Review of the Policies and Procedures of the Office of Education in Administering Contracts Awarded for the Purpose of Studying or Evaluating Educational Programs

Published by the Government Accountability Office on 1971-04-22.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

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             B-164031(1)                                                          APR 22 1971

             Dear Mr, Secretary:

         I         We made a review of the m                        and ~~~~~-~~es,of.~~.~._Offi.ce_of,         s-r
            Education in administering              contracts     a%zed     for the purpose   of    study-
                                                                                                 _ --_,-._,
                               , 1,"1
                                    ._....      1 --_-. -~ .-_
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            in$ij'7KXtiatmg            educatlonal-p-~~-~~~~~          During our review, we acquired
         Zinformation        on Z??%yG<cawarded                to the Consortium of Professional            As-
         Jsociations        for Study of Special Teacher Improvement Programs (CONPASS) fllaT2
            that we believe should be brought to your attention.                      We found that some
            of the basic management functions of the Office of Education that are
            essential     to an effective          administration      of the contract were delegated
            to CONPASSunder the contracts                  This matter is discussed below0 Other
            findings resulting           from our review will be reported upon separately.


                     Since the enactment of the National Defense Education Act of 1958,
             the Office of Education, through its institute     program, has supported
             institutions     of higher education to strengthen instructional services*

                    The institute    program is one of a variety of federally       supported
             special programs designed to improve instruction           in American educational
             institutions.       Under this program, colleges and universities,       through
             Federal support, provide advanced study for short terms or in regular
             sessions for persons concerned with the teaching of modern foreign lan-                             *
             guages, English, history,      geography, reading, economics, civics,        human-
             ities,    the arts, and the industrial    arts,,  Institutes    may also be
             conducted to improve the competencies of persons who use educational
             media, of teachers of disadvantaged or handicapped children,            and of
             counseling and guidance officers,

                    We were informed by the Director of the Division       of College Programs,
             Office of Education, that during 1963 and 1964 many of the universities
             which operated the institutes      contracted for evaluations    of their partic-
             ular programs and, because of the wide variety of programs, funded a
             large number of evaluations.       The Director  stated that, in an effort to
             consolidate   evaluations   and have them cover a number of educational dis-
             ciplines,   he had conceived of a consortium of organizations        from the
             various disciplines     to undertake, as a single body, the evaluations       de-
             sired by the universities.       He stated also that the consortium was
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                                         50TH   ANNIVERSARY        1921-   1971
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        designed to encourage communication between the various disciplines    by
        providing a means for persons from these disciplines  to begin talking
        with each other,

               A conference of representatives   from five educational associations
        and the Office of Education was held in January 1966 to present profile
        reports on the educational disciplines      of each association.       The meeting
        confirmed that, although institute     programs differed    strikingly    among
        disciplines    and radically between subject matter areas, the kinds of in-
        formation and ideas sought in the evaluation of programs were very simi-
        lar and often identical.     It was felt that the piecemeal approach to
        program evaluation had resulted in duplication       of effort    and costs,   A
        cooperative program under a coordinating      body outside the Office of
        Education was proposed to develop a unified "strategic         assessment" of
        institute   programs.

               During additional     meetings in February and May 1966, association
        representatives      developed a framework of a consortium of the five asso-
        ciations    to assess institute     activities  and the Office of Education
        institute     program generally.     The Association  of American Geographers
        was selected to administer the consortium, and the organizational           name
        was formalized as the Consortium of Professional         Associations for Study
        of Special Teacher Improvement Programs0 The acronym adopted for this
        organization     was CONPASS.


              COMPASSconsists of a central office,    an executive committee, and a
        governing board0 The central office has three members--a director,     a
        program associate,   and a staff assistant0   As of September 1970 the exec-
        utive committee had seven members selected from member associations,
        The board consisted of 30 members selected from member associations    as
        well as from other educational organizations.     As of September 1970 there
        were 13 member associations.

              The central office arranges periodic meetings of the executive com-
        mittee as well as meetings of the entire board.        The office    is also re-
        sponsible for the initiation    of new projects and for the publication       and
        dissemination   of final study reports.     The board's responsibilities     in-
        clude directing   the various activities    of CONPASS; reviewing and editing
        study reports;   and developing dialogue among the member associations,
        Government agencies, and educational     institutions,


             The contract with CONPASShas been amended seven times since it was
        awarded on May 3, 1966. The total estimated cost has increased from the


initial   $287,100    to $777,824.        This amount,         however,    represents      only that
part of funds CONPASS received            directly      from the Office         of Education.
CONPASS also received         $465,700    indirectly        from the Office       of Education
through  various    contracts       with universities          and colleges,        Thus, as of
March 24, 1971, CONPASS had received,                directly      and indirectly       from the
Office  of Education,       a total     of $1,243,524.

       CONPASS has submitted              a $2.75         million   proposal     for continued                   funding
covering   the 3-year  period             January         1, 1971, through       December    31,                1973.
As of March 1, 1971, this                proposal         was pending     Office    of Education                   action.


          We believe      that     some of the basic management      functions       of the Office
of Education         that    are essential     to an effective     administration        of the con=
tract      were delegated          to CONPASS under the contracte         Office     of Education
officials       advised      us that a "hands off"        policy  was adopted       with respect   to
the contracte           The director       of CONPASS informed     us that      the Office    of
Education       had given       little,    if any, direction     or guidance       on CONPASS

Contract      terms

         CONPASS was initially         funded    on the basis      of a proposal      submitted    by
CON?ASS to the Office           of Education       on May 3$ 1966,       The Director       of the
Division      of College    Programs      informed     us that he had solicited          the pro-
posal     verbally    and that,    although       no formal   evaluation     was made, he and
another      official    had reviewed       the proposal     and found     it acceptable,

        The original       CONPASS proposal                delineated       the      duties      of   the      CONPASS
board    as follows:

        1,    Develop  the policy  for,    and the details      of,                      a continuing
              study and assessment     plan for the institutes.

        2.    Invite  study projects             from      constituent            associations         and
              from other   organizations                and persons.

        3.    Review     and   approve     or    reject        such     study      projects.

        4,    Commission   acceptable work plans    and take steps to request
              funds from the Office   of Education     or other sources to
              implement  the study projects   approved,

        5.    Monitor     commissioned          projects         aad review          and approve            project

     6.   Prepare a final report on each commissioned project for
          submission to the Office of Education or other funding

      As shown by the above, CONPASSwas given considerable responsibility
for determining what evaluations were to be conducted as well as for
supervising   the conduct of such studies, The Associate Commissioner,
Bureau of Education Personnel Development, informed us that the Office of
Education had abided by CONPASSdecisions on projects unless there were
funding constraints,


      A number of studies have been undertaken under the direction     of
CONPASSsince its establishment.     According to Office of Education offi-
cials, CONPASSconducted none of these studies but instead entered into
subcontracts with colleges,  universities,   and private organizations    for
the studies,

       It appears that the delegation of authority    to CONPASSfor making de-
cisions on what studies would be undertaken or continued was, at least in
one case, not in the best interest     of the Office of Education.    In this
case, an evaluation of the Office of Education's Experienced Teacher
Fellowship   Program, consisting   of a number of individual  studies and cost-
ing about $192,000, was permitted to continue even though the Associate
Commissioner of the Bureau of Educational Personnel Development and another
Office of Education official     were against further funding because the pro-
gram under evaluation was being phased out. Approximately        $45,000 of the
$192,000 was spent after the Office of Education recommended termination
of the contract0

     The stated objective    of the Experienced Teacher Fellowship Program was
to reduce the shortage of teachers and improve the quality of instruction.
To meet this objective,   fellowships  were awarded for full-time  graduate
study leading to advanced degrees to persons who planned to pursue careers
in elementary and secondary education or postsecondary vocational     education.

      The study of the effectiveness     of this program under the direction    of
CONPASSwas initiated    in fiscal year 1967 and was still     being funded in
fiscal year 1970. The Assistant      Director,   Division of College Programs,
Office of Education, informed us that the Experienced Teacher Fellowship
Program was, in effect,   discontinued    sometime in 1968 and that the Office
of Education was against funding the uncompleted part of the study.          In a
memorandum dated January 29, 1970, to the Director of CONPASS, the Chief
of the Trainers of Teacher Trainers Branch, Office of Education, stated:


     "Because the Experienced Teacher Fellowship Program has
      terminated and funds for evaluation of on-going Bureau
      programs are very limited, we do not believe that we
      should attempt to provide additional  funds for the***
      evaluation study."

      In another memorandum, dated March 27, 1970, this same official
stated that the CONPASSboard had made the decision to complete the
study at a cost of about $45,000 even though he had recommended that          it
be terminated,

       When we asked why the Office of Education had funded the last phase
of the study, the Associate Commissioner, Bureau of Educational Personnel
Development, informed us that the CONPASSboard had the authority,    under
the contract terms, to make the decision and that the Office of Education
legally had to abide by that decision,

Hands-off   policy

      Office of Management and Budget Circular No, A-76, as revised, di-
rects that executive agencies perform for themselves those basic functions
of management necessary to retain essential     control over the conduct of
their programs.    These basic functions  include assignment of organizational
responsibilities,   planning of programs, establishment   of performance goals
and priorities,   and evaluation of performancee

      Although an official    of the Office of Management and Budget informed
us that there was a "gray" area with regard to what constituted     basic man-
agement functions,    we believe that some of basic management functions of
the Office of Education were delegated to CONPASSunder the contract0         As
a result,   the Office of Education was unable to exercise the direction     and
control over CONPASSthat was required for effective     contract administration,

        According to a Department of Health, Education, and Welfare adminis-
trative    manual, the Department must exercise considerable direction         and
control over the manner in which a contractor       conducts its work. However,
the Office of Education, according to the director        of CONPASS, gave little,
if any, direction     or guidance on CONPASSprojects.       Office of Education
officials     stated that a general hands-off policy had been adopted by the
Office of Education with regard to the contract.         One official    stated that
he believed that the hands-off policy developed primarily          because CONPASS
members had been accustomed to operating independently and that the Office
of Education was concerned that the primary objective          of the contracts--
communication--would      be thwarted if too much direction     were given.

    We did note that an Office of Education official sometimes sat in on
CONPASSboard meetings,  According to the Director of the Division of

College Programs, however, the Office of Education        had no voting   rights
at board meetings--just persuasive power.

                            MD CUR VIEWS THEREON

       We inquired as to the contribution   made by CONPASSto the evalua-
tions*    The Associate Commissioner, Bureau of Educational Personnel
Development, told us that CONPASShad not provided any particular        exper-
tise in evaluations    but had brought together the member associations    to
discuss teacher training    and education,   Furthermore, he stated that
CONPASSwas being phased out of its evaluation function and that he
wished to use CONPASSas a vehicle for getting member associations
involved in teacher education.

     Examination of the CONPASSproposal for continued funding emphasizes
the major shift in its operations from evaluation       to teacher education,
as indicated by the Associate Commissioner.       The proposal states that
CONPASSwill utilize   professional  associations    to do the work required in
the new area of emphasis. By concentrating       on these associations,   CONPASS
hopes to strengthen the training   of teachers at all levels.


        Although the management functions which COMPASSwould perform under
the $2.75 million     proposal are not clearly    stated, the proposal is writ-
ten in such a way that the relationship       between CONPASSand the Office of
Education could remain essentially      the same, i.e.,   CONPASSwould continue
to determine, without prior approval by the Office of Education, what
activities     are to be carried out under the contract,

      We believe that, for effective   contract administration,        the basic
m.anagement functions needed to control a contractor's      activities     should
be retained by the contracting    agency.


        We recommend that, if the contract with CONPASSis continued, the
Office of Education should provide for the retention     of the basic manage-
ment functions    it needs to effectively  direct and control CO!VPASS

       Your attention is invited to section 236 of the Legislative    Reorgan-
ization Act of 1970 which requires that you submit written      statements of

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*      B-164031(1)

       the action taken with respect to the recommendation.   The statements
       are to be sent to the House and Senate Committees on Government Opera-
       tions not later than 60 days after the date of this report and to the
       House and Senate Committees on Appropriations  in connection with the  .
       first request for appropriations  submitted by your agency more than
       60 days after the date of this report,

             We acknowledge the courtesy and cooperation extended to our staff
       during the reviews   Your comments as to the action taken on the matters
       discussed will be appreciated.

               Copies of this report are being sent today to the Chairmen, House c jc'"
    (,I/ +and Senate Committees on Government Operations; the Chairmen, House and ~3@
          Senate Committees on Appropriations; and the Commissioner, Office of

                                             Sincerely   yours,

                                             Q7ysx?vl‘&L            3-J
                                             Director,   Civil    Division

       The Honorable
       The Secretary of Health,
         Education, and Welfare