractors are required to report child and program data to the California Department of Education (CDE) as directed in the Data Reporting section below.

In addition, effective January 1, 2024, the following changes apply:

• CSPP contractors may use the previous designation of child as a dual language learner by a General Childcare and Development Program (CCTR) or Migrant Childcare and Development Programs (CMIG) to identify the child as a DLL.
  
  
• If a parent or guardian chooses not to participate in the identification process, contractors will not be penalized. However, CSPP contractors are still required to provide the Family Language Instrument to the family and report data on these children, either as a non-DLL or DLL through Teacher Designation.

Directives for Implementation

This MB includes the following documents:

• Family Language Instrument (Attachment A) (DOCX) (Updated July 2025)
• Family Language and Interest Interview (Attachment B) (DOCX) (Updated July 2025)

Note: Contractors may begin using these new forms as of the release of this MB. Contractors are required to use these new forms for any child enrolled on or after September 1, 2025.

Determining DLL Status

Contractors must determine DLL status for every child enrolled in CSPP by using one of two approaches no later than upon enrollment:

• Conduct the Family Language Instrument to determine DLL status, or
  
  
• If the child is dually enrolled in kindergarten for Extended Learning and Care, obtain information on the child’s designation as an EL student in kindergarten as specified below.

Contractors must conduct the Family Language Instrument to determine the DLL status of TK children that are dually enrolled in CSPP, until further notice. Using EL student status for DLL identification of those enrolled in both CSPP and TK is no longer an option.

Conducting the Family Language Instrument

The Family Language Instrument (Attachment A) is a four-question survey. When conducting the Family Language Instrument, contractors must ask all four questions in the instrument to the child's family. However, contractors have the flexibility to place the four-question survey onto their own forms.

A completed Family Language Instrument must be kept and saved in the family data file.

The Family Language Instrument must be completed for each child even if there are multiple children from the same family. When multiple children are enrolled from the same family, the CDE recommends the instruments be conducted at the same time to minimize burden for families.

The Family Language Instrument can either be completed in person, via phone and web conferencing with the enrollment staff, or be shared with families as a form for them to fill out and return as part of their enrollment paperwork. The CDE recommends that the staff providing the instrument share information with families about the intent and purpose of the Family Language Instrument before requiring families to complete it. To aid in this conversation, the CDE has included some information in Attachment A that contractors can share with parents.

To the extent possible, the CDE strongly encourages contractors to communicate with the parent about the instrument and provide it in the family's preferred language. To assist with this, the CDE will be providing translations of the Family Language Instrument in: Spanish, Vietnamese, Simplified Chinese, Traditional Chinese, Armenian, Arabic, Filipino (Pilipino or Tagalog), Punjabi (India and Pakistan), Russian, Farsi (Persian), Japanese, and Korean.

These translations can be accessed on the CSPP DLL Identification Tools Translations web page.

Determining DLL Status

Contractors must designate children as DLLs in CSPP if either of the following are true:

• If a language other than English is the answer to questions 1, 3, or 4 of the Family Language Instrument, or
  
  
• If the answers to the Family Language Instrument questions 1, 3, or 4 indicated English only, but program staff determine within 30 calendar days of enrollment, through child observations, that the child demonstrates they speak, respond to, or understand a language other than English, the contractor must share these observations with the family and review with the family the responses to the Family Language Instrument, updating as necessary to ensure proper designation.

For purposes of DLL identification, the date of enrollment from which to measure 30 calendar days is as follows:

• Part-Day Enrollment: the first day the child is scheduled to receive CSPP services.
  
  
• Full-Day Enrollment: the date that the contractor certifies the family for CSPP services.
  
  
• Pilot Counties: If you are a provider participating in an approved pilot plan that includes the 120-day Certification of Eligibility for Full-Day CSPP pilot flexibility, use the first day the child is scheduled to receive CSPP services. If you are unsure of your pilot status or unsure if this pilot flexibility is part of your county’s pilot plan, please reach out to your Program Quality Implementation (PQI) office Regional Consultant.

Contractors must determine DLL status for every child enrolled in CSPP transferring from CCTR or CMIG by using one of two approaches no later than upon enrollment:

• A CSPP contractor may use the previous designation of child determined by a CCTR or CMIG contractor to identify the child as a DLL or not a DLL.
  
  
  • If the child demonstrates that they speak, respond to, or understand a language other than English, then the contractor will have 30 days from the date of transfer to determine if a Teacher Designation, as described below, is needed.
    
    
• Contractors may only require parents or guardians to complete a new Family Language Instrument and Family Language and Interest Interview, as applicable, at the time of transfer into CSPP if they have a written policy to do so.

Determining DLL Status Through Staff Observation

Contractors may designate children as DLLs by having program staff determine, through child observations, that the child demonstrates they speak, respond to, or understand a language other than English within 30 calendar days of enrollment. This is referred to as "Teacher Designation.”

Contractors may designate children as DLL through Teacher Designation, if within 30 calendar days from the date of enrollment through child observations, the child demonstrates they speak, respond to, or understand a language other than English and either one of the following are true:

• In the event a parent chooses not to answer questions in the Family Language Instrument. (Note: The child will be initially identified as “not a DLL.”)
  
  
• If the parent or guardian initially responded English only to Questions 1, 3, and 4 of the Family Language Instrument.

In the event that observations of the child demonstrate that a child is a DLL, the contractor must meet with the family to share these documented child observations, review the DLL identification process, and revisit the Family Language Instrument to encourage parents to update their initial responses for proper designation. During this meeting, the CDE recommends contractors share the benefits of multilingualism and home language development, share that proper designation can support the program in supporting the child, including their English and home language development, clarify that this designation is specific to CSPP and will not apply in elementary school and beyond, and address any other hesitations or concerns they may have around the process.

If the parent or guardian still chooses not to provide or update their answers to the Family Language Instrument, the contractor may designate the child as a DLL through a Teacher Designation.

For children identified as a DLL through Teacher Designation, contractors should attempt to obtain and document responses to Questions 4, 6, 7, and 8 from the Family Language and Interest Interview within 30 calendar days of designation as these responses are still required to be reported into the Preschool Language Information System (PLIS) or the California Preschool Data Collection (CAPSDAC) system, as applicable.

NOTE: Teacher Designation can only occur after 30 calendar days and after meeting with the parent or guardian.

As a reminder, if Teacher Designation is used, contractors must include the following in the family file:

1. Written observations for how the child has demonstrated they speak, respond to, or understand a language other than English.
   
   
2. Documentation from conversation with the family about their responses to the Family Language Instrument.

The CDE recommends the following:

• Reassuring and addressing parents or guardians concerned about the implications of answering these questions and about DLL identification in preschool. The goal is to create interactions with parents and families and provide opportunities to strengthen the relationship between the program and family.
  
  
• Follow the best practices on Teacher Designation found in the CDE Frequently Asked Questions (FAQs) web page.
  
  
• Review the Purpose and Framing and Instruction sections found in both the Family Language Instrument and Family Language and Interest Interview as these documents offer additional context and supports for both contractors and parents or guardians.
  
  
• The following best practices on Teacher Designation can be found in the FAQs page located on the DLL Support web page.

Determining DLL Status from EL Status

Contractors have two options for determining the DLL status for children receiving extended learning and care from CSPP outside of their kindergarten instructional minutes, pursuant to EC 48000, as described below.

Option #1: If a child enrolled in CSPP is also enrolled in kindergarten, the contractor may choose (but is not required) to determine the DLL status of the child based on their EL student designation in the K-12 system. The EL student designation is determined through the Initial English Language Proficiency Assessments for California (ELPAC).

Contractors that are not the local educational agency (LEA) serving the kindergarten student may determine that the child is designated as an EL student in the K-12 system through one of the following ways:

• Contractors may ask families with children enrolled in kindergarten for a copy of the Initial ELPAC Student Score Report (or more recent documentation, if that is available), designating whether their child is an EL student in the K-12 system.
  
  
• Contractors may ask parents and guardians to sign a consent form for the LEA serving the kindergarten student to allow the release of the Initial ELPAC Student Score Report (or more recent documentation, if available) to the contractor.
  
  
• Contractors may enter into written agreements with LEAs serving the same children to have those LEAs deem the contractor to be their authorized representative for purposes of sharing information on EL student status for CSPP-enrolled students with the contractor. Such agreements must conform to federal and state privacy law requirements including the Family Educational Rights and Privacy Act ([FERPA] 20 U.S.C. § 1232g; 34 Code of Federal Regulations [CFR] Part 99) in order for the LEA to share educational records with the contractor without parental and guardian consent. The CDE encourages all LEAs to create such agreements with contractors in their attendance area so they can share information on EL student status with CSPP contractors at their request to remove the burden from families and ensure important information on children is shared with those responsible for serving the children.
  
  
• Contractors that are the LEA serving the kindergarten child may share the child’s EL student status with the LEA’s preschool staff, as necessary, without the need for parental and guardian consent or a written agreement.

Under any of these approaches, documentation from families or from LEAs serving the child must be saved in the Family Data File.

Option #2: If contractors are unable to or choose not to determine DLL status based on EL student designation for dually enrolled children, contractors must administer the Family Language Instrument for those children to determine DLL status.

If a kindergarten student has been identified as Initially Fluent English Proficient (IFEP) as determined by the Initial ELPAC assessment but appears to know and understand another language besides English, the CDE recommends administering the Family Language Instrument to determine the child’s dual language learner status in CSPP.

Supporting DLLs

For any child who is identified as a DLL, the CDE recommends CSPP contractors provide families with resources on the benefits of strengthening children’s bi- and multilingualism and ideas for what they can do at home to support their child’s language development. Suggested resources to support this can be found at the bottom of this MB.

The Family Language and Interest Interview

The Family Language and Interest Interview (Attachment B) must be completed for all children enrolled in CSPP who have been identified as DLL under the processes described above.

The Family Language and Interest Interview must be conducted by the child's teacher or other designated staff in collaboration with the child's family.

If the child’s teacher is not the staff conducting the interview, staff conducting the interview must share the results with the child’s teacher in order to best support the child. For children that are identified as DLLs, any notes and/or responses from the Family Language and Interest Interview must be kept as part of the family data file.

The CDE recommends at least fifteen minutes be dedicated per family. Ideally, the interviews are to be conducted in person; but can be done by phone or through an online conferencing application such as Zoom, WebEx, or Teams.

The CDE recommends the teacher or other designated staff conducting the interview provide families with information about the intent and purpose of the Family Language and Interest Interview before asking the questions. To aid in this conversation, the CDE has included some information in the beginning of Attachment B that contractors can share with parents.

To the extent possible, the CDE strongly encourages contractors to conduct the interview in the family's preferred language. To assist with this, the CDE will be providing translations of the Family Language and Interest Interview in Spanish, Vietnamese, Simplified Chinese, Traditional Chinese, Armenian, Arabic, Filipino (Pilipino or Tagalog), Punjabi (India and Pakistan), Russian, Farsi (Persian), Japanese, and Korean.

These translations can be accessed on the CDE CSPP DLL Identification Tools Translations web page.

Contractors have the flexibility to place the questions for the Family Language and Interest Interview onto their own forms. Notes and or responses from the Family Language and Interest Interview must be kept as part of the family data file.

The Family Language and Interest Interview must be completed for each child identified as a dual language learner even if there are multiple children from the same family. When multiple children are enrolled from the same family, the CDE recommends the interview questions for all children be asked at the same time to minimize burden for families.

Timeline for Implementation

January 1, 2024, and Beyond

Beginning January 1, 2024, for any child enrolled, contractors must:

• Determine DLL status using the process described in this MB. If using the Family Language Instrument, contractors must complete the instrument with the parent or guardian of each child no later than upon enrollment. These questions must be completed by the parent or guardian of the child no later than upon enrollment. If using EL student designation to determine DLL status, contractors must obtain documentation of the designation no later than upon enrollment.
  
  
• Conduct the Family Language and Interest Interview for children identified as a DLL within 30 calendar days of enrollment.

Requirements for CSPP Contractors Operating Family Child Care Home Education Networks

As required by EC 8241.5, the procedures to identify and report DLLs as described in this MB are the sole responsibility of the CSPP contractor. As a result, CSPP contractors operating through a Family Child Care Home Education Networks (FCCHENs) are responsible for conducting the Family Language Instrument or obtaining documentation on EL student status for all children enrolled in their CSPP program as described above. CSPP contractors operating through a FCCHEN are also responsible for conducting the Family Language and Interest Interview with families enrolled in their CSPP contract.

The CDE encourages CSPP contractors operating through a FCCHEN to conduct the Family Language and Interest Interview alongside, and in collaboration with, the family childcare provider. To the extent this is not possible, the CSPP contractor must share the results of the interview with the family childcare provider serving the child.

Per EC 8241.5, family childcare providers participating in a CSPP FCCHEN are not responsible or liable for the accuracy of data. Additionally, the identification and reporting of DLLs by CSPP contractors shall not impact the status of a provider within a CSPP FCCHEN.

Data Reporting

Per EC 8241.5, contractors are required to report data on DLLs enrolled in a CSPP along with family, classroom, and teacher information.

PLIS (Community-Based Organizations [CBOs] and Community College Districts)
CBO and Community College District CSPP contractors will continue to submit data in the PLIS for the respective reports.

To log in to the CDE PLIS portal, contractors will enter the same credentials used for the CDMIS. The PLIS Data Reporting Instructions (formerly Attachment C) and the PLIS Reporting Schedule (formerly Attachment D) can be found on the CDE PLIS Landing Page.

Contractors are required to submit the PLIS Report on a quarterly basis. Please refer to the PLIS Landing Page for the latest PLIS Data Reporting Instructions and Data Reporting Schedule.

The CDE will periodically hold technical assistance webinars on the PLIS and PLIS Report; contractors will be notified when these occur, via the Early Education Division (EED) email distribution list. Contractors can also expect to receive reminders of data reporting due dates and data cleaning outreach.

CAPSDAC system (LEA CSPP contractors)

Beginning in the 2025–26 fiscal year (FY), LEA CSPP contractors have submitted child, staff, and classroom data to the CAPSDAC system, including all required child, staff, and classroom language information. Access to the CAPSDAC System, data reporting requirements from guidance, and more information on the CAPSDAC data submission instructions and the CAPSDAC Submission schedule can be found on the CDE CAPSDAC Support web page.

Contractor Reimbursement and Fiscal Reporting Requirements

Adjustment Factor for DLL Children

Assembly Bill (AB) 210 increased the DLL adjustment factor from 1.1 to 1.2. The FY 2022–23 Enrollment, Attendance, and Fiscal Report in the Child Development Provider Accounting Reporting Information System (CPARIS) was updated to reflect this change to the DLL adjustment factor.

Note: Unless superseded by a change in statute, due to the provisions of EC 8244, the DLL adjustment factor does not apply to part-day CSPP. 

Enrollment, Attendance, and Fiscal Reporting within CPARIS

In order to utilize the DLL adjustment factor, the process for identification of a DLL set forth in this MB must be used.

Contractors must implement the provisions of this MB before they may report under the DLL adjustment factor. Contractors must make the determination that the child is a DLL as described in the Determining DLL Status section above in order to report the child under the DLL adjustment factor category. Documentation of DLL status using the process described above will support the reporting of the child days of enrollment under the DLL adjustment factor category.

Background and Authority

EC Section 8205 defines “DLL children” as children whose first language is a language other than English or children who are developing two or more languages, one of which may be English.

EC Section 8244 allows for actual child days of enrollment to be adjusted by an adjustment factor when the child meets specified criteria. Adjustment factors recognize that different categories of children require special and appropriate services and that the costs for these services vary. Specifically, EC Section 8244(b)(4) states that in order to reflect the additional expense of serving full-day preschool children, the adjustment factor for DLLs, as defined in EC Section 8205(o) and have been identified as a dual language learner, shall be 1.2.

Pursuant to EC Section 8241.5, enacted through AB 1363 in 2021 and later modified by AB 210 (2022), the CDE is required to develop procedures for CSPP contractors to identify and report data on children that are DLLs enrolled in a CSPP. At a minimum, these procedures are required to include all of the following:

• The distribution and collection of a completed family language instrument
  
  
• A family language and interest interview
  
  
• Criteria for CSPP contractors to use to accurately identify dual language learners enrolled in their preschool programs

EC 8241.5 also requires data to be reported about children that are DLLs and the preschool program that they are being served in, which shall include at a minimum all of the following:

• A child’s home language, the language the child uses most, and the family’s preferred language in which to receive verbal and written communication.
  
  
• A child’s race or ethnicity.
  
  
• Language characteristics of the preschool program, including, but not limited to, whether the program uses the home language for instruction, such as a dual language immersion program, or another program that supports the development of home languages.
  
  
• The language composition of the program staff.

As required by EC 8241.5, DLL identification for CSPP students enrolled in kindergarten may be determined through the EL student designation process (through administration of the Initial ELPAC) in the K-12 system and that identification for children enrolled in CSPP will not be connected to or associated with the EL student designation in the K-12 system.

In addition, AB 321 (Statutes of 2022) modified EC Section 8241.5, effective January 1, 2023, to require that the Family Language Instrument be completed no later than upon enrollment of the child. More recently, AB 393 (Statutes of 2023) modified EC Section 8241.5 to state that parents or guardians of a child enrolled in CSPP are not required to complete the Family Language Instrument or to participate in the Family Language and Interest Interview. If a parent or guardian chooses not to participate in the identification process, contractors will not be penalized, nor will it affect the family’s eligibility for enrollment in a CSPP. It also states that a CSPP contractor may use the previous designation of child as a DLL by a general childcare and development program or migrant childcare program to identify the child as DLL. This requirement was effective January 1, 2024.

Finally, AB 2268 (Statutes of 2024) amended EC Section 60810(b) to exempt TK students from both the Initial ELPAC or the Alternative ELPAC and the summative ELPAC/Alternate ELPAC. Thus, any children dually enrolled in both TK and CSPP must be determined as DLL using the Family Language Instrument or through Teacher Designation.

The CDE intends to promulgate regulations in the future to implement these requirements. In the interim, pursuant to authority provided in EC 8241.5(g)(2), this MB and accompanying attachments constitute implementation procedures and related guidance to implement the legislation and, as such, the directives in this MB must be followed by contractors.

Resources

Resources to share with families regarding the benefits of multilingualism and home language development:

• Ways to Develop Your Child's Billingualism (Spanish) (PDF)

• Keeping Your Home Language (available in 16 languages)

• Benefits of Multilingualism (PDF)

• The Importance of Home Language Series | Early Childhood Learning and Knowledge Center (available in English, Spanish, Arabic, Chinese, and other languages)  

• Supporting DLL's Families : This resource engages DLLs’ families in discussion about language goals and practices. Topics include how families frame their language goals and practices and what those practices look like during everyday interactions with children such as playing and reading.  

• The following resources include family tip sheets, outreach toolkits, multilingual read-alouds, and parent perspective videos and can be found on the Quality Start Los Angeles DLL Resources
  • The Two Languages, Twice the Opportunities Dual Language Learning Campaign spreads the message about the benefits of being bilingual and bicultural. It’s time to empower the next generation. 
  • The DLL Resources for Families web page provides provide tools that can help you on this incredible journey to support your child’s developing bi-/multilingualism.

For technical support, up to date guidance, FAQs, and resources for the identification, reporting, and support of DLLs in the CSPP, visit the following web page.

• Dual Language Learner (DLL) Support

If you have programmatic questions regarding the information in this MB, please contact your assigned Early Education Division (EED) Program Quality Implementation (PQI) Office Regional Consultant.

If you have fiscal questions regarding the information in this MB, please contact your assigned Early Education and Nutrition Fiscal Services (EENFS) fiscal apportionment analyst.