oversight

Safe and Drug-Free Schools: Balancing Accountability With State and Local Flexibility

Published by the Government Accountability Office on 1997-10-10.

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

                United States General Accounting Office

GAO             Report to Congressional Requesters




October 1997
                SAFE AND DRUG-FREE
                SCHOOLS
                Balancing Accountability
                With State and Local
                Flexibility




GAO/HEHS-98-3
      United States
GAO   General Accounting Office
      Washington, D.C. 20548

      Health, Education, and
      Human Services Division

      B-277093

      October 10, 1997

      The Honorable J. Dennis Hastert
      Chairman, Subcommittee on National Security, International Affairs,
        and Criminal Justice
      Committee on Government Reform and Oversight
      House of Representatives

      The Honorable Tom Harkin
      Ranking Minority Member, Subcommittee on Labor, Health
        and Human Services, and Education
      Committee on Appropriations
      United States Senate

      When the Safe and Drug-Free Schools and Communities Act was enacted
      in 1994, about 3 million thefts and violent crimes occurred on or near
      school campuses each year—nearly 16,000 incidents per school day. About
      one in five high school students regularly carried a firearm, knife, razor,
      club, or other weapon. After declining in the eighties, drug use rates
      among school-age youth increased between 1992 and 1995 for more than
      10 different types of drugs. For example, one study reported that the rate
      of marijuana use by eighth grade students more than doubled—from about
      7 to about 16 percent—and the rate for twelfth graders rose from about 22
      to about 35 percent.1

      Since 1986, the federal government has awarded over $4 billion to states
      for implementing school-based drug- and violence-prevention programs
      authorized by the Drug-Free Schools and Communities Act and its
      successor, the Safe and Drug-Free Schools and Communities Act of 1994.
      One of the purposes of the Safe and Drug-Free Schools and Communities
      Act is to help the nation’s schools provide a disciplined environment
      conducive to learning by eliminating violence in and around schools and
      preventing illegal drug use.

      The Safe and Drug-Free Schools and Communities Act authorizes funding
      at federal, state, and local levels for programs supporting this purpose.
      Under the largest program funded under the act, the Department of
      Education awards grants to state education agencies (SEA) mainly for
      further distribution to local education agencies (LEA). In school year



      1
        Monitoring the Future, National Institutes of Health, National Institute on Drug Abuse (Rockville, Md.:
      1996).



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                                                 1995-96, $350 million of the $466 million appropriated for expenditure
                                                 under the act was awarded to SEAs.2 (See fig. 1.)



    Figure 1: How Funding Reaches States and Local Schools, Fiscal Year 1995


                                The Congress
                                Authorizes and
                                                                                                              State
                                 Appropriates
                                                                                                           Administration
                                  $441 Million                             State              4%
                                                                         Educational                        $13.8 Million
                                                                          Agencies
       Governors’           U.S. Dept. of Education                                                            State
                                                                        $344.2 Million         5%
        Offices             Allocates and Disburses                                                           Activities
                                                                               91%
       $86.1 Million                                                                                        $17.2 Million
                                                                           Local
                                                                    Educational Agencies
                                  Legislated
                                                                         $313.2 Million
                                  Set Asides
                                                                      70%          30%
                                 $10.7 Million                      Based on     Based on
                                                                   Enrollment      Need
                                                                  $219.2 Million $94 Million




                                                                        Local Schools




                                                 Among the changes the Safe and Drug-Free Schools and Communities Act
                                                 made to the previous law were changes to increase accountability, that is,
                                                 to better ensure that the activities supported by these funds are consistent
                                                 with the act’s general purposes. The act and its legislative history also


                                                 2
                                                  The remainder of the money under the state grants program is distributed through the governors’
                                                 program, which is used for grants to or contracts with a variety of groups, organizations, and agencies.
                                                 In general, each state’s allocation is determined by the size of its school-age population and the
                                                 amount of part A, title I funding the state received in the previous year for providing supplementary
                                                 educational services to low-achieving children in high-poverty areas. In school year 1995-96, the Safe
                                                 and Drug-Free Schools state grant provided $7.90 per student for illegal drug- and violence-prevention
                                                 programs.
1

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                   indicate the importance of acknowledging local differences in defining
                   measurable goals and objectives—differences reflecting local needs—and
                   ways progress toward them will be assessed and reported. Under the act,
                   SEAs and LEAs are accountable for progress toward the goals and objectives
                   they set as well as for the federal dollars they spend. Increased
                   accountability was a key issue raised in congressional deliberations about
                   the act: critics of programs operated under the previous law claimed that
                   some of the activities were inappropriate and would not contribute to
                   accomplishing the goal of reducing student drug use.

                   To address these concerns, you asked us to review the following:
                   (1) accountability measures the Safe and Drug-Free Schools and
                   Communities Act requires at the federal, state, and local levels;
                   (2) activities Education uses for overseeing state and local programs;
                   (3) how SEAs ensure local programs’ compliance with the act; and (4) how
                   Safe and Drug-Free Schools funding is specifically used at the state and
                   local levels. To determine required accountability measures, we reviewed
                   the act and its legislative history. To assess Education’s oversight
                   measures, we reviewed documents at Department headquarters and
                   followed up on allegations of impropriety in three states (Michigan,
                   Virginia, and West Virginia), reviewing documentation and interviewing
                   state and local officials involved in the alleged impropriety and its
                   investigation and resolution (see app. I). To assess compliance and other
                   activities at the state and local levels, we surveyed the 50 states, the
                   District of Columbia, and Puerto Rico about their activities and reviewed
                   supporting documentation, such as report forms and evaluation reports.
                   (See app. II.)


                   The Safe and Drug-Free Schools program is one of several substance
Results in Brief   abuse- and violence-prevention programs funded by the federal
                   government. The act that authorizes the program requires a variety of
                   federal, state, and local actions to ensure accountability. These actions
                   involve four major types of accountability mechanisms: (1) an application
                   process, requiring approval of state and local program plans;
                   (2) monitoring activities by state agencies; (3) periodic reports and
                   evaluations; and (4) the use of local or substate regional advisory councils.
                   In combination, these mechanisms address accountability for both how
                   funds are spent and progress toward achieving national, state, and locally
                   defined goals.




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Education oversees state programs directly and local programs indirectly
through required state actions. Its state oversight is a combination of
activities required by the act and other generally applicable requirements.
Working along with states, Education reviews, helps states to revise, and,
finally, approves state plans—which include a description of planned
state-level activities, criteria for selecting high-need districts that will
receive supplemental funds, and plans for monitoring local activities—
before disbursing funds. In addition, Education conducts on-site
monitoring visits. To allow states and localities enough flexibility to meet
their needs, Education has issued no program-specific regulations on the
act. Education does, however, require states to conform to general and
administrative regulations and advises states on program matters, such as
allowable expenditures, through nonbinding guidance. In addition, the
Department may get involved in resolving allegations of impropriety in the
use of funds. For example, Education, in response to allegations about
Drug-Free Schools programs, reviewed programs in West Virginia and
participated in resolving adverse audit findings in Michigan.

To date, no overall evaluations of the Safe and Drug-Free Schools program
have been completed. In addition to its activities intended to ensure that
funds are spent appropriately, however, Education conducts evaluation
activities designed to provide both descriptive and evaluative information
about the programs. The descriptive information should document the
nature and extent of school violence, as well as the characteristics of
federally funded violence-prevention programs and their activities,
including those of the Safe and Drug-Free Schools program. Education’s
evaluative activities focus on broader aspects of program implementation,
such as promising practices and program improvement processes, but will
not specifically assess the effectiveness of all Safe and Drug-Free Schools
programs nationwide. Instead, Education is indirectly gathering
information about the effectiveness of specific state and local programs
through reports states must submit to Education every 3 years. The lack of
uniformity in what states report, however, may create a problem for
federal oversight. A survey of LEAs may provide additional information on
local program effectiveness, but that study is still in the planning stages.

Nearly all states use the approved local plans as the primary means for
helping to ensure local programs’ compliance with the act’s requirements.
States use local compliance with the approved plans as a way of ensuring
that funds are spent on activities permitted under the act. Under the act,
each state may establish its own reporting requirements for LEAs. Although
these requirements have some common elements—40 states require a



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             program report, and 42 states require a financial report—state
             requirements generally vary widely. Most states use both on-site visits and
             local self-reports to oversee local program activities. States also resolve
             allegations of impropriety, as in the Virginia case we reviewed. LEAs are
             also required to evaluate the effectiveness of their programs, but most
             states reported in our survey that they had little specific knowledge of the
             content or results of these evaluations.

             SEAs and LEAs use Safe and Drug-Free Schools funds for a variety of
             activities, as permitted by the act. States mostly use their 5-percent set
             aside for activities, such as training and technical assistance, although they
             also use the funds for such activities related to curriculum development,
             violence prevention, state-level evaluations, and demonstration projects.
             Services provided by 60 percent or more of LEAs nationwide include drug-
             prevention instruction for students; staff training; general violence-
             prevention instruction; special one-time events, such as guest speakers,
             drug- and alcohol-free social activities, such as a dance or picnic; parent
             education/involvement; student support services, such as counseling and
             referral services; and curriculum development and acquisition. Ninety-one
             percent of LEAs provide drug-prevention instruction. Staff training is the
             next most offered activity, with 77 percent of districts reporting such
             training.


             In October 1994, the Improving America’s Schools Act, which reauthorized
Background   education programs under the Elementary and Secondary Education Act
             of 1965 (ESEA), revised and expanded drug education under the Safe and
             Drug-Free Schools and Communities Act of 1994, which is title IV of ESEA.
             The purpose of the Safe and Drug-Free Schools Act is to create a
             comprehensive program to support National Education Goal Seven, which
             is “by the year 2000, every school in the United States will be free of drugs,
             violence, and the unauthorized presence of firearms and alcohol and will
             offer a disciplined environment conducive to learning.” School year
             1995-96 was the first school year in which the program was in effect.

             Safe and Drug-Free Schools grants have some of the broad characteristics
             of block grants that we have identified in previous work.3 For example, the
             act authorizes federal aid for a wide range of activities within a broadly
             defined functional area; recipients have substantial discretion to identify

             3
              Block grants provide significant discretion to states and localities to define and implement federal
             programs according to local needs and conditions. For a complete list of the characteristics of block
             grants as well as the issues involved in ensuring accountability in block grant programs, see Block
             Grants: Issues in Designing Accountability Provisions (GAO/AIMD-95-226, Sept. 1, 1995).



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                                 problems, design programs, and allocate resources; federally imposed
                                 requirements are limited to those necessary to ensure that national goals
                                 are being accomplished; and federal aid is distributed on the basis of a
                                 statutory formula. For such grants, accountability plays a critical role in
                                 balancing the potentially conflicting objectives of increasing state and
                                 local flexibility, while attaining certain national objectives.


Safe and Drug-Free               The Safe and Drug-Free Schools program is discussed as part of
Schools Part of                  Education’s strategic plan required by the Government Performance and
Education’s Strategic Plan       Results Act of 19934 (the Results Act). The Results Act requires executive
                                 agencies, including Education, to develop a 5-year strategic plan that
                                 includes long-term strategic goals,5 establish annual performance goals,
                                 and report on progress toward those goals and objectives. Education’s
                                 draft strategic plan for 1998-2002 includes an objective for safe,
                                 disciplined, and drug-free schools.6 Education’s statement of core
                                 strategies for achieving this objective make it clear that Safe and Drug-
                                 Free Schools will play a major role. In addition, the program is specifically
                                 cited in one of the six performance indicators that Education has chosen
                                 for assessing accomplishment of this objective. These indicators are to

                             •   slow recently increasing rates of alcohol and drug use among school-aged
                                 children by 2000;
                             •   achieve continuous decreases in criminal and violent incidents in schools
                                 by students between now and 2002;
                             •   realize continuous improvement in the percentage of students reporting
                                 negative attitudes toward drug and alcohol use between now and 2002;




                                 4
                                  The Government Performance and Results Act of 1993 is intended to improve the efficiency and
                                 effectiveness of federal programs by establishing a system to set goals for program performance and to
                                 measure results. Specifically, the Results Act requires executive agencies to prepare multiyear
                                 strategic plans and annual performance plans and reports. For general information on implementation
                                 of the Results Act, see The Government Performance and Results Act: 1997 Governmentwide
                                 Implementation Will Be Uneven (GAO/GGD-97-109). For specific information on Education’s plan, see
                                 The Results Act: Observations on the Department of Education’s June 1997 Draft Strategic Plan
                                 (GAO/HEHS-97-176R, July 18, 1997).
                                 5
                                  The first 5-year strategic plan must be submitted to the Congress by Sept. 30, 1997.
                                 6
                                  See U.S. Department of Education: Strategic Plan, 1998-2002, Draft for Consultation and Review
                                 (Washington, D.C.: June 17, 1997).



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                            •   improve prevention programs by having the majority of LEAs participating
                                in the Safe and Drug-Free Schools program use prevention programs
                                based on Education’s principles of effectiveness by 1999;7
                            •   ensure, by 1999, that all states collect data statewide on alcohol and drug
                                use among students and violence in schools; and
                            •   increase significantly by 2000 the number of teachers who are
                                appropriately trained to address discipline problems.


Other Federal Laws and          The Safe and Drug-Free Schools program, like other Education programs,
Regulations Also Set            is subject to other federal laws and generally applicable regulations in the
Accountability                  use of its funds and program operations. For example, the Education
                                Department General Administrative Regulations apply to the Safe and
Requirements for Safe and       Drug-Free Schools and Communities program as well as other grant
Drug-Free Schools               programs. These regulations establish uniform requirements for
Program                         administering Education grants and principles to determine costs for
                                activities assisted by the Department. In addition, the Single Audit Act
                                requires each state to conduct annual independent audits of programs in
                                the state that receive federal funds.

                                Some aspects of the Safe and Drug-Free Schools program are also affected
                                by the general provisions of the Improving America’s Schools Act of 1994.
                                In particular, the Improving America’s Schools Act authorizes states to
                                submit a single application for several federal education programs rather
                                than separate program-specific applications. The new consolidated
                                application process, which began with school year 1995-96 funds for
                                Education programs, including the Safe and Drug-Free Schools program, is
                                intended to enhance program integration and reduce SEAs’ administrative
                                burden.

                                The Improving America’s Schools Act also requires Education to establish
                                procedures and criteria under which a SEA may submit a consolidated
                                application or plan. Education’s guidelines state that the consolidated plan
                                should provide a framework for determining, within the context of a
                                state’s school reform plan and other reform initiatives, how the federal




                                7
                                 These principles were published in a notice soliciting public comments in the July 16, 1997, edition of
                                the Federal Register. The principles would require LEAs to develop Safe and Drug-Free programs on
                                the basis of an objective analysis of the need for drug- and violence-prevention services and to use
                                program approaches whose effectiveness has been demonstrated through research.



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                         programs in the consolidated plan will be used to help all children reach
                         the state’s academic achievement goals.8

                         Education’s guidance for the consolidated applications requires states to
                         include some, but not all, of the information required in comprehensive
                         state plans by the Safe and Drug-Free Schools and Communities Act.
                         States must include in their consolidated application their criteria for
                         selecting LEAs for supplemental high-need funding, their plans for spending
                         the 5-percent set aside for state-level program activities, and their process
                         for approving local plans for funding.


Many Programs Support    While the Safe and Drug-Free Schools program’s explicit goal is to reduce
National Safe and        drug use and violence in schools, other programs are also likely to
Drug-Free Schools Goal   influence progress toward this national goal. The Safe and Drug-Free
                         Schools program is one of several substance abuse- and violence-
                         prevention programs funded by the federal government. For example, in
                         fiscal year 1995, 70 federal programs were authorized to provide either
                         substance abuse-prevention or violence-prevention services or both to the
                         youth they serve.9 Thirty-four of these programs could provide both types
                         of prevention services. Education, which administers the Safe and
                         Drug-Free Schools program, along with the Departments of Health and
                         Human Services and Justice, administered most of these programs, 48 in
                         all, but the rest of the programs were disbursed among 10 other federal
                         agencies or entities. For these 70 programs, the fiscal year 1995
                         appropriations for services to youth totaled at least $2.4 billion.

                         Multiple programs dispersed among several agencies creates the potential
                         for inefficient services and ineffective use of funds. Although we have not
                         fully examined these multiple programs, the implications of having
                         multiple, unintegrated substance abuse- and violence-prevention programs
                         might be like those for employment training programs—an area we have
                         examined. In fiscal year 1995, we identified 163 federal employment
                         training programs located in 15 departments and agencies. We recently
                         concluded that consolidating these programs could probably reduce the
                         cost of providing job training services because of the efficiencies achieved
                         by eliminating duplicative administrative activities. Furthermore,


                         8
                          If a state submits and has approved a consolidated application, rather than a comprehensive one, the
                         state may require LEAs receiving funds from more than one program to submit consolidated LEA
                         applications that cover all applicable programs.
                         9
                         See Substance Abuse and Violence Prevention: Multiple Youth Programs Raise Questions of
                         Efficiency and Effectiveness (GAO/T-HEHS-97-166, June 24, 1997).



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                           consolidating similar programs could improve opportunities to increase
                           service delivery and effectiveness.10


Questions Raised About     During the past several years, some members of the Congress, in response
Program Expenditures and   to constituents’ concerns, have questioned how some states and localities
Activities                 have used funding under both the Drug-Free Schools and Communities
                           Act and Safe and Drug-Free Schools and Communities Act programs.
                           Allegations about misuse of funds have spanned diverse areas of program
                           operation, from curriculum content to administrative expenses. In
                           particular, questions have been raised about the extent to which these
                           funds can be used to support programs, such as comprehensive health
                           education programs, of which drug prevention is just one part; the types of
                           activities sponsored by schools, such as alcohol-free dances; and
                           expenditures for materials, such as pencils and tee-shirts imprinted with
                           drug- and violence-prevention messages (see app. I for the results of our
                           examination of some allegations).


                           The Safe and Drug-Free Schools and Communities Act establishes
Act Requires Federal,      accountability mechanisms at the federal, state, and local levels. In
State, and Local           combination, these mechanisms provide accountability for both spending
Actions to Ensure          funds (financial accountability) and reaching national, state, and locally
                           defined goals (program accountability). The act specifies no mechanisms
Accountability             for direct federal oversight of local activities. Rather, the act’s mechanisms
                           for federal oversight of the program focus on state-level programs and
                           activities, while relying on state actions for local program oversight. The
                           act establishes four types of accountability mechanisms: (1) an application
                           process that requires approval of state and local plans; (2) state
                           monitoring of LEAs’ programs; (3) reports on national, state, and local
                           program effectiveness; and (4) LEAs’ use of advisory councils to develop
                           program plans and assist program implementation.


Federal Requirements       Education executes two of the four actions required by the act for
Focus on State Plans,      ensuring accountability in the Safe and Drug-Free Schools program:
National Assessments       approving state plan applications and reporting on national, state, and
                           local program effectiveness.11 The act requires Education to review and


                           10
                            See Department of Labor: Challenges in Ensuring Workforce Development and Worker Protection
                           (GAO/T-HEHS-97-85, Mar. 6, 1997).
                           11
                             The application approval action also includes approval of local plans for which states are
                           responsible.



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                            ensure that state plans for Safe and Drug-Free Schools programs conform
                            with federal requirements before providing funding to a state. The act also
                            directs Education to use a peer review or similar process in reviewing
                            state plans and provides detailed requirements for the contents of the state
                            plan. For example, under the act, states must include in their plans
                            (1) measurable goals and objectives for their drug- and violence-
                            prevention programs, (2) a description of state-level program activities,
                            (3) their plans for monitoring LEAs’ programs, and (4) the state’s criteria
                            for identifying high-need districts that will receive supplemental funding
                            for drug- and violence-prevention programs.

                            The act also requires Education to gather data about school violence and
                            drug abuse and to assess the effectiveness of drug- and violence-
                            prevention activities under the Safe and Drug-Free Schools program and
                            other recent federal initiatives. Education expects to report the results of
                            these assessments, along with its recommendations, to the Congress by
                            January 1998. The act also requires, indirectly, that Education collect data
                            from states on the effectiveness and outcomes of state and local programs.
                            That is, under the act, LEAs must provide the state with information about
                            their programs’ effectiveness, which states must then use in their required
                            reports to Education.


Federal Requirements for    Under the act, states must use application approval, program monitoring,
States Focus on Oversight   and reporting as accountability mechanisms for ensuring that Safe and
of Local Programs           Drug-Free Schools programs conform with federal requirements. States
                            must review applications from LEAs to determine if they are eligible for
                            funding. Through the application process, states must ensure that each LEA
                            receiving funds has (1) measurable goals for its drug- and violence-
                            prevention program, (2) objectively assessed students’ current use of
                            drugs and alcohol as well as violence and safety problems in its schools,
                            and (3) developed plans for a comprehensive drug- and violence-
                            prevention program. The comprehensive plan must describe how the LEA
                            will use its funds; coordinate its efforts with communitywide efforts and
                            other related federal, state, and local programs under this or other acts;
                            and report progress toward the LEA’s drug- and violence-prevention goals.
                            In addition, states may also require the submission of other necessary
                            information and assurances. The act requires each state to monitor local
                            program implementation and report to Education on its progress toward
                            its drug- and violence-prevention goals.




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                           Although the act lists several general oversight responsibilities for states,
                           it does not clearly specify actions states must take to meet these
                           responsibilities. For example, although states must monitor local program
                           implementation, the act leaves states to determine how to do this. In
                           addition, it authorizes states to develop their own reporting requirements
                           for LEAs and determine when LEAs must report on their programs.

                           The act requires LEAs to consult with local or substate regional advisory
                           councils in developing applications for state funds. These councils also
                           regularly review program evaluations and other relevant material and
                           make recommendations to LEAs for improving drug- and violence-
                           prevention programs. In addition, these councils distribute information
                           about drug- and violence-prevention programs, projects, and activities
                           conducted by LEAs and advise LEAs on coordinating such agency activities
                           with other related programs, projects, and activities as well as on the
                           agencies administering such programs, projects, and activities.
                           Education’s General Administrative Regulations require the state to
                           oversee the LEA programs to ensure that such advisory councils are used
                           as intended. Because the focus of our analysis was to describe and assess
                           the accountability measures used at the federal and state levels, we did not
                           assess how these advisory councils operate at the local level.


Act Also Sets              The act, in addition to establishing actions federal, state, and local
Requirements for Program   agencies must take to ensure accountability, has some requirements for
Content and Activities     program content and the types of activities permitted under the law. These
                           requirements are broadly stated, permitting significant discretion at the
                           state and local levels. The act also includes some prohibitions on how
                           funds may be used and restricts Education’s activities regarding
                           curriculum that may be used in state and local programs.


Comprehensive Programs     Local drug- and violence-prevention programs under the act must be
Mandated                   comprehensive. The act requires that comprehensive programs be
                           designed for all students and employees. Programs for students must be
                           designed to prevent use, possession, and distribution of tobacco, alcohol,
                           and illegal drugs; prevent violence and promote school safety; and create a
                           disciplined environment conducive to learning. For employees, the
                           program must be designed to prevent the illegal use, possession, and
                           distribution of tobacco, alcohol, and illegal drugs. The act also requires
                           these comprehensive programs to include activities that promote the




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                          involvement of parents and coordination with community groups and
                          agencies.

Activities Allowed        The act identifies a wide range of programs and activities that a LEA may
                          include in its comprehensive program, though the act does not limit LEAs
                          to the examples it provides. For example, programs noted as permissible
                          include comprehensive drug prevention; comprehensive health education,
                          early intervention, student mentoring, and rehabilitation referral programs
                          that promote individual responsibility and offer techniques for resisting
                          peer pressure to use illegal drugs; and before- and after-school
                          recreational, instructional, cultural, and artistic programs in supervised
                          community settings.12

                          Activities allowed for these programs include the distribution of drug-
                          prevention information; professional development of school personnel,
                          parents, and law enforcement officials through activities such as
                          workshops and conferences; implementation of strategies that integrate
                          services to fight drug use such as family counseling, early intervention
                          activities to prevent family dysfunction and enhance school performance;
                          and activities designed to increase students’ sense of community such as
                          community-service projects. Funds may also be used for metal detectors,
                          safe-passage zones—crime- and drug-free routes students may take to and
                          from school—and security personnel; such uses, however, are limited to
                          no more than 20 percent of a LEA’s funds and are allowed only if a LEA has
                          not received other federal funding for these activities. The law explicitly
                          prohibits use of program funds for construction (except for minor
                          remodeling), medical services, or drug treatment or rehabilitation.


Materials and Curricula   Materials used in Safe and Drug-Free Schools programs must convey a
Allowed                   clear and consistent message that the illegal use of alcohol and other drugs
                          is wrong and harmful. The Secretary of Education may not prescribe the
                          use of any specific program curricula but may evaluate the effectiveness of
                          the curricula and strategies used.




                          12
                            The emphasis on a comprehensive program and the wide range of activities allowed by the act are
                          consistent with the findings of our previous studies: see Drug Control: Observations on Elements of
                          the Federal Drug Control Strategy (GAO/GGD-97-42, Mar. 14, 1997); School Safety: Promising
                          Initiatives for Addressing School Violence (GAO/HEHS-95-106, Apr. 25, 1995); and Adolescent Drug
                          Use Prevention: Common Features of Promising Community Programs (GAO/PEMD-92-2, Jan. 16,
                          1992).



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Distribution of Funds       Most of the funds for state and local drug- and violence-prevention
                            programs must be distributed to LEAs. From the funds awarded to SEAs for
                            state and LEA grant activities, SEAs may reserve no more than 5 percent for
                            statewide activities and no more than 4 percent for program
                            administration. The remaining funds (at least 91 percent) must go to LEAs;
                            in school year 1995-96, this amounted to $313 million. Thirty percent of
                            this amount, $94 million in school year 1995-96, must go to LEAs that the
                            state has determined have the greatest need for additional funds to carry
                            out drug- and violence-prevention programs. The act requires states to
                            provide these supplemental funds to no more than 10 percent of the state’s
                            LEAs, or five such LEAs, whichever is greater.



                            Education uses several mechanisms to execute its responsibilities for
Education Uses State        ensuring program accountability. Some of these mechanisms are required
Application Process,        by the Safe and Drug-Free Schools and Communities Act; others are
Monitoring, and             required or permitted under other generally applicable laws and
                            regulations such as the Single Audit Act and the Education Department
Reports for Program         General Administrative Regulations. Some of these activities—such as the
Oversight                   application review process—are intended to ensure that program activities
                            and expenditures comply with federal requirements. Others seek to
                            determine if programs are addressing national goals.


Plans Form Basis for        State and local plans form the basis for Safe and Drug-Free Schools
Accountability              accountability. States cannot get Safe and Drug-Free Schools funds
                            without submitting a plan consistent with the act and approved by
                            Education. Education reviews states’ plans for compliance with the act
                            and other federal requirements and for program quality. In addition, state
                            plans provide Education with detailed information on what states want to
                            accomplish with their funding and their program management strategy.


Education Properly          Our review of Education’s files on 16 state plans for school years 1995-96
Reviewed Applications for   and 1996-9713 showed that Education, as required by the act, reviewed
School Years 1995-96 and    state plans and required states to revise plans that did not conform with
                            the law’s requirements before disbursing funding to the states. Education
1996-97                     reviewed each application to ensure the completeness and sufficiency of
                            the information provided. When reviewers identified missing or inadequate
                            information, they asked the states to provide additional information, and

                            13
                             We reviewed files for the following states: Connecticut, Delaware, Illinois, Indiana, Iowa,
                            Massachusetts, Michigan, Missouri, Nebraska, Nevada, New York, Rhode Island, Tennessee, Texas,
                            West Virginia, and Wyoming.



                            Page 13                                            GAO/HEHS-98-3 Safe and Drug-Free Schools
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Education notified states on time that they would receive their grant
awards.

For school year 1996-97, states submitted their plans on time, and
Education again reviewed the plans for conformity with federal
requirements. Although Education sometimes requested additional
information from states before awarding Safe and Drug-Free Schools
funding, the Department also approved some state plans conditionally. In
these cases, Education specified in states’ grant award documents
additional time—1 year—for them to revise their plans to conform with
federal requirements.

Education established procedures for its review of state plans and
provided its staff with checklists and other forms on which to document
the results of these reviews. These procedures varied little for the 2 years
encompassing our review. Education documented the results of its review
in departmental records, including at least a copy of each state’s plan, the
reviewers’ comments, material from each state responding to Education’s
request for supplemental information, and grant award documents.

In both years, Education’s review included checks for compliance with the
act. For example, Safe and Drug-Free Schools program staff initially
reviewed plans, checking to make sure each state plan had all of the law’s
required assurances, signatures, and plan components. Education asked
states whose plans did not pass this review to supply the missing
information. Program staff also read state plans, documenting any planned
activities that failed to conform with or fully satisfy federal requirements.
Program staff then shared the results of this review with state officials,
requested additional information, or suggested plan revisions.

Education also reviewed state plans for quality as part of its plan approval
process for the 2 years we reviewed. For school year 1995-96 plans,
Education’s Safe and Drug-Free Schools program staff conducted this
review and raised questions with state officials about a variety of program
quality issues such as the planned program’s ability to address assessed
needs. For school year 1996-97 plans, Education used a peer review
process, with program staff from various Office of Elementary and
Secondary Education programs as reviewers along with external experts.
Education’s process for the quality review was essentially the same for
1996-97 plans as it had been for 1995-96 plans.




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                        B-277093




Education Conducts      Education also monitors states’ activities. Monitoring activities include
Monitoring Activities   state and local visits, reviews of state audit findings, and investigations by
                        Education’s Inspector General (IG). Each monitoring visit involves an
                        initial visit to a SEA; subsequent visits to local school districts may also be a
                        part of the monitoring visit.

                        Until September 1994, Education’s on-site monitoring visits were program
                        specific; that is, they were made only to review Drug-Free Schools’ state
                        and local program activities. In school year 1993-94, Education conducted
                        program-specific monitoring reviews in three states; in school year
                        1994-95, Education conducted two such reviews. The Department used a
                        variety of criteria to select states for on-site reviews, including complaints.

                        In September 1994, however, Education changed the way it conducted
                        on-site monitoring reviews. The Department’s new process—called an
                        integrated review process—uses an entire team of Education officials14
                        representing all the federal education programs in which a state
                        participates to review a state’s use of federal aid to reach its educational
                        goals. Education piloted this integrated review process in school year
                        1994-95, visiting five states. In school year 1996-97, Education visited 20
                        states to conduct integrated reviews, which included reviews of Safe and
                        Drug-Free Schools programs.

                        In addition, the Department has in the past visited states to resolve
                        allegations of impropriety related to the use of funds under the Drug-Free
                        Schools and Communities Act. Education did so in West Virginia in 1992
                        and in resolving adverse audit findings in Michigan in 1994. In West
                        Virginia, Education received a complaint letter from a parent and directed
                        the state superintendent of education to investigate. Education officials
                        twice visited West Virginia—first in 1992 and again in 1994—in response to
                        complaints about the curriculum used in one LEA’s Drug-Free Schools
                        program. As part of their review, federal officials interviewed state and
                        local education officials and reviewed relevant curriculum materials.

                        In Michigan, state auditors questioned some LEA expenditures under the
                        Drug-Free Schools and Communities Act. The findings were reviewed by
                        Education’s IG and the program staff. The Department sustained some
                        findings but disallowed others. (See app. I.)


                        14
                          The team is called a regional service team and includes staff from program offices in the Office of
                        Elementary and Secondary Education. Education has divided the country into eight regions; each
                        region has six to eight states. Each regional service team oversees the federally funded programs and
                        provides technical assistance to the states in its region.



                        Page 15                                              GAO/HEHS-98-3 Safe and Drug-Free Schools
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Education also uses its reviews of state audit findings and on-site IG
reviews to stay informed of state activities. Each year, states’ federally
funded programs must be independently audited as part of the federally
required single state audit process.15 These audits—which may include the
Safe and Drug-Free Schools program—identify specific findings, such as
expenditures not allowable under the authorizing legislation. These
findings are resolved by the Assistant Secretary, Office of Elementary and
Secondary Education, who sustains or rejects the findings after
considering information provided by the auditor and auditee. The single
state audits have uncovered improper and questionable expenditures in
state and local programs. For example, state auditors in Michigan
uncovered questionable state expenditures of federal Drug-Free Schools
and Communities Act funding. Their findings triggered a state legislative
review of the program.

In the last 3 fiscal years, Education’s IG has conducted two studies of
activities under Drug-Free Schools.16 A citizen’s complaint prompted a
1995 audit of certain financial matters in the administration of the West
Virginia program. In response to the complaint, Education’s IG sought to
determine if one of West Virginia’s regional education service agencies
was administering its Drug-Free Schools program in compliance with
applicable federal acts and regulations.17 More recently, in February 1996,
the IG issued a report describing the programs offered in nine local
Drug-Free Schools programs in eight states.18

Although the IG work plan for fiscal years 1996 and 1997 includes no audits
of any Safe and Drug-Free Schools activities, the 1997-98 draft work plan
includes two audits of Safe and Drug-Free Schools and Communities Act
activities. The first audit would examine the use of Safe and Drug-Free
Schools funds and the amount of such funding reaching the classroom.
The second audit would review program performance indicators. In

15
  The Single Audit Act requires states and local entities to undergo a comprehensive single audit of
their financial operations. Some states and local entities, however, are excluded from the requirements
because the funding is lower than thresholds established by the law. States submit their audit reports
to the Single Audit Clearinghouse. The Clearinghouse sends reports with findings directly to the Office
of the Chief Financial Officer, who then distributes the appropriate sections of the reports to the
relevant program offices for resolution.
16
 According to Education officials, most IG staff are assigned to work on the larger Student Financial
Assistance programs. IG staff in areas not related to the student financial assistance programs focus
on programs scheduled for upcoming reauthorization.
17
  See app. I for a more detailed explanation of the allegations and subsequent investigations.
18
 Correspondence to the Honorable William H. Zeliff, Jr. dated Feb. 8, 1996, from Steven A. McNamara,
Assistant Inspector General for Audit, U.S. Department of Education.



Page 16                                                GAO/HEHS-98-3 Safe and Drug-Free Schools
                                 B-277093




                                 addition, Education issued an audit supplement in June 1996 providing
                                 further guidance that will be used, for example, when states audit Safe and
                                 Drug-Free Schools activities. The supplement, which pertains to several
                                 Education programs amended by the Improving America’s Schools Act,
                                 will be used immediately by the states to conduct audits of school year
                                 1995-96 program grantee activities. Suggested audit procedures include
                                 reviews of funded activities, expenditures, and other related records to
                                 determine whether Safe and Drug-Free Schools funds were used for any
                                 prohibited activities.


Education to Report on           As required by the act, Education is gathering information about the Safe
Program Performance and          and Drug-Free Schools program. Overall, Education’s data collection and
Effectiveness                    evaluation activities comprise a (1) national evaluation of drug- and
                                 violence-prevention activities, including those funded under the Safe and
                                 Drug-Free Schools program;19 (2) national data collection on violence in
                                 schools; (3) national survey to gather information about local program
                                 improvement activities; and (4) compilation of state-level reports on
                                 program effectiveness and progress toward state- and locally defined goals
                                 for drug and violence prevention. Education plans to provide information
                                 from these components, except the survey of LEAs, to the Congress in
                                 January 1998. No date has been established for reporting results of the
                                 local survey.

National Studies Provide         Education, in collaboration with the National Institute of Justice, has
Information on School            begun to evaluate the impact of violence-prevention programs as required
Violence-Prevention Activities   by the act.20 The evaluation is designed to describe the types of activities
                                 funded with federal violence-prevention moneys, including Safe and
                                 Drug-Free Schools funds, and to identify the most promising practices
                                 among these activities. To acquire this information, the evaluation will
                                 compare matched pairs of schools with similar characteristics, but
                                 dissimilar safety profiles, to determine why the schools differ on certain
                                 safety measures. The evaluation should provide information about the
                                 effectiveness of specific interventions, officials told us, such as peer
                                 mediation, as well as broader influences on program effectiveness, such as


                                 19
                                   Under the previous Drug-Free Schools and Communities Act, Education sponsored a number of
                                 studies on drug-prevention activities. These studies included a required biennial survey of SEAs that
                                 obtained information on program characteristics and state administrative activities, an assessment of
                                 student outcomes in drug-prevention programs, and a longitudinal study of drug-prevention activities
                                 in 19 school districts that provided information on promising practices and program effectiveness.
                                 20
                                  Education’s collaboration with the National Institute of Justice, a part of the U.S. Department of
                                 Justice, will build on and expand a National Institute of Justice study. Education officials say the
                                 collaborative effort will allow the inclusion of more programs in the study.



                                 Page 17                                                GAO/HEHS-98-3 Safe and Drug-Free Schools
                          B-277093




                          school order and organization and class size. It will not describe the
                          effectiveness of specific Safe and Drug-Free Schools and Communities
                          programs nationwide.

                          In addition to evaluating violence-prevention programs, Education,
                          through its Center for National Education Statistics, is gathering
                          descriptive data on violence in the nation’s schools. The data were
                          obtained by survey from a nationally representative sample of schools and,
                          in conjunction with existing national databases, will provide detailed
                          information on the extent and nature of violence in schools.

Local Survey on Program   Although not required by the act, Education officials told us they plan to
Improvement Planned       survey a nationally representative sample of LEAs participating in the Safe
                          and Drug-Free Schools program to examine program improvement at the
                          local level. The survey, designed to gain information about LEAs’
                          assessment of program effectiveness and their use of such information in
                          ongoing program implementation, will ask LEAs to report the goals and
                          objectives established for their Safe and Drug-Free Schools programs and
                          the measures they use to assess progress toward these goals. Though
                          plans for the survey have not been completed, Education officials report
                          that this survey should be the first of periodically administered surveys to
                          obtain this information.

State Triennial Reports   The state-level reports on program effectiveness required by the act are
                          likely to be the primary source of information about Safe and Drug-Free
                          Schools programs’ effectiveness, both nationally and locally. Education—
                          though not required to do so—has provided states with suggested program
                          performance indicators that may be used to assess and report program
                          effectiveness. However, it is uncertain to what extent data from these
                          indicators will provide information about the effectiveness of Safe and
                          Drug-Free Schools and Communities programs. First, states do not have to
                          use Education’s indicators but may develop and use their own indicators.
                          Second, though the indicators were made available to states in draft form
                          in August 1996, states did not receive the completed data collection
                          instrument until December 1996. As a result, variability in state data
                          collection efforts may prevent some states from providing the desired
                          information, and Education officials acknowledge this. Expecting
                          difficulties in aggregating data from the state-level reports, the Department
                          is working with a private contractor to categorize and summarize the data.
                          Education officials expect state data to conform more closely with
                          Education’s performance indicators, they said, as states become more




                          Page 18                                 GAO/HEHS-98-3 Safe and Drug-Free Schools
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                                  familiar with the form and have a chance to adjust their own data
                                  collection systems.

                                  Although the act requires reports every 3 years, Education is providing
                                  states with a mechanism to furnish yearly information. Education has no
                                  information yet to estimate how many states, if any, will provide
                                  information more often than every 3 years.


                                  Nearly all states use approved local plans as the primary means for
States Review and                 ensuring a local program’s compliance with the act’s requirements as well
Approve Local Plans               as a variety of other methods. States’ use of the plans to ensure
and Monitor Activities            compliance often begins when LEAs submit their plans for state approval,
                                  with states using the approval process to ensure that a LEA’s planned
                                  program conforms with the act’s requirements. Once local plans have been
                                  approved, state officials monitor local programs, they said, using site
                                  visits, telephone contacts, and reviews of reports submitted by LEAs of
                                  their program activities and expenditures. A few states reported using a
                                  combination of these methods to oversee local programs.


State Practices Emphasize         States must approve local plans before a LEA may receive its Safe and
Planning and Conformance          Drug-Free Schools grant. State approval, however, is not automatic.
to Plans                          Ninety-six percent of the state officials responding to our survey said some
                                  LEAs had to revise their plans to obtain state approval. A plan could be
                                  judged unacceptable for minor or rather major reasons, state officials told
                                  us. For example, a plan lacking all the appropriate signatures might
                                  require only minor revisions. Other plans, however, such as those lacking
                                  measurable goals and objectives or those with budgets that were
                                  incongruent with the planned program activities, might require more
                                  substantial revision. Most local plans, however, are eventually successfully
                                  revised and gain state approval. In school year 1995-96, only a small
                                  percentage of LEAs did not receive Safe and Drug-Free Schools funding
                                  because their plans were not approved, state officials told us.

State Process Varies for Review   The act requires states to use a peer review or other method of ensuring
of LEA Plans                      the quality of applications. More than half the states use a peer review
                                  process. Officials in 29 states told us they use a peer review process; in 19
                                  of those states, the peer reviewers’ decisions are binding. The composition
                                  of peer review panels varies by state. In some states, peer review panel
                                  members include representatives from the LEAs. Georgia and Virginia, for
                                  example, are among the states that reported using LEA representatives as



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                        peer reviewers. In other states, such as Colorado, Alabama, and Idaho,
                        peer reviewers come from diverse groups such as the SEA’s staff, Safe and
                        Drug-Free Schools advisory group, and local drug-prevention experts.
                        States that reported using no peer review panel told us that SEA officials
                        review and approve local plans.

                        In the states we visited, officials use their review of local plans to ensure
                        that LEAs’ planned activities conform with the act’s requirements. West
                        Virginia’s coordinator told us that she reviews each local plan for
                        compliance. In Michigan, state officials must certify in writing that each
                        approved local plan conforms with the act’s requirements. We heard
                        similar anecdotal evidence when we spoke with our survey respondents.
                        For example, officials in Arizona and Nebraska also reported reviewing
                        local plans for compliance as part of the local plan approval process.


States Use Variety of   States reported that they monitor local activities and expenditures, in
Mechanisms to Monitor   accordance with the act, using a variety of mechanisms, such as site visits
Local Programs          and document reviews. Most state Safe and Drug-Free Schools officials
                        who use site visits to monitor said site visits are the most effective method
                        for monitoring LEA activities. Documents reviewed by states include
                        program and expenditure reports from LEAs. States use the local plan to
                        monitor program compliance as well as to develop the framework for site
                        visit observations. A few state officials also cited several barriers to
                        monitoring local activities. The most prominent of these are resource
                        shortages, that is, lack of staff and time.

                        State officials oversee local programs by visiting LEAs, reviewing LEAs’
                        program and expenditure reports, as well as making phone contacts. In
                        school year 1995-96, state officials in 48 states21 and Puerto Rico reported
                        making more than 1,900 site visits to local programs; 18 states, Puerto
                        Rico, and the District of Columbia used site visits more frequently than
                        any other oversight method. Although 22 states reported making regular
                        site visits, 12 states selected the sites they visited randomly. Nineteen
                        states reported visiting sites on the basis of LEA requests or complaints.
                        States also selected sites to visit on the basis of other criteria such as the
                        need for technical assistance, the amount of carryover funds, and whether
                        the LEA had received additional funding because it was considered “high
                        need.”



                        21
                         Because Hawaii has only one LEA, it is not a part of these analyses. Rhode Island reported that it
                        does not monitor LEAs.



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When asked how often they expected to perform site visits to local
programs, 16 states that performed site visits in school year 1995-96 said
they expected to visit each local program once every 3 years. Only 3 states,
the District of Columbia, and Puerto Rico expected yearly visits; 19 states
said they expected to visit programs every 3 to 4 years. Site visits include a
wide range of activities, from reviewing program records to on-site
observations, state officials told us. Most of the states that conducted site
visits in school year 1995-96, however, reported the following common
activities: examining program and financial records; reviewing the local
curriculum; and interviewing staff, students, and parents.

In addition to site visits, state officials in 31 states and the District of
Columbia said they oversee local programs by reviewing documents
provided by LEAs. Nine states reported this as the most often used
monitoring method. Only five states reported using phone calls or
technical assistance contacts as the most often used method for
monitoring local activities. (See table III.6 in app. III.)

The states we visited use most of the mechanisms cited by our survey
respondents to monitor LEAs’ program activities and expenditures. For
example, Michigan and West Virginia use site visits and reviews of LEAs’
program and expenditure reports to ensure that programs are
implemented in compliance with the act. West Virginia’s coordinator told
us she also uses telephone contacts as a monitoring mechanism. Virginia’s
coordinator, citing staff shortages as the reason the state could not visit
sites in school year 1995-96, said the state relies on its review of LEA
expenditure reports to monitor LEA programs. Although the three states’
local reporting requirements differ somewhat, each state requires LEAs to
submit an annual progress report, including information on their
programs’ activities and expenditures as well as expenditure reports.

State officials have established standard policies and procedures for site
visits, our research revealed. Michigan’s Office of Drug Control Policy, for
example, has developed a “Local Program Review Guide” that SEA staff
must use when monitoring LEA sites. The guide has specific questions
about the local program’s characteristics, such as curriculum content,
parental involvement, and the local advisory council. The state reviewer
must document findings for each characteristic. The guide also specifies
the type of documentation to be used. West Virginia has also written
policies and procedures to guide monitoring practices. In addition to
reviewing program records, West Virginia’s State and Drug-Free School
coordinator said she conducts interviews with local program



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                                administrators and actually observes program activities. Beginning in the
                                1996-97 school year, she told us, she also plans to include a review of local
                                vouchers in her site visit activities in response to a recommendation by the
                                state auditor.


Periodic Fiscal and
Program Reports and
Evaluations Required
Local Program and Expenditure   As permitted under the act, all states we surveyed had established
Reports Help States Monitor     reporting requirements for LEAs receiving Safe and Drug-
LEA Programs                    Free Schools funds. Generally, states most often rely on annual reporting,
                                although a few states require semiannual or monthly reporting. For
                                example, 36 states reported that they require LEAs to provide an annual
                                progress report. Three states require more frequent reports. Twenty-eight
                                states said they require an annual expenditure report; 17 states require
                                LEAs to report on their expenditures more frequently. In addition, seven
                                reported that they require monitoring reports of LEAs when the LEAs visit
                                program sites.

                                In addition to these requirements, most states require LEAs to submit a
                                report documenting their expenditures before the state releases funding to
                                them. Twenty-six of the states distribute funds on a reimbursement basis,
                                they said. LEAs use their own funds to pay program costs and are later
                                reimbursed for their expenditures by the state. The timing and information
                                requirements of these reports vary, with some states requiring a more
                                detailed explanation of spending than others. For example, Michigan Safe
                                and Drug-Free Schools officials require LEAs to report just the total amount
                                of money spent as of the date the state requests reimbursement. In
                                contrast, South Dakota requires LEAs to send in copies of their vouchers
                                before being reimbursed for program funds, according to state officials.

Evaluations                     States must obtain information from LEAs for the required triennial reports
                                to Education describing the implementation, outcomes, effectiveness, and
                                progress of state-level and LEA-operated programs. At the time of our
                                survey, however, many states had little information about the extent and
                                nature of program evaluation activities at the local level. For example, of
                                those state officials who reported local evaluation activities, many did not
                                know the number of LEAs conducting evaluations or the objectives and
                                activities of the LEA evaluations. In addition, we asked state officials what




                                Page 22                                 GAO/HEHS-98-3 Safe and Drug-Free Schools
                        B-277093




                        information they planned to include in their triennial reports. Many of the
                        state officials who responded to this question told us they either had not
                        determined what information they would include in their report or that
                        they would include whatever information Education required of them.


                        As permitted under the act, SEAs and LEAs use Safe and Drug-Free Schools
SEAs and LEAs           funds for a variety of activities. Although states often require LEAs to report
Report Varied Uses of   on their expenditures, the reported data are seldom routinely aggregated
Funds                   to provide a statewide picture of Safe and Drug-Free Schools spending.
                        State officials do not aggregate expenditure data, they told us, because no
                        reporting requirement exists for them to do so.

                        Although states use their program funds to provide a variety of services, in
                        most states, training and technical assistance for LEA staff and others,
                        including parents, is a frequent investment (see fig. 2 and table III.2 in app.
                        III). Forty-five states and Puerto Rico said they use a portion of their state
                        program funds in this way. Other categories of expenditures reported by
                        many states include curriculum development and acquisition (32 states),
                        violence prevention (27 states), and state-level program evaluation (22
                        states). Other activities reported included demonstration projects (18
                        states) or activities to provide cost-effective programs to LEAs (20 states).




                        Page 23                                  GAO/HEHS-98-3 Safe and Drug-Free Schools
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Figure 2: Nationwide, Most States Use
Safe and Drug-Free Schools Money for       50       Number of States
Staff Training                                       45
                                           45

                                           40

                                           35
                                                                    32

                                           30
                                                                                     27

                                           25
                                                                                             22
                                                                                                    20
                                           20                                                              18
                                                                                                                   17

                                           15

                                           10

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                                           Note: The state activities categories are those used in the Safe and Drug-Free Schools and
                                           Communities Act to describe allowable activities.




                                           LEAs provide a broad range of activities to students with Safe and
                                           Drug-Free Schools program funds, according to state officials (see fig. 3).
                                           These activities include drug-prevention instruction (provided by
                                           91 percent of the LEAs) and violence-prevention instruction (provided by
                                           68 percent of LEAs) and staff training on new drug-prevention techniques
                                           and use of new curriculum materials; special one-time events, such as a
                                           guest speaker, or drug- and alcohol-free social activities, such as a dance
                                           or picnic; parent education/involvement; student support services, such as
                                           counseling and referral services; and curriculum development and
                                           acquisition. Ninety-one percent of LEAs provide drug-prevention
                                           instruction. Staff training is the next most offered activity, with 77 percent
                                           of districts reporting such training.




                                           Page 24                                                         GAO/HEHS-98-3 Safe and Drug-Free Schools
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Figure 3: Most LEAs Provide Drug-Prevention Instruction and Staff Training With Safe and Drug-Free Schools Funds

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      LEA Services


                                                Note: The LEA service categories are those used by the U.S. Department of Education in its
                                                survey of SEAs for school year 1996-97.



                                                The Safe and Drug-Free Schools program is one of several substance
Conclusions                                     abuse- and violence-prevention programs funded by the federal
                                                government. The major purpose of the programs is to help the nation’s
                                                schools provide a disciplined environment conducive to learning by
                                                eliminating violence in and around schools and preventing illegal drug use.
                                                States and localities have wide discretion in designing and implementing
                                                programs funded under the act. They are held accountable for achieving
                                                the goals and objectives they set as well as for the federal dollars they
                                                spend.

                                                As permitted under the act, states and localities are delivering a wide
                                                range of activities and services. Likewise, accountability mechanisms have




                                                Page 25                                               GAO/HEHS-98-3 Safe and Drug-Free Schools
                  B-277093




                  been established and appear to be operating in ways consistent with the
                  act.

                  The lack of uniform information on program activities and effectiveness
                  may, however, create a problem for federal oversight. First, with no
                  requirement that states use a consistent set of measures, the Department
                  faces a difficult challenge in assembling the triennial reports so that a
                  nationwide picture of the program’s effectiveness emerges. Second,
                  although Education provides a mechanism for states to report information
                  annually, under the act, nationwide information on effectiveness and
                  program activities may only be available every 3 years, which may not be
                  often enough for congressional oversight.


                  The Department of Education provided written comments on a draft of
Agency Comments   this report, and we incorporated, where appropriate, technical
                  clarifications it suggested. In addition, the Department expressed concern
                  about our observations on the multiple programs designed to address
                  youth violence and drug abuse. In the Department’s view, “the discussion
                  of the numerous Federal programs designed to reduce or eliminate youth
                  drug use or violence treats the topic too generally. While other Federal
                  programs may address various aspects of these two very serious problems,
                  we know of no other Federal program that provides widely available,
                  sustained support to schools to prevent or reduce youth drug use or
                  violence. The draft fails to provide detailed information about these other,
                  numerous Federal programs, and reaches a tentative conclusion about
                  duplication and effectiveness that is not supported by this draft report.”

                  We did not revise our reference to the multiple programs in response to
                  this comment because (1) we state only that the potential for duplication
                  exists among these multiple, nonintegrated programs and (2) we also state
                  that we did not fully examine these programs to document the extent to
                  which this may be true for drug and violence programs. In addition, this
                  background information provides what we consider to be an important
                  general context for considering the Safe and Drug-Free Schools program.
                  The additional detail about the other programs has been reported in our
                  other products cited in the footnotes.


                  We are sending copies of this report to appropriate House and Senate
                  committees and other interested parties. Please call me at (202) 512-7014




                  Page 26                                GAO/HEHS-98-3 Safe and Drug-Free Schools
B-277093




or Eleanor L. Johnson on (202) 512-7209 if you or your staff have any
questions. Major contributors to this report are listed in appendix IV.




Carlotta C. Joyner
Director, Education and
  Employment Issues




Page 27                                 GAO/HEHS-98-3 Safe and Drug-Free Schools
Contents



Letter                                                                                           1


Appendix I                                                                                      30
                     Michigan                                                                   30
Site Visit Reports   Virginia                                                                   33
                     West Virginia                                                              34

Appendix II                                                                                     38

Methodology
Appendix III                                                                                    40

Data on Safe and
Drug-Free Schools
Appendix IV                                                                                     57

GAO Contacts and
Staff
Acknowledgments
Tables               Table III.1: Safe and Drug-Free Schools Funding Amount by                  40
                       State, School Year 1995-96
                     Table III.2: Percent of Funds Used for Various Activities by SEAs,         42
                       School Year 1995-96
                     Table III.3: Percent of LEAs in Each State Providing Selected              45
                       Services, School Year 1995-96—Teacher/Staff Training,
                       Drug-Prevention Instruction, Violence-Prevention Instruction,
                       Curriculum Development/Acquisitions, and Student Support
                       Services
                     Table III.4: Percent of LEAs in Each State Providing Selected              47
                       Services, School Year 1995-96—Alternative Education Programs,
                       Parent Education/Involvement, After- or Before-School
                       Programs, Community Service Projects, and Out-of-School Youth
                       Services
                     Table III.5: Percent of LEAs in Each State Providing Selected              49
                       Services, School Year 1995-96—Special, One-Time Events,
                       Conflict Resolution/Peer Mediation, Security Staff, Security
                       Equipment, and Other




                     Page 28                               GAO/HEHS-98-3 Safe and Drug-Free Schools
          Contents




          Table III.6: States’ Most Often Used Methods for Monitoring LEAs           50
          Table III.7: Private School Participation in Safe and Drug-Free            52
            Schools Program
          Table III.8: Method Used to Distribute Funds by State                      54
          Table III.9: Method Used to Select Neediest Districts by State             55

Figures   Figure 1: How Funding Reaches States and Local Schools, Fiscal              2
            Year 1995
          Figure 2: Nationwide, Most States Use Safe and Drug-Free                   24
            Schools Money for Staff Training
          Figure 3: Most LEAs Provide Drug-Prevention Instruction and                25
            Staff Training With Safe and Drug-Free Schools Funds




          Abbreviations

          ESEA        Elementary and Secondary Education Act of 1995
          IG          Inspector General
          LEA         local education agency
          RESA VIII   Regional Education Service Agency VIII
          SEA         state education agency


          Page 29                               GAO/HEHS-98-3 Safe and Drug-Free Schools
Appendix I

Site Visit Reports


                     The key issue in this allegation—that the state improperly used federal
Michigan             drug education funding to implement a comprehensive health
                     curriculum—resulted from a state legislative review of the Michigan
                     Department of Education’s implementation of a comprehensive school
                     health curriculum. The state review, which had been prompted by parents’
                     concerns about the curriculum content, uncovered questionable
                     expenditures of federal drug-prevention funding under the Drug-Free
                     Schools and Communities Act for curriculum materials not related to drug
                     education as well as questionable fiscal practices. In addition to the
                     legislative review, Michigan’s Director of Drug Control Policy conducted
                     his own investigation. His review and that of the state auditor concluded
                     that many of the expenditures for the comprehensive school health
                     curriculum violated federal requirements for federal drug-prevention
                     funding.

                     As a result of the state auditor’s adverse audit findings, the U.S.
                     Department of Education became involved. Federal officials reviewed the
                     audit findings and issued final rulings on whether the expenditures under
                     question violated federal requirements. Although state auditors questioned
                     the expenditures for the comprehensive health curriculum, upon obtaining
                     further information from state officials,22 Education found these
                     expenditures acceptable. Education, however, did find that the Michigan
                     Department of Education had violated other federal requirements in
                     managing federal drug-prevention funding. The 1994 passage of the Safe
                     and Drug-Free Schools and Communities Act contained an administrative
                     provision that authorized the use of Safe and Drug-Free Schools funding
                     and, retroactively, the use of Drug-Free Schools and Communities Act
                     funding for comprehensive health programs.


The Facts Reviewed   Between 1992 and 1994, members of the state legislature and the director
                     of Michigan’s Office of Drug Control Policy charged Michigan state
                     education officials with improperly using federal Drug-Free Schools and
                     Communities Act funding to implement a statewide comprehensive school
                     health program. The program, called the Michigan Model for
                     Comprehensive School Health Education, sought to educate students
                     about maintaining health and included a drug education component. The
                     program sparked controversy when parents statewide expressed
                     opposition to their state representatives.


                     22
                      Education questioned Michigan Department of Education officials about the proportion of the
                     comprehensive health curriculum devoted to drug education and the proportion of federal
                     drug-prevention funding spent for the curriculum.



                     Page 30                                             GAO/HEHS-98-3 Safe and Drug-Free Schools
Appendix I
Site Visit Reports




In response to these complaints, state legislators launched their own
inquiry. During their investigations, legislators came to question the
appropriateness and legality of using federal Drug-Free Schools funding to
implement a comprehensive health education program. In addition, they
uncovered questionable administrative practices and expenditures made
with Drug-Free Schools funding.

In 1994, the Family Law, Mental Health and Corrections Committee of the
Michigan State Legislature released a report of its investigation into the
Michigan Department of Education’s management of federal Drug-Free
Schools funding. The Committee examined seven issues, concluding that
the Michigan Department of Education (1)”diverted” federal Drug-Free
Schools funds “to activity not related to drug prevention” and (2) illegally
restricted local school districts’ discretion in using their drug education
funds. The Committee also concluded that “a history of poor grant
management and oversight by the department of education” had occurred
and found that greater accountability was needed to ensure the proper
uses of public funds.23 Among its recommendations, the Committee called
for performance audits of Drug-Free Schools grantees and state-level
agencies involved with Drug-Free Schools program expenditures.

The Committee’s findings echoed the findings of earlier investigations by
the state’s Office of Drug Control Policy. Calling the Michigan Model’s
implementation the “Michigan Morass,” the Director of the Michigan Office
of Drug Control Policy asserted that the problem rested in “how funds
diverted to it were obtained and administered,” especially federal
Drug-Free Schools funds.24 The many problems cited by the director
included questionable bidding practices on competitive contracts,
potential “double-dipping” by state employees who served as both
program coordinators and paid consultants, and the purchase of
curriculum materials not directly related to the drug education
components of the Michigan Model. According to him, these purchases
included giant toothbrushes, a human torso model, dog bone kits, and
bicycle pumps.

Because of the state audit findings, the issue of the use of Drug-Free
Schools funds for delivering a drug education program through a


23
 Final Report, Michigan Department of Education’s Management of Federal Drug-Free Schools and
Communities Act Funds, Family Law, Mental Health and Corrections Committee, Michigan State
Legislature (Lansing, Mich.: Dec. 29, 1994).
24
 Senate Testimony and Final Drug Education Report, Office of Drug Control Policy (Lansing, Mich.:
Oct. 12, 1993).



Page 31                                             GAO/HEHS-98-3 Safe and Drug-Free Schools
Appendix I
Site Visit Reports




comprehensive school health curriculum came before the U.S. Department
of Education for resolution. Specifically, state auditors had found that
(1) the Michigan Department of Education failed to “appropriately
document to what extent Drug-Free Schools and Communities Act (Drug
Free Schools) funds could be used to fund comprehensive health
education programs in accordance with statutory and regulatory
requirements,” and (2) “the level of funding provided by [the act] to
support the Michigan Model exceeds the relative weight of drug abuse
education and prevention criteria contained in the Michigan Model.”25
Federal education officials did not sustain these findings.

Education’s rejection of these findings rested on its analysis of the federal
law, provisions of nonregulatory guidance, and a 1991 ruling by
Education’s Assistant Secretary for Elementary and Secondary Education
on the issue. Citing federal nonregulatory guidance on this issue,
Education pointed out that LEAs may include drug abuse education and
prevention in a comprehensive health education program, but the
expenditure of Drug-Free Schools funds is limited to the drug abuse
education and prevention program components. Education also noted that
the guidance did not “specify particular methods to be used in determining
the proportionate share of a comprehensive health education program to
be funded by the Drug Free Schools Act.”26 Referring to its previous ruling,
Education said the Michigan Department of Education had demonstrated
through an analysis of the Michigan Model’s curriculum content that the
level of Drug-Free Schools funding for the Model was consistent with the
Model’s level of drug abuse education and prevention content.

Though the state auditor challenged the Michigan Department of
Education’s methodology for determining program content, Education
ruled that “the auditors provided no evidence to demonstrate that the
methods used by the subcommittee were in violation of any statutory or
regulatory requirements.”27 Education concluded, “Consequently, there is
insufficient information to establish that the [Michigan State Department
of Education] has violated the requirements contained in the [Drug-Free
Schools and Communities Act] and other applicable regulations related to
the proportionate use of these funds for the Michigan Model.”

25
  Letter of Determination dated Sept. 28, 1995, from Thomas W. Payzant, Office of Elementary and
Secondary Education, U.S. Department of Education, to Arthur Ellis, Superintendent of Public
Instruction, Lansing, Michigan.
26
 Determination Letter dated Sept. 28, 1995, from Office of Elementary and Secondary Education, U.S.
Department of Education.
27
 Determination Letter dated Sept. 28, 1995, from Office of Elementary and Secondary Education, U. S.
Department of Education.



Page 32                                             GAO/HEHS-98-3 Safe and Drug-Free Schools
                     Appendix I
                     Site Visit Reports




                     Though Education officials rejected auditors’ findings on the uses of
                     Drug-Free Schools funds for implementation of the Michigan Model, it
                     sustained audit findings on several other points. In brief, Education
                     sustained audit findings that the Michigan Department of Education failed
                     to (1) respect the broad discretion granted local grantees in developing
                     their drug education programs, (2) ensure that LEA grant application
                     requirements were fulfilled, and (3) evaluate programs in accordance with
                     federal requirements. The Department required the state to take
                     appropriate corrective actions.


                     A LEA’s use of Drug-Free Schools funding to provide out-of-town training
Virginia             for members of its school/community coalitions led to concerns that these
                     expenditures did not meet federal criteria. Although the Drug-Free
                     Schools Act permitted a wide range of activities, state and local education
                     agencies were also required to adhere to the Education Department’s
                     General Administrative Regulations. These regulations include a
                     requirement that costs be “necessary and reasonable” and discuss the
                     allowability of certain kinds of costs.

                     The state learned of the allegation when a caller reported the alleged
                     misuse of funds to the Governor’s Fraud Hotline. The complaint was
                     forwarded to the Virginia Department of Education’s internal auditor for
                     an investigation, which included interviews with local officials and a
                     review of county auditors’ report on the LEA’s expenditures. Ultimately,
                     state officials concluded the expenditures were allowable under federal
                     requirements but expressed concern about the appearance of fiscal
                     impropriety. The entire matter was resolved without federal intervention.


The Facts Reviewed   In 1995, the Governor’s Office, through its fraud hotline, received an
                     allegation charging the Fairfax County Public Schools with the misuse of
                     Drug-Free Schools funds. An anonymous caller to the hotline alleged that
                     Fairfax County school district officials were using federal Drug-Free
                     Schools and Communities Act (Drug-Free Schools) funds for staff training
                     sessions at an expensive summer resort. The call was referred to the
                     Virginia State Department of Education’s internal auditor for investigation.

                     State officials learned that the Fairfax County Public Schools had
                     sponsored a total of 11 training sessions—each for 2-1/2 days—between
                     March 1994 and April 1995 in St. Michael’s, Maryland. The sessions,
                     designed to facilitate the formation of school-community coalitions to



                     Page 33                                GAO/HEHS-98-3 Safe and Drug-Free Schools
                Appendix I
                Site Visit Reports




                support and enhance school-based drug use prevention activities, trained
                community representatives, business owners, school board members,
                alternative school staff, and members of the Fairfax County Board of
                Supervisors. In all, the district trained 876 individuals at a total cost of
                $181,397.71, or $207 per participant, according to Fairfax County public
                school officials.

                In the course of their investigation, state officials also learned that the
                district’s fiscal year 1994 expenditures had been audited to determine if
                Fairfax County Public Schools’ Drug-Free Schools and Communities grant
                was being administered in compliance with federal and state requirements.
                The subsequent audit report discussed the expenditures for the district’s
                training sessions in St. Michael’s. Auditors concluded that federal statutes
                had not been violated but stated the training sessions could be seen as
                excessive, unnecessary, and social in nature and cited Education
                Department General Administrative Regulations requirements that
                expenditures be “necessary and reasonable for proper and efficient
                administration of the grant.” The auditors cited the Regulations’
                requirements that the grant not authorize expenditures for entertainment
                or social activities, including “costs for amusements, social activities,
                meals, beverages, lodging, rentals, transportation and gratuities.” Although
                the auditors concluded that the training expenses had been
                reasonable—the room expenses were no more than an average hotel room
                in the Washington, D.C., metropolitan area, and meals had been
                reasonably priced—they questioned the need to hold the training sessions
                out of state.

                On the basis of the local auditor’s findings and information obtained from
                district officials, Virginia State Department of Education officials
                concluded the costs for the St. Michael’s training sessions were
                reasonable. Though commending the LEA’s “School/Community Action
                Team” concept, state officials cautioned the district to take special
                precautions in guaranteeing that the district’s activities and expenditures
                were viewed by the school as necessary, reasonable, and consistent with
                the purposes of the Drug-Free Schools grant. The state fully reimbursed
                the district for each training session after the audit findings were
                discussed, and the state made procedural changes to avoid a similar
                incident in the future.


                The key issue in this allegation—that the state failed to ensure that local
West Virginia   programs deliver a clear “no use” message and that locals comply with



                Page 34                                 GAO/HEHS-98-3 Safe and Drug-Free Schools
                     Appendix I
                     Site Visit Reports




                     federal requirements for expenditures and financial management—has
                     been addressed by federal reviews of state and local activities under the
                     Drug-Free Schools Act. Regarding the lack of a “no use” message, federal
                     officials found that insufficient evidence existed to support this claim. As
                     noted previously, federal officials did observe instances of noncompliance
                     with financial management requirements. However, both the SEA and the
                     LEA have taken steps to correct these problems.



The Facts Reviewed   In March 1995, the Chief Counsel of the House Subcommittee on National
                     Security, International Affairs, and Criminal Justice met with a West
                     Virginia parent to discuss her concerns about drug education and
                     prevention programs. In subsequent correspondence with the Chief
                     Counsel, the parent reiterated her concerns, charging a lack of
                     accountability on federal officials’ part in ensuring state and local
                     compliance with the Drug-Free Schools Act. Local officials, she said,
                     implemented a curriculum teaching “that only abuse of a drug is harmful,
                     leading our youth to believe and implying that moderation and occasional
                     use of cocaine, marijuana, or alcohol might be an acceptable choice for
                     themselves.” The parent also said she had withdrawn her children from
                     her district’s drug-education program but expressed concern for children
                     still enrolled in the program.

                     The parent’s letter to the Chief Counsel was not the first expression of her
                     concern about West Virginia’s implementation of the Drug-Free Schools
                     Act. For example, she asked federal officials in the U.S. Department of
                     Education in 1991 to conduct a formal investigation of the QUEST
                     curriculum used by her West Virginia school district, Jefferson County.28
                     Characterizing the curriculum as “non-directive,” she said she objected to
                     the curriculum’s lessons in self-esteem and values clarification. The
                     concerns she raised ultimately resulted in a program review by
                     Education’s Drug-Free Schools officials and a limited-scope audit by
                     Education’s Inspector General (IG). In addition, the Office of National Drug
                     Control Policy, at this same parent’s request, reviewed the QUEST
                     curriculum to assess its compliance with federal statutes. Both entities
                     concluded that the curriculum violated no federal statutes.

                     Federal officials performed two site reviews of Drug-Free Schools
                     programs in West Virginia. The first, conducted in 1992, was performed in
                     response to allegations that the county violated federal requirements when

                     28
                      QUEST is a commercially developed and marketed curriculum used by many school districts
                     nationwide.



                     Page 35                                           GAO/HEHS-98-3 Safe and Drug-Free Schools
    Appendix I
    Site Visit Reports




    it failed to adopt and implement a program to prevent students’ use of
    illicit drugs and alcohol.29 As part of their review, federal officials
    interviewed appropriate state and local educational agency personnel and
    examined relevant texts and other materials. As a result of this review, a
    Department official concluded in September 1992 “that there is sufficient
    evidence to indicate that Jefferson County does offer a drug prevention
    program for students in all grades.”

    Education officials conducted another review of West Virginia’s Drug-Free
    Schools program, focusing on SEA activities, in 1994.30 The review
    uncovered several problems with administrative practices, including the
    following:

•   The West Virginia Department of Education incorrectly calculated LEA
    awards in fiscal years 1993 and 1994.
•   LEA applications failed to require all the information and assurances
    specified by the federal statute.
•   LEA applications did not, but should, include information that allowed the
    SEA to assess the use of Drug-Free Schools funds at the local level.
•   The West Virginia Department of Education failed to separately account
    for program activities and expenditures versus administrative activities
    and expenditures.
•   The West Virginia Department of Education may wish to require receipts
    or other evidence from LEAs before reimbursing funds for program
    activities.

    The report also noted significant improvements in the state’s monitoring of
    and technical assistance to LEAs. In addition, federal officials commended
    the West Virginia Department of Education on its peer review process.

    In 1995, Education’s IG performed a limited-scope audit of selected aspects
    of Regional Education Service Agency VIII’s (RESA VIII) administration of
    the federal Drug-Free Schools and Communities Act programs to
    determine if the agency was administering the federal Drug-Free Schools
    program in compliance with applicable statutes and regulations. Overall,

    29
      The full requirement of the law was that districts adopt and implement a program to prevent the use
    of illicit drugs and alcohol by students that, at a minimum, includes age-appropriate, developmentally
    based drug and alcohol education and prevention programs (which address the legal, social, and
    health consequences of drug and alcohol use and which provide information about effective
    techniques for resisting peer pressure to use illicit drugs or alcohol) for students in all grades of the
    schools operated or served by the LEA from early childhood level through grade 12.
    30
     This review included activities funded under the Governor’s Program of Drug-Free Schools. Since
    activities under the Governor’s Program are beyond the scope of our review, findings pertaining to it
    are excluded from the discussion in this site report.



    Page 36                                                GAO/HEHS-98-3 Safe and Drug-Free Schools
Appendix I
Site Visit Reports




the IG found the agency’s internal controls for providing management with
reasonable assurance that assets are safeguarded against loss from
unauthorized use or disposition and that transactions are executed in
accordance with management’s authorization and recorded properly to
permit correct financial reporting—sufficient for the Drug-Free Schools
program.31

The IG cited two cases of material noncompliance with federal laws and
regulations, however. First, RESA VIII had failed to fulfill requirements of the
federal Single Audit Act of 1984 by not conducting annual audits. Second,
RESA VIII used an inappropriate indirect cost rate during fiscal years 1992,
1993, and 1994 when it based its indirect cost on that of its fiscal agent,
Berkeley County. The IG’s recommendations included instructions to both
the RESA and the state. Recommendations to RESA VIII included (1) that the
agency develop appropriate, reasonable indirect cost rates for fiscal years
1992 through 1994 and (2) obtain audits for all years required in
accordance with the federal Single Audit Act and applicable regulations.
The IG also recommended that the West Virginia Department of Education
(1) cease requiring grantees of federal funds to use inappropriate indirect
cost rates, (2) require RESA VIII to develop and submit to the West Virginia
Department of Education its own indirect cost rate in accordance with
federal requirements, and (3) require RESA VIII and all other RESAs to report
to the Department their indirect cost rate audit results.




31
  Audit Results of RESA VIII’s Administration of the Federal Drug-Free Schools Program, Office of the
Inspector General, U.S. Department of Education (Washington, D.C.: Sept. 1995), p. 4.



Page 37                                              GAO/HEHS-98-3 Safe and Drug-Free Schools
Appendix II

Methodology


              To address your concerns about Safe and Drug-Free Schools’
              accountability provisions and their implementation, we asked four
              questions: (1) What accountability measures are required under the act at
              the federal, state, and local levels? (2) What activities are used by
              Education for overseeing state and local programs? (3) How do SEAs
              ensure local programs’ compliance with the act? and (4) What specific
              uses are made of Safe and Drug-Free Schools funding at the state and local
              levels?

              To determine what is required under the act, we reviewed relevant
              documents, such as the act and its legislative history, relevant sections of
              the Code of Federal Regulations, and other related legislation.

              To assess what actions Education is taking, we followed up on allegations
              of impropriety in three states (Michigan, Virginia and West Virginia),
              reviewing documentation and interviewing state and local officials
              involved in the original incident and in the investigation and resolution
              (see app. I for a description of each of these site visits). We also reviewed
              documents at Education’s headquarters in Washington, D.C., and
              interviewed Department officials.

              In addition, we reviewed Department of Education state files for 16 states:
              Connecticut, Delaware, Illinois, Indiana, Iowa, Massachusetts, Michigan,
              Missouri, Nebraska, Nevada, New York, Rhode Island, Tennessee, Texas,
              West Virginia, and Wyoming. These state files included documentation,
              such as a copy of the state’s plan, the reviewers’ comments, materials from
              the state responding to Education’s request for supplemental information,
              and grant award documents. States were selected using a stratified,
              random sample.

              To select states for site visits, we used two main techniques to help
              identify allegations. First, we followed up on leads provided by
              correspondence to a member of the Congress. For example, a set of seven
              letters given to us alleged improper use of funds. We reviewed these
              letters and called all seven authors to clarify their complaints. On the basis
              of the letters and phone calls, we eliminated six of these allegations from
              our investigation because they concerned curriculum issues. Because the
              Safe and Drug-Free Schools Act makes curriculum a state and local issue—
              the Secretary of Education is specifically prohibited from prescribing or
              proscribing specific materials or approaches—curriculum could not be
              used as a basis for inappropriate use of federal funds. We did visit the site
              of the seventh allegation—West Virginia. We also chose the West Virginia



              Page 38                                 GAO/HEHS-98-3 Safe and Drug-Free Schools
Appendix II
Methodology




program because it had been audited by the Inspector General (IG) of the
Department of Education and was the subject of other Department of
Education reviews, providing us with much information that could be
reviewed in a relatively short time. Second, in reviewing the legislative
history, we found that a floor debate in the House had mentioned a
number of other allegations. One, the alleged misuse of funds in Virginia
for training retreats held in a resort location in Maryland, had been the
subject of investigations, giving us ample data to review. Therefore, we
chose Virginia for a site visit. Finally, the use of Drug-Free Schools and
Communities Act program funds in Michigan for a comprehensive health
program had already prompted a large state-level investigation. We chose
Michigan for a site visit because of the importance of this investigation.

To determine what oversight was required and assess accountability
activities at the state and local level, we surveyed the 50 states, the District
of Columbia, and Puerto Rico about their activities, receiving information
from all 50 states, Puerto Rico, and the District of Columbia.32

Although we did not verify the data the states supplied us, we did review
supporting documentation they provided and used our site visits to
Michigan, Virginia, and West Virginia to collect examples of how the law
was being implemented and to observe accountability practices at the
state and local level. Most information about state accountability,
however, collected through the questionnaire and follow-up phone calls
was reported by SEAs. Our work was conducted from February 1996 to
May 1997 in accordance with generally accepted government auditing
standards.




32
  Puerto Rico provided draft responses to our survey, but we could not obtain a final official response
from Puerto Rico before completing our analysis. We have included these draft responses as
applicable.



Page 39                                               GAO/HEHS-98-3 Safe and Drug-Free Schools
Appendix III

Data on Safe and Drug-Free Schools


                                          The tables in this appendix provide information, by state, on selected
                                          aspects of states’ Safe and Drug-Free Schools and Communities programs.
                                          Table III.1 provides the amount of each SEA’s school year 1995-96
                                          allocation; tables III.2, III.3, III.4, and III.5 provide information on the
                                          activities funded by Safe and Drug-Free Schools grants. Information about
                                          state accountability mechanisms, such as methods used for monitoring
                                          and distributing funds, appears in tables III.6 and III.8. Table III.7 provides
                                          information on private school participation in the Safe and Drug-Free
                                          Schools program. Table III.9 provides information on how states selected
                                          their neediest districts.

Table III.1: Safe and Drug-Free Schools
Funding Amount by State, School Year      Dollars in millions
1995-96                                                                                                         State grant
                                          State                                                                    amount
                                          Alabama                                                                     $5.8
                                          Alaska                                                                        1.7
                                          Arizona                                                                       5.1
                                          Arkansas                                                                      3.5
                                          California                                                                  38.4
                                          Colorado                                                                      4.1
                                          Connecticut                                                                   3.2
                                          Delaware                                                                      1.7
                                          District of Columbia                                                          1.7
                                          Florida                                                                     14.8
                                          Georgia                                                                       8.6
                                          Hawaii                                                                        1.7
                                          Idaho                                                                         1.7
                                          Illinois                                                                    15.1
                                          Indiana                                                                       6.2
                                          Iowa                                                                          3.1
                                          Kansas                                                                        2.9
                                          Kentucky                                                                      5.5
                                          Louisiana                                                                     7.7
                                          Maine                                                                         1.7
                                          Maryland                                                                      5.1
                                          Massachusetts                                                                 6.4
                                          Michigan                                                                    13.6
                                          Minnesota                                                                     5.1
                                          Mississippi                                                                   5.0
                                          Missouri                                                                      6.3
                                                                                                                (continued)


                                          Page 40                                  GAO/HEHS-98-3 Safe and Drug-Free Schools
Appendix III
Data on Safe and Drug-Free Schools




Dollars in millions
                                                                  State grant
State                                                                amount
Montana                                                                   1.7
Nebraska                                                                  1.9
Nevada                                                                    1.7
New Hampshire                                                             1.7
New Jersey                                                                8.4
New Mexico                                                                2.7
New York                                                                26.0
North Carolina                                                            7.4
North Dakota                                                              1.7
Ohio                                                                    14.4
Oklahoma                                                                  4.3
Oregon                                                                    3.5
Pennsylvania                                                            14.7
Puerto Rico                                                               9.3
Rhode Island                                                              1.7
South Carolina                                                            4.6
South Dakota                                                              1.7
Tennessee                                                                 6.2
Texas                                                                   27.4
Utah                                                                      2.5
Vermont                                                                   1.7
Virginia                                                                  6.4
Washington                                                                5.8
West Virginia                                                             2.7
Wisconsin                                                                 6.3
Wyoming                                                                   1.7




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Table III.2: Percent of Funds Used for
Various Activities by SEAs, School
Year 1995-96
                                         State                                      Staff training/technical assistance
                                         Alabama                                                                    55
                                         Alaska                                                                     80
                                         Arizona                                                                    70
                                         Arkansas                                                                   15
                                         California                                                                 34
                                         Colorado                                                                   50
                                         Connecticut                                                                65
                                         Delaware                                                                   25
                                         District of Columbia                                                        0
                                         Florida                                                                    70
                                         Georgia                                                                    90
                                         Hawaii                                                                     40
                                         Idaho                                                                      70
                                         Illinois                                                                   20
                                         Indiana                                                                    70
                                         Iowa                                                                       19
                                         Kansas                                                                     59
                                                    a
                                         Kentucky
                                         Louisiana                                                                  97
                                         Maine                                                                      40
                                         Maryland                                                                   98
                                         Massachusetts                                                              80
                                         Michigan                                                                  100
                                         Minnesota                                                                  60
                                         Mississippi                                                                65
                                         Missouri                                                                   27
                                         Montana                                                                    55
                                         Nebraska                                                                   55
                                         Nevada                                                                     35
                                         New Hampshire                                                              50
                                         New Jerseya
                                         New Mexicob                                                                 0
                                         New York                                                                   75
                                         North Carolina                                                             80
                                         North Dakota                                                               54
                                               a
                                         Ohio




                                         Page 42                              GAO/HEHS-98-3 Safe and Drug-Free Schools
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                              Data on Safe and Drug-Free Schools




                       LEA                                                                          Evaluation at
             cost-effective   Demonstration     Violence training/technical       Special LEA         state-level
Curriculum      programs           projects           assistance/prejudice             grants           activities
       10                5                  5                           20                   0                  5
        8                0                  0                           12                   0                  0
       20               10                  0                            0                   0                  0
        5                0                 80                            0                   0                  0
        8                9                  5                            8                   0                 36
        0                0                  4                           25                  20                  1
       10                0                  0                           25                   0                  0
       35               10                 15                            5                  10                  0
        0                0                100                            0                   0                  0
        1                1                  4                            0                  23                  1
        0                0                  0                            0                   8                  2
       20                5                 15                           10                   5                  0
        0                0                  0                            5                   0                 25
       10                0                 50                            0                  10                 10
       10               10                  5                            0                   5                  0
        0                0                  0                            0                   0                 81
        2               35                  0                            4                   0                  0


        3                0                  0                            0                   0                  0
       30               20                  0                           10                   0                  0
        0                2                  0                            0                   0                  0
        0                0                  0                           20                   0                  0
        0                0                  0                            0                   0                  0
       10                0                  0                           30                   0                  0
       15               10                  5                            5                   0                  0
        4               69                  0                            0                   0                  0
       10                0                  0                           20                  10                  5
        9                5                 12                            5                   9                  5
       25               25                  5                            5                   0                  5
       10               30                  5                            5                   0                  0


        0                0                  0                            0                  96                  0
        0                0                  0                           25                   0                  0
       10                0                  0                            0                   0                 10
        0                0                  0                           44                   2                  0


                                                                                                       (continued)



                              Page 43                                     GAO/HEHS-98-3 Safe and Drug-Free Schools
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Data on Safe and Drug-Free Schools




State                                      Staff training/technical assistance
Oklahoma                                                                   90
Oregon                                                                     50
Pennsylvania                                                              100
Puerto Rico                                                                20
Rhode Island                                                               37
                a
South Carolina
South Dakota                                                               80
Tennessee                                                                  60
Texasc
Utah                                                                       35
Vermont                                                                   100
Virginia                                                                   95
Washington                                                                 85
West Virginia                                                              29
Wisconsin                                                                  75
Wyoming                                                                    40




Page 44                              GAO/HEHS-98-3 Safe and Drug-Free Schools
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                                             Data on Safe and Drug-Free Schools




                                   LEA                                                                                         Evaluation at
                         cost-effective         Demonstration        Violence training/technical             Special LEA         state-level
           Curriculum       programs                 projects              assistance/prejudice                   grants           activities
                   2                 2                          2                                   2                     1                1
                  10                 2                          3                                   25                    5                5
                   0                 0                          0                                   0                     0                0
                  17                 0                          0                                   20                 40                  3
                  15                 0                         22                                   16                    0               10


                   1                 0                          0                                   5                     0               14
                   0                10                         30                                   0                     0                0


                  60                 0                          0                                   0                     0                5
                   0                 0                          0                                   0                     0                0
                   5                 0                          0                                   0                     0                0
                   0                 0                          0                                   0                  10                  5
                  17                23                          0                                   20                    1               10
                  10                 0                          0                                   10                    0                5
                  20                10                          0                                   10                 10                 10
                                             a
                                                No data available.
                                             b
                                                 The remaining 4 percent of the funds were carried over to 1996.
                                            c
                                             All funds were provided to Educational Service Centers to fund Safe and Drug-Free Schools
                                            Education Service Center contact positions.




Table III.3: Percent of LEAs in Each State Providing Selected Services, School Year 1995-96—Teacher/Staff Training,
Drug-Prevention Instruction, Violence-Prevention Instruction, Curriculum Development/Acquisitions, and Student Support
Services
                                                                             Violence-        Curriculum
                                Teacher/staff    Drug-prevention           prevention       development/      Student support
Statea                               training         instruction          instruction       acquisitions            services
Alabama                                    90                        100                     100                    100                   80
Alaska                                     30                         95                       45                    60                   20
Arizona                                    80                         80                       50                    30                   70
Arkansas                                   95                         99                       98                    10                   60
California                                 50                         95                       60                    50                   50
Colorado                                  100                        100                     100                     75                   70
Connecticut                                65                        100                       70                    85                   60
Delaware                                  100                        100                     100                     80                  100
Floridab
Georgia                                    98                        100                       75                    60                   60
                                                                                                                                  (continued)


                                            Page 45                                                  GAO/HEHS-98-3 Safe and Drug-Free Schools
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                             Data on Safe and Drug-Free Schools




                                                               Violence-          Curriculum
                 Teacher/staff   Drug-prevention             prevention         development/      Student support
Statea               training         instruction            instruction         acquisitions            services
Idaho                     100                  100                   75                   100                  100
Illinois                   80                   80                   90                    50                   60
Indiana                   100                  100                   80                    80                  100
Iowa                       50                   68                   36                    50                    0
Kansas                     93                  100                    0                    86                  100
Kentucky                  100                  100                  100                    90                   45
Louisiana                 100                  100                  100                   100                    5
Maine                      45                   95                   55                    15                   55
Maryland                   95                  100                    0                    87                  100
Massachusetts              70                   90                   60                    60                   30
Michigan                  100                  100                   50                   100                   40
Minnesota                  90                  100                   85                    50                   75
Mississippi                80                   97                   80                    90                   75
Missouri                   95                  100                   90                    70                   60
Montana                    85                  100                   85                    85                   85
Nebraska                   96                  100                  100                    96                   91
Nevada                     82                   82                   70                    50                   60
New Hampshire              75                   98                   50                    60                   40
New Jerseyb
New Mexico                 70                  100                   60                    15                   85
New Yorkc
North Carolina            100                  100                  100                    95                  100
North Dakota               78                   77                   77                    64                   38
Ohio                       74                   92                   58                    62                   56
Oklahoma                   80                  100                   40                    30                   50
Oregon                     85                  100                   80                    50                   95
Pennsylvania               60                   80                   40                    30                   95
Rhode Island               63                  100                   55                    72                   83
South Carolina            100                  100                   70                    85                   80
South Dakota              100                  100                   50                    85                   80
Tennessee                  70                   80                   40                    30                   30
                                                                       b
Texas                      80                   88                                         69                   61
Utah                      100                  100                  100                   100                  100
Vermont                    90                  100                   60                   100                   90
Virginia                   75                   80                   80                    63                   62
Washington                 70                   80                   80                    60                   80
                                                                       d
West Virginia              59                  100                                         43                  100
                                                                                                        (continued)


                             Page 46                                       GAO/HEHS-98-3 Safe and Drug-Free Schools
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                                          Data on Safe and Drug-Free Schools




                                                                                    Violence-             Curriculum
                             Teacher/staff       Drug-prevention                  prevention            development/          Student support
Statea                           training             instruction                 instruction            acquisitions                services
Wisconsin                               15                        40                          5                       10                      5
Wyoming                                 40                        30                          5                       40                     70

                                          a
                                           The District of Columbia, Hawaii, and Puerto Rico are not included because they each have one
                                          LEA. See app. I.
                                          b
                                             Data were collected by state but were not available at the time of our survey.
                                          c
                                           LEAs provided this information to the state; however, the data were not aggregated at the state
                                          level.
                                          d
                                             No knowledge.




Table III.4: Percent of LEAs in Each State Providing Selected Services, School Year 1995-96—Alternative Education
Programs, Parent Education/Involvement, After- or Before-School Programs, Community Service Projects, and
Out-of-School Youth Services
                                  Alternative                                 After- or
                                   education    Parent education/        before-school Community service        Out-of-school
Statea                             programs          involvement             programs            projects      youth services
Alabama                                 70                       100                        70                        80                     25
Alaska                                   5                        15                          0                        5                     10
                                                                                                                                              b
Arizona                                 35                        80                        40                        40
Arkansas                                50                        50                        10                        20                     10
                                                                                                                                              b
California                              70                        90                        60                        30
Colorado                                50                        80                        25                        40                     60
Connecticut                             25                        35                        50                        15                      0
Delaware                               100                       100                        80                        90                      0
Floridab
Georgia                                 25                        50                        15                        15                     10
Idaho                                   40                       100                        25                        20                     40
Illinois                                 0                        90                        10                        10                      0
                                                                                                                                              b
Indiana                                 35                       100                       100                        30
Iowa                                     0                          0                       46                         0                      0
Kansas                                  40                        82                        34                        34                     10
Kentucky                                60                        65                        25                        10                      5
Louisiana                                3                        60                          0                        0                      0
Maine                                    5                        28                          8                        2                      2
Maryland                                75                       100                        87                        87                     75
Massachusetts                           10                        50                        20                         0                      0
Michigan                                20                        32                        57                        58                      0
                                                                                                                                   (continued)


                                          Page 47                                                 GAO/HEHS-98-3 Safe and Drug-Free Schools
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                             Data on Safe and Drug-Free Schools




                   Alternative                                         After- or
                    education       Parent education/             before-school Community service                  Out-of-school
Statea              programs             involvement                  programs           projects                 youth services
Minnesota                  10                         50                        10                        33                    10
Mississippi               100                         50                        15                        20                     1
Missouri                   40                         30                        55                        95                     5
Montata                    35                         75                        40                        50                    15
Nebraska                   33                         81                        37                        51                    11
Nevada                     70                         70                        50                        40                    25
New Hampshire              10                         75                        10                        10                     1
               b
New Jersey
New Mexico                 25                         40                        25                        25                     5
           c
New York
North Carolina             90                         95                        60                        90                    15
North Dakota                4                         62                          5                       41                     1
Ohio                       19                         58                        24                        30                     2
Oklahoma                    5                         80                        10                         5                     5
Oregon                     30                         60                        25                        15                     5
Pennsylvania               20                         25                        15                        15                    10
Rhode Island                8                         55                          3                        0                     1
South Carolina             35                        100                        33                        25                     0
South Dakota                8                         60                        20                        20                     0
Tennessee                   5                         25                          5                       10                     5
Texas                      28                         64                        24                        26                     7
Utah                      100                        100                        80                      100                     70
Vermont                     5                         90                        25                        10                     2
Virginia                   22                         50                        16                        28                     8
Washington                 20                         40                        40                        60                    20
West Virginia               2                         48                        43                        16                    36
Wisconsin                   1                           1                         1                        0                     0
Wyoming                    10                         60                          5                       10                     2

                             a
                              The District of Columbia, Hawaii, and Puerto Rico are not included because they each have one
                             LEA. See app. I.
                             b
                                 Data were collected by state but were not available at the time of our survey.
                             c
                              LEAs provided this information to the state; however, the data were not aggregated at the state
                             level.




                             Page 48                                                  GAO/HEHS-98-3 Safe and Drug-Free Schools
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                                          Data on Safe and Drug-Free Schools




Table III.5: Percent of LEAs in Each State Providing Selected Services, School Year 1995-96—Special, One-Time Events,
Conflict Resolution/Peer Mediation, Security Staff, Security Equipment, and Other
                           Special, one-time Conflict resolution/                               Security
Statea                                events       peer mediation        Security staff       equipment                  Other
Alabama                                100                   50                  15                     5                    0
Alaska                                  60                   40                   0                     0                    0
Arizona                                 80                   60                   3                    16                    2
Arkansas                                20                   20                   1                     5                    0
California                             100                   72                  30                    50                    0
Colorado                                50                   60                  15                    15                    0
Connecticut                              3                   65                  17                     3                    0
Delaware                                25                   90                   0                     0                    0
Floridab
Georgia                                 75                   50                  15                     5                    0
Idaho                                  100                   80                  10                     2                    0
                                                                                                                              c
Illinois                                20                   30                  10                     0
                                                                                   b                     b
Indiana                                100                   80                                                             35
                                                                                                                              c
Iowa                                     0                    0                   0                     5
                                                                                                                              c
Kansas                                  80                   55                  22                    19
Kentucky                                80                   45                   1                     1                    0
                                                                                                                              c
Louisiana                               98                  100                  10                    10
Maine                                   15                   40                   1                     1                    0
Maryland                                91                    8                  16                     8                  100
Massachusetts                           30                   50                   5                     0                    0
Michigan                               100                   25                   3                     3                    0
Minnesota                               50                   85                   5                    10                    0
Mississippi                             90                   50                  10                    50                    0
Missouri                                75                   65                  30                    20                    0
Montana                                 95                   85                   2                     0                  100
Nebraska                                82                   19                   4                     0                    0
Nevada                                  82                   50                  25                    12                    0
New Hampshire                           80                   45                   1                     1                    0
New Jerseyb
New Mexico                              50                   65                  30                    10                    0
New Yorkd
North Carolina                          95                   90                   0                     0                    0
North Dakota                            56                    0                   1                     0                   14
                                                                                                                              c
Ohio                                    84                   61                   7                     5
Oklahoma                               100                   40                   5                     5                    0
                                                                                                                    (continued)



                                          Page 49                                      GAO/HEHS-98-3 Safe and Drug-Free Schools
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                                            Data on Safe and Drug-Free Schools




                         Special, one-time Conflict resolution/                                                  Security
Statea                              events    peer mediation                      Security staff               equipment                         Other
Oregon                                     5                         75                        10                           5                        0
Pennsylvania                              15                         45                        15                           5                        0
                                                                                                                                                      c
Rhode Island                              14                         42                          0                          3
South Carolina                           100                         40                        10                        40                          0
South Dakota                             100                         40                          0                          0                        0
Tennessee                                 30                         30                          5                       15                          0
                                                                                                  b                         b                         c
Texas                                     73                         40
Utah                                     100                         80                        50                        10                          0
Vermont                                   20                         80                          0                          0                        0
                                                                                                                                                      c
Virginia                                  42                         42                          1                          3
                                                                                                                                                      c
Washington                                85                         60                          5                          5
West Virginia                              5                         78                          0                          2                        2
Wisconsin                                  5                         15                          1                          1                        0
Wyoming                                   80                         20                          5                          2                        0

                                           a
                                            The District of Columbia, Hawaii, and Puerto Rico are not included because they each have one
                                           LEA. See app. I.
                                            b
                                                Data were collected by state but were not available at the time of our survey.
                                            c
                                               Some LEAs provided more than one other type of service.
                                            d
                                             LEAs provided this information to the state; however, the data were not aggregated at the state
                                            level.




Table III.6: States’ Most Often Used Methods for Monitoring LEAs
                                                 Review of       Technical               Telephone calls                                      Did not
State                          Site visits  documentation       assistance                  (monitoring)           Other         Multiple     monitor
Alabama                                                                                                                                              X
Alaska                                                          X
Arizona                              X
Arkansas                                                                            X
California                           X
Colorado                                                                                                                               X
             a
Connecticut
Delaware                             X
Florida                                                                                                                                X
Georgia                                                         X
Idaho                                                                                                                   X
Illinois                             X
                                                                                                                                            (continued)


                                           Page 50                                                    GAO/HEHS-98-3 Safe and Drug-Free Schools
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                               Data on Safe and Drug-Free Schools




                                   Review of          Technical     Telephone calls                          Did not
State            Site visits   documentation         assistance        (monitoring)     Other   Multiple     monitor
Indiana                   X
Iowa                                         X
Kansas                                                                           X
Kentucky                  X
Lousiana                                                                                                             X
Maine                                        X
Maryland                  X
Massachusetts             X
Michigan                                     X
Minnesota                 X
Mississippi               X
Missouri                  X
Montana                                                                                                 X
Nebraska                                                                         X
Nevada                                                                                                               X
New Hampshire                                                                                           X
New Jersey                X
New Mexico                X
New York                  X
North Carolina                                                                                          X
North Dakota                                                                                X
Ohio                                                                                        X
Oklahoma                  X
Oregon                                       X
Pennsylvania                                 X
Rhode Island                                                                                                         X
South Carolina                                                                   X
South Dakota              X
Tennessee                                    X
Texas                                                                                                   X
Utah                                         X
Vermont                   X
Virginia                                                                                    X
Washington                                                                                              X
West Virginia                                                                    X
Wisconsin                                                                                   X
Wyoming                   X

                                                                                             (Table notes on next page)




                               Page 51                                      GAO/HEHS-98-3 Safe and Drug-Free Schools
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                                            Data on Safe and Drug-Free Schools




                                            Note: Hawaii is not included in this table because it has only one LEA.
                                            a
                                            Missing data.



Table III.7: Private School Participation
in Safe and Drug-Free Schools                                                                        Number of private
Program                                                                     Number of private           not-for-profit        Number of
                                                                               not-for-profit                 schools           students
                                            State                                   schools              participating      participating
                                                                                                                        a
                                            Alabama                                           225                                 27,800
                                                                                                 a                      b               b
                                            Alaska
                                                                                                 a
                                            Arizona                                                                    75         15,100
                                                                                                 a
                                            Arkansas                                                                   35         10,200
                                                                                                                        b               a
                                            California                                      4,158
                                            Colorado                                          384                      90         48,800
                                                                                                                        b               b
                                            Connecticut                                       337
                                            Delaware                                          164                      85         15,000
                                                                                                                                        a
                                            District of Columbia                               61                      36
                                                                                                                        a               b
                                            Florida                                         1,168
                                                                                                                        a               a
                                            Georgia                                           521
                                            Hawaii                                             63                      34         10,100
                                            Idaho                                              80                      17            500
                                                                                                                        a               a
                                            Illinois                                        1,380
                                            Indiana                                           961                     307         69,700
                                            Iowa                                              204                     204         44,800
                                                                                                                        a
                                            Kansas                                            152                                 28,000
                                            Kentucky                                          300                     199         49,400
                                                                                                                        a
                                            Lousiana                                          392                                113,300
                                            Maine                                             103                      42         10,500
                                            Maryland                                        1,113                     209         57,400
                                                                                                                        a               a
                                            Massachusetts                                     176
                                            Michigan                                        1,067                     800        176,700
                                            Minnesota                                         543                     407         62,600
                                            Mississippi                                        45                      67         18,500
                                            Missouri                                          445                     400         95,000
                                                                                                 a                      a
                                            Montana                                                                               11,300
                                            Nebraska                                          224                     219         40,700
                                                                                                                        a               a
                                            Nevada                                             99
                                            New Hampshire                                     150                     110         16,800
                                            New Jersey                                      1,006                     886        205,000
                                            New Mexico                                        142                      51         11,900
                                                                                                                              (continued)


                                            Page 52                                              GAO/HEHS-98-3 Safe and Drug-Free Schools
Appendix III
Data on Safe and Drug-Free Schools




                                                            Number of private
                                   Number of private           not-for-profit          Number of
                                      not-for-profit                 schools             students
State                                      schools              participating        participating
                                                                                 b               b
New York                                          2,142
North Carolina                                      545                         28          4,900
North Dakota                                          65                        65          8,000
                                                                                 b               b
Ohio                                                878
                                                                                                 b
Oklahoma                                            200                        200
                                                                                 a               a
Oregon                                              335
Pennsylvania                                      2,179                    1107           278,100
Puerto Rico                                         532                         8           3,000
Rhode Island                                        170                        126         21,500
                                                                                 b               b
South Carolina                                      380
South Dakota                                        167                         92         11,800
                                                        a                        a               a
Tennessee
                                                        a
Texas                                                                          867        165,600
Utah                                                  54                        36          2,100
Vermont                                             103                         40          6,500
                                                        a                        a
Virginia                                                                                   32,300
Washington                                            48                       125          5,000
West Virginia                                       662                        104          4,300
Wisconsin                                           980                        490            100
Wyoming                                               31                        4             200

a
Missing data.
b
    Data were collected by state but were not aggregated at the state level.




Page 53                                                 GAO/HEHS-98-3 Safe and Drug-Free Schools
                                         Appendix III
                                         Data on Safe and Drug-Free Schools




Table III.8: Method Used to Distribute
Funds by State                                                                              Basis
                                                                                       Forward
                                         State                      Reimbursement      funding LEA request            Other
                                         Alabama                               X
                                         Alaska                                X
                                         Arizona                                              X
                                         Arkansas                                             X
                                         California                                           X
                                         Colorado                              X
                                         Connecticut                           X
                                         Delaware                              X
                                         Florida                                                                          X
                                         Georgia                                                            X
                                         Idaho                                 X
                                         Illinois                              X
                                         Indiana                               X
                                         Iowa                                                 X
                                         Kansas                                X
                                         Kentucky                                                                         X
                                         Lousiana                              X
                                         Maine                                                X
                                         Maryland                                                                         X
                                         Massachusetts                                        X
                                         Michigan                              X
                                         Minnesota                             X
                                         Mississippi                           X
                                         Missouri                              X              X
                                         Montana                                                                          X
                                         Nebraska                              X                                          X
                                         Nevada                                                                           X
                                         New Hampshire                         X
                                         New Jersey                                           X
                                                       a
                                         New Mexico                                                         X
                                         New York                              X
                                         North Carolina                                                     X
                                         North Dakota                          X
                                         Ohio                                                                             X
                                         Oklahoma                              X
                                         Oregon                                X
                                                                                                                 (continued)


                                         Page 54                                    GAO/HEHS-98-3 Safe and Drug-Free Schools
                                     Appendix III
                                     Data on Safe and Drug-Free Schools




                                                                                                    Basis
                                                                                               Forward
                                     State                          Reimbursement              funding LEA request          Other
                                     Pennsylvania                                                      X
                                     Rhode Island                                     X
                                     South Carolina                                   X
                                     South Dakota                                                                               X
                                     Tennessee                                                                    X
                                     Texas                                                                                      X
                                     Utah                                             X
                                     Vermont                                                                                    X
                                     Virginia                                         X
                                     Washington                                                                                 X
                                     West Virginia                                    X
                                     Wisconsin                                        X
                                     Wyoming                                                                                    X

                                     Note: Hawaii is not included in this table because it has only one LEA.
                                     a
                                     Missing data.



Table III.9: Method Used to Select
Neediest Districts by State                                                                    Selection method
                                     State                                                 Application                   Formula
                                     Alabama                                                           X
                                     Alaska                                                            X
                                     Arizona                                                           X
                                     Arkansas                                                          X
                                     California                                                                                 X
                                     Colorado                                                          X
                                     Connecticut                                                       X
                                     Delaware                                                          X
                                     Florida                                                           X
                                     Georgia                                                           X                        X
                                     Idaho                                                             X
                                     Illinois                                                                                   X
                                     Indiana                                                                                    X
                                     Iowa                                                              X
                                     Kansas                                                            X
                                     Kentucky                                                          X
                                     Lousiana                                                          X
                                                                                                                       (continued)


                                     Page 55                                              GAO/HEHS-98-3 Safe and Drug-Free Schools
Appendix III
Data on Safe and Drug-Free Schools




                                                          Selection method
State                                                 Application                   Formula
Maine                                                             X
Maryland                                                          X
Massachusetts                                                     X
Michigan                                                          X
Minnesota                                                         X                        X
Mississippia
Missouria
Montana                                                           X
Nebraska                                                                                   X
Nevada                                                            X
New Hampshire                                                     X
New Jersey                                                        X
               a
New Mexico                                                        X
New York                                                                                   X
North Carolina                                                    X                        X
North Dakota                                                      X
Ohio                                                                                       X
Oklahoma                                                          X                        X
Oregon                                                            X
Pennsylvania                                                      X                        X
Rhode Island                                                      X
South Carolina                                                                             X
South Dakota                                                      X
Tennessee                                                         X                        X
Texas                                                             X                        X
Utah                                                                                       X
Vermont                                                           X
Virginia                                                          X
Washington                                                        X
West Virginia                                                     X
Wisconsin                                                         X
Wyoming                                                           X

Note: Hawaii is not included in this table because it has only one LEA.
a
Missing data.




Page 56                                              GAO/HEHS-98-3 Safe and Drug-Free Schools
Appendix IV

GAO Contacts and Staff Acknowledgments


                  Eleanor L. Johnson, Assistant Director, (202) 512-7209
GAO Contacts      Sandra L. Baxter, Evaluator-in-Charge, (202) 512-7053


                  In addition to those named above, the following individuals made
Staff             important contributions to this report: John Carney helped design the
Acknowledgments   questionnaire, gather survey information from states, reviewed
                  Department of Education files, wrote summaries of those reviews, and
                  drafted sections of the report; D. Catherine Baltzell, Dianne Murphy Blank,
                  and Deborah Edwards helped design the study and advised on
                  methodology; Edward Tuchman helped gather survey data from states
                  and, with Wayne Dow, provided survey analyses; and Linda Stokes and
                  Sheila Nicholson helped gather survey information from states. In
                  addition, Robert Crystal and Julian Klazkin performed the legal analysis
                  and provided ongoing legal advice.




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