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				 

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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, [email protected].

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	

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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, [email protected]
Arthur T. Merriam Jr., (617) 788-0541, [email protected]

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.

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