    Special Education: Additional Assistance and Better Coordination
    Needed among Education Offices to Help States Meet the NCLBA
    Teacher Requirements (15-JUL-04, GAO-04-659).

    During the 2001-2002 school year, more than 400,000 special
    education teachers provided instructional services to
    approximately 6 million students with disabilities in U.S.
    schools. Two federal laws contain teacher qualification
    requirements that apply to special education teachers: the No
    Child Left Behind Act (NCLBA) and the Individuals with
    Disabilities Education Act (IDEA). Given the committee's interest
    in issues related to highly qualified special education teachers,
    we are providing information about (1) the state certification
    requirements, including the use of alternative certification
    programs, for special education teachers, and how they relate to
    NCLBA requirements; (2) the factors that facilitate or impede
    state efforts to ensure that special education teachers meet
    NCLBA requirements; and (3) how different offices in the
    Department of Education (Education) assist states in addressing
    NCLBA teacher requirements.
    -------------------------Indexing Terms-------------------------
    REPORTNUM:   GAO-04-659
        ACCNO:   A10930
      TITLE:     Special Education: Additional Assistance and Better
    Coordination Needed among Education Offices to Help States Meet
    the NCLBA Teacher Requirements
         DATE:   07/15/2004
      SUBJECT:   Certificates of competency
    	     Education or training
    	     Educational standards
    	     Special education
    	     Teacher education
    	     Teachers
    	     Federal law
    	     Federal/state relations

    ******************************************************************
    ** This file contains an ASCII representation of the text of a  **
    ** GAO Product.                                                 **
    **                                                              **
    ** No attempt has been made to display graphic images, although **
    ** figure captions are reproduced.  Tables are included, but    **
    ** may not resemble those in the printed version.               **
    **                                                              **
    ** Please see the PDF (Portable Document Format) file, when     **
    ** available, for a complete electronic file of the printed     **
    ** document's contents.                                         **
    **                                                              **
    ******************************************************************
    GAO-04-659

                     United States Government Accountability Office

    GAO	Report to the Ranking Minority Member, Committee on Health, Education,
                            Labor, and Pensions, U.S. Senate

    July 2004

    SPECIAL EDUCATION

    Additional Assistance and Better Coordination Needed among Education Offices to
                    Help States Meet the NCLBA Teacher Requirements

    GAO-04-659

    Highlights of GAO-04-659, a report to the Ranking Minority Member,
    Committee on Health, Education, Labor, and Pensions, United States Senate

    During the 2001-2002 school year, more than 400,000 special education
    teachers provided instructional services to approximately 6 million
    students with disabilities in U.S. schools. Two federal laws contain
    teacher qualification requirements that apply to special education
    teachers: the No Child Left Behind Act (NCLBA) and the Individuals with
    Disabilities Education Act (IDEA).

    Given the committee's interest in issues related to highly qualified
    special education teachers, we are providing information about (1) the
    state certification requirements, including the use of alternative
    certification programs, for special education teachers, and how they
    relate to NCLBA requirements; (2) the factors that facilitate or impede
    state efforts to ensure that special education teachers meet NCLBA
    requirements; and (3) how different offices in the Department of Education
    (Education) assist states in addressing NCLBA teacher requirements.

    GAO recommends that the Secretary of Education provide additional
    assistance to states in explaining NCLBA teacher requirements and
    identifying implementation strategies for special education teachers, and
    formalize its efforts to improve the department's internal coordination
    related to the implementation of these teacher quality requirements.

    www.gao.gov/cgi-bin/getrpt?GAO-04-659.

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

    July 2004

    SPECIAL EDUCATION

    Additional Assistance and Better Coordination Needed among Education Offices to
    Help States Meet the NCLBA Teacher Requirements

    In the 2002-2003 school year, all states, the District of Columbia, and
    Puerto Rico required that special education teachers have a bachelor's
    degree and be certified to teach-two of NCLBA's teacher qualification
    requirements- and half required special education teachers to demonstrate
    subject matter competency in core academic subjects, which is the third
    requirement. Specifically, 24 states, the District of Columbia, and Puerto
    Rico required their teachers to demonstrate some level of subject matter
    competency by having a degree or passing state tests in the core academic
    subjects that they wished to teach. Teachers of core academic subjects in
    the remaining states that did not have such requirements might not be
    positioned to meet the NCLBA requirements. To meet NCLBA teacher
    requirements, teachers would need to demonstrate competency in core
    academic subjects by the end of the 2005-2006 school year.

    Status of Special Education Teacher Subject Matter Competency Requirements
    for School Year 2002-2003, by State

    Source: GAO analysis of survey responses from the state special education
    directors in the 50 states, D.C., and P.R. for the 2002-2003 school year.

    State education officials reported that the availability of funds to
    support professional development facilitated implementation of the NCLBA
    teacher requirements, while other factors, such as uncertainty about how
    to apply the subject matter competency requirement to special education
    teachers, impeded implementation. State education officials and national
    education organizations' representatives we interviewed cited the need for
    more assistance from Education in explaining NCLBA's teacher requirements
    and identifying implementation strategies.

    Education has provided a range of assistance, such as site visits,
    Webbased guidance, and financial assistance, to help states implement the
    highly qualified teacher requirements. However, department coordination
    related to the implementation of NCLBA's teacher requirements for special
    education teachers has been limited.

    Contents

    Letter

    Results in Brief	Background	All States Implemented at Least Two of Three
    NCLBA Teacher

    Requirements for Special Education Teachers

    State Officials Cited Several Factors That Affected the Implementation of
    NCLBA Subject Matter Competency Requirements for Special Education
    Teachers

    Coordination among Education's Offices Responsible for

    Educating Students with Disabilities Was Limited Conclusions
    Recommendations for Executive Action Agency Comments and Our Evaluation

                                           1

                                          2 4

                                           7

    11

    16 18 19 19

    Appendix I
    Thirty-One States with Alternative Routes to Certification in Special
    Education during the 2002-2003 School Year

    Appendix II Comments from the Department of Education

    Appendix III GAO Contacts and Staff Acknowledgments 33

    GAO Contacts 33 Staff Acknowledgments 33

    Table

    Table 1: Application of the NCLBA Teacher Quality Requirements to Special
    Educators' Instructional Roles 14

    Figure

    Figure 1: Status of Special Education Teacher Subject Matter Competency
    Requirements for School Year 2002-2003, by State 9

    Abbreviations

    ESEA Elementary and Secondary Education Act	HOUSSE high, objective,
    uniform state standard of evaluation 	IDEA Individuals with Disabilities
    Education Act	IEP individualized education program	NCLBA No Child Left
    Behind Act of 2001 	OESE Office of Elementary and Secondary Education
       	OSEP Office of Special Education Programs

    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. However, because this
    work may contain copyrighted images or other material, permission from the
    copyright holder may be necessary if you wish to reproduce this material
    separately.

    United States Government Accountability Office Washington, DC 20548

    July 15, 2004

    The Honorable Edward M. Kennedy

    Ranking Minority Member

    Committee on Health, Education, Labor, and Pensions United States Senate

    Dear Senator Kennedy:

    During the 2001-2002 school year, more than 400,000 special education
    teachers provided instructional services to approximately 6 million
    students with disabilities in U.S. schools. Two federal laws contain
    teacher qualification requirements that apply to special education
    teachers: the No Child Left Behind Act (NCLBA) of 2001 and the Individuals
    with Disabilities Education Act (IDEA), which was last amended in 1997.
    Within the Department of Education (Education), the Office of Elementary
    and Secondary Education (OESE) has primary responsibility for implementing
    NCLBA requirements, and the Office of Special Education Programs (OSEP)
    has primary responsibility for implementing IDEA requirements. State
    officials have raised issues regarding the compatibility of the laws'
    teacher qualification requirements and how to apply NCLBA requirements to
    special education teachers.

    NCLBA requires that all teachers of "core academic subjects," such as
    English, meet teacher qualification requirements, and most of these
    teachers must do so by the end of the 2005-2006 school year. To meet
    requirements, teachers (1) must have at least a bachelor's degree, (2) be
    certified to teach by their states, and (3) must demonstrate subject
    matter competence in each core academic subject that they teach. Under the
    NCLBA, all teachers, including special education teachers, who provide
    instruction in core academic subjects are generally required to meet NCLBA
    requirements. However, special education teachers who provide other types
    of instruction do not need to meet NCLBA requirements. IDEA generally
    requires teachers to be appropriately and adequately trained in accordance
    with standards established by each state but does not specify any other
    minimum qualifications for special education teachers. Congress is
    considering including provisions on special education teacher
    qualifications in the pending reauthorization of IDEA.

                        Given your interest in issues related to special
                        education teacher
                        qualifications, we are providing information about (1)
                        the state
                        certification requirements, including the use of
                        alternative certification
                           programs, for special education teachers, and how they
                                                                  relate to NCLBA
                        requirements; (2) the factors that facilitate or impede
                        state efforts to
                        ensure that special education teachers meet NCLBA
                        requirements; and
                              (3) how different offices in the U.S. Department of
                                                          Education assist states
                                in addressing NCLBA teacher requirements.
                        To obtain this information, we used multiple data
                        collection methods.
                             First, we surveyed special education directors in 50
                                                          states, the District of
                        Columbia, and Puerto Rico1 to obtain information on their
                        states or
                        territories for the 2002-2003 school year in the
                        following areas: special
                                education teacher certification requirements, the
                                                        conditions or issues that
                             affected implementation of the NCLBA teacher quality
                                                                 requirements for
                        special education teachers, and the assistance that
                        various Education
                                    offices provided states in implementing NCLBA
                                                         requirements for special
                           education teachers. We achieved a 100 percent response
                                                                 rate. Second, we
                        interviewed education officials in 6 states: Arkansas,
                        Maryland,
                        Massachusetts, New York, South Dakota, and Washington.
                        These states
                        were selected for variance in the number of special
                        education students
                        served, the percentage of certified special education
                        teachers, and
                        geographic location. We also interviewed about 20 federal
                        education
                        officials and representatives from 8 national education
                        organizations
                               regarding special education teacher certification,
                                                          qualifications, meeting
                        NCLBA teacher requirements, and the assistance various
                        Education
                           offices provided to states in these areas. Finally, we
                                                            reviewed the Internet
                        sites of all states to gather information about
                        certification requirements
                               and alternative certification programs for special
                                                           education teachers. We
                             also analyzed agency documentation, legislation, and
                                                              other documentation
                          related to special education teacher qualifications and
                                                                 requirements. We
                        conducted our work between August 2003 and June 2004 in
                        accordance
                         with generally accepted government auditing standards.
                        In the 2002-2003 school year, all states required that
    Results in Brief special education teachers have a bachelor's degree and
                        be certified to teach-two of the
                        NCLBA teacher qualification requirements-and half
                        required special

    1Hereinafter, the term states will refer collectively to the 50 states
    plus the District of Columbia and Puerto Rico.

    education teachers to demonstrate competency in core academic subjects,
    the third requirement. Specifically, 26 states required their teachers to
    demonstrate some level of subject matter competency by having a degree or
    passing tests in the academic subjects that they wished to teach. The
    remaining states did not have such requirements; in these states, state
    certified special education teachers who were assigned to teach core
    academic subjects might not be positioned to meet the NCLBA requirements.
    To meet NCLBA teacher requirements, teachers would need to demonstrate
    competency in core academic subjects by the end of the 2005-2006 school
    year. In 31 states that offered alternative routes to teacher
    certification, certification requirements for alternative route and
    traditional teacher preparation program graduates followed a similar
    pattern in terms of alignment with NCLBA teacher requirements.

    State education officials reported that while the availability of funds to
    support professional development facilitated implementation of the subject
    matter competency requirements, other factors, such as uncertainty about
    how to apply these requirements to special education teachers teaching
    multiple subjects, impeded implementation. Some states helped teachers
    meet requirements by providing financial aid for coursework. Other states
    have provided services to help teachers meet requirements-for example,
    allowing teachers to demonstrate subject matter competency without taking
    an exam or pursuing a degree. About half of the state officials and
    national education organizations' representatives we interviewed reported
    that states needed more assistance on how to implement NCLBA teacher
    requirements. In addition, state officials reported that meeting the
    subject matter competency requirements would be challenging because of the
    time frame for implementation. Although recent Education guidance may have
    resolved some concerns regarding time frames, some state officials we
    interviewed have continued to report uncertainty regarding the application
    of the subject matter competency requirement to special education
    teachers. Education officials noted that NCLBA requirements apply to all
    teachers, but they also have said that the assessment level of the
    students being taught could be considered in determining the level of
    subject matter competency requirements for special education teachers.
    This could be confusing when special education teachers teach high school
    students functioning at elementary school levels because requirements
    differ for different grade levels.

    Education has provided a range of assistance, such as site visits, Web
    based guidance, and financial assistance, to help states implement the
    highly qualified teacher requirements. However, department coordination

    related to the implementation of NCLBA's teacher requirements for special
    education teachers has been limited. Within Education, OESE has taken the
    lead in site visits and posting Web-based guidance, with support from
    offices such as the Office of the Secretary and Office of General Counsel.
    OSEP, however, played a limited role in these efforts. When states
    reportedly sought OSEP's guidance on requirements for special education
    teachers, OSEP officials told us that they generally referred state
    officials to OESE or to the NCLBA Web site. Further, until recently, OSEP
    was not a member of Education's teacher quality policy team, which is
    responsible for responding to state issues and identifying policy
    concerns. Special education teacher issues were among the most frequently
    discussed topics in team meetings. Because of OSEP's limited involvement
    prior to being added to the team, Education may not have been in a
    position to be fully apprised of how special education concerns could
    affect implementation. However, Education officials told us that they
    included OSEP by contacting it to clarify IDEA substantive issues.

    In this report we are recommending that the Secretary of Education provide
    additional assistance to states in explaining NCLBA teacher quality
    requirements and identifying implementation strategies. We are also
    recommending that the Secretary of Education formalize efforts to improve
    the department's internal coordination related to the implementation of
    these NCLBA teacher quality requirements.

    The No Child Left Behind Act of 2001,2 which reauthorized the Elementary
    and Secondary Education Act (ESEA), is designed to improve the education
    of all students and the quality of teachers. NCLBA requires that all
    teachers of "core academic subjects"-defined to mean English, reading or
    language arts, mathematics, science, foreign languages, civics and
    government, economics, arts, history, and geography-be "highly qualified."
    To be highly qualified, teachers (1) must have at least a bachelor's
    degree, (2) be certified to teach by their state, and (3) demonstrate
    subject matter competency in each core academic subject that they teach. A
    teacher's options for demonstrating subject matter competency vary
    according to whether the teacher is new and the grade level being taught.
    New elementary school teachers must demonstrate subject matter competency
    by passing a rigorous state exam in the basic elementary school
    curriculum; new middle or high school teachers may

    Background

                         2Pub. L. No. 107-110, 115 Stat. 1425.

    establish that they are highly qualified by either taking a rigorous state
    exam or successfully completing a degree (or equivalent credentialing) in
    each core academic subject taught. In addition, NCLBA allows current
    teachers to demonstrate subject matter competency based on a "high
    objective uniform state standard of evaluation."3 For example, under these
    uniform state standards, a combination of experience, expertise, and
    professional training could be used to meet the NCLBA subject matter
    competency requirements.

    Education has issued guidance to states on how to apply NCLBA requirements
    to all teachers, including special education teachers. According to
    Education's January 2004 guidance, special education teachers who provide
    instruction in core academic subjects, such as teachers in self-contained
    classrooms, are required to comply with the NCLBA subject matter
    competency requirements. In contrast, those special educators who do not
    provide instruction in core academic subjects, such as those who provide
    consultative services to highly qualified general educators, do not have
    to comply with the NCLBA teacher requirements. In addition, Education's
    March 2004 guidance provided additional flexibility on the implementation
    deadline and competency requirements for some special education teachers.
    Specifically, the guidance stated that educators in eligible rural areas
    who are highly qualified in at least one core academic subject they teach
    would have 3 additional years to demonstrate subject matter competency in
    other academic areas. The guidance also states that teachers who provide
    instruction in multiple core academic subjects will be able to demonstrate
    their subject matter competency through one process under their states'
    uniform standards, such as taking a single test that covers multiple core
    academic subjects.4

    IDEA is the primary federal law that addresses the unique needs of
    children with disabilities, including, among others, children with
    specific learning disabilities, speech and language impairments, mental
    retardation, and serious emotional disturbance. The law mandates that a
    free appropriate public education be made available for all eligible
    children with disabilities, ensures due process rights, requires an

    3Referred to as "HOUSSE" by state education administrators.

    4For additional information on the U.S. Department of Education's March
    2004 guidance on the opportunities for flexibility in meeting the No Child
    Left Behind Act's requirements, go to
    http://www.ed.gov/policy/elsec/guid/secletter/040331.html.

    individualized education program (IEP)5 for each student, requires the
    inclusion of students with disabilities in state and district wide
    assessment programs, and requires the placement of students in the least
    restrictive environment. Under IDEA, states are required to establish
    special education teacher requirements that are based on the highest
    requirements in the state for personnel serving children and youth with
    disabilities.

    Congress is considering including new special education teacher
    qualifications in the reauthorized IDEA. Under H.R. 1350, a new definition
    of "highly qualified," as it refers to teachers, would be added with the
    same meaning as in NCLBA. In contrast, S. 1248 would add an extensive
    definition of "highly qualified" with respect to the qualification of
    educational personnel, while taking into account differences between
    special education and general education teachers. For example, under S.
    1248, special education teachers who consult with secondary school core
    academic subject teachers for children with disabilities would need to be
    fully certified in special education and demonstrate the knowledge and
    skills necessary to teach students with disabilities, to be highly
    qualified.6 In addition, S. 1248 proposes to extend the deadline for
    meeting the highly qualified teacher requirements by 1 year-to school year
    2006
    2007.

    Two offices within the Department of Education are responsible for
    addressing special education teacher qualifications: the Office of
    Elementary and Secondary Education and the Office of Special Education
    Programs. The enactment of NCLBA significantly changed the expectations
    for all teachers, including those instructing students with disabilities.
    For example, states are now required to report on the qualifications of
    their teachers and the progress of their students.

    OESE has assumed responsibility for developing policies for improving the
    achievement of all students and the qualifications of teachers. In
    addition,

    5The term individualized education program refers to a written statement
    that is developed for each student with a disability that specifies, among
    other components, the goals and objectives for the student, describes the
    services that a student will receive, and specifies the extent to which
    the student will participate in the regular education setting with
    nondisabled peers and or in the general curriculum adopted for all
    students.

    6For additional information see The Individuals with Disabilities
    Education Act (IDEA): Selected Changes that Would be Made to the Law by S.
    1248, 108th Congress,

    Congressional Research Service (May 2004).

    the office provides technical and financial assistance to states and
    localities, in part so they can help teachers meet the new qualification
    requirements. For example, in fiscal year 2003, OESE provided funding to
    state and local education agencies through its Improving Teacher Quality
    state grant program.7

    OSEP is responsible for providing leadership and financial resources to
    help states and localities implement IDEA for students with disabilities
    and their teachers. These responsibilities include awarding discretionary
    grants and contracts for projects designed to improve service provision to
    children with disabilities. In 2003, OSEP provided funding to 30 states
    through the State Improvement Grants program.8 OSEP also supports research
    on special education through centers such as the Center on Personnel
    Studies in Special Education.

    In the 2002-2003 school year, all states required that special education
    teachers have a bachelor's degree and be certified to teach-two of the
    three NCLBA teacher qualification requirements-and half required special
    education teachers to demonstrate competency in core academic subjects,
    which is the third requirement. In the 26 states that did not require
    teachers to demonstrate subject matter competency, state-certified special
    education teachers who were assigned to instruct core academic subjects
    might not be positioned to meet the NCLBA requirements. In 31 states that
    offered alternative routes to teacher certification, certification
    requirements for alternative route and traditional teacher preparation
    program graduates followed a similar pattern, with half meeting two of
    three NCLBA teacher requirements.

      All States Implemented at Least Two of Three NCLBA Teacher Requirements for
      Special Education Teachers

    7Improving Teacher Quality state grants are made specifically to encourage
    states to improve the quality of their teaching force through activities
    such as recruiting and retaining highly qualified teachers and principals
    and reforming teacher and principal certification programs.

    8The purpose of State Improvement Grant program is to assist state
    educational agencies and their partners with reforming and improving,
    among other things, their systems for professional development and
    technical assistance to improve results for children with disabilities.

        Half of States Have Similar Teacher Requirements to NCLBA, but 26 States Did
        Not Require Special Education Teachers to Demonstrate Competency in Core
        Academic Subjects

    Every state required special education teachers to hold at least a
    bachelor's degree and to be certified by their states before teaching,
    according to our survey results and reviews of Education documents and
    state Web sites.9 States varied in whether they offered one or more types
    of teaching certificates for special educators. Specifically, 30 states
    established a single certification for special education teachers that
    covered kindergarten through 12th grade, according to survey respondents.
    The remaining 22 states offered two or more certifications. For example,
    some states offered different certifications for teachers of elementary,
    middle school, and high school students. In addition, some states
    certified special education teachers to serve students with specific
    disability categories such as hearing impaired and emotionally disturbed,
    and/or with broader disability categories, such as mild, moderate, and
    severe special needs. Finally, several states certified their special
    education teachers for specific instructional roles such as general
    special education teacher, resource room teacher, or collaborative
    teacher.

    During the 2002-2003 school year, 24 states, the District of Columbia, and
    Puerto Rico required special education teachers to demonstrate some level
    of competency in the core academic subjects that they wished to teach at
    the time of their initial certification by having a degree or passing
    tests in the academic subjects that they wished to teach. Teachers in
    these states are better positioned to meet NCLBA's teacher requirements.
    However, the level of competency required varied by state and in some
    cases may not meet NCLBA competency level requirements. The rest of the
    states did not have any such requirements. (See fig. 1.)

    9Although data are available on the numbers of certified and uncertified
    special education teachers, we did not consider the data to be
    sufficiently reliable for our reporting purposes.

    certification prior to being hired by local school districts for specific
    grade levels, subjects, or instructional roles. Therefore, these
    individuals might not be positioned to meet NCLBA teacher requirements for
    their future instructional roles. Furthermore, any special education
    teacher who was assigned to teach a different subject from one year to the
    next might meet subject matter competency requirements one year but not
    the next. According to Education officials, these challenges are not
    specific to special education teachers and will require school districts
    to be more mindful of teacher qualifications, including subject matter
    mastery, when assigning teachers to various teaching roles.

        Special Education Teachers from Programs Offering Alternative Routes to
        Certification Were Generally Required to Meet the Same Certification
        Requirements as Other Special Education Teachers

    According to survey respondents, 31 states provided alternative routes to
    certification for prospective special education teachers. States have
    developed such routes to meet specific teacher shortages as well as to
    allow professionals in related fields to become teachers. The alternative
    routes to certification programs that we reviewed were generally
    administered by the state education agencies, often through institutions
    of higher education. However, this was not always the case: In Maryland,
    for example, one county contracted with Sylvan Learning Center10 and the
    New Teacher Project11 to provide its alternative route to certification
    program.

    Most of the states that provided alternative routes to certification
    required that the graduates from such alternative route to certification
    programs fulfill the same certification requirements as graduates from
    traditional special education teacher preparation programs, such as having
    a bachelor's degree and passing teacher licensing examinations. The
    primary difference between alternative route programs and traditional
    teacher preparation programs was the extent to which teaching candidates
    received practical teaching experience prior to attaining full state
    certification.

    In general, prospective teachers in alternative route to certification
    programs were required to receive more practical teaching experience

    10Sylvan Learning Centers is an international organization that provides
    personalized instruction to students of all ages and skill levels.

    11The New Teacher Project is a national organization that works with state
    departments of education, school districts, and institutions of higher
    education to recruit, select, and train new teachers.

      State Officials Cited Several Factors That Affected the Implementation of
      NCLBA Subject Matter Competency Requirements for Special Education Teachers

    before being certified than were teachers in traditional programs. For
    example, candidates in an alternative route to certification program in
    Illinois were required to complete a 1-year mentored teaching internship,
    while most traditional certification programs for special education
    teachers required teaching candidates to complete a 9-to 18-week
    supervised student teaching assignment. This additional teaching
    experience has been required because individuals in some alternative
    programs have not received courses in pedagogy and instructional
    techniques. (See app. I for state special education alternative route to
    certification program contact information.)

    State officials indicated that implementing the core academic subject
    competency requirements of NCLBA would be difficult and cited factors that
    have facilitated or impeded application of this requirement to special
    education teachers. State officials identified several key facilitators,
    including having funds available to dedicate to special educators'
    professional development and having preexisting or ongoing efforts to
    develop subject matter competency standards for special educators. State
    officials and national education organizations' representatives also cited
    several factors that impeded meeting the subject competency requirements,
    including uncertainty about how to apply the law to special education
    teachers in some circumstances, and the need for additional assistance
    from Education in identifying implementation strategies.

        Availability of Professional Development Funds Was among the Factors Cited
        as Facilitating the Implementation of NCLBA Requirements

    Survey respondents, as well as state officials and national education
    organizations' representatives we interviewed, reported that the
    availability of professional development funding and the flexibility to
    use funds were essential in helping teachers meet the NCLBA subject matter
    competency requirement. For example, officials in 19 states reported
    helping special education teachers by allocating some of the states'
    professional development money to financial aid for those seeking to
    enhance their knowledge in a core academic subject, such as by pursuing a
    degree. In addition, states can use their professional development funds
    to create alternative routes to certification. This could result in
    developing a cadre of special educators who would already have expertise
    in a core academic subject area.

    Survey respondents described several state assistance initiatives that
    were designed to help special education teachers meet the subject matter

    competency requirements. For example, 17 survey respondents reported
    holding workshops for special education teachers on specific academic
    subjects, and a few states held review sessions to prepare teachers for
    states' academic content exams. In addition, respondents from 7 states
    reported providing sample test questions to help teachers prepare for
    subject matter competency tests. Nineteen survey respondents reported that
    their states had established partnerships with institutions of higher
    education to develop and implement strategies to assist special education
    teachers. For example, Arkansas collaborated with state colleges and
    universities to develop dual-certification programs for special educators.

    Officials we interviewed from 2 of 6 states said that they expected their
    uniform state standards of evaluation would make it easier for their
    experienced teachers to meet NCLBA subject matter requirements.
    Specifically, they asserted that these competency standards would allow
    states and territories to design alternative methods for evaluating
    teachers' knowledge of the subject matter they teach, other than having a
    degree or passing subject matter tests in a core academic subject.
    According to officials in 2 of the 6 states we interviewed, their
    alternative methods of evaluating teachers' subject matter competency
    would take into account both a teacher's years of experience and factors
    such as participation in professional development courses. A few state
    officials and national education organizations' representatives we spoke
    to commented that the flexibility to design alternative methods for
    evaluating teachers' subject matter knowledge provided more options for
    making subject matter competency assessments of experienced special
    education teachers.

        Uncertainty about How to Apply the Subject Matter Competency Requirement to
        Special Education Teachers in Different Instructional Roles Was One of
        Several Barriers Cited to Meeting the NCLBA Requirements

    State officials we interviewed and surveyed reported being concerned about
    how difficult meeting the subject matter competency requirements might be
    for special educators providing instruction, given that their roles may
    require them to teach at multiple grade levels or multiple subjects. State
    officials told us that because of special educator shortages, special
    education teachers' instructional roles might vary. For example, some
    special educators might not have to meet subject matter competency
    requirements when they were hired, but subsequently might have to meet
    subject matter competency requirements for one or more core academic
    subjects, depending upon their instructional roles. Education has issued
    guidance that says that teachers instructing core academic subjects must
    demonstrate subject matter competency. This guidance applies to all
    teachers, including special education teachers. However, Education
    officials told us that the assessment level of the student being taught
    was a consideration in determining the application of the NCLBA subject
    matter

    competency requirement. The inclusion of the assessment levels in
    determining how to apply the NCLBA requirements may explain some of state
    officials' uncertainty regarding the application of the requirement to
    special education teachers.

    About half of the state officials and national education organizations'
    representatives we interviewed reported that states needed more assistance
    on how to implement NCLBA teacher requirements for their special education
    teachers. For example, some state officials from Oklahoma and South Dakota
    reported being uncertain how to apply the requirements to the unique
    situations in which special education teachers provide instruction.
    Officials in these states reported that they were unclear whether a
    teacher providing instruction in core academic subjects to high school age
    students who are performing at the elementary level would need to meet
    elementary or high school level subject competency requirements (See table
    1 for examples of the application of NCLBA requirements to special
    educators' instructional roles).12

    12Students with disabilities generally attend school with other students
    of similar ages. As a result, a high school-aged student with a disability
    would generally receive instruction with other high school-aged students
    in general education or separate classrooms. In addition, students with
    disabilities receive their instruction based upon their individuals needs.
    This instruction may be presented either at or below the student's
    chronological age grade level as required by the student's IEP.

    Table 1: Application of the NCLBA Teacher Quality Requirements to Special
    Educators' Instructional Roles

    NCLBA requirements special education Nature of work Examples of associated
    roles teachers must meet

    Providing instruction Providing instruction to      (1) Bachelor's degree
        to students in core  special education
                             students, e.g., teachers in         (2) State
         academic subjects   self-contained classrooms and     certification
                             some resource room
                                                            (3) Demonstration of
                                       teachers                subject matter
                                                               competency in each
                                                            core academic subject
                                                                  taught.
                                                             (Elementary school
                                                             teachers must only
                                                              demonstrate subject
                                                             matter competency in
                                                             general elementary
                                                            school curriculum.)

    All other special education          Resource room teachers who    None
    instruction                          reinforce
                                            instruction provided by other
                                            highly
                                            qualified teachers
                                            Teachers that consult with a
                                            highly
                                            qualified general education
                                            teacher to
                                            assist students in one grade

    Source: GAO analysis of NCLBA requirements.

    Officials from half the states we surveyed indicated that they did not
    believe the law provided enough flexibility for teachers to meet the
    subject competency requirements. A few state officials we interviewed,
    particularly those with a large percentage of rural districts, such as
    those in South Dakota and Arkansas, mentioned this perceived lack of
    flexibility as a key concern. In particular, these officials indicated
    that because their special education teachers often teach multiple
    subjects, they would have to attain multiple degrees or pass several
    subject matter tests to meet the subject matter competency requirement.
    Recent Education guidance issued after this survey was concluded gives
    states more time to help all teachers, including special education
    teachers who teach core academic subjects, in small, rural school
    districts, meet the requirements. Under this new guidance, teachers in
    eligible rural school districts, who are highly qualified in at least one
    subject, will have 3 years to become highly qualified in the additional
    subjects they teach.

    State officials reported concerns about their states' ability to meet the
    federal timelines for implementing the NCLBA teacher requirements for
    special education teachers. Officials from 32 states reported that the
    time frames were not feasible for implementing the requirements. This
    included 15 states that had established subject matter competency
    requirements for their special education certification. However, depending
    on the specific state certification requirements, teachers in these states
    may still be required to do additional work to meet the subject matter
    competency

    requirements of NCLBA. In addition, some state officials reported that
    their states were not positioned to meet federal deadlines because some
    institutions of higher education had not aligned their programs with NCLBA
    requirements. For example, officials in 31 states reported that that
    current special education teacher preparation programs hindered
    implementation of NCLBA requirements, primarily because these programs did
    not emphasize majors or concentrations in core academic subjects. Given
    these conditions, state officials, in 3 of the 6 states we visited,
    reported the need for additional assistance in identifying strategies to
    meet the timelines for meeting requirements. Education also noted that the
    challenge facing states is developing new mechanisms to make sure that all
    teachers of core academic subjects are able to demonstrate appropriate
    subject matter mastery.

    Some state officials and national education organizations' leaders also
    cited concerns that special education teachers currently teaching might
    leave the field rather than take exams or return to school to take the
    courses needed to demonstrate subject matter competency. Thirty-two survey
    respondents expressed concern that the potential flight of special
    education teachers would hinder efforts to implement the requirements.

    Finally, state education officials reported uncertainty over how to
    reconcile requirements of the two laws that appear to be inconsistent and
    thus could impede implementation of NCLBA. These officials reported that
    they were unsure as to which act-IDEA or NCLBA-should take precedence in
    establishing personnel requirements for special education teachers. For
    example, under IDEA, a student's IEP could require that he be taught
    mathematics at a functional level 3 years below his chronological age, and
    under IDEA a certified special education teacher would be qualified to
    provide this instruction. However, under NCLBA, a teacher might not be
    qualified to instruct this student without first demonstrating subject
    matter competency in mathematics. According to Education officials, the
    requirements would depend in part on the assessment level of the students
    being taught. At the same time, Education officials noted that NCLBA
    teacher requirements apply to all teachers, including special education
    teachers. As a result of this uncertainty, some of the state special
    education officials we interviewed and surveyed said that they had decided
    to wait for further guidance or assistance before beginning to implement
    any NCLBA requirements for special education teachers. Education officials
    reported that they were aware that some states had expressed uncertainty
    about how to implement NCLBA's teacher requirements. Moreover, Education
    officials noted that states that wait for further guidance could hinder
    their special education teachers'

    ability to meet the subject matter competency requirements by the end of
    the 2005-2006 school year.

      Coordination among Education's Offices Responsible for Educating Students with
      Disabilities Was Limited

    Education has provided a range of assistance, such as site visits, Web
    based guidance, and financial assistance, to help states implement the
    highly qualified teacher requirements. However, department coordination
    related to the implementation of NCLBA's teacher requirements for special
    education teachers has been limited. OESE has taken the lead in providing
    this guidance, with support from offices such as the Office of General
    Counsel and the Office of the Secretary. OSEP played a limited role in
    these efforts. Further, departmental coordination among Education's
    offices was limited with respect to OSEP's involvement in other key
    teacher quality initiatives. Because of this, Education may not have been
    in a position to be fully apprised of how special education concerns could
    affect implementation of the NCLBA teacher requirements. However,
    Education officials told us that they included OSEP by contacting OSEP
    staff to clarify IDEA substantive issues. Further, Education officials
    told us they have recently added OSEP to the department's teacher quality
    policy team. However, Education currently does not have plans to develop
    written policies and procedures for coordination among its offices.

        Education Provided Assistance to States in Implementing the NCLBA Teacher
        Requirements

    According to Education officials, OESE took the lead in providing
    assistance to states concerning the NCLBA teacher requirements, with some
    support provided by offices including OSEP, the Office of the Secretary,
    the Office of the Undersecretary, the Assistant Secretary of Elementary
    and Secondary Education, and the Office of General Counsel. One of OESE's
    key efforts to provide technical assistance to states was the Teacher
    Assistance Corps initiative, which sent teams of experts to states to
    provide clarification and guidance on implementing NCLBA teacher
    requirements. According to Education, these teams have been responsible
    for sharing promising strategies, providing advice on compliance issues,
    and assisting state officials in setting and meeting teacher quality
    goals. The teams have also gathered feedback from states on their concerns
    about implementing the teacher requirements. Team members have included
    lead officials from OESE and general counsel, individuals with expertise
    on issues of concern to particular states, higher education
    representatives, and education officials from that state. Education
    officials told us that OSEP staff did not participate in these visits, but
    two state officials with expertise in special education participated in
    some visits.

    OESE also offered states other types of assistance. OESE created a teacher
    quality newsletter, and the Office of the Under Secretary created and then
    updated the No Child Left Behind Toolkit for Teachers booklet, to help
    teachers understand the law in general, the highly qualified teacher
    requirements, and to explain which teachers need to meet the NCLBA
    requirements. However, while the tool kit provided detailed information
    pertaining to general education teachers, it provided limited information
    for special education teachers. According to OESE officials, the office
    had also been developing a Web site on promising practices for
    implementing the NCLBA teacher quality requirements and had plans to
    feature special education on the site. However, at the time of our
    interviews, OESE did not have a timeline for when this Web site would be
    available. Finally, OESE also provided financial assistance to states
    through Improving Teacher Quality state grants; states could use this
    financial assistance to help special education teachers meet NCLBA teacher
    requirements.

        Education's Internal Coordination on Special Education Teacher Qualification
        Issues Was Limited

    The enactment of NCLBA significantly changed the expectations for all
    students and their teachers in the nation's schools and increased the need
    for OESE and OSEP to coordinate their efforts. NCLBA covers to a greater
    extent than did previous educational legislation the groups that have
    historically been the primary responsibility of OSEP-students with
    disabilities and their teachers. Moreover, NCLBA established
    qualifications for all teachers, including special education teachers, who
    provide instruction in core academic subjects such as English, language
    arts, mathematics, and science.

    As state education officials began implementing NCLBA subject matter
    competency requirements, they sought guidance from OSEP, their primary
    source of information on special education issues. However, OSEP officials
    told us that they had generally referred these officials to OESE or to the
    NCLBA Web site. OSEP officials told us that they were waiting until IDEA
    is reauthorized to develop their own guidance on special education teacher
    quality requirements. However, during this time NCLBA requirements applied
    to special educators teaching core academic subjects, and several state
    officials told us they needed clarification of the guidance on these
    requirements.

    Coordination between OSEP and OESE has generally been limited. For
    example, OSEP commented on the teacher quality policies and initiatives
    that OESE developed, but generally was not involved in the initial
    development of these policies. Education officials told us that OSEP was
    included in the implementation of the teacher requirements, noting that

    they contacted this office to clarify IDEA substantive issues and that
    OSEP officials reviewed NCLBA guidance. OSEP did not participate in OESE's
    Teacher Assistance Corps visits to states and generally was not involved
    in the analysis of the information that was collected from these visits.
    OESE officials told us that they did not believe that states would benefit
    from OSEP's participation in these visits, because the focus of the visits
    was on meeting the NCLBA requirements, not IDEA requirements. In addition,
    Education told us that there were no written policies or procedures to
    assist OESE and OSEP in coordinating the development and implementation of
    its teacher quality policies for special education teachers. Finally,
    these officials did not indicate that Education was planning to develop
    such policies.

    In March 2003, Education formed a teacher quality policy team under the
    auspices of the Office of the Under Secretary and included other key
    offices in Education such as the Office of the Secretary, the Office of
    General Counsel, and OESE. This team, run by OESE, has focused on NCLBA
    implementation related to teacher qualifications, and special education
    teacher issues have been among the topics most frequently discussed. OSEP
    was not a member of this team until April 2004, when Education officials
    told us that OSEP had become a part of the team.

    NCLBA is a complex law with new requirements that hold states, districts,
    and schools accountable for ensuring that their teachers meet specific
    qualifications. Further, the law applies to all teachers, including
    special education teachers, resulting in states and districts having to
    reassess how they certify and assign special education teachers, as well
    as provide professional development geared toward helping teachers meet
    requirements.

    State officials reported the need for assistance on how to meet NCLBA
    requirements, with Education also noting the need for states to have more
    information on strategies to meet requirements. Because half of the states
    do not have subject matter competency requirements as part of special
    education certification, these states in particular are challenged with
    developing strategies to help their teachers meet NCLBA requirements.
    Without additional assistance on such strategies, special education
    teachers may not be positioned to meet requirements by the end of 2005
    2006 school year. In addition, several state education officials cited the
    need for additional clarification on the application of the NCLBA subject
    matter competency requirement to special education teachers in special
    circumstances, for example those providing instruction to high school age

      Conclusions

    students who are performing at the elementary level. Without additional
    assistance from Education to resolve state concerns related to special
    education teacher qualification issues, some states might not be able to
    determine how to focus their resources to ensure that their teachers meet
    the act's requirements.

    NCLBA covers to a greater extent than did previous elementary and
    secondary education acts the groups that have historically been the
    primary responsibility of OSEP-students with disabilities and their
    teachers. OESE has assumed primary responsibility for implementing NCLBA,
    including provisions applying to special education teachers. OESE has
    generally not relied on OSEP staff or information produced by OSEP to
    develop policy or guidance. Consequently, OESE may not have fully
    benefited from OSEP's expertise to inform its NCLBA discussions on
    policies and guidance related to special education teacher issues and
    requirements. Although Education has recently added OSEP to its NCLBA
    teacher quality policy team, overall NCLBA coordination efforts among
    Education offices have not been formalized in writing to ensure
    appropriate and continuing involvement of these offices. As a result, the
    department may not fully address states' needs for information and
    assistance on the implementation of NCLBA requirements for special
    education teachers.

    To better address states' concerns about their special education teachers
    being positioned to meet NCLBA teacher requirements, we recommend that the
    Secretary of Education provide additional assistance to states on
    strategies to meet the requirements and clarification of subject matter
    competency requirements for special education teachers.

    To continue to improve policy development and technical assistance that
    Education's offices provide to states on NCLBA requirements, we recommend
    that Education formalize in writing coordination efforts between OESE and
    OSEP. For example, such efforts could include defining how OSEP's
    expertise and staff would be involved in developing NCLBA policies and
    guidance related to special education teachers and in providing technical
    assistance to states.

    We provided a draft of this report to Education for review and comment. In
    their comments, Education officials noted that they believed their
    guidance was clear but recognized that states were still struggling to
    identify strategies to meet requirements. Education officials provided new

      Recommendations for Executive Action

    Agency Comments and Our Evaluation

    information in their comments on the draft that indicated improved
    coordination among those Education offices that are involved in NCLBA
    policy development and guidance. Consequently, we modified the report on
    both these topics to reflect Educations' comments. Education officials
    also provided technical comments that we incorporated into the report
    where appropriate. Education's comments are reproduced in appendix II.

    Given the difficulties states are experiencing in implementing the law and
    the level of uncertainty reported by state officials, we believe that
    additional assistance needs to be provided by Education to help states
    implement the requirements. In Education's comments, the department noted
    that states were having difficulty implementing NCLBA teacher
    requirements. Education officials highlighted assistance they provided and
    their willingness to provide additional technical assistance, depending on
    what states need. We believe Education could help states by identifying
    strategies to help states meet requirements, especially those states
    without subject matter competency requirements for their special education
    teachers. In addition, Education noted in its comments that guidance on
    how to apply the NCLBA subject matter competency requirement for special
    education teachers instructing high school age students functioning at
    elementary school levels was not different from guidance for all teachers.
    However, Education officials have also said that the assessment level of a
    student could be considered in determining how to apply the NCLBA teacher
    requirements. We encourage Education to provide assistance to explain the
    requirements, particularly as they relate to unusual circumstances
    involving varying student assessment levels. We have modified the report
    to reflect Education's comments.

    We continue to believe that improved coordination is needed. However, we
    modified the report to reflect Education's recent addition of OSEP to its
    teacher quality policy team. We acknowledge Education's effort in this
    regard and encourage the department to formalize its coordination policies
    by putting them in writing. We believe that formalizing coordination
    efforts will ensure that the different offices continue to be involved in
    developing NCLBA policies and guidance related to special education
    teachers.

    Copies of this report are being sent to the Secretary of Education,
    relevant congressional committees, and other interested parties. We will
    also make copies available to others upon request. In addition, the report
    will be made available at no charge on GAO's Web site at
    http://www.gao.gov.

    Please contact me on (202) 512-7215 if you or your staff have any
    questions about this report. Other contacts and major contributors are
    listed in appendix III.

    Sincerely yours,

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

    Appendix I: Thirty-One States with Alternative Routes to Certification in
    Special Education during the 2002-2003 School Year

    State alternative route to certification in special State education
    contact information

    Alabama 	Director Teacher Education and Certification Alabama Department
    of Education Post Office Box 302101 Montgomery, AL 36104 Phone: (334)
    242-9560 Fax: (334) 242-0498 Web site: www.alsde.edu

    Arizona 	Deputy Associate Superintendent for Highly Qualified
    Professionals AZ Department of Education 1535 W. Jefferson Street Phoenix,
    AZ 85007-6490 Phone: (602) 364-2294 Fax: (602) 542-1411 Web site:
    www.ade.az.gov/certification

    California 	California Commission on Teacher Credentialing 1900 Capitol
    Avenue Sacramento, CA 95814 Phone: (916) 327-8663 Fax: (916) 324-8927 Web
    site: www.ctc.ca.gov

    Colorado Director Colorado Department of Education 201 E. Colfax Avenue,
    Room 201 Denver, CO 80203 Phone: (303) 866-6932 Fax: (303) 866-6968 Web
    site: www.cde.state.co.us

    Georgia 	Director Educator Preparation Professional Standards Commission
    Two Peachtree, Suite 6000 Atlanta, GA 30303 Phone: (404) 232-2640 Fax:
    (404) 232-2760 Web site: gapsc.com

    Hawaii 	Hawaii Teacher Standards Board 650 Iwilei Road, Suite 201
    Honolulu, HI 96817 Phone: (808) 586-2617 Fax: (808) 585-2606 Web site:
    www.htsb.org

    Appendix I: Thirty-One States with Alternative Routes to Certification in
    Special Education during the 2002-2003 School Year

    State alternative route to certification in special State education
    contact information

    Kentucky Director
    Division of Professional Learning and Assessment
    Education Professional Standards Board
    100 Airport Road
    Third Floor
    Frankfort, KY 40601
    Phone: (502) 564-4606
    Fax: (502) 564-9484
    Web site: www.kyepsb.net

    Louisiana 	Director of Teacher Certification and Higher Education
    Louisiana Department of Education
    1201 North Third Street
    Baton Rouge, LA 70802
    Phone: (225) 342-3562
    Fax: (225) 342-7367
    Web site: http://www/lde/index.html

    Maine 	Education Policy Director
    Maine Department of Education
    23 State House Station
    Augusta, ME 04333
    Phone: (207) 624-6603
    Fax: (207) 624-6604
    Web site: www.state.me.us/education

    Maryland	Director of Quality Teaching
    Maryland State Department of Education
    200 West Baltimore St.
    Baltimore, MD 21201-2595
    Phone: (410) 767-0390
    Fax: (410) 333-8963
    Web site: marylandpublicschools.org/

    Massachusetts	Title II Accountability Team Leader
    Department of Education, Educator Preparation
    350 Main Street
    5th Floor
    Malden, MA 02148
    Phone: (781) 338-3270
    Fax: (781) 338-3396
    Web site: www.doe.mass.edu

    Michigan 	Higher Education Coordinator
    Michigan Department of Education (MDE)
    John A. Hannah Building, 608 West Allegan Street, Lansing,
    MI 48933
    Or P.O. Box 30008
    Lansing, MI 48909
    Phone: (517) 373-1925
    Fax: (517) 373-0542
    Web site: http://www.michigan.gov/mde

    Appendix I: Thirty-One States with Alternative Routes to Certification in
    Special Education during the 2002-2003 School Year

    State alternative route to certification in special State education
    contact information

    Mississippi Director Office of Educator Licensure Mississippi Department
    of Education P. O. Box 771 Jackson, MS 39205-0771 Phone: (601) 359-3483
    Fax: (601) 359-2778 Web site: www.mde.k12.ms.us/license/

    Missouri 	Assistant Director Educator Preparation Department Elementary
    and Secondary Education PO Box 480 Jefferson City, MO 65102 Phone: (573)
    522-2544 Fax: (573) 526-3580 Web site: http://dese.mo.gov/

    Nevada Administrator Nevada Department of Education Office of Teacher
    Education and Licensure 1820 E. Sahara Ave. Suite 205 Las Vegas, NV
    89104-3721 Phone: (702) 486-6496 Fax: (702) 486-6474 Web site:
    www.nde.state.nv.us

    New Hampshire	Administrator Bureau of Credentialing Division of Program
    Support New Hampshire Department of Education 101 Pleasant Street Concord,
    NH 03801 Phone: (603) 271-4196 Fax: (603) 271-8709 Web site:
    ed.state.nh.us

    New Mexico	Director of Professional Licensure New Mexico State Dept. of
    Education Education Building, 300 Don Gaspar Santa Fe, NM 87501-2786
    Phone: (505) 827-6581 Fax: (505) 827-4148 Web site:
    sde.state.nm.us/divisions/ais/licensure/index.html

    New York 	Executive Coordinator New York State Education Department Office
    of Teaching Initiatives 89 Washington Avenue - Room 5N EB Albany, NY 12234
    Phone: (518) 474-4661 Fax: (518) 473-0271 Web site:
    http://www.nysed.gov/tcert

    Appendix I: Thirty-One States with Alternative Routes to Certification in
    Special Education during the 2002-2003 School Year

    State alternative route to certification in special State education
    contact information

    North Carolina	Director Division of Human Resource Management NC
    Department of Public Instruction Mail Service Center 6330 Raleigh, NC
    27699-6330 Phone: (919) 807-3355 Fax: (919) 807-3362 Web site:
    www.ncpublicschools.org

    Ohio 	Office of Educator Preparation Ohio Department of Education 25 S.
    Front St. MS502 Columbus, OH 43215-4183 Phone: (614) 752-9447 Fax: (614)
    728-3058 Web site: www.ode.state.oh.us

    Oklahoma 	Director of Professional Services Oklahoma State Department of
    Education 2500 North Lincoln Boulevard Oklahoma City, OK 73105-4599 Phone:
    (405) 521-2062 Fax: (405) 521-3744 Web site: http://sde.state.ok.us

    Pennsylvania 	Chief Division of Teacher Education Pa. Dept. of Education
    333 Market Street Third Floor Harrisburg, PA 17126 Phone: (717) 783-9252
    Fax: (717) 783-6736 Web site: www.teaching.state.pa.us

    South Carolina 	Title II Coordinator South Carolina Department of
    Education 3700 Forest Drive Columbia, SC 29204 Phone: (803) 734-8944 Fax:
    (803) 734-0872 Web site: http://www.scteachers.org/

    South Dakota	Director of Teacher Education and Certification Department of
    Education 700 Governors Drive Pierre, SD 57501-2291 Phone: (605) 773-4774
    Fax: (605) 773-6139 Web site: www.state.sd.us/deca/account/certif.htm

    Appendix I: Thirty-One States with Alternative Routes to Certification in
    Special Education during the 2002-2003 School Year

    State alternative route to certification in special State education
    contact information

    Tennessee 	Director Office of Teacher Licensing Tennessee State Department
    of Education 5th Floor, Andrew Johnson Tower 710 James Robertson Parkway
    Nashville, TN 37243-0377 Phone: (615) 532-4880 Fax: (615) 532-1448 Web
    site: http://www.tennessee.gov/education/lic_home.htm

    Texas 	Program Administrator State Board for Educator Certification 4616
    W. Howard Lane Suite 120 Austin, TX 78728 Phone: (512) 238-3200 Fax: (512)
    238-3203 Web site: www.sbec.state.tx.us

    Utah 	Utah State Office of Education 250 East 500 South P.O. Box 144200
    Salt Lake City, UT 84114-4200 Phone: (801) 538-7739 Fax: (801) 538-7973
    Web site: www.usoe.org

    Vermont 	Director for Educator Quality Vermont Department of Education 120
    State Street Montpelier, VT 05620 Phone: (802) 828-3850 Fax: (802)
    828-5107 Web site: http://www.state.vt.us/educ

    Virginia 	Director of Teacher Education Virginia Department of Education
    P.O. Box 2120 Richmond, VA 23218-2120 Phone: (804) 692-0251 Fax: (804)
    786-6759 Web site: www.pen.k12.va.us

    West Virginia 	Teacher Preparation Coordinator West Virginia Department of
    Education Building 6, Room 252 1900 Kanawha Blvd. East Charleston, WV
    25305-0330 Phone: (304) 558-2703 Fax: (304) 558-7843 Web site:
    http://wvde.state.wv.us/

    Appendix I: Thirty-One States with Alternative Routes to Certification in
    Special Education during the 2002-2003 School Year

    State alternative route to certification in special State education
    contact information

    Wyoming 	Director Professional Teaching Standards Board 1920 Thomes Ave.
    Suite 400 Cheyenne, WY 82002 Phone: (307) 777-6261 Fax: (307) 777-8718 Web
    site: www.k12.wy.us/ptsb

    Source: GAO analysis of survey responses from the special education
    directors in the 50 states, the District of Columbia, and Puerto Rico, and
    state 2003 Title II reports.

      Appendix II: Comments from the Department of Education

    Appendix II: Comments from the Department of Education

    Appendix II: Comments from the Department of Education

    Appendix II: Comments from the Department of Education

    Appendix II: Comments from the Department of Education

      Appendix III: GAO Contacts and Staff Acknowledgments

    GAO Contacts

        Staff Acknowledgments

    (130286)

    Harriet C. Ganson, (202) 512-7042, gansonh@gao.gov
    Arthur T. Merriam Jr., (617) 788-0541, merriama@gao.gov

    In addition to those named above, Emily Leventhal, Benjamin Howe,
    Ron La Due Lake, Luann Moy, Jean McSween, Bob DeRoy, Bryon Gordon,
    Behn Kelly, and Amy Buck made key contributions to the report.

    GAO's Mission	The Government Accountability Office, the audit, evaluation
    and investigative arm of Congress, exists to support Congress in meeting
    its constitutional responsibilities and to help improve the performance
    and accountability of the federal government for the American people. GAO
    examines the use of public funds; evaluates federal programs and policies;
    and provides analyses, recommendations, and other assistance to help
    Congress make informed oversight, policy, and funding decisions. GAO's
    commitment to good government is reflected in its core values of
    accountability, integrity, and reliability.

    Obtaining Copies of The fastest and easiest way to obtain copies of GAO
    documents at no cost

    is through GAO's Web site (www.gao.gov). Each weekday, GAO postsGAO
    Reports and newly released reports, testimony, and correspondence on its
    Web site. To Testimony have GAO e-mail you a list of newly posted products
    every afternoon, go to

    www.gao.gov and select "Subscribe to Updates."

    Order by Mail or Phone	The first copy of each printed report is free.
    Additional copies are $2 each. A check or money order should be made out
    to the Superintendent of Documents. GAO also accepts VISA and Mastercard.
    Orders for 100 or more copies mailed to a single address are discounted 25
    percent. Orders should be sent to:

    U.S. Government Accountability Office 441 G Street NW, Room LM Washington,
    D.C. 20548

    To order by Phone: 	Voice: (202) 512-6000 TDD: (202) 512-2537 Fax: (202)
    512-6061

          To Report Fraud, Contact:
          Waste, and Abuse in Web site: www.gao.gov/fraudnet/fraudnet.htm