No Child Left Behind Act: More Information Would Help States	 
Determine Which Teachers Are Highly Qualified (17-JUL-03,	 
GAO-03-631).							 
                                                                 
In December 2001, Congress passed the No Child Left Behind Act	 
(NCLBA). The act required that all teachers of core subjects be  
highly qualified by the end of the 2005-06 school year and	 
provided funding to help states and districts meet the		 
requirement. In general, the act requires that teachers have a	 
bachelor's degree, meet full state certification, and demonstrate
subject area knowledge for every core subject they teach. This	 
report focuses on the (1) number of teachers who met the highly  
qualified criteria during the 2002-03 school year, (2) conditions
that hinder states' and districts' ability to meet the		 
requirement, and (3) activities on which states and districts	 
were planning to spend their Title II funds. GAO surveyed 50	 
states and the District of Columbia and a nationally		 
representative sample of districts about their plans to implement
the requirement. GAO also visited and interviewed officials in 8 
states and 16 districts to discuss their efforts to implement the
law.								 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-03-631 					        
    ACCNO:   A07551						        
  TITLE:     No Child Left Behind Act: More Information Would Help    
States Determine Which Teachers Are Highly Qualified		 
     DATE:   07/17/2003 
  SUBJECT:   Evaluation criteria				 
	     Surveys						 
	     Teacher education					 
	     Teachers						 
	     Aid for education					 
	     Education or training costs			 
	     Performance measures				 

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GAO-03-631

Report to Congressional Requesters

United States General Accounting Office

GAO

July 2003 NO CHILD LEFT BEHIND ACT

More Information Would Help States Determine Which Teachers Are Highly
Qualified

GAO- 03- 631

GAO could not develop reliable data on the number of highly qualified
teachers because states did not have the information needed to determine
whether all teachers met the criteria. Officials from 8 states visited
said they did not have the information they needed to develop methods to
evaluate current teachers* subject area knowledge and the criteria for
some teachers

were not issued until December 2002. Officials from 7 of 8 states visited
said they did not have data systems that could track teacher
qualifications for each core subject they teach.

Source: U. S. Department of Education. Both state and district officials
cited many conditions in the GAO survey that hinder their ability to have
all highly qualified teachers. State and district officials reported
teacher pay issues, such as low salaries and lack of incentive pay,
teacher shortages, and other issues as hindrances. GAO*s survey estimates
show that significantly more high- poverty than low- poverty districts
reported hindrances, such as little support for new teachers. Rural
district officials cited hindrances related to their size and isolated
locations. State officials reported they needed assistance or information
from Education, such as in developing incentives to teach in high- poverty
schools, and Education*s strategic plan addresses some of these needs. To
help meet the requirement for highly qualified teachers, state survey

respondents reported they planned to spend about 65 percent of their Title
II funds on professional development activities authorized under Title II,
and districts planned to spend an estimated 66 percent on recruitment and
retention. Both state and district officials planned to spend much larger
amounts of funds from sources other than Title II funds on such
activities. High- poverty districts planned to spend more Title II funds
on recruitment and retention than low- poverty districts. State and
district officials visited said that most activities were a continuation
of those begun previously. In December 2001, Congress

passed the No Child Left Behind Act (NCLBA). The act required that all
teachers of core subjects be highly qualified by the end of the 2005- 06
school year and provided funding to help states and districts meet the
requirement. In general, the act requires that teachers have a bachelor*s
degree, meet full state

certification, and demonstrate subject area knowledge for every core
subject they teach. This

report focuses on the (1) number of teachers who met the highly qualified
criteria during the 2002- 03 school year, (2) conditions that

hinder states* and districts* ability to meet the requirement, and (3)
activities on which states and districts were planning to spend

their Title II funds. GAO surveyed 50 states and the District of Columbia
and a nationally representative sample of districts about their plans to
implement the requirement. GAO also visited and interviewed officials in 8
states and 16 districts to discuss their efforts to implement the law.

To help states determine which teachers are highly qualified and the
actions they need to take to meet the requirement, GAO recommends that the
Secretary of Education provide more

information to states, especially on ways to evaluate the subject area
knowledge of current teachers. The

Department of Education provided written comments on a draft of this
report and generally agreed with GAO*s recommendation. www. gao. gov/ cgi-
bin/ getrpt? GAO- 03- 631. To view the full product, including the scope

and methodology, click on the link above. For more information, contact
Marnie S. Shaul, 512- 7215, shaulm@ gao. gov. Highlights of GAO- 03- 631,
a report to

Congressional Requesters

July 2003

NO CHILD LEFT BEHIND ACT

More Information Would Help States Determine Which Teachers Are Highly
Qualified

Page i GAO- 03- 631 No Child Left Behind Letter 1 Results in Brief 2
Background 5 Many States Were Uncertain about Numbers of Highly Qualified

Teachers 10 State and District Officials Reported Many Conditions as
Hindrances to Meeting the Law 13 To Help Teachers Meet the Requirement
States Planned to Spend Most Title II Funds on Professional Development
Activities, and Districts Will Spend Most on Recruitment and Retention
Activities 23 Conclusions 29 Recommendation for Executive Action 29 Agency
Comments and Our Evaluation 29 Appendix I Scope and Methodology 31

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

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

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

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

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

Table 1: Federal Criteria for a Highly Qualified Teacher 7 Table 2:
Estimated Percentages of Districts That Will Have Difficulty Meeting the
Requirement for Highly Qualified Teachers by Grade Level and Poverty 12
Table 3: Number of States Reporting on Conditions That Hinder

Their Ability to Meet the Requirement for Highly Qualified Teachers
(Ranked from Highest to Lowest) 17 Table 4: Estimated Percentages of
Districts Reporting on

Conditions That Hinder Their Ability to Meet the Requirement for Highly
Qualified Teachers (Ranked from Highest to Lowest) 19 Table 5: Estimated
Percentages of High- and Low- Poverty Districts

with Significant Differences in the Hindrances to Meeting the Requirement
21 Table 6: Estimated Percent of Spending Title II Funds by Activities

for All Districts, High- Poverty Districts, and Low- Poverty Districts 26
Table 7: Population and Sample by Stratum 32 Table 8: Sample Estimates
Compared to Population Values 34 Table 9: Population and Sample by Region
35 Table 10: Title II, Part A State Activities 37 Table 11: Title II, Part
A District Activities 38 Figures

Figure 1: Education*s Assistance to States During Calendar Year 2002 9
Figure 2: Planned Spending of Title II Funds by Reporting States 24 Figure
3: Sources of Funds for Planned Spending by States on Title

II Activities 25 Figure 4: Estimated Spending of Title II Funds as a
Percentage of Total Funds by Activities for All Districts, High- Poverty
Districts, and Low- Poverty Districts 28 Figure 5: State Survey
Respondents 31

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

CCD Core of Common Data CCSSO Council of Chief State School Officers CMSA
Consolidated Metropolitan Statistical Area LEA Local Education Agency MSA
Metropolitan Statistical Area NCLBA No Child Left Behind Act This is a
work of the U. S. Government and is not subject to copyright protection in
the

United States. It may be reproduced and distributed in its entirety
without further permission from GAO. It may contain copyrighted graphics,
images or other materials. Permission from the copyright holder may be
necessary should you wish to reproduce copyrighted materials separately
from GAO*s product.

Page 1 GAO- 03- 631 No Child Left Behind July 17, 2003 The Honorable
Edward M. Kennedy The Honorable Jeff Bingaman

United States Senate In December 2001, Congress passed the No Child Left
Behind Act (NCLBA), which, among other things, focused attention on
closing the achievement gaps among various groups of students. Recently, a
body of research has shown that quality teachers play a significant role
in improving student performance. However, research has also shown that
many teachers, especially those in high- poverty and rural districts, 1
were not certified and lacked knowledge of the subjects they taught. NCLBA
established the requirement that all teachers be highly qualified for each
core subject they teach by the end of the 2005- 06 school year. 2 The
criteria for meeting this requirement vary somewhat by grade level and
experience

but generally require that teachers have (1) a bachelor*s degree, (2)
state certification, and (3) subject area knowledge for each core subject
they teach. This represents the first time the federal government has
established specific criteria for teachers. Title II, Part A, of NCLBA
replaced the Eisenhower Professional Development and Class Size Reduction
programs with the Teacher and Principal Training and Recruiting Fund and
Congress appropriated $2.85 billion to help states and districts meet the
requirement. In addition, Title II directed these funds to be spent on
specific activities to help states and districts recruit, retain, and
develop highly qualified teachers. The Department of Education (Education)
administers Title II and is responsible for oversight of states*
implementation of NCLBA.

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

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

United States General Accounting Office Washington, DC 20548

Page 2 GAO- 03- 631 No Child Left Behind to meet the requirement, and (3)
activities on which states and districts were planning to spend their
Title II funds.

In conducting our work, we surveyed 50 states and the District of
Columbia. We obtained responses for 37 of these 51 surveys and reported
the results as representing only those that responded. The student
enrollment for the responding states represented 85 percent of total
student population in kindergarten through 12th grade. In addition, we
surveyed a nationally representative sample of 830 school districts. We
received a response from 511 or 62 percent. We compared relevant
characteristics of these respondents to the universe of districts and
found them to be similar, which along with the response rate allowed us to
report national estimates. 3 For our comparisons of high- and low- poverty
districts, we included responding districts that had 70 percent or more of
their students approved for free and reduced- price meals as high- poverty
and those with 30 percent or less of their students approved for free and
reduced- price meals as low- poverty. We visited and interviewed officials
in 8 states selected with a range of characteristics that might affect
their

ability to meet the requirement* California, Connecticut, Illinois, Iowa,
Maryland, North Carolina, Delaware, and Wyoming. We visited 2 districts in
each of the states and 1 school in each district. We interviewed U. S.
Department of Education officials, and officials from professional
organizations and unions that represent teachers. Additionally, we
analyzed the legislation, related reports, and relevant documents. See
appendix I for detailed information on the methodology. We conducted our
work from July 2002 through May 2003 in accordance with generally accepted
government auditing standards.

We could not develop reliable data on the number of highly qualified
teachers because states did not have the information needed to determine
whether all teachers met the criteria. During our visits state officials
did not know the criteria for some of their teachers. Education*s draft
guidance on the criteria for teachers in alternative certification
programs changed between June and December of 2002, which meant that
states had to reassess their teachers* qualifications. Guidance for
special education teachers was not available until December 2002, and it
was contained in an 3 All percentage estimates produced from the district
survey have sampling errors of no more than plus or minus 10 percentage
points, at a 95 percent confidence level, unless

otherwise noted. Results in Brief

Page 3 GAO- 03- 631 No Child Left Behind appendix to the Title I
regulations, but not in the federal regulations. Also, states did not have
the information they needed to develop methods to

evaluate subject area knowledge of their current teachers. In our survey,
32 of 37 state respondents said that they needed clear and timely guidance
from Education. Additionally, officials from 7 of the 8 states we visited
said they did not have data systems that could track teacher
qualifications by subject, which they needed to determine if a highly
qualified teacher

taught each core subject. One official added a comment to the survey that
said the state data system on teachers *was designed years ago for state
certification purposes*[ and] has not yet been updated to include all
NCLBA criteria for teachers.* Some state officials we interviewed also
expressed reservations about changing their data systems before complete
guidance was issued. Furthermore, 6 of the 8 state officials were
reluctant to say that their certified teachers might not be highly
qualified because they believed it would harm teacher morale. Thus, we
concluded that the survey data related to the number of highly qualified
teachers would not

likely be reliable. Both state and district officials cited many
conditions that hinder their ability to have all highly qualified
teachers. Many state officials reported issues related to teacher pay,
such as low salaries, lack of incentive pay programs, and a lack of career
ladders as hindrances. For example, 32 of the 37 state officials
responding to our survey said that teacher salaries were low compared with
other occupations. During our visits officials said that salary issues
particularly hindered their efforts to recruit and retain

math and science teachers. Twenty- three of the 37 state officials
reported teacher shortages in high need subject areas* mostly math,
science, and special education. During the late 1990s, there was an
increase in demand for workers with math and science backgrounds,
especially in information technology, and these occupations generally paid
higher salaries than teaching. Other hindrances cited by state officials
included few programs to support new teachers, a lack of leadership from
principals, and union agreements. Our survey estimates show that salary
issues were also hindrances for the majority of the districts, and about
20 percent of all districts cited teacher development conditions such as
(1) weak technology training for teachers, (2) few alternative
certification programs, and (3) professional development programs of too
short a duration to improve teacher quality. In addition, significantly
more highpoverty than low- poverty districts identified some conditions as
hindrances, according to our survey responses. For example, an estimated
30 percent of high- poverty districts compared to 6 percent of low-
poverty

districts cited few programs to support new teachers. Officials in rural
districts we visited and who commented on the survey said they faced

Page 4 GAO- 03- 631 No Child Left Behind unusual conditions because some
of them were very small, isolated, or had only one or two teachers in
total at some schools. While many of the

hindrances that state and district officials reported could not be
addressed by Education, at least half of the state survey respondents
indicated that Education could be more helpful. Specifically, they said
they needed more information on, or assistance with, professional
development programs, best practices related to teacher quality, and
incentives for teachers to teach in high- poverty schools. Education has
identified several steps it will take in its 2002- 07 strategic plan
related to these issues.

Title II provided funds to help meet the requirement for highly qualified
teachers, and state survey respondents said they planned to spend most of
their Title II funds on professional development activities while
districts planned to spend the majority of their funds on recruitment and
retention activities authorized under Title II. Generally, state
educational agencies

could use up to 2.5 percent of the state*s Title II funds for authorized
state activities. State officials reported they planned to spend 65
percent on professional development activities. These activities could
help teachers enhance their subject area knowledge and complete state
licensing requirements to meet the criteria for highly qualified teachers.
States planned to spend much larger amounts of other federal and state
funds than Title II funds on authorized state activities. For example,
states reported that 85 percent of the total funds they planned to spend
on professional development activities would come from other federal and
state funds. Districts received about 95 percent of their state*s Title II

funds for authorized district activities. From our survey we estimated
that districts planned to spend about two- thirds of their Title II funds
on activities to help recruit and retain highly qualified teachers, with
the remaining funds on activities for professional development. High-
poverty districts planned to spend a larger percentage of Title II funds
on recruitment and retention activities than low- poverty districts. For
example, high- poverty districts planned to spend 77 percent of their
Title II funds for recruitment and retention while low- poverty districts
planned to spend 59 percent. Recruitment and retention activities, such as
establishing incentive pay programs and reducing class sizes, could help
attract more highly qualified teachers to schools. Survey results also
show

that districts planned to spend much larger percentages of other federal,
state, and local funds than Title II funds on authorized Title II
activities. For example, an estimated 80 percent of the total funds all
districts planned to spend on professional development came from other
federal, state, and local funds. During our visits, both state and
district officials said that most activities were a continuation of those
begun in previous years.

Page 5 GAO- 03- 631 No Child Left Behind In order to help states meet the
requirement for highly qualified teachers by the end of the 2005- 06
school year, we recommend that the Secretary of

Education provide more information on methods to evaluate subject area
knowledge of current teachers.

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

Recently, a body of research has shown that quality teachers are
significant to improving student performance. For example, a 1996 study by
Sanders and Rivers 4 examined the effect of teacher quality on academic
achievement and found that children assigned to effective teachers scored
significantly higher in math than children assigned to ineffective
teachers. Research has also shown that many teachers, especially those in
highpoverty and rural districts, were not certified and lacked knowledge
of the subjects they taught. For example, a report from The Education
Trust found that in every subject area, students in high- poverty schools
were more likely than other students to be taught by teachers without even
a minor in the subjects they teach. 5 States are responsible for
developing and administering their education

systems and most have delegated authority for operating schools to local
governments. States and local governments provide most of the money for
public elementary and secondary education. In 2002, Education reported 6
that 49 percent of the revenue for education was from state sources,

44 percent from local sources, and 7 percent from federal sources.
Therefore, it is mostly state and local funds that are used to cover most
of the major expenses, such as teacher salaries, school buildings, and
transportation. Although the autonomy of districts varies, states are

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

Education 2002.

Background

Page 6 GAO- 03- 631 No Child Left Behind responsible for monitoring and
assisting their districts that, in turn, monitor and assist their schools.

The federal government plays a limited but important role in education.
The Department of Education*s mission is to ensure equal access to
education and promote educational excellence throughout the nation by,
among other things, supporting state and local educational improvement
efforts, gathering statistics and conducting research, and helping to make
education a national priority. Education provides assistance to help
states

understand the provisions or requirements of applicable laws, as well as
overseeing and monitoring how states implement them. With the passage of
the No Child Left Behind Act, on January 8, 2002, the federal government
intensified its focus on teacher quality by establishing a requirement in
the act for teachers across the nation to be *highly qualified* in every
core subject they teach by the end of the 2005- 06 school year. 7 While
the act contains specific criteria for highly qualified teachers by

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

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

Page 7 GAO- 03- 631 No Child Left Behind Table 1: Federal Criteria for a
Highly Qualified Teacher Grade level and experience Federal criteria

Any public elementary school or secondary school teacher. Has obtained
full state certification as a teacher (including alternative
certification) or

passed the state teacher licensing examination and holds a license to
teach in the state; however, when teaching in a charter school, a the
teacher may not be certified or licensed if the state does not require it.
Further, the teacher has not had certification or licensure requirements
waived on emergency, temporary, or provisional basis. Elementary school
teacher new to the profession. Holds at least a bachelor*s degree; and has
passed a rigorous state test to demonstrate

subject knowledge and teaching skills in reading, writing, math, and other
areas of the basic elementary school curriculum (these tests may be
included in state certification or licensing tests). Middle or secondary
school teacher new to the profession. Holds at least a bachelor*s degree
and has passed a rigorous state academic subject test in each of the
academic subjects in which the teacher teaches (this may be the state

certification or licensure test) or for each academic subject taught, the
teacher has successfully completed an academic major, a graduate degree,
coursework equivalent to an undergraduate academic major, or advanced
certification or credentialing. Elementary, middle, or secondary teacher
not new to the profession. Has met the above standards for new elementary,
middle, and secondary school teachers

or demonstrates competence in all the academic subjects in which the
teacher teaches based on a high objective, uniform state standard of
evaluation that (1) is set by the state for both grade appropriate
academic subject matter knowledge and teaching skills; (2) is aligned with
challenging state academic content and student academic achievement
standards and developed in consultation with core content specialists,
teachers, principals, and school administrators; (3) provides objective,
coherent information about the teacher*s attainment of core content
knowledge in the academic subjects a teacher teaches; (4) is applied
uniformly to all teachers in the same academic subject and the same grade
level throughout the state; (5) takes into consideration, but not be based
primarily on, the time the teacher has been teaching in the academic
subject; (6) is made

available to the public upon request; and (7) may involve multiple,
objective measures of teacher competency. Source: NCLBA, Pub. L. No. 107-
110, section 9101( 2002).

a Charter schools are public schools that are exempt from a variety of
local and state regulations.

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

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

Page 8 GAO- 03- 631 No Child Left Behind equal to what they received for
fiscal year 2001 under the two previous programs. The additional $740
million was distributed to states and

districts based on the number of families with children ages 5 to 17 who
had incomes below the poverty threshold 8 and the relative population of
children ages 5 to 17. The act requires states to ensure that districts
target funds to those schools that have the highest number of teachers who
are not highly qualified, the largest class sizes, or have been identified
as in need of improvement.

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

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

Page 9 GAO- 03- 631 No Child Left Behind Figure 1: Education*s Assistance
to States During Calendar Year 2002 In June 2002, Education issued draft
guidance entitled *Improving Teacher Quality State Grants* which has
served as Education*s principle form of

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

Events Date

NCLBA Web site went online April May

Title II, Part A draft guidance issued First Annual Teacher Quality
Evaluation Conference held, during which the draft guidance was discussed
June

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

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

Final Rule issued on how to apply for Title II, Part A Funds Source: GAO
analysis.

Page 10 GAO- 03- 631 No Child Left Behind In- depth discussions with
officials in 8 states revealed that they could not determine the number of
highly qualified teachers with accuracy because of one or more factors.
All state officials said they did not know the

criteria for some of their teachers because Education*s draft guidance
changed and was not complete. Officials also did not have all the
information they needed to develop methods to evaluate subject area
knowledge for their current teachers. Accordingly, officials in all of the
states interviewed and nearly all surveyed said they needed complete and
clear guidance before they could comply with the law. Most of the states
we visited also did not have data systems that could track teacher
qualifications by core subject taught, which they would have to do to
ensure that teachers were teaching only those subjects for which they had
demonstrated subject area knowledge. Finally, many state officials we
visited were reluctant to say that their certified teachers might not be
highly qualified.

During our review, Education changed its criteria for teachers who were in
alternative certification programs and it reissued the draft guidance to
qualify only teachers in certain programs. 9 The revised draft guidance
stated that only those teachers enrolled in alternative certification
programs with specific elements, such as teacher mentors, would be
considered highly qualified. As a result, state officials had to recount
this group of teachers by determining which alternative certification
programs met the standard and then which teachers participated in those
programs. In one state we visited, there were about 9,000 teachers in
alternative certification programs and all were considered highly
qualified until the revised draft guidance was issued. As of May 2003, an
official said she was still trying to determine the number of teachers who
were highly qualified. Also during our review, state officials were
uncertain about the criteria for

special education teachers. The draft guidance that was available during
most of our visits did not address special education teachers. As a
result, state officials could not know, for example, whether a special
education 9 Many states have alternate routes to certification, referred
to here as alternative

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

majoring in education in order to become a teacher. Many States Were

Uncertain about Numbers of Highly Qualified Teachers

States Did Not Have Complete or Consistent Criteria to Determine the
Number of Highly Qualified Teachers

Page 11 GAO- 03- 631 No Child Left Behind teacher teaching math and
reading would have to demonstrate subject area knowledge in both or
neither of the subjects. For school year

1999- 2000, special education teachers represented about 11 percent of the
national teacher population, 10 so that, on average, state officials were
unable to determine whether at least a tenth of their teachers met the
highly qualified criteria. In some districts, special education teachers
represented a larger portion of the workforce. For example, in one
highpoverty urban district that we visited, special education teachers
were 21 percent of their teachers. Education issued final Title I
regulations on December 2, 2002, with an appendix that discussed the
highly qualified requirements for special education teachers, among other
things. However, the requirements are not discussed in the federal
regulations nor are they discussed in the Title II draft guidance that was
issued December 19, 2002. In addition, as of March 2003 some officials
still had questions about the requirements. Perhaps because the guidance
was issued in an appendix, it was not given the prominence needed to
ensure that all officials would be aware of the information.

Furthermore, neither Education*s draft guidance nor its regulations
provided more information than the law to help state officials develop
methods other than tests to evaluate their current teachers* subject area

knowledge. The law allows states to use a *high, objective uniform state
standard of evaluation* instead of a test. Education*s draft guidance
repeated the language of the law, but provided no further interpretation.
In addition, Education officials said they would review states*

implementation of this provision when they conduct compliance reviews and
then determine if the state evaluation is in compliance with the law.
State officials said they needed more information, such as examples, to be
confident of what Education would consider adequate for compliance with
the law. State officials prefer evaluations instead of tests, according to
an official at the Council of Chief State School Officers (CCSSO), because
they expect evaluations to be less expensive, more flexible, and more
acceptable to teachers and unions. Such evaluations might be done through
classroom observations, examination of portfolios, and peer reviews. In
March 2003, CCSSO held a conference attended by about 25 state officials
and several Education officials to discuss the implementation of state
evaluations. At that conference, state officials said 10 National Center
for Education Statistics, Schools and Staffing Survey, 1990- 2000,

*Number and Percent of Public School Special Education Teachers Who Teach
Special Education Classes as Their Main Assignment or as Their Second
Assignment* (2002).

Page 12 GAO- 03- 631 No Child Left Behind Education*s lack of specificity
was particularly a problem for evaluating middle and high school teachers
who had not demonstrated subject area knowledge. According to our survey
data, 23 of 37 state officials said they

would have difficulty fulfilling the highly qualified requirement for
middle school teachers and 14 anticipated difficulty for high school
teachers. According to district survey results, 20 percent anticipated
difficulties in meeting the federal criteria for middle school teachers
and 24 percent for high school teachers. Furthermore, as table 2 shows, a
significantly higher percentage of high- poverty districts reported they
would have greater difficulty fulfilling the requirement for teachers,
especially at the middle and high school levels, than would low- poverty
districts.

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

Type of school All districts High- poverty districts Low- poverty

districts

Elementary 7 18 4 Middle/ junior high 20 35 13 High 24 46 a 15 Source: GAO
survey. a The percentage estimate for high schools in high- poverty
districts has a 95 percent confidence

interval of plus or minus 11 percentage points.

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

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

Not Track Federal Criteria

Page 13 GAO- 03- 631 No Child Left Behind *was designed years ago for
state certification purposes*[ and] has not yet been updated to include
all NCLBA criteria for teachers.* Other state

officials also told us during our visits and through survey comments that
their state certifications did not always require teachers to demonstrate
subject area knowledge, so they did not have information on many teachers*
qualifications for this criteria. Another state official wrote, *[ We] do
not have data on teachers who were grand fathered in before 1991 or from
out of state* who do not have subject matter competency.* Given the cost
and time they thought it would take, some state officials expressed
reservations about changing their data systems before Education provided
complete guidance.

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

certified teachers. For example, in 5 states we visited officials told us
that the unions in these states objected to the testing of certified
teachers.

Many state officials responding to our survey reported that teacher salary
issues and teacher shortages were hindrances. State officials also
identified other conditions such as few programs to support new teachers,
lack of principal leadership, teacher training, and union agreements.

District officials also cited teacher salary and teacher development
issues as conditions that hindered them. Our district survey also shows
that significantly more high- poverty districts reported some conditions
as hindrances than low- poverty districts, and rural districts officials
we visited cited hindrances specific to their small size and isolated
locations. In our state survey, officials indicated that they needed more
information from Education on professional development programs, best
practices, and developing incentives for teachers to teach in high-
poverty schools. Some State Officials

Reluctant to Report Teachers Not Highly Qualified

State and District Officials Reported Many Conditions as Hindrances to
Meeting the Law

Page 14 GAO- 03- 631 No Child Left Behind Many state officials responding
to our survey reported that pay issues hindered their ability to meet the
requirement to have all highly qualified

teachers. These issues included low salaries, lack of incentive pay
programs, and a lack of career ladders for teachers. For example, 32 of 37
state respondents said low teachers* salaries compared to other
occupations was a hindrance. Officials we visited said that because of the
low salaries it has been more difficult to recruit and retain some highly

qualified teachers, especially math and science teachers. Several
occupations are open to people with a bachelor*s degree in math and
science, such as computer scientists and geologists. During the late
1990s, there was an increase in demand for workers with math and science
backgrounds, especially in information technology occupations. Between
1994 and 2001, the number of workers employed in the mathematical and
computer sciences increased by about 77 percent while the number of
teachers increased by about 28 percent and total employment increased by
about 14 percent. Furthermore, the math and science occupations have

generally paid higher salaries than teaching positions. The U. S.
Department of Labor*s Bureau of Labor Statistics data indicate that in
2001 average weekly earnings was $1,074 for mathematical and computer
scientist positions and $730 for teachers. Some research shows that
teacher salary is only one of many factors that influence teacher
recruitment and retention. For example, the American Association of School
Administrators explained the relationship between pay and working
conditions in a report on higher pay in hard- to- staff schools. 11 The
report stated *How money matters becomes much clearer if salary is viewed
as just one of many factors that employees weigh when assessing the
relative attractiveness of any particular job, such as opportunities for
advancement, difficulty of the job, physical working conditions, length of
commute, flexibility of working hours, and demands on personal time.
Adjusting the salaries upward can compensate for less appealing aspects of
a job; conversely, improving the relative attractiveness of jobs can
compensate for lower salaries.*

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

11 Cynthia Prince, Higher Pay in Hard to Staff Schools: The Case for
Financial Incentives,

American Association of School Administrators, June 2002. State Officials
Cited

Several Problems as Hindrances

Page 15 GAO- 03- 631 No Child Left Behind education. 12 Additionally, 12
state officials reported a shortage in the number of new highly qualified
teachers in subject areas that are not high

need, and 12 reported that having few alternative certification programs
hindered their efforts. Education experts have debated the causes and
effects of teacher shortages. Some experts argue that the problem is not
in the number of teachers in the pool of applicants but in their
distribution across the country. Others argue that poor retention is the
real cause of teacher shortages. As for alternative certification
programs, they were established to help overcome teacher shortages by
offering other avenues for people to enter the teaching profession.
However, in 1 state we visited officials said the success of these
programs had been mixed because the

content and length of the programs varied and some alternative
certification teachers were better prepared than others.

Although states have been facing teacher shortages in some subject areas
for years, the new requirement for highly qualified teachers could make it
even more difficult to fulfill the demand for teachers. The new law

requires states to ensure that teachers only teach subjects for which they
have taken a rigorous state test or evaluation, completed an academic
major or graduate degree, finished course work equivalent to such degrees,
or obtained advanced certification or credentialing in the subjects.
Previously, states allowed teachers to teach subjects without such course
work or credentials. From its Schools and Staffing Survey, 13 the National
Center for Education Statistics, within the Department of

Education, reported that in 1999- 2000, 14 to 22 percent of students in
middle grades and 5 to 10 percent of high school students taking English,
math, and science were in classes taught by teachers without a major,
minor, or certification in the subjects they taught. Also, the report
indicated that in the high school grades, 17 percent of students enrolled
in physics and 36 percent enrolled in geology/ earth/ space science
classes were taught by out- of- field teachers.

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

12 In this report, when discussing a shortage of teachers in the high need
subject area of special education, we are referring to a shortage of
persons qualified to be special education teachers to teach core subjects
to children with disabilities as defined in Section 602 of the Individuals
with Disabilities Education Act Amendments of 1997. 13 Department of
Education, Qualifications of the Public School Teacher Workforce:

Prevalence of Out- of- Field Teaching 1987- 88 and 1999- 2000, Statistical
Analysis Report,

Schools and Staffing Survey, National Center for Education Statistics,
2002.

Page 16 GAO- 03- 631 No Child Left Behind 13 of the 37 state respondents
reported few programs to support new teachers, 14 and 9 reported large
classes as hindrances. State respondents

also cited work environment factors such as teacher performance
assessments, a lack of principal leadership, and lack of school supplies
and equipment as hindrances. See table 3 for more information on
hindrances reported by state officials.

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

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

Page 17 GAO- 03- 631 No Child Left Behind Table 3: Number of States
Reporting on Conditions That Hinder Their Ability to Meet the Requirement
for Highly Qualified Teachers (Ranked from Highest to Lowest) Number of
states

reporting this condition to be a hindrance a (n= 37) Condition

32 Teachers* salaries low compared to other occupations. 23

Shortage in the number of teachers who meet the Title II requirement for
highly qualified teachers in subject areas where there is high need. 21
Teachers* salaries low compared to teachers elsewhere. 18 Lack of
incentive pay programs. 17 Lack of a career ladder for teachers.

14 Professional development programs not of sufficient duration to have an
effect on teacher quality. 13 Few programs to support new teachers. 12 Few
alternative certification programs.

12 Shortage in the number of new teachers who meet the Title II

requirement for highly qualified teachers in subject areas that are not
high need. 12 School lacks supplies and equipment.

11 Lack of leadership on the part of principals. 9 College of Arts and
Science Departments do not work with college

Education Departments to develop teacher preparation programs. 9 Large
class sizes resulting in teacher retention problems.

9 Many currently employed teachers do not meet the Title II

requirement for highly qualified teachers in areas that are not high need.
7 Teacher assessments not based on the Title II requirement for

highly qualified teachers. 7 Weak training for teachers in the use of
technology. 7 Union agreements inhibit implementing activities encouraged
by

Title II to develop highly qualified teachers. 7 Professional development
programs not based on recent scientific

research on teaching methods or subject matter. 4 State certification
requirements not meeting the Title II requirement

for highly qualified teachers. 3 Alternative certification programs not
providing teachers with adequate teaching skills.

3 Teacher preparation programs not aligned with state subject content
standards. 3 State and local laws and regulations inhibit implementing
activities

encouraged by Title II to develop highly qualified teachers. 2 Teacher
preparation programs not providing teachers with

adequate subject matter expertise. Source: GAO survey. a These numbers
include states that reported these conditions as a moderate, great, or
very great hindrance.

Page 18 GAO- 03- 631 No Child Left Behind School district estimates from
our survey show that, similar to state respondents, salary issues hinder
districts* efforts to meet the requirement

for highly qualified teachers. Almost 60 percent of district officials
cited low teacher salaries compared to other occupations as a hindrance,
with a significantly higher number of high- poverty than low- poverty
district

officials reporting this as a hindrance. During our site visits to 4 rural
districts, officials said that their salaries could not compete with
salaries offered in other occupations and locations. One official said
that pay in the rural districts was low compared to teacher salaries in
surrounding states. Both state and district officials also said that these
salary conditions affect the recruitment and retention of highly qualified
teachers.

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

districts reporting conditions that hinder their ability to meet the
requirement for highly qualified teachers. School Districts Reported

Hindrances Similar to Those Reported by States and More High- Poverty
Districts Reported Certain Hindrances

Page 19 GAO- 03- 631 No Child Left Behind Table 4: Estimated Percentages
of Districts Reporting on Conditions That Hinder Their Ability to Meet the
Requirement for Highly Qualified Teachers (Ranked from Highest to Lowest)
Percent of all

districts reporting this condition to be a hindrance a Condition

57 Teachers* salaries low compared to other occupations. 37 Teachers*
salaries low compared to teachers elsewhere. 28 Training for teachers in
the use of technology is weak. 25 Lack of incentive pay programs.

23 Professional development programs not of sufficient duration to have an
effect on teacher quality. 19

Shortage in the number of teachers who meet the Title II requirement for
highly qualified teachers in subject areas where there is high need.

18 Teacher preparation programs not providing teachers with adequate
subject matter expertise. 18 Few alternative certification programs.

17 College of Arts and Science Departments not working with college
Education Departments to develop teacher preparation programs.

16 Alternative certification programs not providing teachers with adequate
teaching skills. 16 Few programs to support new teachers. 16 Lack of a
career ladder for teachers.

16 Shortage in the number of new teachers who meet the Title II
requirement for highly qualified teachers in low achieving schools. 15
Teacher preparation programs not aligned with state subject content

standards. 14 School lacks supplies and equipment.

12 Teacher assessments not based on the Title II requirement for highly
qualified teachers.

10 Union agreements that inhibit implementing activities encouraged by
Title II to develop highly qualified teachers.

7 Lack of leadership on the part of principals. 7 Large class sizes
resulting in teacher retention problems.

7 Professional development programs not based on recent scientific
research on teaching methods or subject matter. 7 State certification
requirements not meeting the Title II requirement

for highly qualified teachers. 6

Many currently employed teachers not meeting the Title II requirement for
highly qualified teachers in areas that are not high need.

4 State and local laws and regulations inhibit implementing activities
encouraged by Title II to develop highly qualified teachers.

Source: GAO survey. a These percentages include districts that reported
these conditions as a moderate, great, or very great hindrance.

Page 20 GAO- 03- 631 No Child Left Behind While the ranking of most of the
hindrances reported by districts and states were similar, three conditions
were reported among the top third of hindrances for districts but among
the bottom third for states. Specifically, these conditions were (1)
alternative certification programs do not provide

teachers with adequate teaching skills, (2) teacher preparation programs
do not provide teachers with adequate subject matter expertise, and (3)
training for teachers in the use of technology is weak. The first two of
these conditions relate to programs that are usually responsibilities of
the state departments of education. States or districts can address the
third condition, technology training. These conditions indicate areas in
which states and districts can work together to improve programs and help
meet the requirement for highly qualified teachers.

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

Page 21 GAO- 03- 631 No Child Left Behind Table 5: Estimated Percentages
of High- and Low- Poverty Districts with Significant Differences in the
Hindrances to Meeting the Requirement

Condition Percent of high- poverty

districts Percent of low- poverty

districts

Teachers* salaries are low compared to other occupations. 75 50 Teachers*
salaries are low compared to teachers elsewhere. 57 33 Lack of incentive
pay programs. 32 17 Few programs to support new teachers. 30 6 Shortage in
the number of teachers who meet the Title II requirement for highly
qualified teachers in subject areas where there is a high need. 29 13
Shortage in the number of new teachers who meet the Title II requirement
in low achieving schools. 26 10 Lack of career ladder for teachers. 25 8
Few alternative certification programs. 24 11 Teacher preparation programs
do not provide adequate subject matter expertise. 24 13

Many currently employed teachers do no meet the Title II requirement in
areas that are not high need. 13 4 Large class sizes resulting in teacher
retention problems. 12 4 Lack of leadership on the part of principals. 12
3 Source: GAO survey.

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

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

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

Page 22 GAO- 03- 631 No Child Left Behind that they were facing teacher
shortages because not enough teachers were willing to teach in rural
districts. For example, one official in a large, rural

state said that the state had only one university, which makes it
difficult for teachers to obtain further course work to meet the federal
criteria for subject area knowledge. Since many teachers in this state*s
rural districts had to teach more than one core subject, with limited
access to subject area training, they may not meet the highly qualified
criteria for all subjects they teach. One survey respondent also wrote,
*Rural schools have to assign teachers to several subject areas at [the]
secondary level. We do not have large numbers of students, and teachers
have to wear more than one hat. Rural schools are also a long way from
colleges and to require licensure in every subject they teach is
ludicrous.* In a 2001 report

to Congress, Education estimated that 84 percent of 4- year institutions
would offer distance education courses 15 in 2002. Such courses may help
address this hindrance.

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

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

More Information from Education and Education Plans to Work with States on
Some Issues

Page 23 GAO- 03- 631 No Child Left Behind To help meet the requirement for
highly qualified teachers, state officials planned to spend most of their
Title II funds on professional development

activities, and district officials planned to spend a majority of their
Title II funds on recruitment and retention activities. State and district
officials planned to spend much larger amounts of other federal, 16 state,
and local funds than Title II funds on the activities authorized in the
act. Generally,

state and district officials told us they were continuing activities from
previous years. The survey data also indicated high- poverty districts
relied more on Title II funds for recruitment and retention activities
than lowpoverty districts. In addition, while the act requires districts
to target their Title II funds to schools that meet certain criteria,
until district officials know the number of highly qualified teachers and
where they are located, they cannot fully comply with this requirement.

Generally, state educational agencies could use up to 2.5 percent of the
state*s Title II funds for authorized state activities. 17 Twenty- four
state officials responding to our survey planned to spend about 65 percent
of their Title II funds on professional development activities to develop
and support highly qualified teachers and principals. For example,
professional development activities could help teachers enhance their
subject area knowledge and complete state licensing requirements to meet
the criteria

for highly qualified teachers. During our site visits, state officials
described their professional development activities as seminars,
conferences, and various instructional initiatives. For example, in one
state we visited, officials planned to hold a workshop to provide middle
and high school math teachers with technology training so that they could
incorporate interactive Web sites in their instruction. Generally, state
officials said

16 For example, districts must use 5 to 10 percent of their Title I- A
funds in fiscal years 2002 and 2003 for professional development
activities to ensure that teachers become highly qualified. 17 State
education agencies receive 5 percent of the total grant funds and can
retain up to 1

percent of these funds for administrative costs. Of the remaining funds,
2. 5 percent must be spent on subgrants to eligible partnerships and the
remaining funds are to be used for authorized activities. We grouped the
Title II activities into five categories: (1)

accountability, (2) certification, (3) professional development, (4)
recruitment and retention, and (5) technical assistance. Appendix II lists
all 18 activities. To Hel p Teachers Meet the Requirement

States Planned to Spend Most Title II Funds on Professional Development
Activities, and Districts Will Spend Most on Recruitment and Retention
Activities

States Planned to Spend the Majority of Title II Funds on Professional
Development

Page 24 GAO- 03- 631 No Child Left Behind they planned to use Title II
funds to continue activities that were begun in previous years.

While professional development activities were to receive the largest
share of funds, survey results show state officials planned to also spend
Title II funds on other activities cited in the act. Officials in 28
states planned to spend about 18 percent on technical assistance
activities, such as providing information about the requirement for highly
qualified teachers to districts via the state Web site. Certification
activities received the

smallest percentage of Title II funds* 2 percent. These activities include
efforts to promote certification reciprocity with other states and efforts
to establish, expand, or improve alternative routes for certification.
(See fig. 2.)

Figure 2: Planned Spending of Title II Funds by Reporting States State
officials reported they planned to spend much larger amounts of other
federal and state funds than Title II funds on nearly all of the
authorized Title II activities. For example, states reported that 85
percent of the total funds they planned to spend on professional
development activities would come from other federal and state funds. The
one exception was technical assistance activities, where Title II funds
Title II Funds Are a Small

Part of Total Funds

2%

Certification

6% 9%

18% 65%

Recruitment and retention Accountability Technical assistance

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

Page 25 GAO- 03- 631 No Child Left Behind accounted for 77 percent of the
total. (See fig. 3.) Providing technical assistance to districts is an
important role for states. In our visits to

districts, several officials said they needed more information and
technical assistance from their state to understand and implement the law.

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

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

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

Funds on Recruitment and Retention Activities

Percent of planned spending on activities 0 10

20 30

40 50

60 70

80 90

100 Accountability

6 94

5 95

15 85

13 87

77 23 Title II funds Other federal and state funds

Certification Professional development

Recruitment and retention

Technical assistance

Source: The 37 states responding to GAO survey.

Page 26 GAO- 03- 631 No Child Left Behind continue activities developed
under the previous Class Size Reduction Program. Class size reduction
activities may help improve teacher

retention because, according to an Education report, 19 teachers in small
classes spend less time on classroom management and more time providing
instruction, thus raising the teacher*s level of job satisfaction. While
class size reduction activities can be seen as a retention tool, they may
also increase the number of highly qualified teachers that need to be
hired. This may be a problem for some districts and states. In fact,
officials

in one large state we visited said class size reduction activities
presented a challenge by increasing the number of classes not being taught
by a highly qualified teacher.

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

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

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

Activity All districts All high- poverty districts All low- poverty

districts

Professional development activities 34 23 41 Recruitment and retention/
class size reduction 66 77 59 Source: GAO survey.

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

Page 27 GAO- 03- 631 No Child Left Behind Note: Each difference between
high- and low- poverty districts in this table is significant at the 95
percent confidence interval.

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

Larger Amounts of Other Funds and Title II Funds Are a Larger Percentage
of Total for High- Poverty Districts

Page 28 GAO- 03- 631 No Child Left Behind Figure 4: Estimated Spending of
Title II Funds as a Percentage of Total Funds by Activities for All
Districts, High- Poverty Districts, and Low- Poverty Districts

We estimated about one- third of all districts (34 percent) were targeting
their Title II funds as required by the act. The act requires districts to
target funds to those schools (1) with the highest number of teachers who
are not highly qualified, (2) with the largest class sizes, or (3) in need
of improvement. There was little difference between the percentages of
high- and low- poverty districts that targeted their funds or between
urban and

rural districts. For example, 29 percent of high- poverty districts and 30
percent of low- poverty districts reported targeting some of their Title
II funds. Additionally, some district officials we visited said they did
not

target funds according to the criteria listed in the act but that they
targeted funds in other ways such as to support math and science programs
for teachers and for administrative leadership programs. It may be too
early for district officials to fully implement this targeting
requirement. Until they know the true number of teachers who are highly
qualified, they cannot target the schools with the highest numbers of
teachers who are not highly qualified. Approximately One- Third

of All Districts Were Targeting Funds

Title II percentage of total funds 0 5

10 15

20 25

30 35

40 45

50 Professional development Recruitment

and retention

All districts All high- poverty districts All low- poverty districts 20 21

15 28

48 15 Source: GAO district survey.

Page 29 GAO- 03- 631 No Child Left Behind Education officials have had to
interpret and help states implement many new requirements established by
the NCLBA, including the highly qualified

teacher requirement. During this first year of implementation, state
officials were still determining how they could assess whether their
teachers met all the criteria and identifying steps they needed to take to
meet the new requirement. Generally, state and district officials
continued to be challenged by many longstanding hindrances and they
continued to fund activities from previous years.

Education issued regulations and draft guidance to help states begin to
implement the requirement for highly qualified teachers and has plans to
help states with some of their challenges. However, state officials need
more assistance from Education, especially about methods to evaluate

current teachers* subject area knowledge. Without this information state
officials are unsure how to assess whether their current teachers meet the
highly qualified requirement. This would also help them accurately
determine the number of teachers who are highly qualified and take
appropriate steps, such as deciding on which activities to spend Title II
funds and targeting Title II funds to schools with the highest numbers of
teachers who are not highly qualified. It is important that states have
the information they need as soon as possible in order to take all
necessary actions to ensure that all teachers are highly qualified by the
2005- 06 deadline.

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

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

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

Recommendation for Executive Action

Agency Comments and Our Evaluation

Page 30 GAO- 03- 631 No Child Left Behind knowledge of current teachers.
Education stated that it will continue to work with state officials and
will actively share promising strategies and

models for *high objective uniform State standard of evaluation* with
states to help them develop ways for teachers to demonstrate subject area
competency.

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

Additionally, Education provided technical comments and we made changes as
appropriate. We are sending copies of this report to appropriate
congressional

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

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

Appendix I: Scope and Methodology Page 31 GAO- 03- 631 No Child Left
Behind In conducting our work, we administered a Web survey to the 50
states and the District of Columbia, and a separate Web survey to a
nationally

representative sample of 830 school districts, that included strata for
highpoverty, low- poverty, rural, and urban districts. The response rate
for the state survey was 71 percent and for the district survey 62
percent. The surveys were conducted between December 4, 2002, and April 4,
2003. We

analyzed the survey data and identified significant results. See figure 5
for a geographic display of responding and nonresponding states.

Figure 5: State Survey Respondents

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

Source: The 37 states that responded to GAO survey. Did not complete
survey (14)

Appendix I: Scope and Methodology Page 32 GAO- 03- 631 No Child Left
Behind Sample Design. The sample design for this survey was a stratified
sample of 830 LEAs in the study population. This sample included the 100
largest

districts and a stratified sample of the remaining districts with strata
defined by community type 1 (city, urban, and rural) and by the district*s
poverty level. 2 Table 7 summarizes the population, sample sizes, and
response rates by stratum.

Table 7: Population and Sample by Stratum Stratum number Description
Districts in population Districts in sample Districts

responding Response rate

1 Largest 100 districts 100 100 64 64% 2 City, low poverty 648 120 76 63%
3 City, high poverty 210 94 35 37% 4 Urban, low poverty 5,264 135 87 64% 5
Urban, high poverty 648 120 79 66% 6 Rural, low poverty 6,515 135 87 64% 7
Rural, high poverty 1,118 126 83 66%

Total 14,503 830 511 62%

Source: GAO analysis of Education*s 2000- 1 CCD data Estimates. All
estimates produced from the district sample in this report are for a
target population defined as all public school districts in the 50 states
and the District of Columbia for the 2002- 03 school year. Estimates to
this target population were formed by weighting the survey data to account
for both the sample design and the response rates for each stratum. For
our estimates of high- and low- poverty districts, we defined high-
poverty districts as those with participation rates in the free and

1 *City* is defined as a central city of Consolidated Metropolitan
Statistical Area (CMSA) or as a central city of a Metropolitan Statistical
Area (MSA). *Urban* refers to Urban Fringe (an incorporated place, Census
Designated Place, or nonplace territory within a CMSA or MSA of a city and
defined as urban by the Census Bureau), to a large town (an

incorporated place or Census Designated Place with a population greater
than or equal to 25,000 and located outside a CMSA or MSA), or to an
incorporated place or Census Designated Place with a population less than
25,000 and greater than 2, 500 located outside a CMSA or MSA. A *rural
community* is any incorporated place, Census Designated Place, or nonplace
territory designated as rural by the Census Bureau.

2 Poverty level was not available on the CCD data files; however, as a
proxy for poverty, we stratified based on participation in the free/
reduced student meals program. For sample selection, high- poverty
districts are those districts having at least 60 percent participation

in free/ reduced meals programs. Less than 60 percent participation in
this program identifies a district as a low- poverty district for
stratification purposes.

Appendix I: Scope and Methodology Page 33 GAO- 03- 631 No Child Left
Behind reduced meals program of 70 percent or above. Low- poverty
districts were defined as those with free and reduced meals program rates
at 30 percent

and below. One of the advantages of this approach was that it allowed for
a sufficient number of cases in each category to conduct statistical
analyses.

Sampling Error. Because we surveyed a sample of school districts, our
results are estimates of a population of school districts and thus are
subject to sampling errors that are associated with samples of this size
and type. Our confidence in the precision of the results from this sample
is expressed in 95 percent confidence intervals. The 95 percent confidence
intervals are expected to include the actual results for 95 percent of the

samples of this type. We calculated confidence intervals for our study
results using methods that are appropriate for a stratified, probability
sample. For the percentages presented in this report, we are 95 percent
confident that the results we would have obtained if we had studied the
entire study population are within plus or minus 10 percentage points of
our results, unless otherwise noted. For example, we estimate that 34
percent of the districts target at least some funds to specific types of
schools. The 95 percent confidence interval for this estimate would be no
wider than plus or minus 10 percent, or from 24 percent to 44 percent.

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

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

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

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

Appendix I: Scope and Methodology Page 34 GAO- 03- 631 No Child Left
Behind students, teachers, number of schools, and administrators that
covered major segments those groups. For example, we did an analysis on
all fulltime

equivalent classroom teachers but not on teachers of ungraded students,
which is a very small proportion of all teachers. We used these values for
the 511 sample respondents to produce sample estimates to the total
population of all 14,503 districts. These estimated values, their
associated 95 percent confidence intervals, and their true population
values are presented in table 8.

Table 8: Sample Estimates Compared to Population Values Description of
estimate

Mean per district estimated from survey

respondents Lower bound of 95 percent confidence

interval Upper bound

of 95 percent confidence interval Mean per district

for population

Students with Individualized Education Programs 455.6 391.8 519.5 424.8
Full- time equivalent classroom teachers 186.0 157.8 214.2 180.8 Students
in Pre- Kindergarten to 12th grade 3,306.8 2, 851.2 3, 762.3 3, 168.1
Total diploma recipients 198.5 169 227.9 201.4 Limited English proficient
students 268.9 210.5 327.3 340.9 Schools in district 6.7 5. 9 7.5 6. 2
Local Education Authority administrators 4.2 3. 6 4.8 3. 7 LEA support
staff 11.8 9. 8 13.9 10.9 School administrators 10.4 8. 9 11.9 9. 7 School
administrative support staff 17.3 14.6 19.9 16.5 Student support services
staff 10.8 9. 3 12.2 10.6 Instructional coordinators and supervisors 2.9
2. 2 3.6 2. 5 Source: GAO analysis of Education*s 2000- 1 CCD data Note:
LEAs are also known as school districts.

For 11 out of the 12 estimates we examined, the population value falls
within the 95 percent confidence interval for the estimate, thus providing
some indication that respondents to this survey reflect the

12 characteristics we examined in the population. Although these
characteristics were selected because they might be related to other
characteristics of district teachers and district administration, we do
not know the extent to which the survey respondents would reflect the
population characteristics for the specific questions asked on our survey.
For example, we are not certain whether districts responding to the survey
were further along in the implementation of Title II requirements than the
districts that did not respond.

Appendix I: Scope and Methodology Page 35 GAO- 03- 631 No Child Left
Behind Our sample was not designed to produce geographical area estimates,
and we did not explicitly stratify our sample by state or region. However,
our

sample was selected nationally and all regions are represented in our
sample. The following table summarizes sample size and responses for 10
regions.

Table 9: Population and Sample by Region Region number State in each
region Districts in population Districts in sample Districts

responding

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

Total 14,503 830 511

Source: Note: for this table, we adopted the Department of Education*s
region definitions as provided at

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

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

Appendix I: Scope and Methodology Page 36 GAO- 03- 631 No Child Left
Behind therefore, could not accurately determine how many teachers were
highly qualified.

We also visited 8 states with a range of characteristics that might affect
their meeting Title II requirement for highly qualified teachers. Those
states were California, Connecticut, Illinois, Iowa, Maryland, North
Carolina, Delaware, and Wyoming. We visited and interviewed officials in 2
districts in each state, one of which was a high- poverty district, and
one school in each district. We interviewed Department of Education
officials,

and officials and representatives from several professional organizations.
We also reviewed the legislation, the regulations, and guidance as well as
related reports and other relevant documents. We conducted our work
between July 2002 and May 2003 in accordance with generally accepted
government auditing standards. Other Methodology

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

Page 37 GAO- 03- 631 No Child Left Behind Table 10 lists our summaries of
the authorized activities on which states can spend Title II funds and
shows the five categories we used to group

them.

Table 10: Title II, Part A State Activities Category Activity

Accountability 1. Developing systems to measure the effectiveness of
professional development programs and strategies to document improvements
in students* academic achievement. 2. Ensuring that teachers use
challenging state academic content standards, assessments, and

student achievement standards to improve their teaching practices and
their students* achievement. Certification 3. Reforming teacher and
principal certification. 4. Reforming tenure and implementing tests for
subject matter knowledge.

5. Promoting license and certification reciprocity agreements with other
states for teachers and principals. 6. Providing programs that establish,
expand, or improve alternative routes for state certification,

especially for highly qualified individuals in the areas of mathematics
and science. Professional development 7. Conducting programs that provide
support to teachers, such as those that provide teacher mentoring

and use assessments that are consistent with student academic achievement
standards. 8. Providing professional development for teachers and
principals. 9. Developing or assisting local educational agencies (LEAs)
in developing and using, proven

innovative strategies for intensive professional development programs that
are both cost effective and easily accessible. 10. Encouraging and
supporting the training of teachers and administrators to integrate
technology into

curricula and instruction, including training to improve their ability to
use data to improve their teaching. 11. Providing assistance to teachers
to enable them to meet certification, licensing, or other Title II
requirements needed to become highly qualified.

Recruitment and retention 12. Developing or assisting LEAs to develop,
merit- based performance systems and strategies that provide pay
differentials and bonus pay for teachers in academic subjects in which
there is high need. 13. Developing projects and programs to encourage men
to become elementary teachers. 14. Establishing and operating a statewide
clearinghouse and programs for the recruitment, placement,

and retention of teachers. 15. Assisting LEAs and schools in recruiting
and retaining highly qualified teachers, including

specialists in core subjects. 16. Developing or assisting LEAs to develop,
teacher advancement initiatives that promote professional

growth, and emphasize multiple career paths and pay differentiation.
Technical assistance 17. Fulfilling the state agency*s responsibility to
properly and efficiently carry out the administration of

programs, including providing technical assistance to LEAs. 18. Assisting
LEAs to develop and implement professional development programs and school
leadership academies for principals and superintendents. Source: NCLBA
Pub. L. No. 107- 110, section 2113 (2002).

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

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

Page 38 GAO- 03- 631 No Child Left Behind Table 11 lists our summaries of
the authorized activities on which districts can spend Title II funds and
shows the two categories we used to group

them.

Table 11: Title II, Part A District Activities Category Activity

Professional development 1. Providing professional development activities
for teachers and principals that improve their knowledge of their core
subjects and effective instructional strategies. 2. Carrying out
professional development activities

designed to improve the quality of principals and superintendents . 3.
Carrying out teacher advancement initiatives to

promote professional growth and to emphasize multiple career paths and pay
differentiation. 4. Carrying out programs and activities that are designed

to improve the quality of teachers, such as professional development
programs, merit pay programs, and testing teachers in the subjects they
teach. Recruitment and retention 5. Developing and implementing mechanisms
to assist

schools in effectively recruiting and retaining highly qualified teachers
and principals. 6. Developing and implementing initiatives to retain

highly qualified teachers and principals, particularly in schools with a
high percentage of low- achieving students; including programs that
provide teacher mentoring and incentives. 7. Carrying out programs and
activities related to

exemplary teachers. 8. Developing and implementing initiatives to assist

schools in recruiting and hiring teachers, including providing financial
incentives, and establishing programs that train and hire special
education and other teachers, recruit qualified professionals from other
fields, and provide increased opportunities for minorities, individuals
with disabilities and others. 9. Hiring highly qualified teachers in order
to reduce class

size, particularly in the early grades. Source: NCLBA Pub. L. No. 107-
110, section 2123 (2002).

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

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

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

Appendix IV: Comments from the U. S. Department of Education Page 41 GAO-
03- 631 No Child Left Behind

Appendix V: GAO Contacts and Staff Acknowledgments

Page 42 GAO- 03- 631 No Child Left Behind Carolyn M. Taylor (202) 512-
2974 or taylorcm@ gao. gov Mary E. Roy (202) 512- 7072 or roym@ gao. gov
In addition to those named above, the following individuals made

important contributions to this report: Susan Higgins, Anjali Tekchandani,
David Garten, Joel Grossman, Richard Kelley, Mark Ramage, Minnette
Richardson, Susan Bernstein, and Jeff Edmondson. Appendix V: GAO Contacts
and Staff

Acknowledgments GAO Contacts Staff Acknowledgments

(130144)

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