Public Education: Meeting the Needs of Students With Limited English
Proficiency (Letter Report, 02/23/2001, GAO/GAO-01-226).
Experts disagree about the best methods to teach student who speak
little English. Even though different approaches to English language
instruction may be effective, many variables may influence a given
school's program choices. Moreover, there is no clear time line for
acquiring English proficiency. Local decisions about the amount of time
needed to attain proficiency and the amount of language support that
should be provided may differ. Of the two main instructional
approaches, English-based instruction is more common than instruction in
which a student's native language is used. From information given at
the state level, most students spent four or less years in these
programs. School districts are required to ensure that English-language
instruction is adequate and to provide these children with equal
educational opportunities. The Office of Civil Rights (OCR) has adopted
procedural requirements for criteria for judging the adequacy of local
English-language instruction programs in meeting those needs. In three
policy documents, OCR set forth requirements that school districts must
meet to pass a three-pronged test established by the courts. When the
adequacy of local English-language instruction programs is questioned,
OCR investigates and, if problems are found, enters into agreement with
the district specifying how the district will address the issues.
--------------------------- Indexing Terms -----------------------------
REPORTNUM: GAO-01-226
TITLE: Public Education: Meeting the Needs of Students With
Limited English Proficiency
DATE: 02/23/2001
SUBJECT: Bilingual education
Educational testing
Public schools
Minority education
Educational standards
State-administered programs
Aid for education
School districts
IDENTIFIER: Dept. of Education Emergency Immigrant Education Act
Program
Migrant Education Program
HHS Individuals With Disabilities Education Act Program
Dept. of Education Perkins Vocational and Applied
Technology Act Program
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GAO-01-226
Report to Congressional Requesters
February 2001 PUBLIC EDUCATION Meeting the Needs of Students With Limited
English Proficiency
GAO- 01- 226
Letter 3 Appendixes Appendix I: Scope and Methodology 34
Appendix II: Data on Number of Years Students Received Language Services in
Arizona and Illinois 37
Appendix III: School Districts' Impressions of Whether OCR Conveyed
Preferences for Type of Language Instruction 39
Appendix IV: Most School Districts That Added Bilingual Instruction Reported
No Pressure by OCR 48
Appendix V: Comments From the Department of Education 50 Appendix VI: GAO
Contacts and Staff Acknowledgments 51
Tables Table 1: Federal Education Programs That Can Provide Support Services
to Students With Limited English Proficiency 8
Table 2: Studies of the Length of Time Children With Limited English
Proficiency Need to Reach the Proficiency Levels of Native English- Speakers
17
Table 3: Amount of Time Spent in English Proficiency Programs by Students
Who Made the Transition From Such Programs in 1998- 99 21 Table 4: Amount of
Time Spent in English Proficiency Programs by More Than Half the Students
Making the Transition From Such
Programs in Selected California School Districts, 1998- 99 22 Table 5: Types
of Problems Districts Reported in OCR's Investigation
Process 29 Table 6: OCR Headquarters Responses to Problems Identified by the
School Districts 30 Table 7: Students Who Were Reclassified Because They Had
Achieved “Fluent English Proficiency” in Arizona, 1998- 99 37
Table 8: Transitioned Students' Years of Participation by Program Type and
Location in Illinois, FY1999 38 Table 9: Most School Districts Reported OCR
Favored No Particular Type
of Language Program 40 Table 10: Information About 10 Districts' Decisions
to Add Bilingual
Education to Their Programs 49
Figures Figure 1: OCR Title VI Investigation Process in Five Cases Reviewed
11 Figure 2: The Majority of School Districts Reported OCR Favored No
Particular Type of Language Program 26 Figure 3: Type of Language Program in
School Districts Before and After
OCR Investigation 27 Figure 4: School Districts' Characterizations of
Interactions With OCR 28
Abbreviations
EEOA Equal Educational Opportunities Act ERIC National Educational Resources
Information Center ESL English as a second language OCR Office for Civil
Rights
Lett er
February 23, 2001 The Honorable John A. Boehner Chairman, Committee on
Education and the Workforce House of Representatives
The Honorable Michael N. Castle Chairman, Subcommittee on
Education Reform Committee on Education and the Workforce House of
Representatives
Over 3. 4 million children with limited proficiency in English were in U. S.
elementary and secondary schools in school year 1996- 97. 1 These children
face a double challenge: learning to speak, read, and write English as well
as learning the content of academic subjects. America's schools have
achieved limited success in meeting the needs of these students, who have
four times the dropout rate of their peers who are fluent in English, as
well as higher grade repetition rates. Moreover, because schools often do
not know what these students have achieved in subjects other than English,
they may be overlooked for programs and educational services that may be
appropriate for some of them, such as gifted and talented programs. Attempts
to create policy and effective curricula to help solve these problems have
been hampered by the continuing controversy about which approach can better
meet the needs of these children- English- based or bilingual- and about how
long special help should be given to these students. Although educating
children is primarily a state and local responsibility, the
federal government has a substantial role in ensuring that the educational
needs of children with limited English proficiency are met- a role that is
based on title VI of the Civil Rights Act of 1964 and court decisions
interpreting it. The Office for Civil Rights (OCR) in the Department of
Education has been tasked with enforcing the rights of these students under
title VI. Questions have been raised about whether the federal government is
achieving the right balance between ensuring that states and local education
agencies meet the needs of these children as defined by the courts and
giving local districts the flexibility they need to implement 1 This figure
is the latest available estimate.
programs that respond to their own unique circumstances. The Congress has
provided oversight on this issue. In February 1998, April 1998, and June
1999, two separate subcommittees of the House Committee on Education and the
Workforce held hearings on bilingual education and oversight of the
Department of Education's OCR. During these hearings, questions were raised
about whether OCR had pressured school districts it had investigated to
implement bilingual approaches- teaching students in native- language- based
programs- to educate students with limited English proficiency. As a result
of your long- standing concerns and issues raised at these hearings, you
asked us to answer the following questions:
? How long do children with limited English proficiency need to become
proficient in English?
? What approaches are used to teach children with limited English
proficiency, and how long do students remain in language assistance
programs?
? What are the requirements for children with limited English proficiency
that OCR expects school districts to meet, how are they set forth, and what
has been the nature of the interactions between OCR and school districts in
those instances in which OCR has entered into an agreement with the school
district concerning language assistance programs?
To answer the first question, we reviewed available studies on
secondlanguage learning and talked to experts in the field. 2 To answer the
second question, we reviewed the literature, spoke to experts, and reviewed
Education's survey data. In addition, we contacted 12 states with
substantial concentrations of students with limited English proficiency, 6
of which- Arizona, Florida, Illinois, New Jersey, Texas, and Washington- had
information on the length of time students spent in language assistance
programs. We also conducted site visits in 10 school districts (2 in each
state) in Arizona, Florida, Illinois, North Carolina, and Texas to obtain
information on teaching approaches used. These states have large or growing
populations of children with limited English proficiency. To answer the
third question, we interviewed OCR officials; reviewed case law 2 We
conferred with a number of experts on second- language learning, searched
relevant education research databases, and reviewed the following National
Research Council
report: Diane August and Kenji Hakuta, eds., Improving Schooling for
Language- Minority Children: A Research Agenda (Washington, D. C.: National
Academy Press, 1997) to identify relevant studies that appeared to meet our
criteria. Ultimately, we reviewed and analyzed 70 studies, program
evaluations, and published articles concerning second- language learning and
eliminated all but the three that met our criteria.
and OCR memos regarding students with limited English proficiency; reviewed
one case related to students with limited English proficiency in each of
five states: Colorado, California, Massachusetts, Michigan, and Texas; 3 and
surveyed all 293 school districts that had entered into corrective action
agreements with OCR from 1992 through 1998 to provide
services to students with limited English proficiency. 4 Of these, 245 (84
percent) responded. Appendix I provides additional information about our
methodology. We conducted our work between September 1999 and January 2001
in accordance with generally accepted government auditing standards.
Results in Brief No clear consensus exists on the length of time children
with limited English proficiency need to become proficient in English.
Several factors make it difficult to generalize about how much time is
needed. First, the two main categories of instructional approaches used to
teach children are designed to take different lengths of time, from 2 to 3
years for Englishbased
approaches to much longer for approaches that make extensive use of a
child's native language. Second, no agreement exists about how proficiency
should be defined or measured. Conversational skills may be
developed within 2 years, while achieving broader academic proficiency, such
as the ability to read or communicate abstract ideas at grade level, may
take several years more. 5 Third, even if there were agreement on
instructional approaches and the meaning of proficiency, individual
differences among children and their family situations make generalizations
difficult. Finally, very few studies have focused specifically 3 We chose
these states to ensure that we included the greatest number of regional
offices
when selecting cases to review from the list you provided us of 15 cases in
which you were interested.
4 OCR began using its automated data system in 1992. When we began our
study, the latest year for which we could obtain information was 1998. 5
See, for example, James Cummins, “The Role of Primary Language
Development in Promoting Educational Success for Language Minority
Students,” Schooling and Language Minority Students: A Theoretical
Framework, developed by the California State Department of Education, Office
of Bilingual Bicultural Education (Los Angeles, Calif.: California State
University, Evaluation, Dissemination, and Assessment Center); Kenji Hakuta,
Yuko Goto Butler, and Daria Witt, “How Long Does It Take English
Learners to Attain Proficiency?” Policy Report No. 2000- 1 (Palo Alto,
Calif.: University of California Linguistic Minority Research Institute,
1999); and Barry McLaughlin, Second- Language Acquisition in Childhood:
Volume 2- School Age Children, 2nd ed. (Hillsdale, N. J.: Lawrence Erlbaum
Associates, 1985).
on how long students need to attain English proficiency. Of the 70 studies
we reviewed, only 3 both addressed this topic and met the other criteria for
inclusion in our analysis. 6 These three studies assessed students in
Englishbased programs and found that it may take 4 to 8 years to develop the
language skills needed to perform on a par with native English- speakers in
all core academic subject areas (reading, language arts, social studies,
science, and mathematics). However, some researchers have concluded that
fewer years are needed. 7
Of the two main instructional approaches, English- based instruction is more
common than instruction in which a student's native language is used
(hereafter referred to as bilingual education). Three- fourths of the
nation's children with limited English proficiency attend schools where both
instructional approaches are used. National data on the length of time
students spend in language assistance programs are not available. However,
we identified six states that collected such information at the
state level. Taken together, most students in these six states spent 4 years
or less in these programs; however, the proportion of students in the
individual states spending 4 years or less in these programs varied from 46
to 90 percent. In addition to the challenge of determining how best to meet
the needs of children with limited English proficiency, school districts are
also required to ensure that English- language instruction is adequate and
to provide
these children with equal educational opportunities, as required under title
VI of the Civil Rights Act. OCR has adopted procedural requirements and
criteria for judging the adequacy of local English- language instruction
programs in meeting those needs. In three policy documents issued between
1970 and 1991, OCR set forth requirements that school districts must meet to
pass a three- pronged test established by the courts. When the adequacy of
local English- language instruction programs is questioned, OCR
investigates, and, if problems are found, it enters into an agreement with
the district specifying how the district will address the issues. Most 6 To
be included in our analysis, a study had to (1) focus on the length of time
children need to become proficient in English, (2) reach specific
conclusions about the length of time needed, (3) have English as the second
language learned by the students, and (4) involve original research
supported by published data.
7 See, for example, Keith Baker, “What Bilingual Education Research
Tells Us,” The Failure of Bilingual Education, Jorge Amselle, ed.
(Washington, D. C.: Center for Equal Opportunity, 1996), and Christine H.
Rossell and Keith Baker, Bilingual Education in Massachusetts: The Emperor
Has No Clothes (Boston, Mass.: Pioneer Institute, 1996).
school districts that were involved in these agreements between 1992 and
1998 (77 percent) reported that in their interactions with OCR regional
staff, OCR did not appear to favor any particular approach to
Englishlanguage
instruction or pressure the districts to adopt a particular approach.
Moreover, they reported that OCR staff were generally courteous and
attempted to minimize the disruptions to the districts' operations
resulting from their visits and inquiries. However, some school districts
reported specific problems related to their interactions with OCR. The two
most frequently reported problems were districts' feeling pressure to change
aspects of their programs not related to the instruction approach, such as
the way they identify students in need of services, and untimely or
inadequate communications by OCR with school districts. The districts also
made suggestions for how OCR could improve its relations with school
districts in areas such as minimizing data requests and being clear about
when the period for monitoring the implementation of the corrective action
plan would end. OCR headquarters officials have acknowledged that problems
have occurred and have told us that some of the concerns identified by the
districts have already been identified by OCR. These officials have
presented us with a set of specific actions they are taking to address
problem areas, such as working more collaboratively with school districts
during investigations to alleviate pressure and limiting the amount
of data they request from school districts. Background States and localities
play the principal role in educating all students,
including those with limited English proficiency, with most states providing
supplemental aid specifically to address the special needs of these
students. According to a November 1997 report (the latest available) by the
Institute for Research in English Acquisition and Development, 39 states
have some form of regulations targeting these students, ranging from a
mandate in Texas that school districts provide bilingual instruction in at
least some grades to a mandate in California that school districts provide
instruction only in English. For the past 30 years, the federal government
has served students with limited English proficiency primarily through title
I of the Elementary and Secondary Education Act. 8 The Bilingual Education
Act, enacted in 1968, also serves a small percentage of these students under
a supplemental 8 Public Education: Title I Services Provided to Students
With Limited English Proficiency (GAO/ HEHS- 00- 25, Dec. 10, 1999).
grant program that assists local school districts in teaching students who
do not know English. Other programs that may address, at least in part, the
educational needs of children with limited English proficiency include the
Emergency Immigrant Education Program, the Migrant Education
Program, the Carl D. Perkins Vocational and Applied Technology Education Act
programs, and the Individuals With Disabilities Education Act programs (see
table 1). The only programs that serve primarily children with limited
English proficiency are those associated with the Bilingual Education Act.
Table 1: Federal Education Programs That Can Provide Support Services to
Students With Limited English Proficiency
FY 2000 funding Program a
(estimate) b Description
Education for Disadvantaged Children (title I, $8. 7 billion Helps
educationally disadvantaged children succeed in Elementary and Secondary
Education Act)
school. Students with limited English proficiency may (20 U. S. C. 6300)
participate in this program if they come from disadvantaged backgrounds and
are at risk of failing in school or if they attend a school that has a
schoolwide program.
Bilingual Education Act programs (instructional 248 million Helps ensure
that students with limited English proficiency services, support services,
training grants, and
master English and develop high levels of academic immigrant education)
attainment in content areas. Provides both state and local (20 U. S. C.
7401- 91) c
grants. Emergency Immigrant Education Program
150 million Provides grants to school districts with unexpectedly large (20
U. S. C. 7541- 49) increases in their student population due to immigration.
Migrant Education Program
355 million Provides funds to states to help educate the children of (20 U.
S. C. 6391- 99) migrant agricultural workers, including migratory fishers
and dairy workers. Carl D. Perkins Vocational and Applied Technology 1.5
billion Provides funds to improve the quality of vocational education
Education Act programs (basic state grants, Indian and and to provide access
to vocational training to special
Hawaiian natives set- aside, territorial set- asides, populations, such as
disadvantaged and disabled students.
technical- preparation education, tribally controlled postsecondary
vocational institutions, research, and National Occupational Information
Coordination Committee)
(20 U. S. C. 2301 et seq.) Individuals With Disabilities Education Act
programs 5.1 billion Supports special education for infants, toddlers,
children, and (grants to states; preschool grants; grants for infants youth
with disabilities.
and families; state improvement, research, and innovation; technical
assistance and dissemination; personnel preparation; parent information
centers; and technology and media) (20 U. S. C. 1400 )
a Other federal programs may also support services to students with limited
English proficiency if these students qualify to receive services under the
programs' guidelines for participation.
b Budget of the United States Government, Fiscal Year 2001 (Washington, D.
C.: Government Printing Office, 2000). c These are the only programs that
target all their benefits to students with limited English proficiency.
Federal policy for ensuring equal educational opportunity for children with
limited English proficiency has been largely shaped by title VI of the Civil
Rights Act of 1964, the Equal Educational Opportunities Act (EEOA), and
related court decisions. Title VI bans discrimination on the basis of race,
color, or national origin in any program or activity receiving federal
financial assistance. In Lau v. Nichols, 9 the Supreme Court held that a
school district's failure to provide English- language instruction to
nonEnglish- speakers violated title VI. 10 Like title VI, the EEOA also
protects the civil rights of students with limited English proficiency.
Under the EEOA, it is unlawful for an educational agency to fail to take
“appropriate action to
overcome language barriers that impede equal participation by its students
in instructional programs.” 11 In 1981, a federal court of appeals
decision, Castaneda v. Pickard, 12 created a test for evaluating the
adequacy of a school district's approach to addressing the needs of its non-
Englishspeaking students and limited- English- speaking students. 13 The
Department of Education uses the test set forth in the Castaneda decision as
the basis for determining whether a school district program for serving
students with limited English proficiency is complying with title VI.
9 414 U. S. 563 (1974). 10 Because the case established children with
limited English proficiency as a protected group under title VI, the
investigations OCR conducts regarding the rights of children with limited
English proficiency are frequently referred to as Lau investigations. In
reaching its conclusion, the Supreme Court upheld a May 25, 1970, Department
of Health, Education, and Welfare memorandum still used by OCR today. 11 20
U. S. C. 1703.
12 648 F. 2d 989 (5th Cir. 1981) . 13 The court created this test on the
basis of language in the EEOA.
Headquartered in Washington, D. C., Education's OCR has 12 regional offices
that enforce title VI and other civil rights statutes. 14 In the five cases
we reviewed, OCR initiated investigations independently 15 or after deciding
that a complaint brought by an individual or group met certain criteria. 16
To determine which school districts had potential problems with their
programs and therefore warranted a compliance review, OCR gathered and
analyzed statistical data and other information from state education
agencies, advocacy groups, parents, and OCR surveys. Once OCR selected a
school district for review, it requested data from the school district and,
if necessary, conducted on- site visits to schools in the district. If OCR
found a
school district was not in compliance with civil rights laws, it worked with
the district to negotiate an agreement on the problems and the steps
required to address those problems (the corrective action plan). During the
period in which OCR monitored the implementation of the corrective action
plan, school districts periodically submitted information to OCR regarding
their programs for children with limited English proficiency. Figure 1 shows
the title VI investigative process used by OCR in the five cases we reviewed
in depth.
14 In addition to title VI, OCR enforces section 504 of the Rehabilitation
Act of 1973, title II of the Americans With Disabilities Act of 1990, title
IX of the Education Amendments of 1972, and the Age Discrimination Act of
1975. 15 An investigation initiated by OCR is called a compliance review. A
compliance review assesses whether a school district is in compliance with
the requirements of title VI.
16 According to the Investigation Procedures Manual, for OCR to begin an
investigation, a complaint must contain the name and address of the
complainant; identify the person or group injured by the alleged
discrimination; identify the program or activity alleged to have
discriminated; describe the discrimination in sufficient detail; say when it
occurred; be in writing; and be signed. In addition, OCR must establish that
the program or activity receives federal financial assistance and the type
of discrimination alleged, and that the complaint is timely.
Figure 1: OCR Title VI Investigation Process in Five Cases Reviewed
Source: GAO analysis.
In November 1994, OCR changed the procedural guidance it followed from the
Investigation Procedures Manual to the Case Resolution Manual. OCR officials
told us that since about 1995 they have implemented a more cooperative
approach to their reviews. Under this approach, OCR has focused on finding
early resolutions to problems and working cooperatively throughout the
process with school district and state
officials. Also, under this approach, a letter of findings is issued only
when problems remain unresolved. Length of Time Needed No clear consensus
exists among researchers and educators on the length for Proficiency of time
needed for children with limited English proficiency to become proficient in
English. Four factors make generalizations difficult: (1)
Depends on Many differences in instructional approaches used to teach
children English and
Factors the quality of that instruction, (2) differences in the ways states
measure
proficiency, (3) differences in student characteristics, and (4) the lack of
definitive research on this issue.
Types of Language Two basic approaches are used to instruct students with
limited English
Assistance for Students skills. One uses English and makes little use of a
student's native language
With Limited English (English- based approach), while the other makes much
more extensive use
Proficiency Vary of a student's native language, often for a number of years
(bilingual approach). Proponents of an English- based approach expect
children to learn English fairly quickly, in 2 to 3 years. For example, in
Monroe County,
Florida, one of the districts we visited, elementary school children with
limited English proficiency receive all formal content area instruction in
English, alongside their English- fluent peers. District officials told us
they
chose this English- based approach in part because they believe children
learn English more quickly when they are immersed in it. On average,
elementary school students enrolled in the district's English- language
acquisition programs receive services for 3 years.
The bilingual approach is designed to take much longer- often 5 years or
more. While bilingual programs vary in both their goals and length, those
programs that promote native- language literacy as well as English- language
literacy may take 5 to 7 years to complete. For example, the San Antonio
School District develops early literacy in Spanish, beginning with
prekindergarten instruction. The program is designed to simultaneously
develop English literacy, with a full transition to English- only
instruction by
the sixth grade. District officials said they believe it is important to
develop bilingual citizens in a city that has a long bilingual tradition.
Most of the
city's population is Hispanic, and a large proportion of the city's
residents speak both Spanish and English.
The National Research Council has determined that there is “little
value in conducting evaluations to conclude which type of program is best.
The key issue is not finding a program that works for all children and all
localities, but rather finding a set of program components that works for
the children in the community of interest, given that community's goals,
demographics, and resources.” 17
Whether a school district chooses an English- based or bilingual approach to
teaching students with limited English proficiency, instructional quality
will ultimately affect children's academic achievement. Characteristics that
contribute to high- quality programs, according to some educators, include
adequately trained teachers, clearly articulated goals, systematic
assessments, and opportunities for children to practice their English. 18 In
our site visits, for example, we visited one classroom in Cicero, Illinois,
in which a bilingual education teacher who had been recruited from a
Spanish- speaking country was using audiotapes to teach students English
during the daily period dedicated to learning English. The students listened
and followed along in their workbooks as a speaker on the tape read them a
children's story in English. There was no interaction between the teacher
and the students. In contrast, in a Key West, Florida, classroom we visited,
the bilingual education classroom teacher did not use audiotapes but instead
read aloud a children's story to his students. This teacher paused
frequently to quiz the students on what they had heard. This activity not
only gave the teacher an opportunity to see what his students understood of
the story but also gave the students an opportunity to speak and practice
English.
States Define Proficiency No clear consensus exists about how proficiency
should be defined or Differently
measured. Educators and researchers have observed that children who speak
little or no English may develop “verbal proficiency”- that is,
conversational skills on a par with those of their English- speaking peers-
17 August and Hakuta, eds., Improving Schooling for Language- Minority
Children. 18 Kenji Hakuta, Supplemental Declaration in Plaintiff's Legal
Brief Requesting Preliminary Injunction on Proposition 227, U. S. District
Court, San Francisco, the Honorable Charles A. Legge presiding, July 15,
1998, and Charles Glenn, “Rethinking Bilingual Education,”
Agenda for Leadership 1998, Gabriela Mrad, ed. (Boston, Mass.: Pioneer
Institute, 1998).
in 2 years or less. Broader “academic proficiency,” such as the
reading and communicating of abstract ideas required for grade- level
academic performance, can take several more years to acquire.
Little agreement exists on an appropriate standard against which English
proficiency should be measured. Some educators and language experts believe
that a child should perform at age- or grade- appropriate levels in reading
and other core academic subjects on standardized tests performed in English
before the child can be considered English- proficient. This means that the
child should score at or above the 50th percentile on a standardized
achievement test. 19 In contrast, some states consider students English-
proficient when they score at the 40th percentile or even at the 32nd. Some
critics question the validity of using these types of standardized
achievement tests to measure whether a student's achievement in English is
better than, the same as, or worse than that of other children in his or her
age group. These critics argue that a student's performance on these tests
does not necessarily reflect mastery or lack of mastery of certain English
skills because the tests are designed to assess a student's mastery of other
subjects.
Performance on standardized achievement tests is just one of several
criteria states and districts may use to determine if a child is proficient
in English. We found that in Rockford, Illinois, officials combined the
results of an academic achievement test, English proficiency tests, and an
academic review conducted by school and district officials to determine a
child's English proficiency level. In contrast, we found that in Texas
students could be considered proficient by scoring at or above the 40th
19 However, students whose native language is English can also post scores
that are below the cutoff score. For example, during our site visit, the
deputy superintendent of the Denver Public Schools pointed out that 40
percent of his students did not score above the cutoff
score (40 percent) set by the courts and used by OCR. He said that insofar
as the students with limited English proficiency shared the characteristics
of those low- performing nativeEnglish- speakers, they might never reach the
required scores on the standardized tests. The deputy superintendent did not
think students should be in bilingual classes “forever.”
percentile on both the English reading and language arts sections of a
stateapproved norm- referenced academic assessment. 20 Time Needed to Attain
Research indicates that the length of time needed to become proficient in
Proficiency Can Vary With English can vary from child to child. It can be
affected by such factors as Student Characteristics
the child's age, socioeconomic background, and amount of formal schooling
already received in another language. For example, a 1997 study concluded
that the most striking feature about learning a second language is the
variability in outcomes. 21 A frequently cited factor is a child's age.
Older children generally make faster initial progress than very young
children do. For example, a study of students with limited English
proficiency attending school in Fairfax County, Virginia, found that
students who arrived in this country between ages 8 and 11 needed 5 to 7
years to compete with native speakers in all subject areas, while children
who arrived when they were aged 4 to 7 needed 7 to 10 years. Researchers
have proposed that this difference perhaps reflects the fact that older
learners have developed more sophisticated language and thinking skills
before beginning to learn English. 22 Educators have also observed that
students with prior formal schooling and higher socioeconomic
backgrounds tend to learn a second language more easily. Other
characteristics tied to differences in success rates include the amount of
exposure students have already had to English; the level of parental support
they have at home; and their classroom, school, and community environments.
Any of these factors could affect how long students need to catch up with
native speakers. 20 Norm- referenced academic assessments are constructed to
yield a measure of relative performance of the individual or group by
comparison with the performance of other individuals or groups taking the
same test. For example, fourth- graders taking a mathematics test that has
national norms would have their scores reported in terms of the scores of
other fourth- graders who took that test, so their performance could be
compared with that of fourth- graders nationally. In school year 2000- 01,
the list of approved assessments in Texas included the TerraNova (CTBS/ 5),
the Iowa Test of Basic Skills, the Iowa Tests of Educational Development,
the Metropolitan Achievement Test, and the Stanford Achievement Tests.
21 August and Hakuta, eds., Improving Schooling for Language- Minority
Children. 22 Virginia Collier, “The Effect of Age on Acquisition of a
Second Language for School,” New Focus (winter 1987- 88).
Research on Time Needed While many evaluations of programs serving children
with limited English to Attain Proficiency Is Not
proficiency have been conducted, we identified very few that focused
Definitive
specifically on the length of time students need to become proficient in
English. Our review of existing research yielded three studies that met the
following criteria: (1) they addressed the acquisition of English rather
than
other languages, (2) they focused specifically on the length of time
required to become proficient, (3) they reached a specific conclusion about
the length of time needed to become proficient in English (as described in
app. I), and (4) they had been published. Two of these studies were carried
out in Canada and one in the United States (see table 2). The students in
each
of these studies were schooled primarily in English. In general, the studies
concluded that children with limited English proficiency need 4 years or
more to develop the language skills needed to perform in academic subject
areas on a par with native English- speakers. However, with so few studies
available, the results should not be viewed as definitive, 23 and other
researchers in the field have challenged some of the results. 24
23 While children may require many years to achieve a degree of proficiency
at which they can perform academically at age- and grade- appropriate
levels, we are not implying that they will require targeted language
assistance- either in English- based or native- languagebased programs- in a
classroom separate from their peers during this entire period of time. Some
education experts have suggested that children may need language assistance
for substantially less time than is needed to reach academic proficiency. 24
See, for example, Keith Baker, “What Bilingual Education Research
Tells Us,” and
Christine H. Rossell and Keith Baker, Bilingual Education in Massachusetts.
Table 2: Studies of the Length of Time Children With Limited English
Proficiency Need to Reach the Proficiency Levels of Native English- Speakers
Length of time needed to reach proficiency levels of Study Measure of
proficiency native English- speakers
Toronto Grade- level norms on English At least 5 years
(Canada) Board vocabulary and language competency of Education a
tests Fairfax County
Grade- level norms on academic At least 4 to 8 years (Virginia) School
achievement tests in all areas District b (reading, language arts, social
studies, science, and mathematics [given in English])
North York Age- level norms on tests measuring At least 6 years
(Canada) Board English speaking, listening, reading, of Education c
and writing skills a James Cummins, “Age on Arrival and Immigrant
Second Language Learning in Canada: A Reassessment,” Applied
Linguistics, Vol. 11, No. 2 (summer 1981), pp. 132- 49.
b Virginia P. Collier, “Age and Rate of Acquisition of Second Language
for Academic Purposes,” TESOL Quarterly, Vol. 21, No. 4 (1987), pp.
617- 41, and Virginia P. Collier and Wayne P. Thomas, “How Quickly Can
Immigrants Become Proficient in School English?” The Journal of
Educational Issues of Language Minority Students, Vol. 5 (fall 1989), pp.
26- 39. c Harold Klesmer, “Assessment and Teacher Perceptions of ESL
Student Achievement,” English Quarterly, Vol. 26, No. 3 (spring 1994),
pp. 8- 11.
The three studies we identified examined students' progress in English with
respect to two different sets of skills. The two Canadian studies focused on
language skills alone, examining the point at which students' scores on
tests of vocabulary, auditory perception, and other language
skills approached those of native English- speakers. The Fairfax County
study focused on students' academic achievement in English, measuring the
point at which students' performance on tests in reading, mathematics, and
other subjects, given in English, began to approach that of nativeEnglish-
speaking students. The Fairfax study showed that children took longer to
reach grade norms in reading than in other subjects. For example, even among
the highest performing subgroup of children (those who arrived in this
county between ages 8 and 11), the performance in different subject areas
varied widely, averaging 2 years to reach national norms in mathematics, 3
years in language arts, and 5 years or more in reading.
English- Based English- based instruction is more commonly found in the
nation's public Approaches
schools than bilingual instruction is. However, most students with limited
English proficiency attend schools in which both approaches are used. In
Predominate; In the Six the six states we reviewed, most children received
services for 4 years or States Reviewed, Most less.
Children Receive Services for 4 Years or Less
English- Based Approaches More children with limited English proficiency
receive instruction through
Are More Common Than an English- based approach than through an approach
that makes use of Bilingual Approaches
their native language, according to data from the Department of Education's
most recent survey on the subject. 25 About 76 percent of students with
limited proficiency in English receive English- based instruction (such as
English as a second language [ESL]); 40 percent receive bilingual
instruction aimed at teaching subject matter in the student's home language
(such as teaching math in Spanish); and slightly fewer, 37 percent, receive
instruction aimed at maintaining or improving fluency in their home language
(such as Spanish language lessons for Spanish speakers.) 26 The Education
survey, which covered the 1993- 94 school year, also asked schools about the
types of instructional programs they offer and found that more schools offer
English- based programs than bilingual programs. For example, about 85
percent of schools enrolling students with limited
English proficiency offer ESL programs, and about 36 percent offer bilingual
programs in which the student's native language is used to varying degrees.
27 Nearly three- fourths of all children with limited English 25 U. S.
Department of Education, National Center for Education Statistics, A Profile
of Policies and Practices for Limited English Proficient Students: Screening
Methods, Program Support, and Teacher Training (SASS 1993- 94) (NCES 97-
472) (Washington, D. C.:
Department of Education, Jan. 1997). 26 Percentages do not total 100 because
students could, and often did, receive more than one type of instruction
during a school day. 27 Percentages do not total 100 because about one-
third of all schools offer both ESL and bilingual programs.
proficiency attend schools with both types of programs. We visited 10 school
districts in Arizona, Florida, Illinois, North Carolina, and Texas and found
that 6 of the 10 used both English- based and bilingual instruction.
The survey also found that students often receive more than one type of
instruction during a school day. For example, ESL is often a component of
programs classified as bilingual education programs- that is, although
explanations and some content areas may be taught in the student's native
language, ESL techniques may be used to teach English. However, the study's
data were not collected in a way that would allow accurate estimates of the
proportion of students who received a combination of services.
Determining the type of instruction students actually receive is more
complicated than these results would indicate for two reasons. First, the
instructional approaches used to teach children with limited English
proficiency are far more varied than the categories typically used to
capture this information. For example, a program model called
“structured immersion” uses simplified English to teach subject
matter and sometimes allows for the teacher's use of students' native
language for clarification.
While clearly not a bilingual approach, some might classify this approach
with English- based approaches, such as ESL; others might classify it as a
distinct third approach that makes limited use of students' native language.
Second, the broad program labels used by educators may not reflect actual
classroom practices. For example, in the Monroe School District, Florida, we
observed a language arts class designed to teach ESL to Spanishspeaking
students. Normally, such an approach would involve little or no use of
Spanish. In this case, however, the teacher was not only specially
trained to teach English language arts to speakers of other languages, but
also fluent in Spanish. She provided instruction first in English and then
translated much of that instruction into Spanish.
Most Children in the Six We found no national data on the length of time
children with limited
States Reviewed Spend 4 English proficiency actually spend in programs aimed
at helping them Years or Less in Programs
become proficient in English. Thus, we contacted education agencies in 12
states with substantial concentrations of students with limited English
Aimed at Increasing English
proficiency to collect any available state- level data on this issue. 28 Of
the 12 Proficiency
states contacted, 6 had information on the length of time children with
limited English proficiency spent in language assistance programs. Data from
these six states- Arizona, Florida, Illinois, New Jersey, Texas, and
Washington- indicate that in 1998- 99 (the latest year for which data are
available), the majority of children with limited English proficiency who
made the transition from English- language programs spent 4 years or less in
language assistance programs. 29 As table 3 shows, at least two- thirds of
the children in Florida, Illinois, New Jersey, and Washington made the
transition from programs within 4 years. In Arizona and Texas, the portion
that made the transition within 4 years was lower: closer to one- half. In
five states, 12 percent or fewer of the children were out within 1 year. In
the sixth state- New Jersey- about one- third exited within 1 year. At the
other end of the scale, 10 percent of the students with limited English
proficiency in New Jersey spent 5 years or more in programs, while 41
percent of such students in Arizona spent more than 5 years.
28 Alaska, Arizona, California, Florida, Illinois, Massachusetts, Nevada,
New Jersey, New Mexico, New York, Texas, and Washington. 29 “Making
the transition” generally means that these children met the program's
criteria for proficiency.
Table 3: Amount of Time Spent in English Proficiency Programs by Students
Who Made the Transition From Such Programs in 1998- 99
Percentage a of students who spent . . . 1 year or
2 years or 3 years or
4 years 5 years or State
less less less or less less
Arizona 12.0 24.0 36.0 49. 0 59.0 b Florida 10.0 23.0 39.0 66. 0 79. 0
Illinois c 0.1 23.0 40.0 67. 0 86. 0 New Jersey 29. 0 57. 0 78. 0 90. 0 d
Texas 10.0 21.0 37.0 57. 0 e Washington f 17. 0 36. 0 57. 0 77. 0 87.0 g a
Percentages are cumulative. b Appendix II contains data for Arizona students
receiving language assistance services for as long as 13 years.
c Appendix II contains additional analyses of years of participation in
language assistance programs by type of program (bilingual or ESL). d Ten
percent of New Jersey students with limited English proficiency who exited a
program in school year 1998- 99 had been enrolled in language assistance
programs for 5 years or more. The percentage of students staying 5 years or
less cannot be determined. e Data are based on a 5- year study of children
with limited English proficiency enrolled in Texas public schools between
1992- 93 and 1996- 97. The percentage of students staying beyond 5 years
cannot be
determined. f These percentages include students who graduated from high
school but may not have met program exit criteria.
g Washington reported that 14 percent of students spent more than 5 years in
the program. These percentages do not total 100 because of rounding.
California, with about 40 percent of the nation's students with limited
English proficiency in 1996- 97, 30 did not have statewide data that could
be used to determine how long children were spending in its programs. To
provide an indication of what was happening there, we obtained data from
four large school districts with large numbers of students with limited
English proficiency: Los Angeles, San Francisco, Santa Ana, and San Diego
(see table 4).
30 Reynaldo F. Macias, Summary Report of the Survey of the States' Limited
English Proficient Students and Available Educational Program and Services
(Washington, D. C.: National Clearinghouse for Bilingual Education, George
Washington University, 1998).
Table 4: Amount of Time Spent in English Proficiency Programs by More Than
Half the Students Making the Transition From Such Programs in Selected
California School Districts, 1998- 99 District Time spent Los Angeles 5
years or more San Francisco 5 years or less Santa Ana a 5 years or less San
Diego 7 years or more a Data are for school year 1999- 2000.
Because of the limited number of states and school districts from which the
data were drawn, these results should be interpreted cautiously. Differences
in the way these states and school districts define proficiency for exiting
such programs, as well as the types of tests used to measure proficiency,
make direct comparisons across states and districts nearly impossible. In
addition, districts may also decide on their own whether to
apply additional criteria beyond the requirements set by their states.
Moreover, in June 1998, California passed Proposition 227, mandating
English- based instruction in California public schools (although waivers
have been granted under this system, and bilingual programs still operate in
some California public schools). This new requirement may have an
impact on future data coming from these districts. As school districts
address the various challenges associated with meeting the educational needs
of children with limited English proficiency, districts are also required to
provide these children equal educational opportunities
under title VI of the Civil Rights Act. We now focus on the requirements
that Education's OCR expects school districts to meet and how OCR interacted
with school districts whose language assistance programs it investigated
from 1992 to 1998.
OCR's Interactions During the 6 years covered by our review, OCR relied on
the three policy With School Districts
documents regarding children with limited English proficiency discussed
below. These documents incorporate the Castaneda decision's threepronged
Were Generally
test for assessing the adequacy of programs for students with Positive; Some
Specific
limited English proficiency to determine whether school districts are in
Problems Reported
compliance with title VI. 31 OCR did not promulgate Castaneda's requirements
as regulations, instead setting them forth in policy documents. 32 OCR used
compliance reviews to monitor school districts' compliance with these
requirements. School districts that were found out of compliance with the
title VI requirements were required to enter into negotiated agreements with
OCR to correct their programs for students
with limited English proficiency. Our survey and case reviews of school
districts involved in negotiated agreements resulting from OCR's compliance
reviews between 1992 and 1998 revealed that the interaction between OCR and
school districts has been generally positive. A majority of districts
indicated that OCR regional staff did not favor, or pressure them to adopt,
a particular language approach, and almost all of the 245 respondents
indicated that OCR was courteous and minimized disruption of daily
activities when visiting school districts. However, some school officials
reported problems in their
interactions with OCR, most frequently related to feeling pressured to
change aspects of their programs not related to the language approach used
and to OCR's untimely or inadequate communication with school
districts. OCR's Title VI Requirements Castaneda set forth a three- part
test for determining whether a school Are Set Forth in Three
district has adopted a satisfactory method for teaching children with Policy
Documents limited English proficiency. The federal courts and OCR now
generally accept this test as a threshold for determining compliance with
title VI. The test is based on a combination of education theory, practice,
and results and requires that school district programs (1) be based on sound
educational principles, (2) effectively implement the educational
principles, and (3) have succeeded in alleviating language barriers.
OCR requirements for title VI compliance are articulated through three
policy documents known as the May 1970 memorandum, the December
31 As of December 2000, OCR was still using this test. 32 OCR officials said
that they disseminated information about a school district's requirements
for serving students with limited English proficiency through workshops,
conferences, meeting with state agencies, written materials, and technical
assistance activities. In December 1999, OCR made available another resource
for understanding title VI requirements- Programs for English Language
Learners: Resource Materials for Planning and Self Assessments- available on
the Internet at http:// www. ed. gov/ ocr/ ELL.
1985 memorandum, and the September 1991 policy update. The May 1970
memorandum required school districts to meet four basic criteria for title
VI compliance:
? districts must take “affirmative steps” to rectify the
language deficiency of students with limited English proficiency;
? students may not be designated as academically deficient on the basis of
English language skills;
? the school system's tracking system for students with limited English
proficiency must be designed to meet their needs as soon as possible, and it
must not work to lock students into a particular curriculum; and
? schools must notify parents of school activities in a language they can
understand.
The second document, the December 1985 memorandum, stipulates that OCR does
not require schools to adopt any particular educational or language-
teaching approach and that OCR will determine title VI compliance on a case-
by- case basis. Any sound educational approach that ensures the effective
participation of students with limited English
proficiency is acceptable. The December memorandum also outlines steps OCR
staff should take to determine whether there is a need for an alternative
language program for students with limited English proficiency and whether
the district's program is adequate for meeting the needs of these students.
The September 1991 policy update provides additional guidance for applying
the May 1970 and December 1985 memorandums. The 1991 document describes the
legal standard set forth by the court in Castaneda and therefore contains
more specific standards for staffing requirements, criteria for student
completion of language assistance programs, and program evaluation. Policy
issues related to access to special education programs and gifted/ talented
programs, as well as OCR's policy with regard to segregation of students
with limited English proficiency, are also highlighted in this update.
OCR Staff Generally Did Not Over three- fourths of the school districts
responding to our survey (77
Pressure Districts to Adopt percent) reported that when investigating cases
OCR staff did not appear to a Bilingual Approach and
favor bilingual instruction over English- based instruction. For example,
Were Courteous and
one school district noted that OCR staff made no mention of bilingual
instruction as a recommendation, but rather they emphasized meeting the
Professional needs of students with limited English proficiency. But three
districts felt
pressure to increase emphasis on bilingual instruction. 33 While most school
districts indicated that OCR appeared to be neutral regarding instructional
approach, about 18 percent reported OCR favored the bilingual approach and
about 4 percent reported that OCR favored English- based instruction
(see fig. 2). The 38 districts that reported that OCR favored bilingual
education were located in every OCR region except for Region 6 (the District
of Columbia regional office). More than half of these districts had cases
that were handled by either the San Francisco or Denver regional office, two
regions that serve almost half the students with limited English
proficiency. (See app. III for more detailed information on the cases
related to students with limited English proficiency by district, the
percentage of students in each of the regions, and the districts' views
about whether OCR
favored a particular approach.) 33 Two districts in California that had both
bilingual and English- only programs before the OCR investigation reported
that they felt pressure to increase emphasis on the bilingual approach. One
district in Oklahoma that had an English- only program before the OCR
investigation felt pressure to add bilingual instruction to its program.
Figure 2: The Majority of School Districts Reported OCR Favored No
Particular Type of Language Program
Percentage
80
77
70 60 50 40 30 20
18
10
4 1
0 No Particular
Bilingual English- Based Other Type
Type of Language Program Favored by OCR
In addition, in the school districts investigated by OCR, the kind of
program offered after the corrective action plan had been implemented
changed little. Further, some school district officials indicated that OCR
did not influence the type of language assistance program implemented.
Figure 3 shows the distribution of the instructional approaches school
districts offered before and after OCR investigation. (See app. IV for
further details.)
Figure 3: Type of Language Program in School Districts Before and After OCR
Investigation
Percentage
60
52 53
Before OCR Investigation 50
After OCR Investigation
42 40
40 30 20 10
4 5
0 English- Based
English- Based Bilingual and Bilingual
Type of Program
Overall, school districts reported that their interactions with OCR staff
during investigations were positive in three areas: courtesy, minimization
of disruption of daily activities, and consideration of the rationale for
the school district's existing program (see fig. 4).
Figure 4: School Districts' Characterizations of Interactions With OCR
Percentage
100 90
89
Very Good/ Good Poor/ Very Poor
81
80
75
70 60 50 40 30 20 10
4 5
5
0 Being
Minimizing Considering
Courteous Disruption
Rationale
Dimensions of Interactions
In comments written on their questionnaires, 13 school districts reported
that services to students with limited English proficiency had improved as a
result of OCR's investigation. For example, one respondent indicated that
OCR had pointed out identification and assessment procedures that the school
district had not previously implemented, and that, as a result of the
OCR investigation, improved procedures were adopted. In addition, some
respondents called OCR's approach “collaborative” or
“professional.” Similarly, during our site visits, officials in
two school districts noted that their interactions with OCR staff were
positive. For example, one superintendent said that OCR staff were very
professional, the goal of both OCR staff and school officials during the
investigation was to meet the needs of students with limited English
proficiency, and the students had
benefited from OCR's assistance. In another school district, officials told
us that OCR staff were pleasant and cordial and that they showed an interest
in how the district was delivering alternative language services to children
with limited English proficiency.
Some School Districts As part of our survey, we gave school district
officials the opportunity to Reported Problems With
make suggestions on how OCR could improve its investigation procedures OCR's
Investigation and to offer any additional comments about OCR's investigation
of their school district. Of the 245 questionnaires returned by school
districts, almost half (47 percent) contained comments on what OCR could do
to be more effective or improve its investigative process, and over half (53
percent) made additional comments about OCR's investigation of their school
district. Although district officials generally reported positive
interactions between their school district and OCR, some respondents
commented on the types of problems they encountered during OCR's
investigation process. We sorted these problems into seven categories and
have listed them in table 5 in descending order of the frequency of the
comments. Several of the problems reported in the survey comments also
surfaced in our case investigations. Table 5: Types of Problems Districts
Reported in OCR's Investigation Process Number of
districts reporting Problem type
problem Specific example cited
OCR “applied pressure.” 50 OCR told districts that federal funds
would be taken away if districts did not comply with OCR's recommendations,
used attorneys in negotiations, and was inflexible during negotiations with
school districts.
OCR's communications were 40 OCR did not provide enough feedback on data and
reports submitted; untimely or inadequate. several districts reported that
OCR took as long as a year to give districts feedback on data and reports.
Districts lacked sufficient resources 26 Several districts commented that
they were unable to successfully recruit to address problems. qualified
bilingual teachers, particularly in rural areas.
OCR made burdensome data 22 One official reported that it took over 600
staff- hours to collect the data requests. requested by OCR.
OCR investigators lacked 20 OCR teams were not knowledgeable in language
instruction or acquisition, educational expertise in a variety of
state bilingual mandates, bilingual program operations, or school district
areas. operations.
OCR was not clear enough about 20 OCR was not clear about when and under
what circumstances it would case closure practices. close a district's case.
State and federal requirements 17 Districts in California, Illinois,
Indiana, Massachusetts, Michigan, New differed. Jersey, New Mexico, Texas,
and Washington cited examples suggesting that conflicts existed between
state and federal requirements and that the
lack of coordination between OCR and state agencies had been problematic for
the district.
Some districts suggested that OCR could address some of these issues by
ensuring that communications were timely, providing more feedback in
response to submitted reports, understanding the constraints within which
districts have to operate, attempting to minimize paperwork requirements,
including educators on OCR's investigative teams, and being clear about when
the monitoring period would end and the case would be closed. In addition,
some districts suggested that OCR should work more closely with state
education agencies and involve the state in the early stages of the
investigations to deal with situations in which state guidance differs from
federal guidance on meeting the needs of students with limited English
proficiency. We asked OCR headquarters officials to respond to the problems
school districts identified. In doing so, OCR headquarters officials
indicated that OCR had also identified some of the issues and that it, in
conjunction with regional office staff, was already taking the following
steps to address them (see table 6).
Table 6: OCR Headquarters Responses to Problems Identified by the School
Districts Problem type OCR response
OCR “applied pressure.” Although OCR is increasingly working in
collaboration with school districts and reviews are now partnershiporiented,
it is still OCR's responsibility to ensure that school districts comply with
the law.
OCR's communications OCR examines how long cases are taking to resolve and
works with the field offices to correct problems if were untimely or cases
are not being resolved in a timely manner. Also, OCR now maintains closer
contact with school inadequate. districts during the investigation and the
monitoring period, as required in the Case Resolution Manual.
Districts lacked sufficient Serving students with limited English
proficiency takes time and costs money. OCR attempts to be flexible
resources to address with school districts. For example, in the negotiated
agreements, OCR gives school districts time to hire the
problems. necessary qualified teachers. In some cases, OCR has worked with
universities to put teacher- training
programs into place; it has also worked to increase certification
opportunities for teachers. OCR made burdensome OCR is refining its approach
to data requests. Having moved to the Case Resolution Manual, OCR's data
requests. emphasis is now on resolving compliance issues in partnership with
school districts instead of on making
findings. This often results in less burdensome data requests. OCR
investigators lacked OCR is addressing this issue through conferences for
OCR enforcement staff. OCR has established educational expertise in a
employee groups organized by subject matter to discuss policy and legal
decisions related to students with variety of areas. limited English
proficiency. Through these groups, guest speakers and other resources are
now readily available. In addition, the Lau Articulation Project produced a
list of educational resources that OCR enforcement staff use.
OCR was not clear Although negotiated agreements do not specify when the
monitoring period will end, the agreements discuss enough about case
evaluation expectations. OCR is working on building appropriate evaluation
measures into the agreements. closure practices. OCR is also holding
discussions with school districts to identify those that are successful in
helping students with limited English proficiency and to share their
practices with other school districts.
(Continued From Previous Page)
Problem type OCR response
State and federal Where federal and state requirements differ for students
with limited English proficiency, OCR staff discuss requirements differed.
the issues with state education officials. Also, state education officials
accompany OCR staff on some reviews. Concluding Policymakers are faced with
particularly difficult decisions with regard to Observations students with
limited English proficiency because their needs are varied and experts
disagree about the best methods to teach them. Moreover, there is no clear
time line for acquiring English proficiency. Even though different
approaches to English language instruction may be effective, many variables
may influence the choice of program used by a school, such
as the percentage of students with limited English proficiency, the number
of languages spoken by students, and students' family backgrounds. As a
result, local decisions about the amount of time needed to attain
proficiency and the amount of language support that should be provided
may differ. Available research does not definitively indicate the best
teaching methods to use or the amount of time support should be provided.
However, guidance from OCR provides the framework and standards that school
districts must meet to ensure that students with limited English proficiency
have a meaningful opportunity to participate in public education. School
districts have the flexibility to select methods of instruction that they
deem will produce the best results for their students, so long as they meet
OCR
requirements. We found that when OCR followed up on complaints or engaged in
compliance reviews, for the most part, it worked effectively with districts.
Moreover, few districts changed their approach to teaching students with
limited English proficiency after OCR investigations. There have been some
problems, however, with OCR's working relationships with districts, which
OCR acknowledges and is taking steps to improve.
Agency Comments In commenting on a draft of this report, the Department of
Education generally agreed with its findings and said it was particularly
gratified by
the survey results (see app. V). Education also provided technical comments,
which we incorporated as appropriate.
We are sending copies of this report to the Honorable Roderick R. Paige,
Secretary of Education; appropriate congressional committees; and other
interested parties. We will also make copies available to others upon
request.
If you or your staff have any questions about this report, please call me on
(202) 512- 7215. Other GAO contacts and staff acknowledgments are listed in
appendix VI.
Marnie S. Shaul Director, Education, Workforce,
and Income Security Issues
Appendi Appendi xes x I
Scope and Methodology To determine how long students with limited English
proficiency need to become proficient in English, we identified potential
studies for review and selected studies that met four criteria. To ensure
quality and relevance, the study had to (1) focus on the length of time
children need to become proficient in English, (2) reach a specific
conclusion about the length of time, (3) have English as the second language
learned by the students, and (4) involve original research supported by
published data. We identified potential studies for review by searching two
national databases for information on second- language learning- the
National Clearinghouse for Bilingual Education (Department of Education) and
the National Educational Resources Information Center (ERIC)- and by
contacting experts to obtain both their recommendations on research
regarding second- language learning and information on any research they
might have conducted on second- language learning. We contacted the
following.
? Mr. Jorge Amselle, Executive Director, Center for Equal Opportunity,
Washington, D. C.
? Dr. Keith Baker, Education Consultant
? Dr. James Cummins, Ontario Institute for Studies in Education
? Dr. Russell Gersten, University of Oregon
? Dr. Kenji Hakuta, Stanford University
? Dr. Stephen Krashen, University of Southern California
? Dr. Rosalie Porter, Editor, READ Perspectives
? Dr. Christine Rossell, Boston University
? Dr. J. David Ramirez, California State University Long Beach We also
reviewed research summaries, including Improving Schooling for Language-
Minority Children: A Research Agenda, by the National Research Council,
National Academy of Sciences (1997). We also used the bibliographies of all
the studies we identified and reviewed to obtain additional relevant
research. From these efforts, we obtained over 70
published articles and other reports that appeared relevant and reviewed
each of them. Only three met all four of our selection criteria. 1
To determine what approaches are used to teach children with limited English
proficiency, we reviewed the literature, spoke with experts, and reviewed
the results of survey data collected by the Department of Education. 2 We
also obtained information on the approaches used in 10 school districts we
visited in Arizona, Florida, Illinois, North Carolina, and Texas- states
with large or growing populations of students with limited English
proficiency. To determine how long students remained in language assistance
programs, because national data are not available, we contacted 12 states in
spring 2000, each with over 40,000 students who have limited
English proficiency or with populations of such students constituting over 9
percent of the student population (that is, states with substantial
concentrations of students with limited English proficiency): Alaska,
Arizona, California, Florida, Illinois, Massachusetts, Nevada, New Jersey,
New Mexico, New York, Texas, and Washington. We obtained state- level data
from the six states that had such data: Arizona, Florida, Illinois, New
Jersey, Texas, and Washington. Although no state data were available for
California, we did obtain data from four districts in that state: Los
Angeles, San Francisco, and San Diego for school year 1998- 99 and Santa Ana
for school year 1999- 2000 (the only data available).
To determine the requirements for children with limited English proficiency
that the Department of Education's Office for Civil Rights (OCR) expects
school districts to meet and how they are set forth, we interviewed OCR
officials, searched the Education Web site, and reviewed OCR policy
documents and case law regarding students with limited
English proficiency. To determine the nature of the interactions between OCR
and school districts in those instances in which OCR has entered into an
agreement with the school district concerning language assistance 1 James
Cummings, “Age on Arrival and Immigrant Second Language Learning in
Canada: A
Reassessment,” Applied Linguistics, Vol. 11, No. 2 (summer 1981);
Virginia P. Collier, “Age and Rate of Acquisition of Second Language
for Academic Purposes,” TESOL Quarterly; Virginia P. Collier and Wayne
P. Thomas, “How Quickly Can Immigrants Become Proficient in School
English?” The Journal of Educational Issues of Language Minority
Students; and Harold Klesmer, “Assessment and Teacher Perceptions of
ESL Student Achievement,” English Quarterly.
2 Department of Education, National Center for Education Statistics, A
Profile of Policies and Practices for Limited English Proficient Students:
Screening Methods, Program Support, and Teacher Training (SASS 1993- 94).
programs, we investigated 5 of the 15 cases suggested by your staff in
California, Colorado, Massachusetts, Michigan, and Texas. We also surveyed
293 school districts listed by OCR as having entered into corrective action
agreements with OCR for providing services to students
with limited English proficiency from 1992 through 1998. Of the 293, 245
responded (84 percent). We also reviewed the transcripts of three
congressional hearings before the Subcommittee on Early Childhood, Youth,
and Families of the Committee on Education and the Workforce:
? Bilingual Education Reform, San Diego, Calif., February 18, 1998. Serial
No. 105- 75
? Reforming Bilingual Education, Washington, D. C., April 30, 1998. Serial
No. 105- 101
? The Review and Oversight of the Department of Education's Office for Civil
Rights, Washington, D. C., June 22, 1999. Serial No. 106- 49
We also contacted Mr. James M. Littlejohn of Jim Littlejohn Consulting, The
Sea Ranch, California. Mr. Littlejohn worked for OCR for 27 years. From 1981
to 1993, he was policy director of OCR in Washington and, according to the
director of the Denver Regional Office, during the years covered by our
study, Mr. Littlejohn trained most of the OCR investigators in how to
properly conduct a Lau investigation (those title VI investigations related
to children with limited English proficiency). He retired from OCR in 1996
and
now works as a consultant to school systems around the country and on
several federal court cases involving bilingual education. Mr. Littlejohn
was a key information source for the Committee, testifying and providing key
analyses. 3
3 Jim Littlejohn, Federal Control Out of Control: The Office for Civil
Rights' Hidden Policies on Bilingual Education (Washington, D. C.: Center
for Equal Opportunity, Nov. 1998).
Data on Number of Years Students Received
Appendi x II
Language Services in Arizona and Illinois Arizona was the only state we
reviewed that had detailed breakdowns by year on how long students who had
received bilingual or English- as- asecond- language (ESL) services did so
before making the transition out of these services (see table 7).
Table 7: Students Who Were Reclassified Because They Had Achieved
“Fluent
English Proficiency” in Arizona, 1998- 99 Years students received ESL
Cumulative percentage of students or bilingual services achieving English
proficiency
1 11. 8 2 23. 6 3 36. 4 4 48. 8 5 59. 2 6 67. 8 7 75. 7 8 81. 0 9 86. 1 10
92. 8 11 96. 4 12 98. 4 13 100.0 Source: Report of the superintendent of
public instruction to the Arizona legislature: English Acquisition Services:
A Summary of Bilingual and English as a Second Language Programs for School
Year 1998– 99.
Illinois was the only state that had data broken down by type of program
(ESL or bilingual) (see table 8).
Table 8: Transitioned Students' Years of Participation by Program Type and
Location in Illinois, FY1999 Transitional bilingual education programs ESL
programs a
Chicago Rest of the state Chicago Rest of the state Years in program
Number Percentage b Number Percentage b Number Percentage b Number
Percentage b
Less than 1 132 0.84 434 2.75 40 0.25 623 3. 95 1 to 2 600 3.8 623 3.95 100
0. 63 1, 015 6.43 2 to 3 1, 030 6.53 677 4.29 217 1. 38 844 5.35 3 or more
6,211 39.36 1, 669 10.58 537 3. 40 1, 026 6. 5
Total 7, 973 3, 403 894 3, 508
a In Illinois these programs are called Transitional Programs of
Instruction. b Percentages were calculated on the basis of the total number
of students who made the transition out of services (15,778).
Source: Illinois State Board of Education.
School Districts' Impressions of Whether OCR Conveyed Preferences for Type
of Language
Appendi x II I Instruction We asked school district officials to answer the
following question: “Did
OCR staff, as a whole, convey the impression that they favored Englishonly
instruction, they favored bilingual education, they favored another language
program, or they were neutral on the question?”
Of the 225 districts responding, 77 percent replied that OCR did not convey
an impression that it favored any particular type of instruction. However,
23 percent indicated that OCR did convey a preference:
? 18 percent indicated that, in their opinion, OCR favored bilingual
education;
? 4 percent indicated that, in their opinion, OCR favored English- only
instruction; and
? 1 percent indicated that, in their opinion, OCR favored another type of
language program. (See table 9.)
Table 9: Most School Districts Reported OCR Favored No Particular Type of
Language Program Did OCR staff as a whole, convey the impression that they
... Regional percentage of national total of Favored
students with Favored Favored
another limited English
English- only bilingual
language Were neutral on proficiency School district
education? education?
program? the question? OCR's Region 1- Boston
2. 3 Bristol School District, CT X Danbury School District, CT X East
Hartford School District, CT X New Britain School District, CT X Stratford
School District, CT X West Hartford School District, CT X Lowell School
District, MA X Quincy School District, MA X Revere School District, MA X
Somerville School District, MA X Manchester School District, NH X Pawtucket
School District, RI X Providence School District, RI X Woonsocket School
District, RI X
OCR's Region 2- New York
7. 9 Atlantic City, NJ X Linden City, NJ X Newark City, NJ X Passaic City,
NJ X Brentwood Unified School District, NY X Mineola Unified School
District, NY X Ossining Unified School District, NY X Port Chester- Rye
Unified School District, NY X
Westbury Unified School District, NY X
OCR's Region 3- Philadelphia
2.0 Jefferson County, KY X Avon Grove School District, PA X Central York
School District, PA X Gettysburg Area School District, PA X
(Continued From Previous Page)
Did OCR staff as a whole, convey the impression that they ... Regional
percentage of national total of Favored
students with Favored Favored
another limited English
English- only bilingual
language Were neutral on proficiency School district
education? education?
program? the question?
Neshaminy School District, PA X Upper Adams School District, PA X West York
Area School District, PA X
OCR's Region 4- Atlanta
8. 2 DeKalb County School District, GA X Gwinnett County School District, GA
X Aiken County School District, SC X Beaufort County School District, SC X
Charleston County School District, SC X
Greenville County School District, SC X Pickens County School District, SC X
Richland School District 01, SC X Nashville- Davidson County School
District, TN X
Rutherford County School District, TN X Shelby County School District, TN X
OCR's Region 5- Dallas
16. 3 Orleans Parish School Board, LA X DeSoto County School District, MS X
Blackwell, OK X Oklahoma City, OK X Stillwater, OK X Anna Independent School
District, TX X Corpus Christi Independent School District, TX X
Donna Independent School District, TX X
Fort Worth Independent School District, TX X
Lubbock Independent School District, TX X
McAllen Independent School District, TX X
(Continued From Previous Page)
Did OCR staff as a whole, convey the impression that they ... Regional
percentage of national total of Favored
students with Favored Favored
another limited English
English- only bilingual
language Were neutral on proficiency School district
education? education?
program? the question? OCR's Region 6- Washington, D. C.
1. 0 District of Columbia Public Schools, DC X Harnett County Schools, NC X
Yadkin County Schools, NC X
OCR's Region 7- Chicago
5. 6 Aurora East Unit School District 1, IL X School District 46, IL X
School City of East Chicago, IN X Elkhart Community Schools, IN X Fort Wayne
Community Schools, IN X Gary Community School Corp., IN X School City of
Hobart, IN X Indianapolis Public Schools, IN X Lake Station Community
School, IN X MSD Lawrence Township, IN X Merrillville Community School, IN X
MSD Perry Township, IN X MSD Pike Township, IN X River Forest Community
School County, IN X
South Bend Community School Corp., IN X
MSD Warren Township, IN X MSD Washington Township, IN X Whiting School City,
IN X Faribault, MN X Willmar, MN X Racine School District, WI X
(Continued From Previous Page)
Did OCR staff as a whole, convey the impression that they ... Regional
percentage of national total of Favored
students with Favored Favored
another limited English
English- only bilingual
language Were neutral on proficiency School district
education? education?
program? the question? OCR's Region 8- Cleveland
1. 4 Bloomfield Hills School District, MI X Capac Community School District,
MI X Dearborn City School District, MI X East Lansing School District, MI X
Farmington Public School District, MI X Ferndale Public Schools, MI X Flint
City School District, MI X Hazel Park City School District, MI X Oak Park
City School District, MI X Pontiac City School District, MI X School
District City of Royal Oak, MI X Southfield Public School District, MI X
Troy School District, MI X Walled Lake Consolidated School District, MI X
West Bloomfield School District, MI X South- Western City School District,
OH X
OCR's Region 9- Kansas City
Columbus Community School District, 1.5 IA X
Des Moines Independent Community School District, IA X Muscatine Community
School District, IA X
South Tama County Community School District, IA X Storm Lake Community
School District, IA X Washington Community School District, IA X West
Liberty Community School District, IA X Dodge City, KS X
(Continued From Previous Page)
Did OCR staff as a whole, convey the impression that they ... Regional
percentage of national total of Favored
students with Favored Favored
another limited English
English- only bilingual
language Were neutral on proficiency School district
education? education?
program? the question?
Emporia, KS X Garden City, KS X Holcomb, KS X Junction City, KS X Kansas
City, KS X Kismet- Plains, KS X Liberal, KS X Shawnee Mission Public
Schools, KS X Wichita, KS X Winfield, KS X McDonald County R- 1, MO X
University City, MO X Lincoln Public Schools, NE X Grand Island Public
Schools, NE X Madison Public Schools, NE X Mitchell Public Schools, NE X
Scottsbluff Public Schools, NE X South Sioux City Public Schools, NE X Hill
City 51- 2, SD X
OCR's Region 10- Denver
7. 5 Nogales Unified District, AZ X Washington Elementary District, AZ X
Yuma Elementary District, AZ X Alamos RE- 11J, CO X Brighton 27J, CO X Brush
RE- 2( J), CO X Colorado Springs 11, CO X Durango 9- R, CO X Gilcrest RE- 1,
CO X Ignacio 11JT, CO X Johnstown- Milliken RE- 5J, CO X Lamar RE- 2, CO X
Mesa County Valley 51, CO X
(Continued From Previous Page)
Did OCR staff as a whole, convey the impression that they ... Regional
percentage of national total of Favored
students with Favored Favored
another limited English
English- only bilingual
language Were neutral on proficiency School district
education? education?
program? the question?
Pueblo City 60, CO X Roaring Fork RE- 1, CO X Sierra Grande R- 30, CO X Weld
County RE- 8, CO X Westminster 50, CO X Artesia Public Schools, NM X
Espanola Municipal Schools, NM X Famington Municipal Schools, NM X Gallup-
McKinley County Schools, NM X Hobbs Municipal Schools, NM X Las Cruces
Public Schools, NM X Portales Municipal Schools, NM X Silver City
Consolidated Schools, NM X Davis School District, UT X Duchesne School
District, UT X Granite School District, UT X Jordan School District, UT X
Ogden School District, UT X Washington School District, UT X
OCR's Region 11- San Francisco
41. 0 Alameda City Unified, CA X Atwater Elementary, CA X Beaumont Unified,
CA X Bellevue Union Elementary, CA X Brawley Union High, CA X Burbank
Unified, CA X Cajon Valley Union Elementary, CA X Centralia Elementary, CA X
Chino Unified, CA X Colton Joint Unified, CA X East Side Union High, CA X
Empire Union Elementary, CA X Franklin- McKinley Elementary, CA X
(Continued From Previous Page)
Did OCR staff as a whole, convey the impression that they ... Regional
percentage of national total of Favored
students with Favored Favored
another limited English
English- only bilingual
language Were neutral on proficiency School district
education? education?
program? the question?
Fremont Union High, CA X Fresno Unified, CA X Golden Plains Unified, CA X
Grant Joint Union High, CA X Hacienda La Puente Unified, CA X Hanford Joint
Union High, CA X Inglewood Unified, CA X Lindsay Unified, CA X Lynwood
Unified, CA X Manteca Unified, CA X Merced City Elementary, CA X Milpitas
Unified, CA X Monterey Peninsula Unified, CA X Moreland Elementary, CA X
Moreno Valley Unified, CA X Napa Valley Unified, CA X Newport- Mesa Unified,
CA X Norwalk- La Mirada Unified, CA X Ocean View Elementary, CA X Ojai
Unified, CA X Orange Center Elementary, CA X Orland Joint Unified, CA X
Porterville Elementary, CA X Poterville Union High, CA X Roseland
Elementary, CA X Saddleback Valley Unified, CA X San Rafael City Elementary,
CA X San Rafael City High, CA X Santa Ana Unified, CA X Santa Cruz City
Elementary, CA X Santa Cruz City High, CA Sweetwater Union High, CA X
Ventura Unified, CA X
(Continued From Previous Page)
Did OCR staff as a whole, convey the impression that they ... Regional
percentage of national total of Favored
students with Favored Favored
another limited English
English- only bilingual
language Were neutral on proficiency School district
education? education?
program? the question?
West Covina Unified, CA X Winters Joint Unified, CA X
OCR's Region 12- Seattle
5. 0 Aberdeen School District 58, ID X Blackfoot School District 55, ID X
Emmett School District 221, ID X Glenns Ferry Joint School District
X 192, ID Idaho Falls School District 91, ID X
Jefferson County Joint School District X 251, ID Minidoka County Joint
School District
331, ID X Nampa School District 131, ID X Snake River School District 52, ID
X Twin Falls School District 411, ID X Douglas County School District, NV X
Elko County School District, NV X Central School District 13J, OR X
Hillsboro School District 01J, OR X Medford School District 549, OR X
Newberg School District 29J, OR X Clover Park, WA X Federal Way, WA X North
Franklin, WA X Pasco, WA X Pullman, WA X Shoreline, WA X Spokane, WA X
Vancouver, WA X Wahluke, WA X Yak i ma , WA X
Most School Districts That Added Bilingual
Appendi x V I Instruction Reported No Pressure by OCR We asked school
districts a number of questions about the type of program they had that was
specifically designed to meet the English- language needs of students with
limited English proficiency (solely bilingual education, English- only
instruction, both bilingual and English- only instruction, or another type
of language program) before and after the OCR investigation. We also asked
about any changes in the type of program used by the district as a result of
OCR actions.
Ten school districts added bilingual instruction to their English- language
learning program after OCR intervention. Of these, six indicated that before
OCR's investigation they had not planned to change the type of language
program they used; three indicated that before the OCR investigation they
had planned to change the type of program they used and that the changes
that resulted from OCR's investigation were consistent with the changes they
had planned to make; and one district did not indicate whether or not it had
planned to change the type of language program used before the OCR
investigation. One of the 10 school districts indicated that it felt
pressured by OCR to change the type of language program it was using.
Our analysis indicated that of the 89 school districts that indicated they
had English- only programs before OCR's investigation,
? 10 added bilingual education to their English- only programs and
? no school district changed from English- only to solely bilingual. Table
10 lists these 10 school districts and their corresponding OCR regional
offices and provides details about the changes made in the districts'
English- language acquisition programs.
Table 10: Information About 10 Districts' Decisions to Add Bilingual
Education to Their Programs
Planned change Change consistent Change due
before OCR with planned to pressure District
investigation change
by OCR Region 2- New York
New York City Board of Education, NY No response a No
Region 5- Dallas
Blackwell Public Schools, OK No a Yes
Region 8- Cleveland
Toledo Public Schools, OH No a No
Region 9- Kansas City
Washington Community School District, IA No a No Garden City Unified School
District #457, KS No a No
Region 10- Denver
Jefferson County Public Schools, CO No a No Washington School District #6,
AZ Yes Yes No
Region 11- San Francisco
Winters Joint Unified School District, CA No a No
Region 12- Seattle
Medford School District, OR Yes Yes No Vancouver School District No. 37, WA
Yes Yes No a This district had planned no change.
Comments From the Department of
Appendi x V Education
Appendi x VI
GAO Contacts and Staff Acknowledgments GAO Contacts Eleanor L. Johnson,
(202) 512- 7209 Benjamin F. Jordan, Jr., (202) 512- 4876 Staff
In addition to those named above, Malcolm Drewery, Behn Miller, Ellen
Acknowledgments
Soltow, and Virginia Vanderlinde made key contributions to this report.
(104983) Lett er
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GAO United States General Accounting Office
Page 1 GAO- 01- 226 Students With Limited English Proficiency
Contents
Contents Page 2 GAO- 01- 226 Students With Limited English Proficiency
Page 3 GAO- 01- 226 Students With Limited English Proficiency United States
General Accounting Office
Washington, D. C. 20548 Page 3 GAO- 01- 226 Students With Limited English
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Appendix I
Appendix I Scope and Methodology
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Appendix I Scope and Methodology
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Appendix II
Appendix II Data on Number of Years Students Received Language Services in
Arizona and Illinois
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Appendix III
Appendix III School Districts' Impressions of Whether OCR Conveyed
Preferences for Type of Language Instruction
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Appendix III School Districts' Impressions of Whether OCR Conveyed
Preferences for Type of Language Instruction
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Appendix III School Districts' Impressions of Whether OCR Conveyed
Preferences for Type of Language Instruction
Page 42 GAO- 01- 226 Students With Limited English Proficiency
Appendix III School Districts' Impressions of Whether OCR Conveyed
Preferences for Type of Language Instruction
Page 43 GAO- 01- 226 Students With Limited English Proficiency
Appendix III School Districts' Impressions of Whether OCR Conveyed
Preferences for Type of Language Instruction
Page 44 GAO- 01- 226 Students With Limited English Proficiency
Appendix III School Districts' Impressions of Whether OCR Conveyed
Preferences for Type of Language Instruction
Page 45 GAO- 01- 226 Students With Limited English Proficiency
Appendix III School Districts' Impressions of Whether OCR Conveyed
Preferences for Type of Language Instruction
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Appendix III School Districts' Impressions of Whether OCR Conveyed
Preferences for Type of Language Instruction
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Appendix IV
Appendix IV Most School Districts That Added Bilingual Instruction Reported
No Pressure by OCR
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Appendix V
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Appendix VI
United States General Accounting Office Washington, D. C. 20548- 0001
Official Business Penalty for Private Use $300
Address Correction Requested Presorted Standard
Postage & Fees Paid GAO Permit No. GI00
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