The United States has seen a tremendous growth in dual-language programs over the last decade. This rapid growth brings up questions about the congruency between labels and implementation. Our experiences observing some of the programs and listening to teachers talk about the programs in New York City led us to propose that many of the self-designated dual-language programs stray from even the minimal guidelines for such programs. Our study investigated this, and within this paper we will juxtapose those programs that are congruent with the minimal standards with those that are less faithful to the model in order to gain a better understanding of how schools and districts can work to create dual-language programs that foster an authentic transformation of the instructional environment. (Contains 9 tables and 3 endnotes.)