oversight

Title I: Although Definitions of Administrative Expenditures Vary, Almost All Districts Studied Spent Less Than 10 Percent on Administration

Published by the Government Accountability Office on 2003-04-07.

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

             United States General Accounting Office

GAO          Report to Congressional Committees




April 2003
             TITLE I
             Although Definitions
             of Administrative
             Expenditures Vary,
             Almost All School
             Districts Studied
             Spent Less Than 10
             Percent on
             Administration




GAO-03-386
             a
                                                April 2003


                                                TITLE I

                                                Although Definitions of Administrative
Highlights of GAO-03-386, a report to the       Expenditures Vary, Almost All School
Committee on Health, Education, Labor
and Pensions, United States Senate and          Districts Studied Spent Less Than 10
the Committee on Education and
Workforce, House of Representatives             Percent on Administration


Because of concern about school                 In defining local administrative expenditures, all studies reviewed always
district spending on administration,            included the school district Title I coordinator’s salary and benefits but,
Congress directed GAO in two                    beyond this, their definitions varied. District spending classified as
separate mandates in the No Child               administrative in these studies varied, from 4 percent to 10 percent. In the
Left Behind Act of 2001 to (1)                  six school districts we studied, definitions of administrative expenditures
examine how school districts
                                                varied, in part because of differing state and local requirements or practices.
defined and spent Title I funds on
administrative activities and (2)
review Title I expenditures in at               Because there is no common agreement on what constitutes administrative
least six school districts. In                  expenditures, GAO identified a set of categories as “administrative
response to these mandates, we are              expenditures” for the purposes of this study and found that, in the six school
reporting on (1) how five studies               districts, Title I expenditures for administrative activities ranged from 13
define Title I administrative                   percent of total Title I expenditures to no Title I funds spent on
expenditures and what they found                administration. Most Title I funding—at least 84 percent in every district—
about the percentage of funds                   was spent on activities related to instruction. In addition, most school
spent on these activities and (2)               districts spent a relatively small percentage of their Title I funds on other
what proportion of Title I funds                non-instructional expenditures, such as transportation. Title I expenditures
was spent on administrative
                                                represent allocation decisions made by the six school districts during a
activities compared with
instructional and other activities in           particular year and, because some administrative costs may have been
six school districts.                           covered by funds from sources other than Title I, do not necessarily reflect
                                                the total amount districts spent on Title I administration in that year.

                                                Percentage of Title I Funds Spent in Six School Districts on Instructional, Administration,
                                                and Other Noninstructional Expenditures, School Year 2000-01




www.gao.gov/cgi-bin/getrpt?GAO-03-386.

To view the full report, including the scope
and methodology, click on the link above.
For more information, contact Marnie Shaul at
(202) 512-7215 or shaulm@gao.gov.
Contents


Letter                                                                                        1
               Results in Brief                                                               2
               Background                                                                     3
               Select Studies Used Varying Definitions of Administrative
                 Expenditures                                                                 5
               The Proportion of Title I Funding Spent on Administrative
                 Activities Varied, but Most School Districts Spent Less Than
                 10 Percent                                                                 10
               Concluding Observations                                                      14
               Agency Comments                                                              14

Appendix I     Scope and Methodology                                                        15
               Objectives                                                                   15
               Scope and Methodology                                                        15

Appendix II    Comments from the U.S. Department of Education                               23



Appendix III   GAO Contacts and Staff Acknowledgments                                       24
               Contacts                                                                     24
               Acknowledgments                                                              24


Tables
               Table 1: Expenditure Categories Considered to be Title I
                        Administrative Expenditures in Five Selected Studies                  6
               Table 2: Summary of Studies Reviewed                                           7
               Table 3: Proportion of Title I Spending by Type of Expenditure,
                        School Year 2000-01, by Size of Title I Expenditures                12
               Table 4: Number of Full-Time Equivalent Staff Funded by Title I
                        and the Total Staff in the School Districts, School Year
                        2000-01                                                             13
               Table 5: Characteristics of School Districts Selected, School Year
                        2000-01                                                             17
               Table 6: Six School Districts’ Views of Whether Three Categories of
                        Expenditures Are Title I Administrative Expenditures                18
               Table 7: Description of Instructional, Administrative, and Other
                        Noninstructional Expenditures Used in This Study                    19




               Page i                            GAO-03-386 Title I Administrative Expenditures
         Table 8: GAO Categories of Administrative Expenditures
                  Compared with In$ite Administration-Related
                  Expenditure Categories                                                           20


Figure
         Figure 1: Percents of Total Title I and Total School District
                  Expenditures Spent on Administration, School Year
                  2000-01                                                                          11




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         Page ii                                  GAO-03-386 Title I Administrative Expenditures
United States General Accounting Office
Washington, DC 20548




                                   April 7, 2003

                                   The Honorable Judd Gregg, Chairman
                                   The Honorable Edward M. Kennedy
                                   Ranking Minority Member
                                   Committee on Health, Education, Labor and Pensions
                                   United States Senate

                                   The Honorable John A. Boehner, Chairman
                                   The Honorable George Miller
                                   Ranking Minority Member
                                   Committee on Education and the Workforce
                                   House of Representatives

                                   In 2001, the Congress passed the No Child Left Behind Act (NCLB) in part
                                   to improve the academic achievement of disadvantaged children. The act
                                   also provided additional funding to school districts with students from
                                   low-income families. For fiscal year 2002, $10 billion was available through
                                   Title I of the act,1 the largest source of federal funding for elementary and
                                   secondary education. To ensure that most of these funds were spent on
                                   instructional activities that improve student learning, in the conference
                                   report accompanying NCLB, the Congress indicated that only the
                                   necessary and appropriate amount of funds be used for administrative
                                   activities. However, the law does not specifically define administrative
                                   activities or set specific limits on administrative spending by school
                                   districts.

                                   We were directed in two separate mandates by the Congress to (1)
                                   examine how school districts defined and spent Title I funds on
                                   administrative activities and (2) review Title I expenditures in at least six
                                   school districts. In response to these mandates, we are reporting on (1)
                                   how five studies define Title I administrative expenditures and what they
                                   found about the percentage of funds spent on these activities and (2) what
                                   proportion of Title I funds was spent on administrative activities compared
                                   with instructional and other activities in six school districts.



                                   1
                                    Throughout this report, we refer to Title I, Part A of the No Child Left Behind Act as “Title
                                   I.” Part A of Title I in the act is directed at improving basic programs operated by local
                                   education agencies, which we refer to as “school districts” in this report.



                                   Page 1                                     GAO-03-386 Title I Administrative Expenditures
                   In response to the first mandate, we examined five studies related to Title I
                   that we found in our literature review which defined school district
                   administrative expenditures and the percentage of funds school districts
                   spent on administration. In response to the second mandate, we
                   conducted site visits in six school districts and gathered information about
                   Title I expenditures to assess what proportion of Title I funding was spent
                   on administrative activities compared with instructional and other
                   activities. We selected six school districts in the following locations to
                   ensure variation in enrollment size, ethnic composition, economic
                   condition, and geographic location: Portsmouth, Rhode Island; Douglas
                   County, Nevada; Jefferson Parish, Louisiana; Indianapolis, Indiana; St.
                   Louis, Missouri; and San Diego, California. Because there is no agreement
                   on a definition of administrative expenditures, in order to compare the six
                   districts, we identified expenditure categories as “administrative” from our
                   analysis of the five studies and consultations with school finance experts.
                   The administrative expense categories include (1) the salaries and fringe
                   benefits of Title I coordinators, managers, and administrative support
                   staff; (2) support expenditures, such as equipment, for staff in category
                   one, and (3) the salaries, fringe benefits and related expenditures for
                   district- and school-level administrative leadership, such as principals. We
                   then broke the districts’ total Title I spending into three subcategories:
                   instruction and instructional support, administration, and other
                   noninstructional activities, such as transportation. Because of the limited
                   number of districts and other factors outlined in appendix I, our findings
                   cannot be generalized to school districts nationwide. (Appendix I explains
                   our methodology in more detail.) We conducted our work between April
                   2002 and January 2003 in accordance with generally accepted government
                   auditing standards.


                   All studies reviewed included the school district Title I coordinator’s
Results in Brief   salary and benefits in their definition of local administrative expenditures,
                   but, beyond this, their definitions varied. For example, professional
                   development activities were included in one definition but not in others.
                   District spending classified as administration in these studies varied, from
                   4 percent to 10 percent.

                   Using a set of administrative expenditure categories developed for this
                   study we found that, in the six school districts we studied, Title I
                   expenditures for administrative activities ranged from 13 percent of total
                   Title I expenditures to no Title I funds spent on administration. However,
                   only in one district did Title I administrative expenditures exceed 10
                   percent. Most Title I funding—at least 84 percent in every district—was


                   Page 2                             GAO-03-386 Title I Administrative Expenditures
             spent on activities related to instruction. However, the amount of Title I
             funds spent on administration reflects school district decisions about how
             expenses for administrative activities are allocated among various
             programs. For example, Portsmouth, Rhode Island, spent no Title I funds
             on administration but conducts Title I administrative activities. The
             district pays for them with local funds, according to district officials. Four
             of the school districts spent a relatively small percentage of their Title I
             funds on other noninstructional expenditures, including student
             transportation, building maintenance, and capital projects. The Title I
             expenditures on administration represent allocation decisions made by the
             six school districts for a particular year and do not represent school
             district spending in other years. Such decisions may change from one
             school year to the next.


             States and localities provide most of the funding for public schools. In the
Background   1998-99 school year, funds from state and local governments accounted for
             93 percent of elementary and secondary school funding. Overall, states
             and localities contribute roughly an equal amount to educational
             programs, although individual state shares vary considerably. For
             example, in 1997, the state share in New Hampshire was 9 percent while in
             New Mexico it was 72 percent. The federal government also provides
             funding for elementary and secondary education, largely through the
             Elementary and Secondary Education Act (ESEA) of 1965.

             The NCLB Act of 2001 reauthorized ESEA. Title I of NCLB is intended to
             help elementary and secondary schools establish and maintain programs
             that will improve the educational opportunities of low-income and
             disadvantaged children. Title I funds are intended to provide instruction
             and instructional support for these disadvantaged children so that they
             can master challenging curricula and meet state standards in core
             academic subjects. Although NCLB incorporated new or expanded
             requirements for the Title I program that related to such issues as
             strengthening accountability for results, it does not stipulate exactly how
             these funds are to be spent. Instead, the Title I program is an example of
             flexible funding for state educational agencies and school districts.

             The Congress intended for most Title I funds to be spent on instruction
             and instructional activities, while limiting other costs, such as those on
             administrative activities. However, Title I does not contain a general
             definition of administrative expenses that school districts must use. Before
             the enactment of NCLB, ESEA required the U.S. Department of Education
             (Education) to conduct a study and report on the use of the funds for


             Page 3                             GAO-03-386 Title I Administrative Expenditures
administration under the act and, based on the results of that study
develop a definition of what types of activities constitute administration.
Within 1 year of the study, which was required to have been completed by
July 1, 1997, Education was required to promulgate final regulations or
guidance regarding the use of funds for administration under ESEA,
including limitations on the amount of funds that may be used for
administration where no limit had been specified in law.2 Education did
not develop a definition of administrative activities or issue regulations or
guidance. However, these requirements were repealed by NCLB.

While Education has not developed a specific definition of administrative
activities for Title I, the agency’s general administrative regulations and
guidance address the issue of how grantees should identify administrative
costs. Education’s general administrative regulations contain a statement
that “administrative requirements mean those matters common to grants
in general, such as financial management, kinds and frequency of reports,
and retention of records. These are distinguished from programmatic
requirements, which concern matters that can be treated only on a
program-by-program or grant-by-grant basis, such as kinds of activities
that can be supported by grants under a particular program.”3 (Emphasis
in original.)

In response to the requirement in the ESEA that Education report on the
results of its study, in 1998 the agency issued The Use of Federal
Education Funds for Administrative Costs, which included a section
entitled “Definitions of Administrative Spending.” The report includes a
discussion of various definitions of administrative costs and activities
described in law and guidance, definitions used by researchers, and
“issues that should be considered in developing a definition of
administrative costs for federal education programs.” The report refers to
prior guidance issued by Education on what constitutes administrative
costs where the term is not otherwise defined in statute or regulation.4
This guidance states that “[t]he costs of administration are those portions
of reasonable, necessary and allowable costs associated with the overall
project management and administration and which are not directly related


2
 P.L. 103-382, title I,§101 (Oct. 20, 1994), amending ESEA. These requirements were
repealed by NCLB.
3
34 C.F.R. §80.3.
4
 U.S. Department of Education, Indirect Cost Determination: Guidance for State and
Local Government Agencies, (Washington, D.C., 1997) pp. 72.




Page 4                                   GAO-03-386 Title I Administrative Expenditures
                               to the provision of services to participants or otherwise allocable to the
                               program cost objectives/categories. These costs can be both personnel and
                               nonpersonnel costs and both direct and indirect.5 (Emphasis in original.)6
                               The guidance provides a list of examples of direct administration such as
                               the salaries, benefits, and other expenses of staff who perform overall
                               program management, program coordination, and office management
                               functions.


                               All five studies we reviewed included the school district Title I
Select Studies Used            coordinator’s salary and benefits in their definition of local administrative
Varying Definitions of         expenditures but, beyond this, the activities categorized as administration
                               varied. District spending on administration in the five studies reviewed
Administrative                 varied from 4 percent to 10 percent. Several factors may contribute to this
Expenditures                   variation, such as the use of different definitions of administrative
                               expenditures or reliance on different data types, such as budget numbers
                               or actual expenditures.


In Five Studies, Definitions   Although they had common elements, the definitions of administrative
of Administrative              expenditures used in the studies we reviewed varied. In all five of the
Expenditures Varied            studies, the salaries and benefits of school district Title I coordinators
                               were considered to be administrative expenditures.7 However, four of the
                               studies used a definition that encompassed more than this. For example,
                               four of the studies also included supplies and equipment to support Title I
                               administration in their definition. Table 1 highlights the similarities and
                               differences among the various definitions of administrative expenditures
                               used in the studies.


                               5
                                Direct expenditures are those that can be specifically identified with a program, such as
                               the salaries and benefits of program administrators. Indirect expenditures are for resources
                               that cannot be specifically identified with a program, such as the portion of expenditures
                               for data processing or accounting that support the program.
                               6
                                While this document is termed “Guidance,” such guidance issued by the agency authorized
                               to administer the program is generally binding in determining the allowability of costs. See
                               California v. U.S., 547 F.2d 1388 (9th Cir. 1977). The overallocation of indirect costs, for
                               example, would be considered unauthorized and, therefore, unallowable. Principles of
                               Federal Appropriations Law, 2nd ed, vol. II, pps. 10-75.
                               7
                                One study we examined did not include a definition of administration in their report.
                               However, researchers used definitions developed by the National Center for Education
                               Statistics when categorizing district expenditures. See table 2 for the center’s definition.
                               This study is: U.S. Department of Education, Planning and Evaluation Service, Study of
                               Education Resources and Federal Funding, (Washington, D.C.: 2000).




                               Page 5                                     GAO-03-386 Title I Administrative Expenditures
                               Table 1: Expenditure Categories Considered to be Title I Administrative
                               Expenditures in Five Selected Studies

                                   Expenditure categories            Study 1a      Study 2b    Study 3c     Study 4d    Study 5e
                                   Salaries and benefits of Title I
                                   coordinators
                                   Supplies and equipment to
                                   support Title I administration
                                   Salaries and benefits of Title I
                                   administrative support staff
                                   Professional development for
                                   Title I coordinators and
                                   administrative support staff
                                   District administration (salaries
                                   and benefits for
                                   superintendents, school
                                   boards, senior administrators,
                                   and other central office staff)
                                   Researchers and program
                                   evaluators
                                   School administration
                                   (principals and assistant
                                   principals)
                                   Business services (payroll,
                                   personnel, purchasing,
                                   accounting, and data
                                   processing)
                                   Furniture, computers and
                                   supplies for school and district
                                   administrators
                                   Legal services
                               Source: GAO analysis.
                               a
                               U.S. Department of Education, Planning and Evaluation Service, Study of Education Resources and
                               Federal Funding. (Washington, D.C.: 2000).
                               b
                               U.S. Department of Education Inspector General, Following Title I, Part A and Secondary School
                               Vocational Education Program Dollars to the Schools in 36 LEAs Visited, (Atlanta, Ga.: 1998).
                               c
                               U.S. Department of Education, Planning and Evaluation Service, Elementary and Secondary
                               Education Division, The Use of Federal Education Funds for Administrative Costs, (Washington, D.C.:
                               1998).
                               d
                                   Abt Associates,Inc. The Chapter 1 Implementation Study, Interim Report, Cambridge, Mass., 1992.
                               e
                               U.S. General Accounting Office, Compensatory Education-Most Chapter 1 Funds in Eight Districts
                               Used for Classroom Services, GAO/HRD-92-136FS (Washington, D.C.: Sept. 30, 1992).


District Spending on Title I   Using different definitions of administrative expenditures, estimates of
Administration Ranged          Title I district spending on administration varied among the five studies
from 4 Percent to 10           that we reviewed (see table 2). The studies generally found that school
                               districts spent between 4 percent and 10 percent of Title I funds on
Percent                        administrative activities. These estimates can also differ from school



                               Page 6                                          GAO-03-386 Title I Administrative Expenditures
                                       district to school district within a single study. For example, Education’s
                                       1998 study of expenditure data from 41 school districts located in 3 states
                                       found that a school district in Milwaukee spent 4 percent of Title I funds
                                       on administrative activities, school districts in South Carolina spent an
                                       average of 6 percent on administrative activities, and school districts in
                                       Rhode Island spent an average of 10 percent on such activities.

Table 2: Summary of Studies Reviewed

                            School     Number of                                                              Estimate of Title I
                            year of       school                                                                   spending on
                               data      districts                                                            administration (in
Study                     reviewed      sampled Definition of administration                                           percent)
U.S. Department of        1997-98             180 Although the study does not develop its own definition                       8
Education, Planning and                            of administration, researchers used definitions
Evaluation Service,                                developed for categorized district data in National
Study of Education                                 Center for Education Statistics guidance contained in
Resources and Federal                              Financial Accounting for Local and State School
Funding                                            Systems.

                                                   The National Center for Education Statistics definition
                                                   includes two types of administration categories: general
                                                   administration and school administration. Both
                                                   categories include salaries, fringe benefits, furniture,
                                                   equipment, and supplies associated with administrative
                                                   activities.

                                                   General administration:
                                                   • Superintendent
                                                   • School board
                                                   • Labor relations and negotiations
                                                   • Central office expenditures for administering special
                                                     programs (e.g., Title I) and other central office
                                                     expenditures
                                                   • Legal services
                                                   • Election services
                                                   • Tax assessment and collection
                                                   • Community relations
                                                   • Grant procurement

                                                   School administration:
                                                   Principal’s office (including vice principals and
                                                   administrative support) and full-time department
                                                   chairpersons.




                                       Page 7                                   GAO-03-386 Title I Administrative Expenditures
                                School    Number of                                                                          Estimate of Title I
                                year of      school                                                                               spending on
                                   data     districts                                                                        administration (in
 Study                        reviewed     sampled Definition of administration                                                       percent)
 U.S. Department of           1996-97              36 Primarily included salaries, related benefits, and                                      6
 Education Inspector                                  professional development for program coordinators and
 General, Following Title                             their administrative staff, as well as any materials and
 I, Part A and Secondary                              equipment used to support administrative functions.
 School Vocational
 Education Program
 Dollars to the Schools in
 36 LEAs Visited
 U.S. Department of           1995-96             41 Based on Coopers & Lybrand Financial Analysis Model                                      4-10
 Education, Planning and                             [currently called the In$ite model]. Divided
 Evaluation Service,                                 administration into three categories: district and school
 Elementary and                                      administration and business services. Each of these
 Secondary Education                                 three categories includes salaries and fringe benefits
 Division, The Use of                                for administrative staff as well as non-personnel costs
 Federal Education                                   such as furniture, computers, and supplies. District
 Funds for Administrative                            administration includes superintendents, school boards,
 Costs                                               senior administrators, legal services, research and
                                                     program evaluators, and other central office staff.
                                                     School administration includes principals and assistant
                                                     principals. Business services include payroll,
                                                     purchasing, personnel, accounting, and data
                                                     processing. For federal education programs,
                                                     administrative costs will typically include salaries and
                                                     expenses for district and school level federal program
                                                     coordinators.
 Abt Associates, Inc. The     1990-91          1,600 Salaries and benefits for Title I administrators, including                                  4
 Chapter 1                                           district staff.
 Implementation Study,
 Interim Report
 U.S. General Accounting      1990-91               8 Primarily salaries and benefits for Title I coordinators                                   10
 Office, Compensatory                                 and administrative staff, as well as supplies and
 Education-Most Chapter                               equipment used to support the program.
 1 Funds in Eight Districts
 Used for Classroom
 Services, GAO/HRD-92-
 136FS
Source: GAO analysis.
                                          A
                                           The term “Chapter 1” was used until the 1994 reauthorization of ESEA to refer to what is now Title I.
                                          For clarity, this report will refer to the program as Title I even when discussing data collected prior to
                                          the 1994 reauthorization.


                                          Several factors, such as different definitions of administration or data
                                          types, may have contributed to the variety of findings among the studies
                                          we reviewed. The study that found that school districts were using the
                                          smallest percent of Title I funds for administration used the most limited
                                          definition of administration, only including the salaries and benefits of
                                          Title I administrators. Also, the scope of the studies differed. Two studies
                                          produced national estimates by reviewing a large number of school


                                          Page 8                                           GAO-03-386 Title I Administrative Expenditures
                             districts nationwide, while the other three selected fewer school districts,
                             and the findings were not generalizable to school districts nationwide. In
                             addition, the studies’ data types for estimating administration spending
                             were not the same. For example, two studies based their findings on
                             budget estimates provided by school districts while the other three studies
                             used expenditure reports from school districts. Finally, the studies
                             reviewed expenditure data from different school years.


In Six School Districts We   The six school districts that we studied used different definitions of
Studied, Definitions of      administrative expenditures, in part because of differing state and local
Administrative               requirements or practices. As a result, expenditures may be accounted for
                             in different ways across the school districts we studied. Local officials in
Expenditures Varied          all six school districts agreed that salaries and benefits of Title I
                             coordinators, managers, and administrative support staff who are engaged
                             in basic program operation and management, such as office administration
                             and program coordination, were administrative. However, beyond this,
                             what district officials counted as administrative expenditures varied. For
                             example, St. Louis school district officials considered staff time dedicated
                             to the professional development of teachers as administration, while
                             school district officials in Jefferson Parish, La., did not.

                             In some cases, states may develop definitions of Title I administrative
                             expenditures for school districts to limit the amount charged to the
                             program for administration. Varying state accounting requirements and
                             use of different state accounting handbooks may influence the
                             characteristics of school district expenditure data. Two of the school
                             districts we visited described state requirements that affect how school
                             districts define and track expenditures in their state. For example, as part
                             of the Title I application process, the state of Indiana encouraged school
                             districts to reserve a maximum of 4 percent for administration and a
                             minimum of 62 percent for instruction.8 Taking a slightly different
                             approach, the state of California education code directs school districts to
                             spend at least 85 percent of their Title I allocation at schools for direct
                             services to students, thereby limiting the amount that can be spent on
                             other activities, including administration.9




                             8
                             Title I Application Review Questions, Indiana Department of Education.
                             9
                             California Education Code sec. 63001 (2000).




                             Page 9                                  GAO-03-386 Title I Administrative Expenditures
                             Because there is no common agreement on what constitutes
The Proportion of            administrative expenditures, we identified a set of expenditure categories
Title I Funding Spent        as “administrative” for the purposes of this study and found that, in the six
                             school districts, Title I expenditures for administrative activities ranged
on Administrative            from 0 percent to 13 percent of total Title I expenditures for the 2000-01
Activities Varied, but       school year.10 However, only in one district did Title I administrative
                             expenditures exceed 10 percent. Most Title I expenditures—at least 84
Most School Districts        percent in every district—were spent on instructional activities.
Spent Less Than 10           Instructional expenditures include spending on instruction and
Percent                      instructional support. Spending on instruction included the salaries of
                             instructional teachers, paraprofessionals and substitutes. Spending on
                             instructional support included classroom materials and pupil and teacher
                             support.

                             Administration for the purposes of this study include the following
                             expenditure categories that we developed:

                             •    The salaries and fringe benefits of Title I coordinators, managers, and
                                  administrative support staff who are engaged in basic program
                                  operation and management, such as office administration and program
                                  coordination.

                             •    The related expenditures of coordinators, managers, and
                                  administrative support staff of Title I, such as equipment, supplies,
                                  furniture and business services required to support the administrative
                                  function, and auditing and legal services and data processing.

                             •    Salaries, fringe benefits, and related indirect expenditures for district
                                  or school-level administrative leadership (including school board,
                                  superintendent, superintendent’s cabinet, school principal, and vice
                                  principal) involved in directing and supervising staff who are providing
                                  instruction or instruction-related services for Title I programs.

The Proportion of Title I    In the six school districts, the proportion of Title I funding spent on
Funding Spent on             administrative activities varied, though most Title I funds were spent on
Administration Varied        instruction and instructional support. Of the six school districts, San Diego
                             spent the largest percentage of Title I funds on administration (13
among Six School Districts   percent), while Portsmouth, Rhode Island, spent none of its Title I funds


                             10
                              Expenditure data from five of the six districts are from the 2000-01 school year.
                             Expenditure data from Indianapolis, however, are from calendar year 2000. Hereafter, we
                             will refer to the year of our data collection as school year 2000-01.




                             Page 10                                 GAO-03-386 Title I Administrative Expenditures
on administration. Title I expenditures on administration represent
allocation decisions made by the six school districts for a particular year.
The amount of Title I funds spent on administration reflects school district
decisions about what funds to use for administrative activities and not
necessarily how much total funding was dedicated to the administration of
Title I. For example, the Portsmouth school district does conduct Title I
administrative activities, but pays for them with local funds. In all six
school districts, the share of total Title I spending on administration was
less than the share of total district spending on administration (see fig. 1).

Figure 1: Percents of Total Title I and Total School District Expenditures Spent on
Administration, School Year 2000-01




Note: Expenditure data from Indianapolis are from calendar year 2000.




Page 11                                      GAO-03-386 Title I Administrative Expenditures
                                                          Though they spent different percentages of their Title I funds on
                                                          administration, the types of administrative activities the six school
                                                          districts chose to pay for with Title I funds were similar. In five of the six
                                                          school districts, Title I coordinators were funded by Title I during the
                                                          2000-01 school year. In all but the Portsmouth school district, Title I funds
                                                          supported other district staff with Title I responsibilities, such as staff who
                                                          provided technical assistance to the schools in specific areas such as
                                                          finance, professional development, and technology. None of the school
                                                          districts we visited used Title I funds to pay for activities by principals and
                                                          vice principals.


Most Title I Funds Were                                   In all six school districts, most Title I funding was spent on activities
Spent on Activities Related                               related to instruction. Each school district spent at least 84 percent of its
to Instruction                                            Title I funds on instruction and instructional support (see table 3). (See
                                                          appendix I for details on what constitutes each type of expenditure.)

Table 3: Proportion of Title I Spending by Type of Expenditure, School Year 2000-01, by Size of Title I Expenditures

                                                                   Instructional          Administration                      Other noninstructional
                                         Total Title I                 Instructional
 School district                       expenditures      Instruction        support Total          Total                   Operations         Other     Total
 Portsmouth, R.I.                          $110,912            100%              0% 100%              0%                           0%           0%        0%
 Douglas County, Nev.                      $377,233             85%              8%  93%              7%                           0%           0%        0%
 Jefferson Parish, La.                   $9,096,895             71%             14%  85%              6%                           4%           5%        9%
 Indianapolis, Ind.                     $15,060,344             57%             27%  84%              3%                           0%          12%       12%
 St. Louis, Mo.                         $18,658,131             81%              8% 90%               8%                           0%           2%        2%
 San Diego, Calif.                      $32,547,153             57%             28%  85%            13%                            0%           2%        2%
Source: GAO’s data analysis of Title I spending.

                                                          Notes: (1) Percentages do not represent total district spending on instructional, administrative, and
                                                          other noninstructional activities. (2) Percentages reflect local Title I allocation decisions and not
                                                          necessarily total expenditures in those spending categories, as state and local funds my be used in
                                                          addition to or in place of Title I funds in any category. (3) The proportions of Title I funding spent on
                                                          various activities reflect the decisions and circumstances of school districts for a particular year and
                                                          do not represent school district spending in other years. (4) The proportion of Title I expenditures
                                                          spent on instructional, administrative, and other noninstructional activities take into account direct and
                                                          indirect expenditures. (For more information about how indirect expenditures were included in the
                                                          analysis, see appendix I.) (5) Total Instructional, Administration, and Other Noninstructional
                                                          percentages of total Title I expenditures may not sum to 100 percent due to rounding. (6) Expenditure
                                                          data from Indianapolis are from calendar year 2000.


                                                          In addition, four of the school districts spent a relatively small percentage
                                                          of their Title I funds on other noninstructional expenditures, such as out-
                                                          of-district obligations, student transportation, building maintenance, and
                                                          capital projects. Indianapolis spent the largest proportion of Title I funds




                                                          Page 12                                         GAO-03-386 Title I Administrative Expenditures
on other noninstructional expenditures, a majority of which were Title I
payments to parochial, private, and charter schools.11

Title I funds were used to support staff in all of the school districts we
studied. Table 4 provides the number of full-time equivalent teachers and
teacher aides and other district staff funded by Title I as compared with
the total full-time equivalent staff working in the school district. Title I
staff represented between less than 1 percent and about 7 percent of total
staff in the school districts. In districts with the smallest Title I grants,
other district staff were funded only partially or not at all with the Title I
grant. However, in the districts with the largest grants, other district staff,
such Title I coordinators, were funded entirely by Title I.

Table 4: Number of Full-Time Equivalent Staff Funded by Title I and the Total Staff
in the School Districts, School Year 2000-01

                                                     Funded by Title I
                                           Teachers &                                   Total district
    School district                      teacher aides Other staff       Total staff             staff
    Portsmouth, R.I.                              2.33         0.00            2.33           345.50
    Douglas County, Nev.                          4.80         0.30            5.10           599.00
                                                                                                     a
    Jefferson Parish. La.                      220.60         43.80         264.40             7,913
                                                                                                     a
    Indianapolis, Ind.                         205.68         56.49         262.17             5,800
    St. Louis, Mo.                             329.50         96.50         426.00          6,324.00
    San Diego, Calif.                          175.17        126.09         301.26         15,059.49
Source: GAO’s analysis of school district staffing.
a
 Total district staff for Jefferson Parish and Indianapolis represents the number of employees rather
than full-time equivalent staff.
The proportions of Title I funding spent on various activities reflect the
decisions and circumstances of school districts for a particular year. For
example, in school year 2000-01 San Diego invested in teacher training in
literacy at the start of a districtwide reform effort, which accounts for
much of the high proportion (28 percent) spent on instructional support in
that year. Similarly, Indianapolis spent 27 percent on instructional support
in calendar year 2000, investing in pupil, teacher, and program support.

Some school district officials noted that spending decisions might change
in the future due to new federal requirements. They pointed out that a



11
 These payments may be used for instructional activities in parochial, private, or charter
schools. However, because these payments are not for instruction at public schools they
are, therefore, categorized as other noninstructional expenditures.




Page 13                                                GAO-03-386 Title I Administrative Expenditures
                  larger proportion of Title I funds may be needed for administrative and
                  other noninstructional activities due to new requirements in the NCLB Act.
                  For example, officials from two school districts said that the
                  implementation of the school choice provisions in NCLB may increase
                  transportation costs. A new requirement in NCLB stipulates that school
                  districts must offer students in Title I schools that do not perform
                  adequately for 2 consecutive years the option of transferring to another
                  public school. School districts must provide transportation for, or pay the
                  transportation costs of, the students who choose this option.


                  This report provides insights from studies about administrative
Concluding        expenditures and a snapshot of Title I expenditures in six school districts
Observations      for 1 year. Although definitions of administrative expenditures varied, the
                  studies and our work in six districts suggest that despite the flexibility
                  school districts have in the use of these federal funds, they limited Title I
                  spending for administration and spent most Title I funds on instruction.


                  We received comments from Education on a draft of this report, which are
Agency Comments   reprinted in appendix II. Education found the report to be informative and
                  noted that the report should be useful to the Congress, Education itself,
                  and state and local grantees.


                  We are sending copies of this report to the Secretary of Education,
                  appropriate congressional committees, and other interested parties.
                  Copies will also be made available at no charge on GAO’s Web site at
                  http://www.gao.gov. If you or your staff have any questions or wish to
                  discuss this material further, please call me at (202) 512-7215.

                  Marnie S. Shaul




                  Director, Education, Workforce,
                   and Income Security Issues




                  Page 14                            GAO-03-386 Title I Administrative Expenditures
                    Appendix I: Scope and Methodology
Appendix I: Scope and Methodology


                    The objectives of our review were to report on (1) how five studies define
Objectives          Title I administrative expenditures and what they found about the
                    percentage of funds spent on these activities and (2) what proportion of
                    Title I funds was spent on administrative activities compared with
                    instructional and other activities in six school districts.


                    To assess how selected studies define Title I administrative expenditures,
Scope and           we conducted a literature review of studies and reports related to Title I
Methodology         and what they found about the percentage of funds spent on these
                    activities. Each of these studies included an estimate of the percentage of
                    Title I funds that school districts spent on administrative activities.
                    Because there is no common agreement on what constitutes
                    administrative expenditures, for the purposes of this study, we identified a
                    set of expenditure categories as “administrative” based on federal
                    guidance, previous studies, and interviews with subject matter experts. To
                    assess what proportion of Title I funding specific school districts spent on
                    administrative activities compared with instructional and other activities,
                    we conducted site visits to five school districts and telephone interviews
                    with officials from an additional school district. We gathered information
                    about Title I administrative expenditures for the 2000-01 school year1 and
                    analyses of expenditure reports from six school districts. Officials in six
                    school districts we surveyed provided us with feedback on which of our
                    three expenditure categories they considered to be administrative
                    expenditures. We contracted with a consulting firm to analyze school
                    district Title I expenditures using the three expenditure categories. Due to
                    the limited number of districts, however, our findings cannot be
                    generalized to school districts nationwide. We conducted our review
                    between April 2002 and January 2003 in accordance with generally
                    accepted government auditing standards.


Literature Review   To assess how selected studies define Title I administrative expenditures,
                    we conducted a literature review of studies and reports related to Title I.
                    Literature was gathered by conducting bibliographic searches of major
                    educational databases2 and through consultation with experts in school


                    1
                    Expenditure data from five of the six districts are from the 2000-01 school year.
                    Expenditure data from Indianapolis, however, are from calendar year 2000. Hereafter, we
                    will refer to the year of our data collection as school year 2000-01.
                    2
                    Databases searched include Pro Quest, Education Resource Information Center, and the
                    Database of Department of Education Publications in ERIC.



                    Page 15                                 GAO-03-386 Title I Administrative Expenditures
              Appendix I: Scope and Methodology




              finance. We examined five studies that met the following criteria: (1)
              included data on school district Title I spending on administration; (2)
              reviewed school districts located in more than one state; and (3) was
              published after 1990. Each of the studies reviewed included an estimate of
              the percentage of Title I funds that school districts spent on administrative
              activities. The studies we examined include:

              •   U.S. Department of Education, Planning and Evaluation Service, Study
                  of Education Resources and Federal Funding (Washington, D.C.:
                  2000).

              •   U.S. Department of Education Office of Inspector General, Following
                  Title I, Part A and Secondary School Vocational Education Program
                  Dollars to the Schools in 36 LEAs Visited (Atlanta, Ga.: 1998).

              •   U.S. Department of Education, Planning and Evaluation Service,
                  Elementary and Secondary Education Division, The Use of Federal
                  Education Funds for Administrative Costs (Washington, D.C.: 1998).

              •   Abt Associates Inc., The Chapter 1 Implementation Study, Interim
                  Report (Cambridge, Mass.: 1992).

              •   U.S. General Accounting Office, Compensatory Education-Most
                  Chapter 1 Funds in Eight Districts Used for Classroom Services,
                  GAO/HRD-92-136FS (Washington, D.C.: Sept. 30, 1992).


Site Visits   To assess what proportion of Title I funding spent by specific school
              districts on administrative activities compared with instructional and other
              activities, we gathered information about Title I administrative
              expenditures for the 2000-01 school year through site visits to five school
              districts and analysis of their expenditure reports. We gathered
              information about a sixth school district through telephone interviews
              with district officials and analysis of its expenditure reports.

              We selected the school districts based on the characteristics described in
              our congressional mandates, including variation in enrollment size, ethnic
              composition, economic condition, and geographic location. We also
              considered the ability of the consultant to analyze the expenditures of
              school districts selected. All school districts, with the exception of San
              Diego, California, used a financial reporting model called In$ite, which is
              used by Fox River Learning, the consulting firm we worked with to
              categorize expenditures. Although the school district did not use the



              Page 16                             GAO-03-386 Title I Administrative Expenditures
                            Appendix I: Scope and Methodology




                            model, we selected San Diego because it added to the geographic
                            dispersion of the sample and represented a large metropolitan area. See
                            table 5 for characteristics of the school districts selected. In addition to
                            San Diego, we selected school districts in the following locations:
                            Portsmouth, Rhode Island; Douglas County, Nevada; Jefferson Parish,
                            Louisiana; Indianapolis, Indiana; and St. Louis, Missouri. Because of the
                            limited number of districts selected, our findings cannot be generalized to
                            school districts nationwide.

                            Table 5: Characteristics of School Districts Selected, School Year 2000-01

                                                                                                                                         % Eligible for
                                                                      Student                                      % Minority            free/reduced
                             School district                       enrollment Locale & region                      enrollment              price lunch
                             Portsmouth, R.I.                            2,869 Small town,                                4%                        7%
                                                                               northeast
                             Douglas County, Nev.                        7,022 Rural, west                                   14%                        21%
                             Jefferson Parish, La.                     51,413 Urban fringe of a                              61%                        68%
                                                                               large city, south
                             Indianapolis, Ind.                        41,108 Large central                                  68%                        76%
                                                                               city, midwest
                             St. Louis, Mo.                            41,400 Large central                                  83%                        83%
                                                                               city, midwest
                             San Diego, Calif.                        141,804 Large central                                  73%                        62%
                                                                               city, west
                            Source: Locale and region from National Center for Education Statistics Common Core of Data. Student enrollment, percent minority
                            enrollment, percent eligible for free and reduced price lunch reported by the school districts for school year 2000-01.



Our Categorization of       To compare the six school districts, we identified a set of expenditure
Administrative Activities   categories as “administrative,” based on federal guidance, previous
                            studies, and interviews with experts in school finance.3 We identified those
                            administrative activities mentioned most frequently by experts or
                            identified in the documents we reviewed. See table 6, which illustrates
                            which of these three categories each district included in its definition of
                            Title I administrative expenditures.

                            During our interviews, school district officials stated whether they
                            considered our three categories of expenditures to be administrative



                            3
                             We consulted with the following school finance experts: Dr. Lawrence Picus, University of
                            Southern California; Dr. Jay Chambers, American Institutes for Research; Stephanie
                            Stullich, Planning and Evaluation Service, U.S. Department of Education; Dr. Donald
                            Tetreault, University of South Carolina; and Dr. William Fowler, National Center for
                            Education Statistics, U.S. Department of Education.




                            Page 17                                                     GAO-03-386 Title I Administrative Expenditures
                                          Appendix I: Scope and Methodology




                                          expenditures under the program. School district officials in all six school
                                          districts agreed that salaries and benefits of Title I coordinators and
                                          administrative support staff were administrative expenditures under the
                                          Title I program. However, agreement on the other two categories of
                                          expenditures was not unanimous.

Table 6: Six School Districts’ Views of Whether Three Categories of Expenditures Are Title I Administrative Expenditures

                                                                      Three categories of expenditures
                                            Category 1                              Category 2                       Category 3
                                The salaries and fringe benefits        The related costs of             Salaries, fringe benefits, and
                                                       a
                                of Title I coordinators                 coordinators, managers, and      related indirect expenditures
                                managers and administrative             administrative support staff of  for district or school level
                                support staff who are engaged           Title I, such as equipment,      administrative leadership
                                in basic program operation and          supplies, furniture and business (including school board,
                                management, such as office              services required to support the superintendent, school
                                administration and program              administrative function, and     principal, and vice principal)
                                coordination.                           auditing and legal services and involved in directing and
                                                                        data processing.                 supervising staff who are
                                                                                                         providing instruction or
                                                                                                         instruction-related services for
                                                                                                         Title I programs.

 School district
                                                                              b                                      b ,e
 Portsmouth, R.I.               Yes                                      Yes, with exceptions                  Yes, with exceptions
 Douglas County, Nev.           Yes                                      No                                    No
 Jefferson Parish, La.          Yes                                      Yes                                   Yes,c with exceptions
                                                                                                                    d,e
 Indianapolis, Ind.             Yes                                      Yes                                   Yes, with exceptions
                                                                                                                  e
 St. Louis, Mo.                 Yes                                      Yes                                   Yes
 San Diego, Calif.              Yes                                      Yes                                   No
Source: GAO analysis.
                                          a
                                           For these categories, Title I coordinators are responsible for managing the Title I program for the
                                          district and are equivalent to managers or directors.
                                          b
                                           Portsmouth agreed with Category 2, with the exception of coordinators and managers, and Category
                                          3, with the exception of school board.
                                          c
                                              Jefferson Parish agreed with Category 3, with the exception of school principals and vice principals.
                                          d
                                              Indianapolis agreed with Category 3, with the exception of school board and superintendent.
                                          e
                                           Although Portsmouth, Indianapolis, and St. Louis considered expenditures associated with principals
                                          and vice principals to be allowable Title I expenditures, none charged any of their salaries to Title I in
                                          2000-01.




                                          Table 7 summarizes how we classified instructional, administrative, and
                                          other noninstructional expenditures for this study.




                                          Page 18                                           GAO-03-386 Title I Administrative Expenditures
                            Appendix I: Scope and Methodology




                            Table 7: Description of Instructional, Administrative, and Other Noninstructional
                            Expenditures Used in This Study

                             Expenditure               Activities
                             Instructional
                             Instruction               •   Face-to-face teaching (salaries of instructional teachers
                                                           and paraprofessionals, substitutes)

                             Instructional support     •   Classroom materials (pupil-use technology and software;
                                                           instructional materials, trips, and supplies).
                                                       •   Pupil support (guidance and counseling; library and
                                                           media; extracurricular; and student health and services).
                                                       •   Teacher support (curriculum development; in-service,
                                                           staff development and support; and sabbaticals).

                             Administrative            •   The salaries and fringe benefits of Title I coordinators,
                                                           managers, and administrative support staff who are
                                                           engaged in basic program operation and management,
                                                           such as office administration and program coordination.
                                                       •   The related expenditures of coordinators, managers, and
                                                           administrative support staff of Title I, such as equipment,
                                                           supplies, furniture, and business services (auditing, legal
                                                           services, and data processing) required to support the
                                                           administrative function.
                                                       •   Salaries, fringe benefits, and related indirect expenditures
                                                           for district or school level administrative leadership
                                                           (including school board, superintendent, superintendent’s
                                                           cabinet, school principal, and vice principal) involved in
                                                           directing and supervising staff who are providing
                                                           instruction or instruction-related services for Title I
                                                           programs.

                             Other noninstructional    •   Noninstructional pupil services (transportation, food
                             (operations + other           service, and safety).
                             commitments)              •   Facilities (building upkeep, utilities, and maintenance).
                                                       •   Budgeted contingencies.
                                                       •   Capital (debt service and capital projects).
                                                       •   Out-of-district obligations (parochial, private, charter and
                                                           public school pass through; retiree benefits;
                                                           enterprise/community service operations).
                                                       •   Legal obligations (claims and settlements).

                            Source: GAO analysis.



Education Consulting Firm   To expedite data collection and analysis, we contracted with a consulting
Contract                    firm selected via a competitive bidding process to analyze school district
                            Title I expenditures. The expenditure reports were produced by Fox River
                            Learning, an education consulting firm using their analytical tool, the
                            In$ite model, formerly known as the Coopers and Lybrand Finance
                            Analysis Model. The model is used by 400 school districts across the
                            country. Five of the six school districts we selected for this study used the



                            Page 19                                  GAO-03-386 Title I Administrative Expenditures
Appendix I: Scope and Methodology




model in the past for a variety of purposes, such as calculating the cost per
student by school and identifying the proportion of funds spent on
instruction and schools with the greatest needs. One school district, San
Diego, did not use the model, but the consultant worked with the district
to categorize its Title I expenditures using the model. Table 8 shows how
our set of administrative expenditure categories relates to the model.

Table 8: GAO Categories of Administrative Expenditures Compared with In$ite
Administration-Related Expenditure Categories

 GAO categories of administrative             In$ite model administration-related
 expenditures                                 expenditure categories
 The salaries and fringe benefits of Title    Program development/management
 I coordinators, managers, and                Salaries and related employment costs of staff
 administrative support staff who are         who manage and coordinate the Title I
 engaged in basic program operation           program. Includes office costs and clerical
 and management, such as office               costs associated with the administrator’s
 administration and program                   activities.
 coordination.

 The related expenditures of                  Business services
 coordinators, managers, and                  Salaries and related employment costs
 administrative support staff of Title I,     associated with data processing, payroll,
 such as equipment, supplies, furniture,      human resources, accounting and finance,
 and business services required to            auditing, and procurement.
 support the administrative function, and
 auditing and legal services and data
 processing.

 Salaries, fringe benefits, and related       School management
 indirect expenditures for district or        Salaries and related employment costs of
 school-level administrative leadership       principals, assistant principals, and
 (including school board,                     administrative support staff for the principal and
 superintendent, superintendent’s             assistant principals.
 cabinet, school principal, and vice
 principal) involved in directing and         District management
 supervising staff who are providing          Salaries and related employment costs of the
 instruction or instruction-related           superintendent, the superintendent’s cabinet
 services for Title I programs.               (deputies, senior administrators, researchers,
                                              and program evaluators), the school board, and
                                              the legal department.

Source: GAO analysis.


We did not verify the reliability of the data collected from school districts
that were entered into the model. However, to assess the accuracy of the
data school districts provided to the consultant, we reviewed the district’s
most recent independent audit report related to the internal control
structure. These reports did not disclose any material weaknesses in




Page 20                                      GAO-03-386 Title I Administrative Expenditures
                      Appendix I: Scope and Methodology




                      internal controls. In addition, all school districts reported how they
                      monitored Title I funds spent at the school level.

                      We did not verify the reliability of the expenditure reports. However, we
                      took steps to ensure the reliability of the consulting firm, including
                      interviewing a current and a former user of the firm’s model and reviewing
                      descriptions of the process the firm uses to input, categorize, and perform
                      quality assurance on the data provided by school districts. The U.S.
                      Department of Education worked with this finance analysis model when it
                      was known as the Coopers and Lybrand Finance Analysis Model. In
                      addition, all six school districts confirmed that the data from the
                      expenditure reports included in this report were accurate.


Indirect Cost Rates   The proportion of Title I expenditures spent on instructional,
                      administrative, and other noninstructional activities take into account
                      direct and indirect expenditures. Direct expenditures are those that can be
                      specifically identified with a program, such as the salaries and benefits of
                      program administrators. Indirect expenditures are those that cannot be
                      specifically identified with a program, such as general administrative
                      services.

                      The indirect cost rate represents the ratio of the school district’s total
                      indirect costs to some element of its direct costs. The rates are calculated
                      by state education agencies using a methodology that is approved by
                      Education. Indirect cost rates may vary among school districts due to
                      differing financial management and accounting policies. It is difficult to
                      compare indirect cost rates among school districts. Under Title I, school
                      districts must use a restricted indirect cost rate, which is a rate that does
                      not include state and local costs that would be incurred with or without
                      the existence of the federal program.

                      Administrative expenditures were determined by adding the indirect
                      administrative expenditures to the direct administrative expenditures.
                      During the 2000-01 school year or fiscal year, three of the six school
                      districts we reviewed did not charge indirect costs to Title I. For example,
                      in Portsmouth, Rhode Island, district officials said that they used their
                      allocation solely for salaries of teachers and teacher aides, leaving no
                      additional dollars to charge to Title I. Three school districts, San Diego,
                      Douglas County, and Indianapolis, did charge indirect costs to Title I. The
                      indirect cost rates used by these school districts during the 2000-01 school
                      year or fiscal year were 4.15 percent, 2.60 percent, and 2.01 percent
                      applied to direct expenditures, respectively. Since accounting for indirect


                      Page 21                             GAO-03-386 Title I Administrative Expenditures
Appendix I: Scope and Methodology




expenditures varies among school districts, the consultant worked with
school district officials to determine the category most appropriate for
indirect expenditures.




Page 22                             GAO-03-386 Title I Administrative Expenditures
              Appendix II: Comments from the U.S.
Appendix II: Comments from the U.S.
              Department of Education



Department of Education




              Page 23                               GAO-03-386 Title I Administrative Expenditures
                  Appendix III: GAO Contacts and Staff
Appendix III: GAO Contacts and Staff
                  Acknowledgments



Acknowledgments

                  Eleanor L. Johnson, (202) 512-7209
Contacts
                  In addition to the staff named above, Virginia Vanderlinde and Catherine
Acknowledgments   Roark made major contributions in leading and staffing this assignment.
                  Julianne Hartman-Cutts and Corinna Nicolaou also made key
                  contributions to this report.




(130147)
                               Page 24                   GAO-03-386 Title I Administrative Expenditures
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