oversight

No Child Left Behind Act: More Information Would Help States Determine Which Teachers Are Highly Qualified

Published by the Government Accountability Office on 2003-07-17.

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

             United States General Accounting Office

GAO          Report to Congressional Requesters




July 2003
             NO CHILD LEFT
             BEHIND ACT

             More Information
             Would Help States
             Determine Which
             Teachers Are Highly
             Qualified




GAO-03-631
                                                 July 2003


                                                 NO CHILD LEFT BEHIND ACT

                                                 More Information Would Help States
Highlights of GAO-03-631, a report to            Determine Which Teachers Are Highly
Congressional Requesters
                                                 Qualified



In December 2001, Congress                       GAO could not develop reliable data on the number of highly qualified
passed the No Child Left Behind                  teachers because states did not have the information needed to determine
Act (NCLBA). The act required that               whether all teachers met the criteria. Officials from 8 states visited said they
all teachers of core subjects be                 did not have the information they needed to develop methods to evaluate
highly qualified by the end of the               current teachers’ subject area knowledge and the criteria for some teachers
2005-06 school year and provided
funding to help states and districts
                                                 were not issued until December 2002. Officials from 7 of 8 states visited said
meet the requirement. In general,                they did not have data systems that could track teacher qualifications for
the act requires that teachers have              each core subject they teach.
a bachelor’s degree, meet full state
certification, and demonstrate
subject area knowledge for every
core subject they teach. This
report focuses on the (1) number of
teachers who met the highly
qualified criteria during the 2002-03
school year, (2) conditions that
hinder states’ and districts’ ability
to meet the requirement, and (3)
activities on which states and
districts were planning to spend
their Title II funds. GAO surveyed
50 states and the District of
Columbia and a nationally
representative sample of districts
about their plans to implement the
requirement. GAO also visited and
interviewed officials in 8 states and            Source: U.S. Department of Education.
16 districts to discuss their efforts
to implement the law.                            Both state and district officials cited many conditions in the GAO survey that
                                                 hinder their ability to have all highly qualified teachers. State and district
                                                 officials reported teacher pay issues, such as low salaries and lack of
                                                 incentive pay, teacher shortages, and other issues as hindrances. GAO’s
To help states determine which                   survey estimates show that significantly more high-poverty than low-poverty
teachers are highly qualified and                districts reported hindrances, such as little support for new teachers. Rural
the actions they need to take to                 district officials cited hindrances related to their size and isolated locations.
meet the requirement, GAO                        State officials reported they needed assistance or information from
recommends that the Secretary of
                                                 Education, such as in developing incentives to teach in high-poverty schools,
Education provide more
information to states, especially on             and Education’s strategic plan addresses some of these needs.
ways to evaluate the subject area
knowledge of current teachers. The               To help meet the requirement for highly qualified teachers, state survey
Department of Education provided                 respondents reported they planned to spend about 65 percent of their Title II
written comments on a draft of this              funds on professional development activities authorized under Title II, and
report and generally agreed with                 districts planned to spend an estimated 66 percent on recruitment and
GAO’s recommendation.                            retention. Both state and district officials planned to spend much larger
 www.gao.gov/cgi-bin/getrpt?GAO-03-631.          amounts of funds from sources other than Title II funds on such activities.
                                                 High-poverty districts planned to spend more Title II funds on recruitment
 To view the full product, including the scope
 and methodology, click on the link above.       and retention than low-poverty districts. State and district officials visited
 For more information, contact Marnie S.         said that most activities were a continuation of those begun previously.
 Shaul, 512-7215, shaulm@gao.gov.
Contents


Letter                                                                                    1
               Results in Brief                                                           2
               Background                                                                 5
               Many States Were Uncertain about Numbers of Highly Qualified
                 Teachers                                                               10
               State and District Officials Reported Many Conditions as
                 Hindrances to Meeting the Law                                          13
               To Help Teachers Meet the Requirement States Planned to Spend
                 Most Title II Funds on Professional Development Activities, and
                 Districts Will Spend Most on Recruitment and Retention
                 Activities                                                             23
               Conclusions                                                              29
               Recommendation for Executive Action                                      29
               Agency Comments and Our Evaluation                                       29

Appendix I     Scope and Methodology                                                    31



Appendix II    Activities on Which States Can Spend Title II, Part A
               Funds                                                                    37



Appendix III   Activities on Which Districts Can Spend Title II,
               Part A Funds                                                             38



Appendix IV    Comments from the U.S. Department of Education                           39



Appendix V     GAO Contacts and Staff Acknowledgments                                   42
               GAO Contacts                                                             42
               Staff Acknowledgments                                                    42




               Page i                                       GAO-03-631 No Child Left Behind
Tables

          Table 1: Federal Criteria for a Highly Qualified Teacher                    7
          Table 2: Estimated Percentages of Districts That Will Have
                   Difficulty Meeting the Requirement for Highly Qualified
                   Teachers by Grade Level and Poverty                              12
          Table 3: Number of States Reporting on Conditions That Hinder
                   Their Ability to Meet the Requirement for Highly Qualified
                   Teachers (Ranked from Highest to Lowest)                         17
          Table 4: Estimated Percentages of Districts Reporting on
                   Conditions That Hinder Their Ability to Meet the
                   Requirement for Highly Qualified Teachers (Ranked from
                   Highest to Lowest)                                               19
          Table 5: Estimated Percentages of High- and Low-Poverty Districts
                   with Significant Differences in the Hindrances to Meeting
                   the Requirement                                                  21
          Table 6: Estimated Percent of Spending Title II Funds by Activities
                   for All Districts, High-Poverty Districts, and Low-Poverty
                   Districts                                                        26
          Table 7: Population and Sample by Stratum                                 32
          Table 8: Sample Estimates Compared to Population Values                   34
          Table 9: Population and Sample by Region                                  35
          Table 10: Title II, Part A State Activities                               37
          Table 11: Title II, Part A District Activities                            38


Figures

          Figure 1: Education’s Assistance to States During Calendar Year
                   2002                                                              9
          Figure 2: Planned Spending of Title II Funds by Reporting States          24
          Figure 3: Sources of Funds for Planned Spending by States on Title
                   II Activities                                                    25
          Figure 4: Estimated Spending of Title II Funds as a Percentage of
                   Total Funds by Activities for All Districts, High-Poverty
                   Districts, and Low-Poverty Districts                             28
          Figure 5: State Survey Respondents                                        31




          Page ii                                       GAO-03-631 No Child Left Behind
Abbreviations

CCD                        Core of Common Data
CCSSO                      Council of Chief State School Officers
CMSA                       Consolidated Metropolitan Statistical Area
LEA                        Local Education Agency
MSA                        Metropolitan Statistical Area
NCLBA                      No Child Left Behind Act




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Page iii                                                GAO-03-631 No Child Left Behind
United States General Accounting Office
Washington, DC 20548




                                   July 17, 2003

                                   The Honorable Edward M. Kennedy
                                   The Honorable Jeff Bingaman
                                   United States Senate

                                   In December 2001, Congress passed the No Child Left Behind Act
                                   (NCLBA), which, among other things, focused attention on closing the
                                   achievement gaps among various groups of students. Recently, a body of
                                   research has shown that quality teachers play a significant role in
                                   improving student performance. However, research has also shown that
                                   many teachers, especially those in high-poverty and rural districts,1 were
                                   not certified and lacked knowledge of the subjects they taught. NCLBA
                                   established the requirement that all teachers be highly qualified for each
                                   core subject they teach by the end of the 2005-06 school year.2 The criteria
                                   for meeting this requirement vary somewhat by grade level and experience
                                   but generally require that teachers have (1) a bachelor’s degree, (2) state
                                   certification, and (3) subject area knowledge for each core subject they
                                   teach. This represents the first time the federal government has
                                   established specific criteria for teachers. Title II, Part A, of NCLBA
                                   replaced the Eisenhower Professional Development and Class Size
                                   Reduction programs with the Teacher and Principal Training and
                                   Recruiting Fund and Congress appropriated $2.85 billion to help states and
                                   districts meet the requirement. In addition, Title II directed these funds to
                                   be spent on specific activities to help states and districts recruit, retain,
                                   and develop highly qualified teachers. The Department of Education
                                   (Education) administers Title II and is responsible for oversight of states’
                                   implementation of NCLBA.

                                   Given the need for states and districts to meet the requirement for highly
                                   qualified teachers by the end of the 2005-06 school year, you asked us to
                                   determine what they were doing to have their teachers meet the
                                   requirement. Specifically, this report focuses on the (1) number of
                                   teachers who met the highly qualified teacher criteria during the
                                   2002-03 school year, (2) conditions that hinder states’ and districts’ ability


                                   1
                                       In this report, the term “district” refers to local education agencies.
                                   2
                                    Core subjects include English, reading or language arts, mathematics, science, foreign
                                   languages, civics and government, economics, arts, history, and geography.



                                   Page 1                                                         GAO-03-631 No Child Left Behind
                   to meet the requirement, and (3) activities on which states and districts
                   were planning to spend their Title II funds.

                   In conducting our work, we surveyed 50 states and the District of
                   Columbia. We obtained responses for 37 of these 51 surveys and reported
                   the results as representing only those that responded. The student
                   enrollment for the responding states represented 85 percent of total
                   student population in kindergarten through 12th grade. In addition, we
                   surveyed a nationally representative sample of 830 school districts. We
                   received a response from 511 or 62 percent. We compared relevant
                   characteristics of these respondents to the universe of districts and found
                   them to be similar, which along with the response rate allowed us to
                   report national estimates.3 For our comparisons of high- and low-poverty
                   districts, we included responding districts that had 70 percent or more of
                   their students approved for free and reduced-price meals as high-poverty
                   and those with 30 percent or less of their students approved for free and
                   reduced-price meals as low-poverty. We visited and interviewed officials in
                   8 states selected with a range of characteristics that might affect their
                   ability to meet the requirement—California, Connecticut, Illinois, Iowa,
                   Maryland, North Carolina, Delaware, and Wyoming. We visited 2 districts
                   in each of the states and 1 school in each district. We interviewed U.S.
                   Department of Education officials, and officials from professional
                   organizations and unions that represent teachers. Additionally, we
                   analyzed the legislation, related reports, and relevant documents. See
                   appendix I for detailed information on the methodology. We conducted
                   our work from July 2002 through May 2003 in accordance with generally
                   accepted government auditing standards.


                   We could not develop reliable data on the number of highly qualified
Results in Brief   teachers because states did not have the information needed to determine
                   whether all teachers met the criteria. During our visits state officials did
                   not know the criteria for some of their teachers. Education’s draft
                   guidance on the criteria for teachers in alternative certification programs
                   changed between June and December of 2002, which meant that states had
                   to reassess their teachers’ qualifications. Guidance for special education
                   teachers was not available until December 2002, and it was contained in an



                   3
                    All percentage estimates produced from the district survey have sampling errors of no
                   more than plus or minus 10 percentage points, at a 95 percent confidence level, unless
                   otherwise noted.




                   Page 2                                                  GAO-03-631 No Child Left Behind
appendix to the Title I regulations, but not in the federal regulations. Also,
states did not have the information they needed to develop methods to
evaluate subject area knowledge of their current teachers. In our survey,
32 of 37 state respondents said that they needed clear and timely guidance
from Education. Additionally, officials from 7 of the 8 states we visited
said they did not have data systems that could track teacher qualifications
by subject, which they needed to determine if a highly qualified teacher
taught each core subject. One official added a comment to the survey that
said the state data system on teachers “was designed years ago for state
certification purposes…[and] has not yet been updated to include all
NCLBA criteria for teachers.” Some state officials we interviewed also
expressed reservations about changing their data systems before complete
guidance was issued. Furthermore, 6 of the 8 state officials were reluctant
to say that their certified teachers might not be highly qualified because
they believed it would harm teacher morale. Thus, we concluded that the
survey data related to the number of highly qualified teachers would not
likely be reliable.

Both state and district officials cited many conditions that hinder their
ability to have all highly qualified teachers. Many state officials reported
issues related to teacher pay, such as low salaries, lack of incentive pay
programs, and a lack of career ladders as hindrances. For example, 32 of
the 37 state officials responding to our survey said that teacher salaries
were low compared with other occupations. During our visits officials said
that salary issues particularly hindered their efforts to recruit and retain
math and science teachers. Twenty-three of the 37 state officials reported
teacher shortages in high need subject areas—mostly math, science, and
special education. During the late 1990s, there was an increase in demand
for workers with math and science backgrounds, especially in information
technology, and these occupations generally paid higher salaries than
teaching. Other hindrances cited by state officials included few programs
to support new teachers, a lack of leadership from principals, and union
agreements. Our survey estimates show that salary issues were also
hindrances for the majority of the districts, and about 20 percent of all
districts cited teacher development conditions such as (1) weak
technology training for teachers, (2) few alternative certification
programs, and (3) professional development programs of too short a
duration to improve teacher quality. In addition, significantly more high-
poverty than low-poverty districts identified some conditions as
hindrances, according to our survey responses. For example, an estimated
30 percent of high-poverty districts compared to 6 percent of low-poverty
districts cited few programs to support new teachers. Officials in rural
districts we visited and who commented on the survey said they faced


Page 3                                          GAO-03-631 No Child Left Behind
unusual conditions because some of them were very small, isolated, or had
only one or two teachers in total at some schools. While many of the
hindrances that state and district officials reported could not be addressed
by Education, at least half of the state survey respondents indicated that
Education could be more helpful. Specifically, they said they needed more
information on, or assistance with, professional development programs,
best practices related to teacher quality, and incentives for teachers to
teach in high-poverty schools. Education has identified several steps it will
take in its 2002-07 strategic plan related to these issues.

Title II provided funds to help meet the requirement for highly qualified
teachers, and state survey respondents said they planned to spend most of
their Title II funds on professional development activities while districts
planned to spend the majority of their funds on recruitment and retention
activities authorized under Title II. Generally, state educational agencies
could use up to 2.5 percent of the state’s Title II funds for authorized state
activities. State officials reported they planned to spend 65 percent on
professional development activities. These activities could help teachers
enhance their subject area knowledge and complete state licensing
requirements to meet the criteria for highly qualified teachers. States
planned to spend much larger amounts of other federal and state funds
than Title II funds on authorized state activities. For example, states
reported that 85 percent of the total funds they planned to spend on
professional development activities would come from other federal and
state funds. Districts received about 95 percent of their state’s Title II
funds for authorized district activities. From our survey we estimated that
districts planned to spend about two-thirds of their Title II funds on
activities to help recruit and retain highly qualified teachers, with the
remaining funds on activities for professional development. High-poverty
districts planned to spend a larger percentage of Title II funds on
recruitment and retention activities than low-poverty districts. For
example, high-poverty districts planned to spend 77 percent of their Title
II funds for recruitment and retention while low-poverty districts planned
to spend 59 percent. Recruitment and retention activities, such as
establishing incentive pay programs and reducing class sizes, could help
attract more highly qualified teachers to schools. Survey results also show
that districts planned to spend much larger percentages of other federal,
state, and local funds than Title II funds on authorized Title II activities.
For example, an estimated 80 percent of the total funds all districts
planned to spend on professional development came from other federal,
state, and local funds. During our visits, both state and district officials
said that most activities were a continuation of those begun in previous
years.


Page 4                                          GAO-03-631 No Child Left Behind
             In order to help states meet the requirement for highly qualified teachers
             by the end of the 2005-06 school year, we recommend that the Secretary of
             Education provide more information on methods to evaluate subject area
             knowledge of current teachers.

             Education provided written comments on a draft of this report including
             information on the guidance for special education teachers that we
             incorporated as appropriate. Additionally, Education indicated that it
             plans to take steps to address our recommendation. Our evaluation of
             their comments is in the report and Education’s comments are in appendix
             IV.

             Recently, a body of research has shown that quality teachers are
Background   significant to improving student performance. For example, a 1996 study
             by Sanders and Rivers4 examined the effect of teacher quality on academic
             achievement and found that children assigned to effective teachers scored
             significantly higher in math than children assigned to ineffective teachers.
             Research has also shown that many teachers, especially those in high-
             poverty and rural districts, were not certified and lacked knowledge of the
             subjects they taught. For example, a report from The Education Trust
             found that in every subject area, students in high-poverty schools were
             more likely than other students to be taught by teachers without even a
             minor in the subjects they teach.5

             States are responsible for developing and administering their education
             systems and most have delegated authority for operating schools to local
             governments. States and local governments provide most of the money for
             public elementary and secondary education. In 2002, Education reported6
             that 49 percent of the revenue for education was from state sources,
             44 percent from local sources, and 7 percent from federal sources.
             Therefore, it is mostly state and local funds that are used to cover most of
             the major expenses, such as teacher salaries, school buildings, and
             transportation. Although the autonomy of districts varies, states are



             4
              Sanders, W. and Rivers, J., Cumulative and Residual Effects of Teachers on Future
             Student Academic Achievement. Knoxville, TN: University of Tennessee Value-Added
             Research and Assessment Center, November, 1996.
             5
                 Kati Haycock, Closing the Achievement Gap (The Education Trust, March 2001).
             6
             National Center for Education Statistics, U.S. Department of Education, The Condition of
             Education 2002.




             Page 5                                                  GAO-03-631 No Child Left Behind
responsible for monitoring and assisting their districts that, in turn,
monitor and assist their schools.

The federal government plays a limited but important role in education.
The Department of Education’s mission is to ensure equal access to
education and promote educational excellence throughout the nation by,
among other things, supporting state and local educational improvement
efforts, gathering statistics and conducting research, and helping to make
education a national priority. Education provides assistance to help states
understand the provisions or requirements of applicable laws, as well as
overseeing and monitoring how states implement them. With the passage
of the No Child Left Behind Act, on January 8, 2002, the federal
government intensified its focus on teacher quality by establishing a
requirement in the act for teachers across the nation to be “highly
qualified” in every core subject they teach by the end of the 2005-06 school
year.7

While the act contains specific criteria for highly qualified teachers by
grade and experience levels, in general, the act requires that teachers:
(1) have a bachelor’s degree, (2) have state certification, and
(3) demonstrate subject area knowledge for each core subject they teach.
Table 1 lists the specific criteria by grade and experience levels as defined
in the act.




7
  Title I of NCLBA requires that every state that accepts Title I funds must ensure that all
their teachers meet the requirement. All states and the District of Columbia have accepted
the funds. Title I of NCLBA is designed to help educate disadvantaged children—those with
low academic achievement attending schools serving high-poverty areas. Title I was
appropriated funding of over $10 billion in fiscal year 2002.




Page 6                                                   GAO-03-631 No Child Left Behind
Table 1: Federal Criteria for a Highly Qualified Teacher

 Grade level and experience               Federal criteria
 Any public elementary school or          Has obtained full state certification as a teacher (including alternative certification) or
 secondary school teacher.                passed the state teacher licensing examination and holds a license to teach in the state;
                                          however, when teaching in a charter school,a the teacher may not be certified or licensed if
                                          the state does not require it. Further, the teacher has not had certification or licensure
                                          requirements waived on emergency, temporary, or provisional basis.
 Elementary school teacher new to the     Holds at least a bachelor’s degree; and has passed a rigorous state test to demonstrate
 profession.                              subject knowledge and teaching skills in reading, writing, math, and other areas of the
                                          basic elementary school curriculum (these tests may be included in state certification or
                                          licensing tests).
 Middle or secondary school teacher new   Holds at least a bachelor’s degree and has passed a rigorous state academic subject test
 to the profession.                       in each of the academic subjects in which the teacher teaches (this may be the state
                                          certification or licensure test) or for each academic subject taught, the teacher has
                                          successfully completed an academic major, a graduate degree, coursework equivalent to
                                          an undergraduate academic major, or advanced certification or credentialing.
 Elementary, middle, or secondary teacher Has met the above standards for new elementary, middle, and secondary school teachers
 not new to the profession.               or demonstrates competence in all the academic subjects in which the teacher teaches
                                          based on a high objective, uniform state standard of evaluation that (1) is set by the state
                                          for both grade appropriate academic subject matter knowledge and teaching skills; (2) is
                                          aligned with challenging state academic content and student academic achievement
                                          standards and developed in consultation with core content specialists, teachers,
                                          principals, and school administrators; (3) provides objective, coherent information about
                                          the teacher’s attainment of core content knowledge in the academic subjects a teacher
                                          teaches; (4) is applied uniformly to all teachers in the same academic subject and the
                                          same grade level throughout the state; (5) takes into consideration, but not be based
                                          primarily on, the time the teacher has been teaching in the academic subject; (6) is made
                                          available to the public upon request; and (7) may involve multiple, objective measures of
                                          teacher competency.
Source: NCLBA, Pub.L. No. 107-110, section 9101(2002).
                                                         a
                                                         Charter schools are public schools that are exempt from a variety of local and state regulations.


                                                         For Title II, Part A of the act, Congress appropriated $2.85 billion to the
                                                         Teacher and Principal Training and Recruiting Fund in fiscal year
                                                         2002—about $740 million more than states received in fiscal year
                                                         2001 under the previous two programs that it replaced—the Eisenhower
                                                         Professional Development and Class Size Reduction programs. The
                                                         purpose of the fund is to increase student academic achievement by
                                                         providing support for states and districts to implement authorized
                                                         activities cited in Title II to help them meet the requirement for highly
                                                         qualified teachers. (See apps. II and III for state and district authorized
                                                         activities.)

                                                         States had to complete an application in order to receive funds. All
                                                         applications were due by June 2002, and states received the funds by
                                                         August 2002. The funds were to be distributed according to the formula
                                                         defined in the act. Specifically, states and districts received an amount



                                                         Page 7                                                         GAO-03-631 No Child Left Behind
equal to what they received for fiscal year 2001 under the two previous
programs. The additional $740 million was distributed to states and
districts based on the number of families with children ages 5 to 17 who
had incomes below the poverty threshold8 and the relative population of
children ages 5 to 17. The act requires states to ensure that districts target
funds to those schools that have the highest number of teachers who are
not highly qualified, the largest class sizes, or have been identified as in
need of improvement.

To help states understand and implement the new law, Education took a
number of actions. The department established a Web site, developed an
application package for the formula grant program, issued draft guidance,
and held informational conferences for states and districts. Figure 1
summarizes Education’s assistance to states.




8
    For 2002, the poverty threshold was $18,556 annually for a family of four.




Page 8                                                      GAO-03-631 No Child Left Behind
Figure 1: Education’s Assistance to States During Calendar Year 2002


            Date         Events

             April       NCLBA Web site went online

             May         Final Rule issued on how to apply for Title II, Part A Funds

            June         Title II, Part A draft guidance issued

                         First Annual Teacher Quality Evaluation Conference held, during
                         which the draft guidance was discussed




         October         Regional conferences held, during which Education officials reviewed
                         the authorized activities listed in Title II, Part A and the criteria for
                         highly qualified teachers


    December             Title II, Part A draft guidance reissued

                         Final Title I Regulations issued that provide highly qualified criteria for
                         some categories of teachers including those who are currently
                         teaching, newly hired and in alternative certification programs; with
                         an appendix discussing requirements for special education teachers

 Source: GAO analysis.



In June 2002, Education issued draft guidance entitled “Improving Teacher
Quality State Grants” which has served as Education’s principle form of
assistance to states. In December of 2002, Education expanded and
modified the draft guidance and issued final regulations on NCLBA that
included some criteria related to the requirement for highly qualified
teachers. Education does not plan to issue a final version of its draft
guidance; instead, the draft includes the statement that it “should be
viewed as a living document” that will be updated (1) as new questions
arise, (2) if there is a change in the program statute that requires
modification, or (3) when Education determines that more information
would be helpful.




Page 9                                                            GAO-03-631 No Child Left Behind
                            In-depth discussions with officials in 8 states revealed that they could not
Many States Were            determine the number of highly qualified teachers with accuracy because
Uncertain about             of one or more factors. All state officials said they did not know the
                            criteria for some of their teachers because Education’s draft guidance
Numbers of Highly           changed and was not complete. Officials also did not have all the
Qualified Teachers          information they needed to develop methods to evaluate subject area
                            knowledge for their current teachers. Accordingly, officials in all of the
                            states interviewed and nearly all surveyed said they needed complete and
                            clear guidance before they could comply with the law. Most of the states
                            we visited also did not have data systems that could track teacher
                            qualifications by core subject taught, which they would have to do to
                            ensure that teachers were teaching only those subjects for which they had
                            demonstrated subject area knowledge. Finally, many state officials we
                            visited were reluctant to say that their certified teachers might not be
                            highly qualified.


States Did Not Have         During our review, Education changed its criteria for teachers who were
Complete or Consistent      in alternative certification programs and it reissued the draft guidance to
Criteria to Determine the   qualify only teachers in certain programs.9 The revised draft guidance
                            stated that only those teachers enrolled in alternative certification
Number of Highly            programs with specific elements, such as teacher mentors, would be
Qualified Teachers          considered highly qualified. As a result, state officials had to recount this
                            group of teachers by determining which alternative certification programs
                            met the standard and then which teachers participated in those programs.
                            In one state we visited, there were about 9,000 teachers in alternative
                            certification programs and all were considered highly qualified until the
                            revised draft guidance was issued. As of May 2003, an official said she was
                            still trying to determine the number of teachers who were highly qualified.

                            Also during our review, state officials were uncertain about the criteria for
                            special education teachers. The draft guidance that was available during
                            most of our visits did not address special education teachers. As a result,
                            state officials could not know, for example, whether a special education


                            9
                             Many states have alternate routes to certification, referred to here as alternative
                            certification programs, that allow an individual who has a bachelor’s degree from a college
                            or university but who does not hold a degree in education, to receive a license to teach.
                            Alternative certification programs range from those that place people in classrooms
                            immediately to longer programs that delay placing people in classrooms until they have
                            completed course work and received a mentor. While these programs vary within and
                            among states, nearly all states have some type of alternative to the traditional path of
                            majoring in education in order to become a teacher.




                            Page 10                                                 GAO-03-631 No Child Left Behind
teacher teaching math and reading would have to demonstrate subject
area knowledge in both or neither of the subjects. For school year
1999-2000, special education teachers represented about 11 percent of the
national teacher population,10 so that, on average, state officials were
unable to determine whether at least a tenth of their teachers met the
highly qualified criteria. In some districts, special education teachers
represented a larger portion of the workforce. For example, in one high-
poverty urban district that we visited, special education teachers were
21 percent of their teachers. Education issued final Title I regulations on
December 2, 2002, with an appendix that discussed the highly qualified
requirements for special education teachers, among other things.
However, the requirements are not discussed in the federal regulations nor
are they discussed in the Title II draft guidance that was issued December
19, 2002. In addition, as of March 2003 some officials still had questions
about the requirements. Perhaps because the guidance was issued in an
appendix, it was not given the prominence needed to ensure that all
officials would be aware of the information.

Furthermore, neither Education’s draft guidance nor its regulations
provided more information than the law to help state officials develop
methods other than tests to evaluate their current teachers’ subject area
knowledge. The law allows states to use a “high, objective uniform state
standard of evaluation” instead of a test. Education’s draft guidance
repeated the language of the law, but provided no further interpretation. In
addition, Education officials said they would review states’
implementation of this provision when they conduct compliance reviews
and then determine if the state evaluation is in compliance with the law.
State officials said they needed more information, such as examples, to be
confident of what Education would consider adequate for compliance with
the law. State officials prefer evaluations instead of tests, according to an
official at the Council of Chief State School Officers (CCSSO), because
they expect evaluations to be less expensive, more flexible, and more
acceptable to teachers and unions. Such evaluations might be done
through classroom observations, examination of portfolios, and peer
reviews. In March 2003, CCSSO held a conference attended by about
25 state officials and several Education officials to discuss the
implementation of state evaluations. At that conference, state officials said



10
 National Center for Education Statistics, Schools and Staffing Survey, 1990-2000,
“Number and Percent of Public School Special Education Teachers Who Teach Special
Education Classes as Their Main Assignment or as Their Second Assignment” (2002).




Page 11                                              GAO-03-631 No Child Left Behind
                             Education’s lack of specificity was particularly a problem for evaluating
                             middle and high school teachers who had not demonstrated subject area
                             knowledge. According to our survey data, 23 of 37 state officials said they
                             would have difficulty fulfilling the highly qualified requirement for middle
                             school teachers and 14 anticipated difficulty for high school teachers.
                             According to district survey results, 20 percent anticipated difficulties in
                             meeting the federal criteria for middle school teachers and 24 percent for
                             high school teachers. Furthermore, as table 2 shows, a significantly higher
                             percentage of high-poverty districts reported they would have greater
                             difficulty fulfilling the requirement for teachers, especially at the middle
                             and high school levels, than would low-poverty districts.

                             Table 2: Estimated Percentages of Districts That Will Have Difficulty Meeting the
                             Requirement for Highly Qualified Teachers by Grade Level and Poverty

                                                                                        High-poverty              Low-poverty
                                 Type of school                All districts                districts                districts
                                 Elementary                                7                       18                        4
                                 Middle/junior high                       20                       35                       13
                                 High                                     24                      46a                       15
                             Source: GAO survey.
                             a
                              The percentage estimate for high schools in high-poverty districts has a 95 percent confidence
                             interval of plus or minus 11 percentage points.


                             State officials from the 8 states we visited said they could not determine
                             the number of highly qualified teachers because the draft guidance was
                             changing, not clear, or incomplete. Most, 32 of 37, state officials
                             responding to our survey said they needed clear and timely guidance to
                             help them meet the law.


State Data Systems Did       Officials from 7 of the 8 states we visited told us they did not have data
Not Track Federal Criteria   systems that would allow them to track teachers’ qualifications according
                             to the federal criteria by every subject taught. Officials in one state
                             projected that it would take at least 2 years before the state could develop
                             and implement a system to track teachers by the federal criteria. State
                             officials we visited said since their state certifications had not required
                             some teachers to demonstrate subject area knowledge as required in the
                             federal criteria, their information systems did not track such information.
                             In written comments to our survey, for example, one official said,
                             “Questions [related to counting teachers] are impossible to answer at this
                             point because we not have finished the identification of those who need to
                             be tested or evaluated.” Another respondent wrote that the data system



                             Page 12                                                        GAO-03-631 No Child Left Behind
                       “was designed years ago for state certification purposes…[and] has not yet
                       been updated to include all NCLBA criteria for teachers.” Other state
                       officials also told us during our visits and through survey comments that
                       their state certifications did not always require teachers to demonstrate
                       subject area knowledge, so they did not have information on many
                       teachers’ qualifications for this criteria. Another state official wrote, “[We]
                       do not have data on teachers who were grand fathered in before 1991 or
                       from out of state… who do not have subject matter competency.” Given
                       the cost and time they thought it would take, some state officials
                       expressed reservations about changing their data systems before
                       Education provided complete guidance.


Some State Officials   Officials in 6 of the 8 states visited were reluctant to report their certified
Reluctant to Report    teachers might not be highly qualified. Three of these officials equated
Teachers Not Highly    their state certification with the federal criteria for a highly qualified
                       teacher even though they differed. They expressed a reluctance to say that
Qualified              their state certification requirements did not produce a highly qualified
                       teacher even though the requirements did not match all the federal
                       criteria, such as demonstration of subject area knowledge. Additionally,
                       state officials expressed concern about the morale of teachers who are
                       state certified but who would not meet the federal criteria. They were also
                       concerned about how teachers and unions would react to testing already
                       certified teachers. For example, in 5 states we visited officials told us that
                       the unions in these states objected to the testing of certified teachers.


                       Many state officials responding to our survey reported that teacher salary
State and District     issues and teacher shortages were hindrances. State officials also
Officials Reported     identified other conditions such as few programs to support new teachers,
                       lack of principal leadership, teacher training, and union agreements.
Many Conditions as     District officials also cited teacher salary and teacher development issues
Hindrances to          as conditions that hindered them. Our district survey also shows that
                       significantly more high-poverty districts reported some conditions as
Meeting the Law        hindrances than low-poverty districts, and rural districts officials we
                       visited cited hindrances specific to their small size and isolated locations.
                       In our state survey, officials indicated that they needed more information
                       from Education on professional development programs, best practices,
                       and developing incentives for teachers to teach in high-poverty schools.




                       Page 13                                          GAO-03-631 No Child Left Behind
State Officials Cited   Many state officials responding to our survey reported that pay issues
Several Problems as     hindered their ability to meet the requirement to have all highly qualified
Hindrances              teachers. These issues included low salaries, lack of incentive pay
                        programs, and a lack of career ladders for teachers. For example,
                        32 of 37 state respondents said low teachers’ salaries compared to other
                        occupations was a hindrance. Officials we visited said that because of the
                        low salaries it has been more difficult to recruit and retain some highly
                        qualified teachers, especially math and science teachers. Several
                        occupations are open to people with a bachelor’s degree in math and
                        science, such as computer scientists and geologists. During the late
                        1990s, there was an increase in demand for workers with math and science
                        backgrounds, especially in information technology occupations. Between
                        1994 and 2001, the number of workers employed in the mathematical and
                        computer sciences increased by about 77 percent while the number of
                        teachers increased by about 28 percent and total employment increased by
                        about 14 percent. Furthermore, the math and science occupations have
                        generally paid higher salaries than teaching positions. The U.S.
                        Department of Labor’s Bureau of Labor Statistics data indicate that in
                        2001 average weekly earnings was $1,074 for mathematical and computer
                        scientist positions and $730 for teachers. Some research shows that
                        teacher salary is only one of many factors that influence teacher
                        recruitment and retention. For example, the American Association of
                        School Administrators explained the relationship between pay and
                        working conditions in a report on higher pay in hard-to-staff schools.11 The
                        report stated “How money matters becomes much clearer if salary is
                        viewed as just one of many factors that employees weigh when assessing
                        the relative attractiveness of any particular job, such as opportunities for
                        advancement, difficulty of the job, physical working conditions, length of
                        commute, flexibility of working hours, and demands on personal time.
                        Adjusting the salaries upward can compensate for less appealing aspects
                        of a job; conversely, improving the relative attractiveness of jobs can
                        compensate for lower salaries.”

                        Many state survey respondents also cited teacher shortages as a
                        hindrance. Specifically, 23 of the 37 state officials reported teacher
                        shortages in high-need subject areas—such as, math, science, and special




                        11
                         Cynthia Prince, Higher Pay in Hard to Staff Schools: The Case for Financial Incentives,
                        American Association of School Administrators, June 2002.




                        Page 14                                               GAO-03-631 No Child Left Behind
education.12 Additionally, 12 state officials reported a shortage in the
number of new highly qualified teachers in subject areas that are not high
need, and 12 reported that having few alternative certification programs
hindered their efforts. Education experts have debated the causes and
effects of teacher shortages. Some experts argue that the problem is not in
the number of teachers in the pool of applicants but in their distribution
across the country. Others argue that poor retention is the real cause of
teacher shortages. As for alternative certification programs, they were
established to help overcome teacher shortages by offering other avenues
for people to enter the teaching profession. However, in 1 state we visited
officials said the success of these programs had been mixed because the
content and length of the programs varied and some alternative
certification teachers were better prepared than others.

Although states have been facing teacher shortages in some subject areas
for years, the new requirement for highly qualified teachers could make it
even more difficult to fulfill the demand for teachers. The new law
requires states to ensure that teachers only teach subjects for which they
have taken a rigorous state test or evaluation, completed an academic
major or graduate degree, finished course work equivalent to such
degrees, or obtained advanced certification or credentialing in the
subjects. Previously, states allowed teachers to teach subjects without
such course work or credentials. From its Schools and Staffing Survey,13
the National Center for Education Statistics, within the Department of
Education, reported that in 1999-2000, 14 to 22 percent of students in
middle grades and 5 to 10 percent of high school students taking English,
math, and science were in classes taught by teachers without a major,
minor, or certification in the subjects they taught. Also, the report
indicated that in the high school grades, 17 percent of students enrolled in
physics and 36 percent enrolled in geology/earth/space science classes
were taught by out-of-field teachers.

Some states also cited several other conditions that might hinder their
ability to meet the requirement for highly qualified teachers. For example,


12
 In this report, when discussing a shortage of teachers in the high need subject area of
special education, we are referring to a shortage of persons qualified to be special
education teachers to teach core subjects to children with disabilities as defined in Section
602 of the Individuals with Disabilities Education Act Amendments of 1997.
13
 Department of Education, Qualifications of the Public School Teacher Workforce:
Prevalence of Out-of-Field Teaching 1987-88 and 1999-2000, Statistical Analysis Report,
Schools and Staffing Survey, National Center for Education Statistics, 2002.




Page 15                                                   GAO-03-631 No Child Left Behind
13 of the 37 state respondents reported few programs to support new
teachers,14 and 9 reported large classes as hindrances. State respondents
also cited work environment factors such as teacher performance
assessments, a lack of principal leadership, and lack of school supplies
and equipment as hindrances. See table 3 for more information on
hindrances reported by state officials.

Additionally, 7 state officials who responded to our survey cited union
agreements as a hindrance. Officials in 5 states that we visited said that the
teachers’ unions objected to testing currently certified teachers for subject
area knowledge, and officials in 2 of these states also said that current
teachers might leave rather than take a test. An official representing the
American Federation of Teachers (AFT), an organization that represents
teachers, school support staff, higher education faculty and staff, among
others, said that AFT supports the federal definition for highly qualified
teachers and incentive pay for teachers in high-need subject areas and that
certified teachers should have a choice between taking a test and having a
state evaluation to determine subject area knowledge. The National
Education Association, an organization with members who work at every
level of education, issued an analysis of the NCLBA that identified several
changes it believes should be made in the law, including clarifying the
requirement for highly qualified teachers. The union officials we spoke
with from 2 states we visited said they also support the requirement for
highly qualified teachers but expressed concerns about how their states
would implement the legislation. One state union official said the current
state process for certification requires multiple tests—more than is
required in the legislation—and the union is concerned that the state will
collapse the testing and streamline the teacher preparation process as part
of its changes to meet the requirement. The union official from the other
state said that his union was concerned because the state’s approach for
implementing the requirement for highly qualified teachers has become a
moving target and this causes frustration for teachers.




14
 As provided in Title II of NCLBA, programs to support new teachers include teacher
mentoring, team teaching, reduced class schedules, and intensive professional
development.




Page 16                                                GAO-03-631 No Child Left Behind
Table 3: Number of States Reporting on Conditions That Hinder Their Ability to
Meet the Requirement for Highly Qualified Teachers (Ranked from Highest to
Lowest)

    Number of states
    reporting this
    condition to be a
              a
    hindrance (n=37)    Condition
    32                  Teachers’ salaries low compared to other occupations.
                        Shortage in the number of teachers who meet the Title II
                        requirement for highly qualified teachers in subject areas where
    23                  there is high need.
    21                  Teachers’ salaries low compared to teachers elsewhere.
    18                  Lack of incentive pay programs.
    17                  Lack of a career ladder for teachers.
                        Professional development programs not of sufficient duration to
    14                  have an effect on teacher quality.
    13                  Few programs to support new teachers.
    12                  Few alternative certification programs.
                        Shortage in the number of new teachers who meet the Title II
                        requirement for highly qualified teachers in subject areas that are
    12                  not high need.
    12                  School lacks supplies and equipment.
    11                  Lack of leadership on the part of principals.
                        College of Arts and Science Departments do not work with college
    9                   Education Departments to develop teacher preparation programs.
    9                   Large class sizes resulting in teacher retention problems.
                        Many currently employed teachers do not meet the Title II
                        requirement for highly qualified teachers in areas that are not high
    9                   need.
    7                   Teacher assessments not based on the Title II requirement for
                        highly qualified teachers.
    7                   Weak training for teachers in the use of technology.
    7                   Union agreements inhibit implementing activities encouraged by
                        Title II to develop highly qualified teachers.
    7                   Professional development programs not based on recent scientific
                        research on teaching methods or subject matter.
    4                   State certification requirements not meeting the Title II requirement
                        for highly qualified teachers.
    3                   Alternative certification programs not providing teachers with
                        adequate teaching skills.
    3                   Teacher preparation programs not aligned with state subject
                        content standards.
    3                   State and local laws and regulations inhibit implementing activities
                        encouraged by Title II to develop highly qualified teachers.
    2                   Teacher preparation programs not providing teachers with
                        adequate subject matter expertise.
Source: GAO survey.
a
 These numbers include states that reported these conditions as a moderate, great, or very great
hindrance.




Page 17                                                       GAO-03-631 No Child Left Behind
School Districts Reported    School district estimates from our survey show that, similar to state
Hindrances Similar to        respondents, salary issues hinder districts’ efforts to meet the requirement
Those Reported by States     for highly qualified teachers. Almost 60 percent of district officials cited
                             low teacher salaries compared to other occupations as a hindrance, with a
and More High-Poverty        significantly higher number of high-poverty than low-poverty district
Districts Reported Certain   officials reporting this as a hindrance. During our site visits to 4 rural
Hindrances                   districts, officials said that their salaries could not compete with salaries
                             offered in other occupations and locations. One official said that pay in the
                             rural districts was low compared to teacher salaries in surrounding states.
                             Both state and district officials also said that these salary conditions affect
                             the recruitment and retention of highly qualified teachers.

                             Our survey estimates also show that conditions related to teacher
                             development were hindering districts’ ability to meet the highly qualified
                             teacher requirement. The conditions reported by districts included
                             (1) weak training for teachers in the use of technology (28 percent),
                             (2) few alternative certification programs (18 percent), and
                             (3) professional development programs that are not of sufficient duration
                             to improve teacher quality (23 percent). Weak training programs can leave
                             teachers unprepared to deal with all the challenges of teaching and lead to
                             job dissatisfaction. Table 4 provides estimates of the percentages of
                             districts reporting conditions that hinder their ability to meet the
                             requirement for highly qualified teachers.




                             Page 18                                          GAO-03-631 No Child Left Behind
Table 4: Estimated Percentages of Districts Reporting on Conditions That Hinder
Their Ability to Meet the Requirement for Highly Qualified Teachers (Ranked from
Highest to Lowest)

    Percent of all
    districts
    reporting this
    condition to be
    a hindrancea      Condition
    57                Teachers’ salaries low compared to other occupations.
    37                Teachers’ salaries low compared to teachers elsewhere.
    28                Training for teachers in the use of technology is weak.
    25                Lack of incentive pay programs.
                      Professional development programs not of sufficient duration to
    23                have an effect on teacher quality.
                      Shortage in the number of teachers who meet the Title II
                      requirement for highly qualified teachers in subject areas where
    19                there is high need.
                      Teacher preparation programs not providing teachers with adequate
    18                subject matter expertise.
    18                Few alternative certification programs.
                      College of Arts and Science Departments not working with college
    17                Education Departments to develop teacher preparation programs.
                      Alternative certification programs not providing teachers with
    16                adequate teaching skills.
    16                Few programs to support new teachers.
    16                Lack of a career ladder for teachers.
                      Shortage in the number of new teachers who meet the Title II
    16                requirement for highly qualified teachers in low achieving schools.
                      Teacher preparation programs not aligned with state subject content
    15                standards.
    14                School lacks supplies and equipment.
                      Teacher assessments not based on the Title II requirement for
    12                highly qualified teachers.
                      Union agreements that inhibit implementing activities encouraged by
    10                Title II to develop highly qualified teachers.
    7                 Lack of leadership on the part of principals.
    7                 Large class sizes resulting in teacher retention problems.
                      Professional development programs not based on recent scientific
    7                 research on teaching methods or subject matter.
                      State certification requirements not meeting the Title II requirement
    7                 for highly qualified teachers.
                      Many currently employed teachers not meeting the Title II
                      requirement for highly qualified teachers in areas that are not high
    6                 need.
                      State and local laws and regulations inhibit implementing activities
    4                 encouraged by Title II to develop highly qualified teachers.
Source: GAO survey.
a
 These percentages include districts that reported these conditions as a moderate, great, or very
great hindrance.




Page 19                                                        GAO-03-631 No Child Left Behind
While the ranking of most of the hindrances reported by districts and
states were similar, three conditions were reported among the top third of
hindrances for districts but among the bottom third for states. Specifically,
these conditions were (1) alternative certification programs do not provide
teachers with adequate teaching skills, (2) teacher preparation programs
do not provide teachers with adequate subject matter expertise, and
(3) training for teachers in the use of technology is weak. The first two of
these conditions relate to programs that are usually responsibilities of the
state departments of education. States or districts can address the third
condition, technology training. These conditions indicate areas in which
states and districts can work together to improve programs and help meet
the requirement for highly qualified teachers.

A significantly higher number of high-poverty districts than low-poverty
districts identified some conditions as hindrances. As table 5 shows, in
addition to teacher shortages and pay issues, a larger percentage of high-
poverty districts cited few programs to support new teachers and few
alternative certification programs, among others, as hindrances to meeting
the requirement.




Page 20                                        GAO-03-631 No Child Left Behind
Table 5: Estimated Percentages of High- and Low-Poverty Districts with Significant
Differences in the Hindrances to Meeting the Requirement

                                                                      Percent of           Percent of
                                                                    high-poverty         low-poverty
 Condition                                                              districts            districts
 Teachers’ salaries are low compared to other
 occupations.                                                                    75                    50
 Teachers’ salaries are low compared to teachers
 elsewhere.                                                                      57                    33
 Lack of incentive pay programs.                                                 32                    17
 Few programs to support new teachers.                                           30                     6
 Shortage in the number of teachers who meet the
 Title II requirement for highly qualified teachers in
 subject areas where there is a high need.                                       29                    13
 Shortage in the number of new teachers who meet
 the Title II requirement in low achieving schools.                              26                    10
 Lack of career ladder for teachers.                                             25                     8
 Few alternative certification programs.                                         24                    11
 Teacher preparation programs do not provide
 adequate subject matter expertise.                                              24                    13
 Many currently employed teachers do no meet the
 Title II requirement in areas that are not high need.                           13                    4
 Large class sizes resulting in teacher retention
 problems.                                                                       12                    4
 Lack of leadership on the part of principals.                                   12                    3
Source: GAO survey.

Note: Each difference between high- and low-poverty districts in this table is significant at the 95
percent confidence interval.


During our site visits, officials from high-poverty districts told us they had
great difficulty retaining teachers. For example, officials in one district
said that although the district provided training for new teachers in the
skills they needed, these teachers became more marketable after they
completed the training and often left for higher paying teaching positions.
According to these officials, the schools in this district did not always
benefit from the district’s training programs. High-poverty district officials
also said they could not compete with surrounding, wealthier districts in
teacher pay. Officials in these districts and at the American Association of
School Administrators also said that some unions do not support the use
of incentive pay for high-poverty schools because they believe that salary
scales should be equal for all schools within a district.

Rural district officials we visited and also those who provided survey
comments said they faced unusual hindrances because some of them were
very small, isolated, or had only one or two teachers in total at some
schools. During our site visits, some officials from rural districts also said


Page 21                                                          GAO-03-631 No Child Left Behind
                            that they were facing teacher shortages because not enough teachers were
                            willing to teach in rural districts. For example, one official in a large, rural
                            state said that the state had only one university, which makes it difficult
                            for teachers to obtain further course work to meet the federal criteria for
                            subject area knowledge. Since many teachers in this state’s rural districts
                            had to teach more than one core subject, with limited access to subject
                            area training, they may not meet the highly qualified criteria for all
                            subjects they teach. One survey respondent also wrote, “Rural schools
                            have to assign teachers to several subject areas at [the] secondary level.
                            We do not have large numbers of students, and teachers have to wear
                            more than one hat. Rural schools are also a long way from colleges and to
                            require licensure in every subject they teach is ludicrous.” In a 2001 report
                            to Congress, Education estimated that 84 percent of 4-year institutions
                            would offer distance education courses15 in 2002. Such courses may help
                            address this hindrance.

States Say They Need        As districts work to address the conditions that affect their ability to meet
More Information from       the new federal requirement, they look to their state officials for guidance
Education and Education     and technical assistance. In turn, states look to Education for help. Many
                            of the hindrances that state and district officials reported related to
Plans to Work with States   conditions that they could address such as teachers’ salaries, the number
on Some Issues              of alternative certification programs, and certification requirements.
                            However, states indicated they needed some additional information and
                            assistance from Education. At least half of the 37 state respondents
                            reported needing (1) information or other assistance to meet the
                            requirement that professional development programs be based on recent
                            scientific research and be of sufficient duration to have an effect on
                            teacher quality, (2) information on best practices in the area of teacher
                            quality, and (3) assistance in developing incentives for teachers to teach in
                            high-poverty schools. Education’s 2002-07 strategic plan identifies several
                            steps it will take to work with states. Specifically, the strategies listed
                            under the plan’s goal for improving teacher and principal quality include
                            supporting professional development in research-based instruction and
                            encouraging innovative teacher compensation and accountability systems.
                            Additionally, in December 2002, Education reorganized and established a
                            new office to administer the Title II program.




                            15
                              The Higher Education Act defines distance education as an educational process where
                            the student is separated in time or place from the instructor.




                            Page 22                                               GAO-03-631 No Child Left Behind
                           To help meet the requirement for highly qualified teachers, state officials
To Help Teachers           planned to spend most of their Title II funds on professional development
Meet the Requirement       activities, and district officials planned to spend a majority of their Title II
                           funds on recruitment and retention activities. State and district officials
States Planned to          planned to spend much larger amounts of other federal,16 state, and local
Spend Most Title II        funds than Title II funds on the activities authorized in the act. Generally,
                           state and district officials told us they were continuing activities from
Funds on Professional      previous years. The survey data also indicated high-poverty districts relied
Development                more on Title II funds for recruitment and retention activities than low-
Activities, and            poverty districts. In addition, while the act requires districts to target their
                           Title II funds to schools that meet certain criteria, until district officials
Districts Will Spend       know the number of highly qualified teachers and where they are located,
Most on Recruitment        they cannot fully comply with this requirement.

and Retention
Activities

States Planned to Spend    Generally, state educational agencies could use up to 2.5 percent of the
the Majority of Title II   state’s Title II funds for authorized state activities. 17 Twenty-four state
Funds on Professional      officials responding to our survey planned to spend about 65 percent of
                           their Title II funds on professional development activities to develop and
Development                support highly qualified teachers and principals. For example, professional
                           development activities could help teachers enhance their subject area
                           knowledge and complete state licensing requirements to meet the criteria
                           for highly qualified teachers. During our site visits, state officials described
                           their professional development activities as seminars, conferences, and
                           various instructional initiatives. For example, in one state we visited,
                           officials planned to hold a workshop to provide middle and high school
                           math teachers with technology training so that they could incorporate
                           interactive Web sites in their instruction. Generally, state officials said



                           16
                            For example, districts must use 5 to 10 percent of their Title I-A funds in fiscal years 2002
                           and 2003 for professional development activities to ensure that teachers become highly
                           qualified.
                           17
                            State education agencies receive 5 percent of the total grant funds and can retain up to 1
                           percent of these funds for administrative costs. Of the remaining funds, 2.5 percent must be
                           spent on subgrants to eligible partnerships and the remaining funds are to be used for
                           authorized activities. We grouped the Title II activities into five categories: (1)
                           accountability, (2) certification, (3) professional development, (4) recruitment and
                           retention, and (5) technical assistance. Appendix II lists all 18 activities.




                           Page 23                                                   GAO-03-631 No Child Left Behind
                             they planned to use Title II funds to continue activities that were begun in
                             previous years.

                             While professional development activities were to receive the largest share
                             of funds, survey results show state officials planned to also spend Title II
                             funds on other activities cited in the act. Officials in 28 states planned to
                             spend about 18 percent on technical assistance activities, such as
                             providing information about the requirement for highly qualified teachers
                             to districts via the state Web site. Certification activities received the
                             smallest percentage of Title II funds–2 percent. These activities include
                             efforts to promote certification reciprocity with other states and efforts to
                             establish, expand, or improve alternative routes for certification. (See fig.
                             2.)

                             Figure 2: Planned Spending of Title II Funds by Reporting States

                                                                                   2%
                                                                                   Certification
                                                                                   Recruitment and retention


                                                               6%
                                                                       9%          Accountability




                                                                          18%      Technical assistance
                                          65%




                                                                                   Professional development
                             Source: The 37 states that responded to GAO survey.




Title II Funds Are a Small   State officials reported they planned to spend much larger amounts of
Part of Total Funds          other federal and state funds than Title II funds on nearly all of the
                             authorized Title II activities. For example, states reported that 85 percent
                             of the total funds they planned to spend on professional development
                             activities would come from other federal and state funds. The one
                             exception was technical assistance activities, where Title II funds



                             Page 24                                                         GAO-03-631 No Child Left Behind
                               accounted for 77 percent of the total. (See fig. 3.) Providing technical
                               assistance to districts is an important role for states. In our visits to
                               districts, several officials said they needed more information and technical
                               assistance from their state to understand and implement the law.

                               Figure 3: Sources of Funds for Planned Spending by States on Title II Activities

                               Percent of planned spending on activities
                               100                                          95
                                                  94
                                90                                                                          87
                                                                                         85

                                80                                                                                   77

                                70

                                60

                                50

                                40

                                30
                                                                                                                            23
                                20                                                15
                                                                                                    13
                                10        6                       5

                                    0
                                        Accountability           Certification   Professional      Recruitment       Technical
                                                                                 development       and retention     assistance

                                               Title II funds

                                               Other federal and state funds

                               Source: The 37 states responding to GAO survey.




Districts Planned to Spend     Districts received about 95 percent of their state’s Title II funds for
a Majority of Their Title II   authorized activities.18 Based on our survey, district officials planned to
Funds on Recruitment and       spend an estimated 66 percent of their Title II funds on recruitment and
                               retention activities and 34 percent on activities related to professional
Retention Activities           development. Class size reduction activities were the largest funded
                               recruitment and retention activity and accounted for 56 percent of total
                               Title II funds. In a majority of our site visits we learned that district
                               officials used these funds to hire additional highly qualified teachers to


                               18
                                 Districts are to spend their Title II funds on 9 authorized activities that we grouped into
                               2 categories: (1) professional development and (2) recruitment and retention. Appendix III
                               lists all 9 activities.




                               Page 25                                                          GAO-03-631 No Child Left Behind
continue activities developed under the previous Class Size Reduction
Program. Class size reduction activities may help improve teacher
retention because, according to an Education report,19 teachers in small
classes spend less time on classroom management and more time
providing instruction, thus raising the teacher’s level of job satisfaction.
While class size reduction activities can be seen as a retention tool, they
may also increase the number of highly qualified teachers that need to be
hired. This may be a problem for some districts and states. In fact, officials
in one large state we visited said class size reduction activities presented a
challenge by increasing the number of classes not being taught by a highly
qualified teacher.

Additionally, district officials in our site visits said that they implemented
or planned to implement a broad range of professional development
activities. For example, one district had a teacher-coach program for its
math and science teachers. This program used senior teachers as full-time
coaches to assist less experienced teachers with instructional strategies
and curriculum preparation. Other programs focused on math and reading,
varied instructional strategies for different types of students, and use of
technology. District officials in our site visits said most activities were in
place prior to the act.

While all districts spent more on recruitment and retention activities than
professional development, there were differences between high- and low-
poverty districts. From our survey, we estimate that high-poverty districts
planned to spend a significantly larger percentage of Title II funds on
recruitment and retention and a smaller percentage on professional
development activities than low-poverty districts. (See table 6.)

Table 6: Estimated Percent of Spending Title II Funds by Activities for All Districts,
High-Poverty Districts, and Low-Poverty Districts

                                                  All high-poverty      All low-poverty
 Activity                         All districts           districts            districts
 Professional development
 activities                                 34                  23                   41
 Recruitment and
 retention/class size reduction             66                  77                   59
Source: GAO survey.




19
 U. S. Department of Education, The Class-Size Reduction Program: Boosting Student
Achievement in Schools Across the Nation, A First-Year Report, September 2000.




Page 26                                                 GAO-03-631 No Child Left Behind
                             Note: Each difference between high- and low-poverty districts in this table is significant at the
                             95 percent confidence interval.


Districts Planned to Spend   From our survey, we estimated all districts planned to spend much larger
Larger Amounts of Other      percentages of other federal, state, and local funds than Title II funds on
Funds and Title II Funds     authorized activities but in high-poverty districts the share of the funds
                             was lower. Overall, 80 percent of the total funds districts planned to spend
Are a Larger Percentage of   on professional development activities came from other federal, state, and
Total for High-Poverty       local funds. Title II funds represented a larger percentage of total funds
Districts                    spent on authorized activities for high-poverty districts than low-poverty
                             districts. For example, in high-poverty districts Title II funds were
                             48 percent of the funds they planned to spend for recruitment and
                             retention activities compared to 15 percent in low-poverty districts. There
                             may be several reasons for these differences. For example, Title II
                             allocated more funds to those districts with more high-poverty families,
                             and low-poverty districts may have had more local funds to contribute to
                             the total. Figure 4 shows the Title II percentage of total funds for
                             professional development activities and recruitment and retention
                             activities, for all, high-poverty, and low-poverty districts. A majority of
                             district officials said they planned to fund activities that were begun in
                             previous years.




                             Page 27                                                          GAO-03-631 No Child Left Behind
                          Figure 4: Estimated Spending of Title II Funds as a Percentage of Total Funds by
                          Activities for All Districts, High-Poverty Districts, and Low-Poverty Districts


                          Title II percentage of total funds
                          50                                     48

                          45

                          40

                          35

                          30                               28

                          25
                                        21
                                 20
                          20
                                               15                      15
                          15

                          10

                           5

                           0
                                 Professional             Recruitment
                                 development              and retention


                                          All districts

                                          All high-poverty districts

                                          All low-poverty districts

                          Source: GAO district survey.



Approximately One-Third   We estimated about one-third of all districts (34 percent) were targeting
of All Districts Were     their Title II funds as required by the act. The act requires districts to
Targeting Funds           target funds to those schools (1) with the highest number of teachers who
                          are not highly qualified, (2) with the largest class sizes, or (3) in need of
                          improvement. There was little difference between the percentages of high-
                          and low-poverty districts that targeted their funds or between urban and
                          rural districts. For example, 29 percent of high-poverty districts and
                          30 percent of low-poverty districts reported targeting some of their Title II
                          funds. Additionally, some district officials we visited said they did not
                          target funds according to the criteria listed in the act but that they targeted
                          funds in other ways such as to support math and science programs for
                          teachers and for administrative leadership programs. It may be too early
                          for district officials to fully implement this targeting requirement. Until
                          they know the true number of teachers who are highly qualified, they
                          cannot target the schools with the highest numbers of teachers who are
                          not highly qualified.



                          Page 28                                            GAO-03-631 No Child Left Behind
                     Education officials have had to interpret and help states implement many
Conclusions          new requirements established by the NCLBA, including the highly qualified
                     teacher requirement. During this first year of implementation, state
                     officials were still determining how they could assess whether their
                     teachers met all the criteria and identifying steps they needed to take to
                     meet the new requirement. Generally, state and district officials continued
                     to be challenged by many longstanding hindrances and they continued to
                     fund activities from previous years.

                     Education issued regulations and draft guidance to help states begin to
                     implement the requirement for highly qualified teachers and has plans to
                     help states with some of their challenges. However, state officials need
                     more assistance from Education, especially about methods to evaluate
                     current teachers’ subject area knowledge. Without this information state
                     officials are unsure how to assess whether their current teachers meet the
                     highly qualified requirement. This would also help them accurately
                     determine the number of teachers who are highly qualified and take
                     appropriate steps, such as deciding on which activities to spend Title II
                     funds and targeting Title II funds to schools with the highest numbers of
                     teachers who are not highly qualified. It is important that states have the
                     information they need as soon as possible in order to take all necessary
                     actions to ensure that all teachers are highly qualified by the 2005-06
                     deadline.


                     In order to assist states’ efforts to determine the number of highly qualified
Recommendation for   teachers they have and the actions they need to take to meet the
Executive Action     requirement for highly qualified teachers by the end of the 2005-06 school
                     year, we recommend that the Secretary of Education provide more
                     information to states. Specifically, information is needed about methods to
                     evaluate subject area knowledge of current teachers.


                     We received written comments on a draft of this report from Education.
Agency Comments      These comments are reprinted in appendix IV. In response to our
and Our Evaluation   recommendation related to requirements for special education teachers,
                     Education stated that the appendix of the Title I Final Regulations clarifies
                     how the highly qualified requirements apply to special education teachers.
                     Consequently, we modified the report to reflect this information and we
                     withdrew this recommendation.

                     Education indicated it plans to take steps to address our recommendation
                     on the need for information about methods to evaluate subject area


                     Page 29                                         GAO-03-631 No Child Left Behind
knowledge of current teachers. Education stated that it will continue to
work with state officials and will actively share promising strategies and
models for “high objective uniform State standard of evaluation” with
states to help them develop ways for teachers to demonstrate subject area
competency.

Also, Education commented that it views a “one–size fits all” approach to
addressing many of the issues raised in the report as undesirable because
states and districts will have to meet the requirement highly qualified
teachers in a manner that is compatible with their teacher certification,
assessment and data collection processes. Education stated that it will
provide assistance wherever possible to help states meet the requirement.
We generally agree that this is an appropriate approach.

Additionally, Education provided technical comments and we made
changes as appropriate.

We are sending copies of this report to appropriate congressional
committees, the Secretary of Education, and other interested parties.
Copies will be made available to other interested parties upon request. In
addition, the report will be available at no charge on GAO’s Web site at
http://www.gao.gov. If you have any questions about this report, please
call me at (202) 512-7215. Key contributors are listed in appendix V.




Marnie S. Shaul, Director
Education, Workforce, and
 Income Security Issues




Page 30                                       GAO-03-631 No Child Left Behind
             Appendix I: Scope and Methodology
Appendix I: Scope and Methodology


             In conducting our work, we administered a Web survey to the 50 states
             and the District of Columbia, and a separate Web survey to a nationally
             representative sample of 830 school districts, that included strata for high-
             poverty, low-poverty, rural, and urban districts. The response rate for the
             state survey was 71 percent and for the district survey 62 percent. The
             surveys were conducted between December 4, 2002, and April 4, 2003. We
             analyzed the survey data and identified significant results. See figure 5 for
             a geographic display of responding and nonresponding states.

             Figure 5: State Survey Respondents




                           Did not complete survey (14)


             Source: The 37 states that responded to GAO survey.




             The study population for the district survey consisted of public school
             districts contained in the Department of Education’s Core of Common
             Data (CCD) Local Education Agency (LEA) file for the 2000-2001 school
             year. From this, we identified a population of 14,503 school districts in the
             50 states and the District of Columbia.


             Page 31                                               GAO-03-631 No Child Left Behind
Appendix I: Scope and Methodology




Sample Design. The sample design for this survey was a stratified sample
of 830 LEAs in the study population. This sample included the 100 largest
districts and a stratified sample of the remaining districts with strata
defined by community type1 (city, urban, and rural) and by the district’s
poverty level.2 Table 7 summarizes the population, sample sizes, and
response rates by stratum.

Table 7: Population and Sample by Stratum

    Stratum                                           Districts in Districts in  Districts   Response
    number     Description                            population       sample responding          rate
    1          Largest 100 districts                          100          100          64        64%
    2          City, low poverty                              648          120          76        63%
    3          City, high poverty                             210           94          35        37%
    4          Urban, low poverty                           5,264          135          87        64%
    5          Urban, high poverty                            648          120          79        66%
    6          Rural, low poverty                           6,515          135          87        64%
    7          Rural, high poverty                          1,118          126          83        66%
               Total                                       14,503          830        511         62%
Source: GAO analysis of Education’s 2000-1 CCD data



Estimates. All estimates produced from the district sample in this report
are for a target population defined as all public school districts in the
50 states and the District of Columbia for the 2002-03 school year.
Estimates to this target population were formed by weighting the survey
data to account for both the sample design and the response rates for each
stratum. For our estimates of high- and low-poverty districts, we defined
high-poverty districts as those with participation rates in the free and



1
 “City” is defined as a central city of Consolidated Metropolitan Statistical Area (CMSA) or
as a central city of a Metropolitan Statistical Area (MSA). “Urban” refers to Urban Fringe
(an incorporated place, Census Designated Place, or nonplace territory within a CMSA or
MSA of a city and defined as urban by the Census Bureau), to a large town (an
incorporated place or Census Designated Place with a population greater than or equal to
25,000 and located outside a CMSA or MSA), or to an incorporated place or Census
Designated Place with a population less than 25,000 and greater than 2,500 located outside
a CMSA or MSA. A “rural community” is any incorporated place, Census Designated Place,
or nonplace territory designated as rural by the Census Bureau.
2
  Poverty level was not available on the CCD data files; however, as a proxy for poverty, we
stratified based on participation in the free/reduced student meals program. For sample
selection, high-poverty districts are those districts having at least 60 percent participation
in free/reduced meals programs. Less than 60 percent participation in this program
identifies a district as a low-poverty district for stratification purposes.




Page 32                                                               GAO-03-631 No Child Left Behind
Appendix I: Scope and Methodology




reduced meals program of 70 percent or above. Low-poverty districts were
defined as those with free and reduced meals program rates at 30 percent
and below. One of the advantages of this approach was that it allowed for
a sufficient number of cases in each category to conduct statistical
analyses.

Sampling Error. Because we surveyed a sample of school districts, our
results are estimates of a population of school districts and thus are
subject to sampling errors that are associated with samples of this size and
type. Our confidence in the precision of the results from this sample is
expressed in 95 percent confidence intervals. The 95 percent confidence
intervals are expected to include the actual results for 95 percent of the
samples of this type. We calculated confidence intervals for our study
results using methods that are appropriate for a stratified, probability
sample. For the percentages presented in this report, we are 95 percent
confident that the results we would have obtained if we had studied the
entire study population are within plus or minus 10 percentage points of
our results, unless otherwise noted. For example, we estimate that
34 percent of the districts target at least some funds to specific types of
schools. The 95 percent confidence interval for this estimate would be no
wider than plus or minus 10 percent, or from 24 percent to 44 percent.

Nonsampling Error. In addition to these sampling errors, the practical
difficulties in conducting surveys of this type may introduce other types of
errors, commonly referred to as nonsampling errors. For example,
questions may be misinterpreted, the respondents’ answers may differ
from those of districts that did not respond, or errors could be made in
keying questionnaire data. We took several steps to reduce these errors.

To minimize some of these errors, the state and district questionnaires
were each pretested three times to ensure that respondents would
understand the questions and that answers could be provided. To increase
the response rate, sampled districts received two calls encouraging them
to complete and return the questionnaire.

We also performed an analysis to determine whether some sample-based
estimates compared favorably with known population values.3 We
performed this analysis for 12 estimates providing information on



3
 This was possible because the CCD population file contains certain data elements for the
universe of districts from which we drew our sample.




Page 33                                                 GAO-03-631 No Child Left Behind
                                                      Appendix I: Scope and Methodology




                                                      students, teachers, number of schools, and administrators that covered
                                                      major segments those groups. For example, we did an analysis on all full-
                                                      time equivalent classroom teachers but not on teachers of ungraded
                                                      students, which is a very small proportion of all teachers. We used these
                                                      values for the 511 sample respondents to produce sample estimates to the
                                                      total population of all 14,503 districts. These estimated values, their
                                                      associated 95 percent confidence intervals, and their true population
                                                      values are presented in table 8.

Table 8: Sample Estimates Compared to Population Values

                                                                Mean per district
                                                                 estimated from Lower bound of 95         Upper bound
                                                                         survey percent confidence        of 95 percent Mean per district
 Description of estimate                                           respondents             interval confidence interval   for population
 Students with Individualized Education Programs                           455.6              391.8               519.5            424.8
 Full-time equivalent classroom teachers                                   186.0              157.8               214.2            180.8
 Students in Pre-Kindergarten to 12th grade                              3,306.8            2,851.2             3,762.3          3,168.1
 Total diploma recipients                                                  198.5                169               227.9            201.4
 Limited English proficient students                                       268.9              210.5               327.3            340.9
 Schools in district                                                         6.7                 5.9                7.5              6.2
 Local Education Authority administrators                                    4.2                 3.6                4.8              3.7
 LEA support staff                                                          11.8                 9.8               13.9             10.9
 School administrators                                                      10.4                 8.9               11.9              9.7
 School administrative support staff                                        17.3               14.6                19.9             16.5
 Student support services staff                                             10.8                 9.3               12.2             10.6
 Instructional coordinators and supervisors                                  2.9                 2.2                3.6              2.5
Source: GAO analysis of Education’s 2000-1 CCD data

                                                      Note: LEAs are also known as school districts.


                                                      For 11 out of the 12 estimates we examined, the population value falls
                                                      within the 95 percent confidence interval for the estimate, thus providing
                                                      some indication that respondents to this survey reflect the
                                                      12 characteristics we examined in the population. Although these
                                                      characteristics were selected because they might be related to other
                                                      characteristics of district teachers and district administration, we do not
                                                      know the extent to which the survey respondents would reflect the
                                                      population characteristics for the specific questions asked on our survey.
                                                      For example, we are not certain whether districts responding to the survey
                                                      were further along in the implementation of Title II requirements than the
                                                      districts that did not respond.




                                                      Page 34                                             GAO-03-631 No Child Left Behind
Appendix I: Scope and Methodology




Our sample was not designed to produce geographical area estimates, and
we did not explicitly stratify our sample by state or region. However, our
sample was selected nationally and all regions are represented in our
sample. The following table summarizes sample size and responses for
10 regions.

Table 9: Population and Sample by Region

 Region                                                    Districts in Districts in  Districts
 number      State in each region                          population       sample responding
 1           CT, ME, MA, NH, RI, and VT                          1,079           42          25
 2           NY and NJ                                           1,281           49          27
 3           DE, DC, MD, PA, VA, and WV                            731           41         26
 4           AL, FL, GA, KY, MS, NC, SC, and TN                  1,049          113         76
 5           IL, IN, MI, MN, OH, and WI                          3,413          179        111
 6           AR, LA, NM, OK, and TX                              2,061          144        100
 7           IA, KS, MO, and NE                                  1,744           54          30
 8           CO, MT, ND, SD, UT, and WY                          1,111           42          32
 9           AZ, CA, HI, and NV                                  1,375          135          62
 10          AK, ID, OR, and WA                                    659           31          22
 Total                                                          14,503          830        511
Source:

Note: for this table, we adopted the Department of Education’s region definitions as provided at
http://www.ed.gov/offices/OIIA/Regions.


On the basis of the national distribution of our sample and on the result of
our comparison of a set of survey estimates to known population values
from the CCD file, we chose to include the survey results in our report and
to produce sample based estimates to the total population of school
districts in our study population.

We chose not to report the survey responses to questions asking about the
number of highly qualified teachers because other information from the
survey and our in-depth discussions with officials during our site visits
indicated that the respondents could not accurately answer the question.
For example, three of five officials who completed the survey but did not
answer this question commented in the survey that they could not answer
because they could not count the number of teachers. Additionally, one
official who reported that 100 percent of the teachers were highly qualified
and another who reported 94 percent, also commented that they were
unable to count their teachers. During our site visits we learned that
officials did not have know the criteria for some groups of teachers, did
not have data systems to allow them to track teachers by class and



Page 35                                                        GAO-03-631 No Child Left Behind
                    Appendix I: Scope and Methodology




                    therefore, could not accurately determine how many teachers were highly
                    qualified.


Other Methodology   We also visited 8 states with a range of characteristics that might affect
                    their meeting Title II requirement for highly qualified teachers. Those
                    states were California, Connecticut, Illinois, Iowa, Maryland, North
                    Carolina, Delaware, and Wyoming. We visited and interviewed officials in
                    2 districts in each state, one of which was a high-poverty district, and one
                    school in each district. We interviewed Department of Education officials,
                    and officials and representatives from several professional organizations.
                    We also reviewed the legislation, the regulations, and guidance as well as
                    related reports and other relevant documents. We conducted our work
                    between July 2002 and May 2003 in accordance with generally accepted
                    government auditing standards.




                    Page 36                                        GAO-03-631 No Child Left Behind
                                                         Appendix II: Activities on Which States Can
Appendix II: Activities on Which States Can              Spend Title II, Part A Funds



Spend Title II, Part A Funds

                                                         Table 10 lists our summaries of the authorized activities on which states
                                                         can spend Title II funds and shows the five categories we used to group
                                                         them.

Table 10: Title II, Part A State Activities

 Category                                 Activity
 Accountability                           1. Developing systems to measure the effectiveness of professional development programs and
                                              strategies to document improvements in students’ academic achievement.
                                          2. Ensuring that teachers use challenging state academic content standards, assessments, and
                                              student achievement standards to improve their teaching practices and their students’ achievement.
 Certification                            3. Reforming teacher and principal certification.
                                          4. Reforming tenure and implementing tests for subject matter knowledge.
                                          5. Promoting license and certification reciprocity agreements with other states for teachers and
                                              principals.
                                          6. Providing programs that establish, expand, or improve alternative routes for state certification,
                                              especially for highly qualified individuals in the areas of mathematics and science.
 Professional development                 7. Conducting programs that provide support to teachers, such as those that provide teacher
                                              mentoring
                                              and use assessments that are consistent with student academic achievement standards.
                                          8. Providing professional development for teachers and principals.
                                          9. Developing or assisting local educational agencies (LEAs) in developing and using, proven
                                              innovative strategies for intensive professional development programs that are both cost effective
                                              and easily accessible.
                                          10. Encouraging and supporting the training of teachers and administrators to integrate technology into
                                              curricula and instruction, including training to improve their ability to use data to improve their
                                              teaching.
                                          11. Providing assistance to teachers to enable them to meet certification, licensing, or other Title II
                                              requirements needed to become highly qualified.
 Recruitment and retention                12. Developing or assisting LEAs to develop, merit-based performance systems and strategies that
                                              provide pay differentials and bonus pay for teachers in academic subjects in which there is high
                                              need.
                                          13. Developing projects and programs to encourage men to become elementary teachers.
                                          14. Establishing and operating a statewide clearinghouse and programs for the recruitment, placement,
                                              and retention of teachers.
                                          15. Assisting LEAs and schools in recruiting and retaining highly qualified teachers, including
                                              specialists in core subjects.
                                          16. Developing or assisting LEAs to develop, teacher advancement initiatives that promote professional
                                              growth, and emphasize multiple career paths and pay differentiation.
 Technical assistance                     17. Fulfilling the state agency’s responsibility to properly and efficiently carry out the administration of
                                              programs, including providing technical assistance to LEAs.
                                          18. Assisting LEAs to develop and implement professional development programs and school
                                              leadership academies for principals and superintendents.
Source: NCLBA Pub.L. No. 107-110, section 2113 (2002).




                                                         Page 37                                                   GAO-03-631 No Child Left Behind
               Appendix III: Activities on Which Districts
Appendix III: Activities on Which Districts
               Can Spend Title II, Part A Funds



Can Spend Title II, Part A Funds

               Table 11 lists our summaries of the authorized activities on which districts
               can spend Title II funds and shows the two categories we used to group
               them.

               Table 11: Title II, Part A District Activities

                Category                                Activity
                Professional development                1. Providing professional development activities for
                                                            teachers and principals that improve their knowledge
                                                            of their core subjects and effective instructional
                                                            strategies.
                                                        2. Carrying out professional development activities
                                                            designed to improve the quality of principals and
                                                            superintendents .
                                                        3. Carrying out teacher advancement initiatives to
                                                            promote professional growth and to emphasize
                                                            multiple career paths and pay differentiation.
                                                        4. Carrying out programs and activities that are designed
                                                            to improve the quality of teachers, such as
                                                            professional development programs, merit pay
                                                            programs, and testing teachers in the subjects they
                                                            teach.
                Recruitment and retention               5. Developing and implementing mechanisms to assist
                                                            schools in effectively recruiting and retaining highly
                                                            qualified teachers and principals.
                                                        6. Developing and implementing initiatives to retain
                                                            highly qualified teachers and principals, particularly in
                                                            schools with a high percentage of low-achieving
                                                            students; including programs that provide teacher
                                                            mentoring and incentives.
                                                        7. Carrying out programs and activities related to
                                                            exemplary teachers.
                                                        8. Developing and implementing initiatives to assist
                                                            schools in recruiting and hiring teachers, including
                                                            providing financial incentives, and establishing
                                                            programs that train and hire special education and
                                                            other teachers, recruit qualified professionals from
                                                            other fields, and provide increased opportunities for
                                                            minorities, individuals with disabilities and others.
                                                        9. Hiring highly qualified teachers in order to reduce class
                                                            size, particularly in the early grades.
               Source: NCLBA Pub.L. No. 107-110, section 2123 (2002).




               Page 38                                                            GAO-03-631 No Child Left Behind
              Appendix IV: Comments from the U.S. Department of Education
Appendix IV: Comments from the U.S.
Department of Education




              Page 39                                              GAO-03-631 No Child Left Behind
Appendix IV: Comments from the U.S. Department of Education




Page 40                                              GAO-03-631 No Child Left Behind
Appendix IV: Comments from the U.S. Department of Education




Page 41                                              GAO-03-631 No Child Left Behind
                  Appendix V: GAO Contacts and Staff
Appendix V: GAO Contacts and Staff
                  Acknowledgments



Acknowledgments

                  Carolyn M. Taylor (202) 512-2974 or taylorcm@gao.gov
GAO Contacts      Mary E. Roy (202) 512-7072 or roym@gao.gov


                  In addition to those named above, the following individuals made
Staff             important contributions to this report: Susan Higgins, Anjali Tekchandani,
Acknowledgments   David Garten, Joel Grossman, Richard Kelley, Mark Ramage, Minnette
                  Richardson, Susan Bernstein, and Jeff Edmondson.




(130144)
                  Page 42                                       GAO-03-631 No Child Left Behind
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