    Illegal Alien Schoolchildren: Issues in Estimating State-by-State
    Costs (23-JUN-04, GAO-04-733).

    In 1982 the Supreme Court ruled that states and school districts
    cannot deny education to illegal alien children residing here.
    Issues in estimating the costs of providing education to them are
    of interest because (1) policy discussions concerning illegal
    immigration often focus on cost impacts; (2) potential costs are
    borne mostly at the state and local levels; and (3) the Congress
    could authorize federal reimbursement for benefits provided to
    illegal aliens, based on estimated state costs or numbers of
    illegal aliens. The foreign-born population is growing and is
    concentrated in certain states; the illegal immigrant component
    is thought to be substantial. Concerns about education costs may
    reflect "squeezed" state and local budgets, rising school
    enrollments, and overcrowded schools. To address the potential
    for estimating the costs of educating illegal alien
    schoolchildren, this report (1) identifies major government
    sources of relevant data, (2) describes a Census Bureau plan for
    developing new information, and (3) outlines costestimation
    approaches. GAO provided a draft of this report to the National
    Center for Education Statistics, the Department of Homeland
    Security, and the Census Bureau. The agencies informed GAO they
    had no formal comments.
    -------------------------Indexing Terms-------------------------
    REPORTNUM:   GAO-04-733
        ACCNO:   A10564
      TITLE:     Illegal Alien Schoolchildren: Issues in Estimating
    State-by-State Costs
         DATE:   06/23/2004
      SUBJECT:   Cost analysis
    	     Data collection
    	     Data integrity
    	     Education or training costs
    	     Elementary school students
    	     Illegal aliens
    	     Intergovernmental relations
    	     Population statistics
    	     Projections
    	     Public schools
    	     Secondary school students
    	     State programs
    	     Cost estimates

    ******************************************************************
    ** 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-04-733

    United States General Accounting Office

    GAO	Report to the Chairman, Committee on the Judiciary, House of Representatives

    June 2004

    ILLEGAL ALIEN SCHOOLCHILDREN

                                  Issues in Estimating
                                  State-by-State Costs

    GAO-04-733

    Highlights of GAO-04-733, a report to the Chairman of the Committee on the
    Judiciary, House of Representatives

    In 1982 the Supreme Court ruled that states and school districts cannot
    deny education to illegal alien children residing here. Issues in
    estimating the costs of providing education to them are of interest
    because (1) policy discussions concerning illegal immigration often focus
    on cost impacts; (2) potential costs are borne mostly at the state and
    local levels; and (3) the Congress could authorize federal reimbursement
    for benefits provided to illegal aliens, based on estimated state costs or
    numbers of illegal aliens.

    The foreign-born population is growing and is concentrated in certain
    states; the illegal immigrant component is thought to be substantial.
    Concerns about education costs may reflect "squeezed" state and local
    budgets, rising school enrollments, and overcrowded schools.

    To address the potential for estimating the costs of educating illegal
    alien schoolchildren, this report (1) identifies major government sources
    of relevant data, (2) describes a Census Bureau plan for developing new
    information, and (3) outlines costestimation approaches.

    GAO provided a draft of this report to the National Center for Education
    Statistics, the Department of Homeland Security, and the Census Bureau.
    The agencies informed GAO they had no formal comments.

    www.gao.gov/cgi-bin/getrpt?GAO-04-733.

    To view the full product, including the scope and methodology, click on
    the link above. For more information, contact Nancy Kingsbury at (202)
    512-2700 or kingsburyn@gao.gov.

    June 2004

    ILLEGAL ALIEN SCHOOLCHILDREN

    Issues in Estimating State-by-State Costs

    Current government information is not sufficient to directly estimate the
    stateby-state costs of educating illegal alien schoolchildren. Although a
    variety of data are available, no government source estimates the numbers
    of illegal alien schoolchildren for most or all states. Specifically:

    o  	States and local areas record data on school enrollment and costs but
    not on immigration status. In response to GAO's survey, a few states
    estimated costs of educating illegal alien children, based partly on
    assumptions.

    o  	The National Center for Education Statistics (NCES) maintains
    enrollment and cost data-but has no information on immigration status.

    o  	The Department of Homeland Security (DHS) developed state-by-state
    estimates of the illegal alien population, but the estimates do not break
    out age groups and are subject to methodological limitations.

    The Census Bureau is developing a plan to estimate the size of the
    resident illegal alien population, indirectly by age group and state. This
    new information might help in developing state-by-state estimates of the
    number of school-age illegal alien children. However, the plan does not
    specify the age groups to be estimated, faces technical challenges, and
    depends upon future funding. Overall, it is too early to evaluate the
    Census Bureau's plan.

    The simplest approach to estimating the costs of educating illegal alien
    children is to multiply average current per pupil expenditures by the
    estimated number of illegal alien schoolchildren separately for each state
    (see fig.). At present, government information is insufficient for
    developing reliable estimates based on this approach. If the Census
    Bureau's plan proves successful, relevant data would be available by
    2007-09. Taking account of cost determinants such as variation in local
    area expenditures, student needs, and school capacity requires additional
    data.

    Simplest Approach to State-by-State Cost Estimation

    Sources: GAO (analysis), NCES (per pupil expenditure data), Census Bureau
    (estimation plans), U.S. Department of Education (photo).

    Contents

    Letter                                                                   1
                                      Results in Brief                          2
                                         Background                             3
                             Objectives, Scope, and Methodology                10
                         Currently Available Government Information            12
               The Census Bureau's Plans for Estimating Illegal Immigrants Are
                                         Preliminary                           18
                                Approaches to Cost Estimation                  21
                                        Observations                           28
                                       Agency Comments                         28

      Table

    Table 1: Cost Categories Relevant to the School-Capacity Approach

      Figures

    Figure 1: Total Foreign-Born Population (Legal and Illegal) in Key States,
    1990 and 2000 7 Figure 2: Simplest State-by-State Estimation Approach 22

    Abbreviations

    ACS American Community Survey
    CPS Current Population Survey
    DHS Department of Homeland Security
    ELL English language learner
    INS Immigration and Naturalization Service
    NCES National Center for Education Statistics
    TPS temporary protected status

    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 General Accounting Office Washington, DC 20548

    June 21, 2004

    The Honorable F. James Sensenbrenner, Jr.
    Chairman
    Committee on the Judiciary
    House of Representatives

    Dear Mr. Chairman:

    Reliable data are needed to support policy decisions in the area of
    illegal
    immigration, but such data have often been lacking or inadequate.1 In this
    report, we respond to your request that we examine the potential for
    estimating state-by-state costs of public schooling for illegal alien
    children,
    based on government information.2

    As you know, the U.S. Supreme Court has ruled that states and school
    districts cannot deny K-12 education to resident children who are illegal
    aliens. Government estimates of the state-by-state costs of educating them
    would, however, be policy relevant for a number of reasons, such as the
    potential for federal reimbursement to states.

    Because government estimates are not available at present, in this report
    we (1) identify currently available government information, (2) describe
    the Census Bureau's plan for developing new information, and (3) outline
    possible approaches to estimating costs and, for each approach, briefly
    assess whether needed information is currently available or planned.

    GAO collected relevant information through a survey of 20 states, did
    outreach through associations of governors and mayors, conducted

    1See U.S. Commission on Immigration Reform, Becoming an American:
    Immigration and Immigrant Policy (Washington, D.C.: Government Printing
    Office, 1997), pp. 194-98. We pointed to this issue in U.S. General
    Accounting Office, Immigration Statistics: Information Gaps, Quality
    Issues Limit Utility of Federal Data to Policymakers, GAO/GGD-98-164
    (Washington, D.C., July 31, 1998), pp. 12-13 and 22-24.

    2According to data from the National Center for Education Statistics
    (NCES), the proportion of students in private elementary and secondary
    schools has changed little over the past 10 years, remaining around 11
    percent; we do not include or discuss expenditures by private schools in
    this report.

      Results in Brief

    interviews at federal agencies, performed a literature review, and
    consulted with experts.

    Overall, our review indicates that at present, government information is
    not sufficient for directly estimating the state-by-state costs of
    providing public schooling to illegal alien children. Specifically:

    o  	Government data include a variety of information on school
    expenditures and on the foreign-born population. However, estimates of the
    numbers of illegal alien schoolchildren, by state, are lacking.

    o  	The Census Bureau has outlined a preliminary plan to develop indirect
    state-by-state estimates of the resident illegal alien population by age.
    Such estimates could help determine the number of schoolchildren in that
    population. But even if age-group estimates are successfully developed,
    they would not be available before 2007-09.

    o  	Approaches to state-by-state cost estimation differ in the extent to
    which they attempt to account for various factors that can affect costs,
    but all approaches require data on or estimates of the number of illegal
    alien schoolchildren in each state.

    State governments and school districts routinely record school enrollments
    and dollar expenditures. Although a few states responded to our survey
    with estimates of the costs of educating illegal alien children, none
    actually collect data on children's immigration status.

    At the federal level, the National Center for Education Statistics (NCES)
    centrally maintains data on school enrollment and expenditures, as well as
    certain other information. (For example, NCES has collected data on school
    overcrowding for a sample of areas.) But like the states and school
    districts, NCES has no data on the immigration status of schoolchildren.

    The Census Bureau collects citizenship data on foreign-born U.S.
    residents, including children, but does not ask further questions about
    immigration status.

    The Department of Homeland Security (DHS) has developed indirect
    stateby-state estimates of the size of the resident illegal population,
    but these

    estimates do not break out age groups; the DHS estimates are subject to
    methodological limitations as well.3

    The Census Bureau has outlined a plan for research to develop age-group
    estimates for the resident illegal immigrant population, by geographic
    divisions (states and selected counties), with trends across time. It is
    too early to judge the quality of this plan, but if it is successfully
    implemented, it could help quantify the school-age portion of the resident
    illegal alien population. The Census Bureau also suggested that other
    government agencies might expand on its planned population estimates-for
    example, by developing further estimates on the extent to which illegal
    alien children attend public schools or require special programs.

    The simplest approach to estimating state-by-state costs multiplies
    current average per pupil expenditures for each state by an estimate of
    the number of illegal alien children attending school in that state. Other
    approaches take account of potentially key cost factors, including cost
    variations across local areas within a state and higher costs for students
    needing special programs, such as English Language Learner (ELL)
    programs.4 Yet another approach assesses the role of enrollment growth,
    school capacity, and "incremental costs."5 All these approaches require
    estimates of numbers of illegal alien schoolchildren by state.

    We provided a draft of this report to the Census Bureau, DHS, and NCES.
    The agencies informed us that they had no formal comments, but we received
    informal comments from the Census Bureau and NCES on minor technical
    points and made changes in the report as appropriate.

    Background 	In 1982, the U.S. Supreme Court ruled that it would be
    unconstitutional for any state or school district to deny K-12 education
    to a child residing in that state or school district on the basis of the
    child's being an illegal

    3DHS estimates use decennial census data on the foreign-born population
    and administrative data on legal immigrants, among other sources. These
    estimates are termed "indirect" because information on the illegal
    immigrant population is not directly collected; instead, a variety of
    other estimates (some marked by uncertainty) are combined to project
    state-by-state figures for this population.

    4The term English language learner is defined in the Background section of
    this report (see

    p. 10).

    5Theoretically, in schools or classes with excess capacity, enrollment
    growth might not cause overcrowding, and incremental per pupil costs might
    be lower than average per pupil costs. Otherwise, the opposite would hold
    true.

    alien.6 Nevertheless, issues in estimating the state-by-state costs of
    educating illegal alien children are policy relevant because

    1. 	concern about cost impacts is often among the issues raised in debates
    and discussions about immigration policy,7

    2. 	illegal alien schoolchildren represent a potential cost component that
    is particularly relevant to states and local areas because they bear most
    of the costs of educating illegal alien schoolchildren,8 and

    3. 	the Congress could authorize federal reimbursement of the costs of
    providing K-12 education to illegal alien children, based on the
    stateby-state costs of educating them or on the estimated numbers residing
    in each state.9

    The following sections provide background on (1) issues that have
    heightened concern about the costs of educating illegal alien
    schoolchildren; (2) variation in education expenditures-and immigration
    levels-across states and local areas; and (3) other factors that may
    contribute to cost variation.

    Concern about Costs May Concern about the costs of illegal alien
    schoolchildren may be heightened

    Be Heightened 	because education costs are high and the illegal immigrant
    population is thought to be large.

    According to NCES, for the 1999-2000 school year, current expenditures by
    primary and secondary public schools-not including capital outlays-

    6See Plyler v. Doe, 457 U.S. 202 (1982).

    7U.S. Commission on Immigration Reform, U.S. Immigration Policy: Restoring
    Credibility. (Washington, D.C.: Government Printing Office, 1994), pp.
    109-43.

    8U.S. Commission on Immigration Reform, U.S. Immigration Policy: Restoring
    Credibility, pp. 143-52.

    9Such reimbursement was recently enacted for emergency health benefits.
    The Medicare Prescription Drug, Improvement, and Modernization Act of
    2003, Public Law 108-173 (Dec. 8, 2003), S:1011, Federal Reimbursement of
    Emergency Health Services Furnished to Undocumented Aliens, specifies that
    annually, from 2005 through 2008, $167 million will be distributed among
    the states, based on the estimated percentage of undocumented aliens
    residing in each state. Also see U.S. General Accounting Office,
    Undocumented Aliens: Questions Persist about Their Impact on Hospitals'
    Uncompensated Care Costs.

    GAO-04-472 (Washington, D.C.: May 21, 2004).

    totaled about $324 billion. Capital outlays in that school year-for
    facilities acquisition and construction-were an additional $35 billion.10
    These costs were borne primarily at state and local levels; federal
    dollars represented about 7 percent of school revenue.11

    The Immigration and Naturalization Service (INS) estimated that the
    illegal immigrant population increased to 7 million as of January 2000.12
    However, there is no government estimate of the percentage of the illegal
    alien population that is of school age or that is now attending public
    school in grades K-12.

    Some possibly related reasons for concern about costs include the
    following:

    o  	Many state and local budgets are squeezed, and education costs
    represent their largest expenditure item.13

    10An additional $22 billion was spent on other categories and programs,
    some not part of K12 education. "Current expenditures," as used in the
    NCES finance surveys, means current expenditures for public elementary and
    secondary education-not including capital outlays. Current expenditures
    include instruction expenditures and expenditures for other functions that
    support public elementary and secondary education, such as school support
    (guidance counselors, nurses), instructional support (libraries, teacher
    training), administration, student transportation, and food services.
    School districts also spend money on functions that fall outside of public
    elementary and secondary education, such as adult education, community
    services, and support for private education. NCES collects and tracks
    these expenditures separately.

    11Local dollars represented 43 percent of total school revenues and state
    dollars 50 percent. National Center for Education Statistics, Statistics
    in Brief (Washington, D.C.: May 2002),

    p. 1. More recently, the No Child Left Behind Act of 2001 (Public Law
    107-110, Jan. 8, 2002) may have increased the federal share slightly, at
    least in some states. Notably, title III specifies a formula grant
    program, based on estimated state-by-state distributions of children who
    have limited English proficiency and are recent immigrants.

    12U.S. Immigration and Naturalization Service, Office of Policy and
    Planning, "Estimates of the Unauthorized Immigrant Population Residing in
    the United States: 1990-2000," Washington, D.C., January 2003. (On March
    1, 2003, INS was transferred from the Department of Justice to DHS.) We
    discuss the 7 million estimate in a later section of this report; for a
    fuller discussion, see U.S. General Accounting Office, Overstay Tracking:
    A Key Component of Homeland Security and a Layered Defense, GAO-04-82
    (Washington, D.C.: May 21, 2004), app. III.

    13See Elizabeth McNichol and Makeda Harris ("Many States Cut Budgets as
    Fiscal Squeeze Continues," Center on Budget and Policy Priorities,
    Washington, D.C., 2004), who state that "the amount of state education
    spending included in proposed fiscal year 2005 budgets in a number of
    states-including California . . . [and] New York . . . falls short of the
    amount needed to maintain current-law funding levels or restore cuts made
    over the last few years."

    o  	School enrollments are rising. From 1990 to 2000, school enrollments
    rose about 15 percent-with steeper rises in states like Nevada (with an
    increase close to 70 percent), Arizona and Florida (each with an increase
    greater than 30 percent), and California, Colorado, and Georgia (each with
    an increase of about 25 percent).

    o  	Despite a 1990s boom in school construction, one in five schools were
    overcrowded in 1999, rising to one in three for schools in western
    states.14

        Immigration Levels and Education Costs Vary across Areas

    It is likely that the costs of educating illegal alien children vary
    across states and local areas because (1) immigration (including
    foreign-born persons residing here legally and illegally) is heavily
    concentrated in certain areas and (2) per pupil school expenditures vary
    by state and school district.

    As shown in figure 1, between 1990 and 2000 foreign-born populations
    increased in the top 5 traditional destination states-California, Florida,
    Illinois, New York, and Texas. As of 2000, the foreign-born represented 12
    to 26 percent of these states' populations. (Illegal immigration may
    follow similar patterns; for example, INS estimated that as of January
    2000, 2 million illegal immigrants resided in California, 1 million in
    Texas, and nearly  1/2 million in New York.) Also, as illustrated in
    figure 1, certain smaller states (with somewhat lower concentrations of
    immigrants-for example, Georgia, Nevada, and North Carolina have 5 to 16
    percent foreign born) have recently experienced growth in their
    foreign-born populations.

    14U.S. General Accounting Office, School Facilities: Construction
    Expenditures Have Grown Significantly in Recent Years, GAO/HEHS-00-41
    (Washington, D.C.: Mar. 3, 2000),

    p. 7, and National Center for Education Statistics, The Condition of
    Education 2001: Indicator 45, Overcrowding in Schools, NCES-2001-072
    (Washington, D.C.: U.S. Government Printing Office, 2001), p. 72. NCES
    defined overcrowding as enrollment more than 5 percent above the
    facility's initial capacity. About half of all schools were operating at
    less than capacity.

    Figure 1: Total Foreign-Born Population (Legal and Illegal) in Key States,
    1990 and 2000

    Million 9 8 7 6 5 4 3 2 1 0

     Traditional destination states of foreign-born population States with highest
                    percentage of growth in foreign-born population

                              1990 foreign-born population

                              2000 foreign-born population

    Source: Census Bureau.

    Note: Data or estimates for illegal aliens are not available from the
    Census Bureau. Other state-bystate estimates of illegal aliens are not
    included because of data reliability concerns.

    States with at least 10 percent foreign born as of 2000 that are not shown
    in figure 1 include Arizona, Hawaii, New Jersey, and Rhode Island. In
    contrast, states such as Mississippi, Montana, North Dakota, South Dakota,
    and West Virginia had 2 percent or less foreign born.

    Per pupil school expenditures also vary by state. To illustrate this for
    selected states, in the 1999-2000 school year, current per pupil
    expenditures (exclusive of capital outlays) averaged about

    o  $10,000 in New York and New Jersey

    o  $8,000 in Michigan and Wisconsin

    o  $7,000 in Illinois, Indiana, and Virginia

    o  $6,000 in California, Florida, Georgia, Nevada, and North Carolina

    o  $5,000 in Arizona and Arkansas

    o  $4,000 in Utah15

    Local areas can also vary in terms of both immigration concentration and
    per pupil expenditures, despite equalization rules and programs in some
    states.16

    Two California areas serve as illustration.17 Current per pupil
    expenditures in Pasadena Unified School District (near Los Angeles)
    averaged about $7,000 for the 1999-2000 school year; about 24 percent of
    the population in Pasadena City is foreign born. In contrast, current per
    pupil expenditures in Fairfield-Suisun School District averaged about
    $5,000; this school district is the largest in Solano County (located
    between San Francisco and Sacramento), in which about 17 percent of
    residents are foreign-born. A variety of factors affect local-area costs.
    For example, among other determinants, teacher salaries may vary according
    to the cost of living in different areas of a state.

    Other Factors Are Related Other factors that add to the complexity of
    fully accounting for variation

    to Costs 	in education costs include variation in student needs and school
    capacity. Even within a single school district, costs can vary among
    individual students. That is, expenditures are higher for students who
    live in poverty

    15Table 167, Total and Current Expenditures Per Pupil in Fall Enrollment
    in Public and Secondary Public Education, by Function and State:
    1999-2000. NCES Digest of Education Statistics, List of Tables and Figures
    for 2002, ch. 2, Elementary and Secondary Education, Revenues and
    Expenditures. http://www.nces.ed.gov/programs/digest/ (May 16, 2004).
    Note: Excludes capital expenditures. We report costs for the 1999-2000
    school year for consistency with decennial census data. The most recent
    cost data available from NCES indicate that by 2001-02, per pupil
    expenditures had increased by an average of $765 for these states as a
    group.

    16In 1971, the California Supreme Court ruled in Serrano v. Priest, 487
    P.2d 1241 (Cal. 1971), that equalization of revenue should be required
    across school districts. Various other states also have equalization
    programs. For a summary of "persistent challenges" to fiscal equity or
    adequacy, and a list of relevant studies, see Margaret Hadderman, "Equity
    and Adequacy in Educational Finance." ERIC Digest.
    http://www.ericdigests.org/20021/equity.html (May 19, 2004).

    17Table 91, Revenues and Expenditures of Public School Districts Enrolling
    More Than 15,000 Pupils, by State: 1999-2000. NCES Digest of Education
    Statistics, List of Tables and Figures for 2002, ch. 2, Elementary and
    Secondary Education, Schools and School Districts.
    http://www.nces.ed.gov/programs/digest/ (May 17, 2004).

    or who have limited English proficiency, if schools attempt to meet these
    needs (for example, with English Language Learner or ELL programs).

    According to the Education Alliance at Brown University, ELL indicates

    a person who is in the process of acquiring English and has a first
    language other than English. Other terms commonly found in the literature
    include language minority students, limited English proficiency (LEP),
    English as a second language (ESL) and culturally and linguistically
    diverse (CLD).18

    In 2000-2001, some school districts enrolled high percentages of students
    in various ELL programs. More than 40 percent of Los Angeles students and
    about 33 percent of Dallas students are enrolled in ELL programs; of
    course, not all students enrolled in these programs are foreign-born.19

    The costs of meeting the needs of such students have been variously
    estimated. Bringing ELL-enrolled children up to the grade level of sameage
    non-ELL-enrolled children has been estimated to potentially increase costs
    by an additional 10 to 100 percent over usual per pupil costs; for
    students living in poverty (independent of ELL programs), the
    corresponding range of estimates is 20 to 100 percent.20 Bringing students

    18See the Education Alliance at Brown University,
    http://www.lab.brown.edu/tdl/ell.shtml (May 20, 2004). NCES describes ELL
    students as "born outside of the United States with a native language
    other than English; or . . . from environments where the language is
    predominantly non-English; or . . . American Indians and Alaska Natives
    whose level of English proficiency may have been affected by a non-English
    environment resulting in difficulty speaking, reading, writing, or
    understanding the English language." NCES notes that ELL students were
    "formerly known as Limited-English-Proficient (LEP)." See National Center
    for Education Statistics, Instructions for Completing the Nonfiscal
    Surveys of the Common Core of Data: School Universe Survey, Agency Use
    Survey, State Nonfiscal Survey, 2003-2004 (Washington, D.C.: U.S.
    Department of Education, OMB No. 1850-0067, expires Nov. 30, 2004), p. 94.

    19See Beth Antunez, English Language Learners in the Great City Schools:
    Survey Results on Students, Languages, and Programs (Washington, D.C.:
    Council of Great City Schools, March 2003).

    20See U.S. General Accounting Office, School Finance: Per-Pupil Spending
    Differences between Selected Inner City and Suburban Schools Varied by
    Metropolitan Area, GAO-03-234 (Washington, D.C.: Dec. 9, 2002), pp. 5-6;
    William Duncombe, Anna Lukemeyer, and John Yinger, "Financing an Adequate
    Education: A Case Study of New York," in William J. Fowler, ed.,
    Developments in School Finance: 2001-02 (Washington, D.C.: National Center
    for Education Statistics, 2003); and U.S. General Accounting Office,

    Bureau of Indian Affairs Schools: Expenditures in Selected Schools Are
    Comparable to Similar Public Schools, but Data Are Insufficient to Judge
    Adequacy of Funding and Formulas, GAO-03-955 (Washington, D.C.: Sept. 4,
    2003), p. 39.

      Objectives, Scope,
      and Methodology

    characterized by both poverty and limited English proficiency up to
    average levels of achievement could potentially increase average costs by
    a larger amount-perhaps 30 to 200 percent over average per pupil costs.

    School capacity to absorb new students is an issue because some schools
    are overcrowded while others are operating below capacity. This suggests
    variation across schools in the added costs associated with enrolling
    additional children, such as illegal alien children.

    Finally, we note that a broad array of costs additional to dollar costs
    may potentially be relevant. For example, overcrowded facilities may be
    related to growth in enrollments and, thus, to immigration. If sufficient
    temporary space is not added, class-size-and, potentially, the quality of
    education-may be affected.21

    Our objectives were to address three questions regarding the potential for
    estimating the costs of educating illegal alien schoolchildren K-12, by
    state, using government information:

    1. 	What information is currently available from state and local
    governments or federal agencies on either the specific costs of educating
    illegal alien schoolchildren or related topics, such as overall education
    costs or the illegal alien population?

    2. 	What is the Census Bureau's plan for developing new information on the
    illegal alien population in the future?

    3. 	What are possible approaches to estimating the costs of educating
    illegal alien schoolchildren, and are government data available to support
    such approaches?

    The main methods we used to address these questions included:

    o  	A mail survey sent to 22 states, which we selected to include (1) the
    major immigration-destination states, identified in terms of numbers of

    21See Ricardo R. Fernandez and P. Michael Timpane, "Bursting at the Seams:
    Report of the Citizens' Commission on Planning for Enrollment Growth,"
    Office of the Chancellor, Board of Education, New York City, 1995, and
    Francisco Rivera-Batiz and Lillian Marti, "A School System at Risk: A
    Study of the Consequences of Overcrowding in New York City Public
    Schools," Institute for Urban and Minority Education, Teachers College,
    Columbia University, New York, New York, 1995.

    foreign-born residents; (2) the main new-growth states, which we
    identified on the basis of large percentage increases in numbers of
    foreign-born residents; and (3) some other states with lower percentages
    of foreign-born residents (questions 1 and 3).22

    o  	Telephone or e-mail inquiries to six local government or school
    district officials (question 1).23

    o  	Outreach to states and local areas through the National Governors
    Association and the U.S. Conference of Mayors (question 1).

    o  	Discussions with officials and staff at NCES, DHS (which incorporates
    the former INS), and the Census Bureau, plus a collection of relevant
    documents from these agencies (questions 1 and 2).24

    o  	Analysis, including a review of literature and of the results from our
    state survey, local area checks, and discussions with federal agencies- as
    well as consultation with experts in economics and school funding
    (question 3).25

    In discussions with your staff, we agreed to limit the scope of this
    report to (1) government estimates and government sources of information,
    (2) children of illegal aliens born outside the United States, and (3)
    issues concerning the estimation of gross costs, rather than attempting to

    22We asked for specific information on enrollments of illegal alien
    schoolchildren, the costs of educating these children, and opinions on the
    factors that should be considered in estimating these costs. The 20 states
    that responded were Arizona, Arkansas, California, Colorado, Illinois,
    Indiana, Iowa, Kentucky, Michigan, Nebraska, Nevada, New Jersey, New York,
    North Carolina, Pennsylvania, Tennessee, Texas, Utah, Virginia, and
    Wisconsin. The 2 that did not respond were Florida and Georgia. We
    supplemented our mailing to the 22 states with e-mails, faxes, and
    telephone calls.

    23We contacted local officials in (1) two traditional destinations for
    immigrants (Los Angeles County, California, and New York City), (2) the
    fastest growing urban area in the United States (Las Vegas, Nevada), (3)
    two suburban counties (Arlington, Virginia, and Fairfax, Virginia), and
    (4) one city on the Mexico-United States border (Nogales, Arizona).

    24Other than NCES, DHS, and the Census Bureau, we could not identify any
    federal agency as a primary source of information on illegal alien
    schoolchildren, whether numbers or costs.

    25These include F. Howard Nelson of the American Federation of Teachers
    Educational Foundation; Frank H. Johnson, an NCES statistician; and GAO's
    Chief Economist as well as GAO's Center for Economics staff.

    quantify net impacts.26 Additionally, we did not consider preschool,
    postsecondary, or after-school programs.

    With respect to data reliability, we discussed NCES data quality
    procedures with an NCES statistician specializing in NCES surveys of
    school expenditures and enrollments, and we reviewed NCES's survey
    documentation. We determined that the NCES data were sufficiently reliable
    for use in estimating school costs.27 As we discuss in the body of the
    report, other federal information concerning estimates of illegal aliens
    is not as reliable.

    We conducted our work in accordance with generally accepted government
    auditing standards from January 2003 to May 2004.

    Looking across local, state, and federal levels of government, we found
    that a wealth of data are available on school enrollments and dollar
    expenditures, but with few exceptions, specific information on illegal
    alien schoolchildren has not been developed.

                                  Currently Available

    Government
    Information

        State and Local Data Sources

    Of the 22 state governments we surveyed, only 3 provided information on
    the costs of schooling illegal alien children. Seventeen states said that
    they did not have such information, and 2 states (Florida and Georgia) did
    not respond.

    Texas, Pennsylvania and North Carolina multiplied their states' average
    current per pupil expenditures for the 1999-2000 school year by estimates
    of the number of illegal alien schoolchildren. Specifically:

    26We excluded from consideration the costs of educating children born in
    the United States (and, therefore, U.S. citizens) to parents who were
    illegal immigrants. Net costs of providing benefits to a specific
    population would consider the full range of benefits received by that
    population as well as taxes paid and other potential contributions.
    Because we are not examining net costs, we do not address the issue of
    life-cycle analysis. Barry Edmonston and Ronald Lee, eds., discuss
    life-cycle analysis briefly in Local Fiscal Effects of Illegal
    Immigration: Report of a Workshop (Washington, D.C.: National Academy
    Press, 1996), p. 25.

    27NCES data do not break out certain costs that are needed for some
    approaches to cost estimation.

    o  	Texas state government staff told us that they first obtained an
    estimate of the number of school-aged illegal alien children younger than
    18 living in Texas, from a nongovernment organization.28 The

    Texas staff then multiplied this figure by the upper and lower bounds

    of a range based on alternative assumptions about the percentages of

    such children attending public schools-66.8 to 74.8 percent.29

    o  	Pennsylvania's state government staff told us told us that they
    estimated the number of illegal immigrant schoolchildren in terms of a
    range by (1) accepting DHS's estimate for the resident illegal immigrant
    population in their state and (2) assuming that schoolchildren represent
    10 to 18 percent of this population.30 The staff then multiplied

    the upper and lower bounds of the range by average per pupil

    expenditures-and also specified an estimate of additional

    expenditures for supplemental services such as ELL programs.

    o  	North Carolina did not provide documentation of its specific methods
    of estimation.

    We did not evaluate the estimation procedures these states used. The
    annual cost estimates that they provided to us ranged from $50 million to
    $87.5 million in Pennsylvania to $932 million to $1.04 billion in Texas.31

    Of the 17 states that said they did not have information on the costs of
    schooling illegal alien children, 6 indicated that it would be illegal to
    ask about children's immigration status. Three of these 6 mentioned the
    1982 U.S. Supreme Court decision we cited earlier; these states'
    interpretation

    28At the request of the Texas state demographer, an immigration expert at
    The Urban Institute, Washington, D.C., estimated this figure indirectly,
    using census and other data. We did not evaluate that estimate.

    29Texas based this range on data, indicating that, overall, 74.8 percent
    of Texas children under age 18 attend school and 66.8 percent attend
    public school.

    30They told us that 18 percent of households in Pennsylvania have
    school-age children and that they expected this figure to be lower for the
    resident illegal alien population because it is likely that some families
    of illegal aliens remain in their native land.

    31Pennsylvania state government staff estimated a range of $38.1 million
    to $66.3 million for current average per pupil expenditures ($7,772) and
    possible additions to these costs of $12.2 million to $21.2 million for
    ELL and other special programs. These two ranges total $50 million to
    $87.5 million.

    of this U.S. Supreme Court decision may be overly cautious.32 (Of course,
    regardless of legal issues, a state or school district might determine
    that asking about immigration status would be inadvisable or
    inappropriate.)

    The six local governments or school districts that we contacted did not
    provide estimates of either the costs of educating or the numbers of
    illegal alien schoolchildren, suggesting a lack of widespread local
    government ability or effort to make such estimates. However, one school
    district, on the southwest border, identified the problem of
    schoolchildren who resided in Mexico and crossed the border daily or
    weekly to attend U.S. schools in border areas.33

    Outreach through the U.S. Conference of Mayors yielded one local area
    estimate. San Jose, California, estimated the presence of approximately
    20,000 illegal alien school children-noting, however, that no study had
    been done. In other responding areas, various city officials said that,
    given the 1982 U.S. Supreme Court decision that we mentioned above, they
    did not ask about children's immigration status.34 Of course, only a
    complete census of school districts could assess the number of local areas
    that actually have or have not developed data or specific methodological
    procedures for making estimates.

        Federal Data and Estimates

    Federal data sources are also limited. NCES and the Census Bureau
    routinely collect a variety of education data, including school
    enrollments and dollar expenditures, with annual figures for

    32The Supreme Court's decision in Plyler v. Doe, 457 U.S. 202 (1982), said
    only that children may not be denied education on the basis of their
    immigration status. Subsequently, a 1997 district court case (League of
    United Latin American Citizens v. Wilson, 997 F.Supp. 1244 (C.D. Cal.
    1997)) declared unconstitutional a provision in California's Proposition
    187 that required schools to verify the status of schoolchildren because
    the Court found that the intent of the requirement was to deny the
    students access to a public education. Presumably, a state or local
    government could inquire about legal status for another, constitutional
    reason (such as to seek federal reimbursement).

    33The Superintendent of Nogales Unified School District #1 informally
    estimated, from anecdotal information, including observations of children
    in Nogales school uniforms crossing the border, that in his school
    district such children might number 400 to 600. He said that based on
    Arizona's average annual per pupil expenditures of $5,000, he estimates
    the annual cost of such children at about $2 million to $4 million.

    34These cities include Anchorage, Alaska; Boston, Massachusetts; Dayton,
    Ohio; Lincoln, Nebraska; Oklahoma City, Oklahoma; St. Petersburg, Florida;
    San Leandro, California; and West Palm Beach, Florida.

    o
    numbers of pupils, pupil-teacher ratios, ELL program use, and a measure of
    overcrowding and

    o
    current per pupil expenditures and capital expenditures for items such as
    facilities acquisition, construction, and computer purchases.

    NCES maintains these data and makes them available by state and by school
    district or local education agency. NCES told us that staff check the
    validity of these data by (1) comparing data from the school
    district-level survey to data from the state-level surveys and (2)
    examining trends for possible anomalies.

    NCES tallies education expenditures by set categories. Thus, expenditures
    cannot be broken down for specific types of programs-notably, the costs of
    ELL programs are not reported separately. Also, NCES collects no data on
    the number of foreign-born children enrolled in school or their
    immigration status.

    The Census Bureau also does not collect data on the legal status of
    foreign-born persons residing in the United States. As we stated in a
    previous report,

    Neither [the decennial] census nor CPS [the Current Population Survey
    conducted by the Census Bureau] asks about the legal status of
    noncitizens-or whether they are, in fact, here illegally. There are good
    reasons for this: such questions fall under the heading of `threatening'
    survey questions . . . many respondents might not answer these questions
    truthfully; and others might avoid participating altogether if they hear
    that such questions

    35

    will be asked. In addition, . . . Census is concerned about privacy
    invasion issues.

    DHS has provided indirect, national and state-by-state estimates of the
    size of the resident illegal alien population.36 DHS estimated this
    population nationally at 7 million as of January 2000 and has published
    additional

    35GAO/GGD-98-164, p. 39.

    36Immigration and Naturalization Service, "Estimates of the Unauthorized
    Immigrant Population Residing in the United States: 1990-2000."
    (Washington, D.C.: Jan. 2003).
    http://uscis.gov/graphics/shared/aboutus/statistics/index.htm (May 21,
    2004).

    estimates for 42 states and the District of Columbia.37 As defined by DHS,
    the illegal population excludes approximately 577,000 aliens, who
    constitute several groups, including unauthorized immigrants with pending
    applications for legal permanent resident status.38

    As we have explained elsewhere,

    o
    DHS based its 7 million estimate on two component estimates. The first
    component is an estimate of 5.5 million illegal residents who entered the
    United States between 1990 and 2000. The estimate was developed by using
    the generally accepted residual method.39 The second component is an
    estimate of 1.5 million illegal residents who entered before 1990 and were
    still here, illegally, in 2000. With respect to this estimate of 1.5
    million, DHS has not published an explanation of the base figure or
    starting point of its calculations-3.5 million illegal immigrants here as
    of 1990. DHS did specify the subsequent steps that it used to determine
    how many of the 3.5 million were still here and still illegal as of 2000.
    (We note that the 3.5 million base figure is consistent with other
    available estimates for 1990.)40

    37In addition to estimates for 42 states published in Immigration and
    Naturalization Service, "Estimates of the Unauthorized Immigrant
    Population Residing in the United States: 19902000," DHS provided us with
    unpublished estimates for 4 more states (New Hampshire, South Dakota, West
    Virginia, and Wyoming), rounded to the nearest thousand. DHS told us
    estimates for the 4 remaining states (Maine, Montana, North Dakota, and
    Vermont) rounded to zero.

    38There are about (1) 200,000 unauthorized immigrants who have submitted
    applications for lawful permanent resident alien status that are pending
    and likely to be approved and (2) 377,000 aliens in various groups. The
    latter include aliens, mostly from Central America, who otherwise would be
    unauthorized residents but are allowed to remain and work in the United
    States under various legislative provisions or court rulings, such as
    people with Temporary Protected Status (TPS), asylees, and parolees. TPS
    derives from the U.S. Attorney General's designating foreign nationals
    eligible for temporary refuge. "Asylee" refers to an alien granted asylum,
    "parolee" to an alien otherwise inadmissible but allowed to enter
    temporarily for urgent humanitarian reasons or significant public benefit.

    39The residual method consists of (1) deriving estimates of legal
    immigrants, based primarily on DHS's own administrative data, and (2)
    subtracting these estimates of legal immigrants from the census figure for
    the total number of aliens residing here. DHS's calculations were
    completed separately for different years of arrival in the United States;
    that is, census data include a report of the year in which each
    foreign-born individual came to the United States to live, and DHS
    administrative data indicate the year in which each legal immigrant
    entered.

    40See U.S. General Accounting Office, Overstay Tracking: A Key Component
    of Homeland Security and a Layered Defense. GAO-04-82. (Washington, D.C.,
    May 21, 2004), app. III.

    o
    By definition, DHS's estimates of the resident illegal immigrant
    population do not include short-term illegal aliens-for example, persons
    here for weeks or months and not likely to be included in the decennial
    census (or corrections for undercounts).41

    o
    DHS has stated that its national estimates are marked by uncertainty-
    noting, for example, "actual trends might be somewhat higher or lower than
    those shown"-but has not developed ranges to characterize this
    uncertainty.42

    DHS's published state-by-state estimates of illegal immigrant residents
    cover 42 states and the District of Columbia. These estimates are based,
    in part, on comparing legal immigrants' statements about their intended
    destinations, as reflected in INS administrative records when they were
    admitted to the United States, to decennial census geographic
    distributions for the total population of foreign-born residents.43
    However, these state-level estimates are uncertain to the extent that
    legal immigrants moved to different states from the states of their
    intended destinations, at any time before the 2000 census-and some did
    move to a different state.44

    Information not provided by DHS is also problematic. First, the DHS paper
    presenting these indirect estimates does not include ranges so that other
    analysts can gauge the degree of uncertainty-and hence their suitability
    for specific purposes. For example, DHS does not indicate whether some
    state estimates may be highly uncertain. Second, DHS has not published

    41Similarly, DHS's estimates do not, by definition, include children who
    reside in Mexico and cross the border daily or weekly to attend U.S.
    schools in border areas.

    42DHS's paper, "Estimates of the Unauthorized Immigrant Population
    Residing in the United States: 1990-2000," discusses limitations of its
    data, including the complexity of estimating numbers of persons residing
    here with legal temporary visas (such as temporary workers and students),
    and so forth. The paper does not, however, attempt to validate assumptions
    about emigration (how many legal and illegal immigrants leave the United
    States).

    43DHS calculates state estimates of illegal immigrants by, essentially,
    subtracting state-level estimates of legal immigrants-based on these
    immigrants' statements about their intended state of residence, on their
    applications-from the total number of foreign-born persons residing in
    each state, based on the 2000 census.

    44See, for example, Marc J. Perry and Jason P. Schachter, Migration of
    Natives and the Foreign Born: 1995 to 2000, CENSR-11 Census 2000 Special
    Reports (Washington, D.C.: U.S. Census Bureau, August 2003).

    any description of analyses conducted to validate its national or state
    estimates. Third, DHS's estimates of illegal immigrants do not break out
    age groups. This is important because it is not known whether the age
    distribution-and thus percentage of school-age children-for the illegal
    population is or is not different from that for other groups.45

      The Census Bureau's Plans for Estimating Illegal Immigrants Are Preliminary

    The Census Bureau is developing a research plan aimed at eventually
    developing new information on the population of illegal immigrants
    residing in the United States.46 Census Bureau staff told us that the
    objective of the plan is to produce annual estimates of international
    migrants according to four statuses: (1) legal immigrants, (2) temporary
    migrants, (3) quasi-legal migrants, and (4) unauthorized migrants, "in
    order to better inform . . . population estimates." The plan will be based
    on an indirect approach that does not involve asking census or survey
    questions about immigration status.

    Importantly, the Census Bureau anticipates that the new information will
    include indirect estimates of illegal aliens in various age groups-perhaps
    coming close to identifying the number of resident illegal alien children
    who are of school age.47 The Census Bureau staff said that it is not yet
    known how many age groups can be reliably broken out. For example, it
    might be possible to use 5-year age groups or perhaps five main age groups
    (0-17, 18-29, 30-49, 50-64, and 65 and older), but Census Bureau staff
    told us that if this is not possible, perhaps only three age groups would
    be estimated (0-17, 18-64, and 65 and older).

    45A possible additional issue regarding information not provided concerns
    the fact that illegal alien schoolchildren may include some
    nonresidents-that is, Mexican children who cross the border each school
    day to attend U.S. schools. DHS's estimates of the resident illegal alien
    population would, by definition, not include schoolchildren who reside
    outside the United States.

    46Charles L. Kincannon, Director of the Census Bureau, letter to F. James
    Sensenbrenner Jr., Chairman of the Committee on the Judiciary, U.S. House
    of Representatives, U.S. Congress, Washington, D.C., Aug. 20, 2003. The
    preliminary work necessary to carry out this plan was mentioned in a
    presentation to a Census Bureau advisory group (see Kevin Deardorff,
    "Immigration Research Update," presentation to Census Information
    Conference Steering Committee, Feb. 26, 2004).

    47By definition, such an estimate would not include schoolchildren who
    reside in Mexico and cross the border daily or weekly to attend U.S.
    schools in border areas.

    While an exact methodology has not yet been specified, the Census Bureau
    previously experimented with models for imputing temporary legal status
    (for example, possessing a valid temporary work or student visa) to groups
    of foreign-born survey respondents.48 This effort used administrative and
    other data to suggest the potential numbers of foreignborn residents with
    temporary legal status-by age group, as well as by race and country of
    birth. The age groups were defined as 0-17, 18-29, 30- 49, 50-64, and 65
    and older.

    Census Bureau analysts reason that a similar process could be developed
    for group imputation of lawful permanent resident status (that is, green
    card status).49 If this approach were expanded to cover virtually every
    legal immigration status, then the numbers and characteristics of illegal
    alien residents could also be estimated, based on a modified residual or
    subtraction approach.

    The Census Bureau intends to use its new indirect procedures on data from
    the new American Community Survey (ACS), scheduled for full implementation
    later this year. A variety of other information sources may be tapped. The
    Census Bureau further anticipates that

    o
    the new information on age groups nationally will be available in 2007,
    with estimates for states-and perhaps key counties--potentially available
    by 2009 (pending budget approvals needed for the geographic estimates);

    o
    key estimates will be made annually, and other estimates (such as
    estimates for smaller groups) will be made with 3-year or 5-year
    averages;50

    48Rachel Cassidy and Lucinda Pearson, "Evaluating Components of
    International Migration: Legal Temporary Migrants," Working Paper 60,
    Population Division, Census Bureau, January 2002. (Census Bureau working
    papers report the results of research undertaken by Census Bureau staff
    and undergo a more limited review than official Census Bureau
    publications.)

    49Characteristics of persons with green cards might also be based on
    survey data on greencard holders developed by using one legal-status card
    from the "three-card method." See U.S. General Accounting Office, Survey
    Methodology: An Innovative Technique for Estimating Sensitive Survey
    Items, GAO/GGD-00-30 (Washington, D.C., Nov. 1999), pp. 1 and 5.

    50Thus, the size of the group for which an estimate is derived, as well as
    the specific estimation methodology, will determine the time period for
    initial estimates and trends. For example, trends based on comparing
    3-year averages for two points in time with no overlap would not be
    available until 2011.

    o
    the new estimates will include ranges to indicate a margin of uncertainty;
    and

    o
    an assessment of the quality of the new estimates will be conducted,
    perhaps using an expert panel.

    Census Bureau staff told us that its plan does not include estimating the
    number of illegal alien children who attend public school or estimating
    the children's English proficiency. However, Census Bureau staff suggested
    to us that, potentially, other agencies might develop such estimates by
    combining the Census Bureau's state-by-state age group estimates of
    illegal aliens with other information, assumptions, or models or a
    combination of them.

    The ACS asks about English proficiency and school attendance. Although
    administrative data on legal immigrants do not include this information,
    the New Immigrant Survey (NIS)-sponsored by DHS and the National Institute
    of Child Health and Human Development, in partnership with other federal
    agencies-asks a sample of new green-card holders about their English
    proficiency and their school attendance.51

    We believe that Census Bureau analysts face a number of technical
    challenges in developing reasonably valid and reliable information.
    Challenges include (1) assessing coverage of the illegal alien population
    in the ACS by age group, as well as coverage of legal foreign-born
    residents; (2) developing adequate sources of information to calibrate and
    validate a model for estimating immigration status; and (3) assessing and
    reporting the levels of uncertainty associated with the estimates.

    Additionally, developing this new information resource will depend on
    continued funding approvals. Specifically, the Census Bureau's budget
    request for 2005 indicates that increased funding (more than requested for

    51The NIS asks for the name of the school currently attended rather than
    whether the school is public or private. (The NIS is described briefly at
    www.pop.upen.edu/nis (May 22, 2004).) Information on a broader spectrum of
    foreign-born children legally residing in the United States (for example,
    information on their school attendance or their English language
    proficiency) might also be developed by using data gathered in a survey
    using one or more legal status cards from the three-card method
    (GAO/GGD-00-30).

      Approaches to Cost Estimation

    2005) will be needed for work during fiscal years 2006 to 2008 to begin
    developing migration estimates at the state and local levels.52

    Because the Census Bureau's plan is in an early stage of development
    (detailed documents are not yet publicly available), it is not yet
    possible to judge its quality. However, when more details become
    available, the Census Bureau's plan might be compared to DHS's methodology
    to determine whether the Census Bureau's approach will be likely to avoid
    the weaknesses associated with DHS's.53

    We identified four approaches to estimating the dollar costs of illegal
    alien schoolchildren by state. These four approaches to estimating dollar
    costs are not necessarily mutually exclusive; that is, some are
    refinements of, or may be used together with, one or more of the others.54

    The four approaches are as follows:

    1. state-by-state multiplication;

    2. local-area refinement of state-by-state multiplication;

    3. student-needs refinement of state-by-state multiplication; and

    4.
    capacity-based estimation of incremental costs, also a refinement of
    state-by-state multiplication.

        State-by-State Multiplication Approach

    The first approach consists of multiplying current average per pupil
    expenditures in each state by an indirect estimate of the number of
    illegal alien schoolchildren in that state, as illustrated in fig. 2. This
    approach has

    52Census Bureau staff told us these plans are documented in Exhibit 13 of
    the President's Fiscal Year 2005 Budget. (Exhibit 13 is about the
    "Measuring Migration Across U.S. Borders" program of the Intercensal
    Demographic Estimates Sub-activity.)

    53We note, however, that the Census Bureau's plan to estimate the resident
    illegal alien population would (like DHS's estimates) exclude short-term
    illegal aliens who are not likely to be included in the decennial census,
    or corrections for undercounts. Also, the Census Bureau's estimates would
    not include illegal alien schoolchildren residing in Mexico who cross the
    border to attend school.

    54Estimation of a broad array of potential costs, including overcrowding
    and possible reductions in education quality, represents an alternative
    direction in assessing cost impacts.

    been used in the past to estimate the costs in some states of educating
    illegal alien schoolchildren.55

    Figure 2: Simplest State-by-State Estimation Approach

    Sources: GAO (analysis), NCES (per pupil expenditure data), Census Bureau
    (estimation plans), U.S. Department of Education (photo).

    A variant of this approach might take account of capital expenditures (for
    example, add per pupil capital outlays to per pupil current
    expenditures).56

    o
    The main advantage of state-by-state multiplication is its simplicity: If
    input data are available, cost figures are easily calculated.
    Additionally, this approach seems logical and is easily understood.

    55For detailed examples of using current average per pupil expenditures
    (and the effects of various assumptions about how to define such
    expenditures) to estimate states' costs of educating illegal aliens, see
    Rebecca L. Clark, and others, "Costs of Providing Public Primary and
    Secondary Education to Undocumented Aliens in Seven States," in Fiscal
    Impacts of Undocumented Aliens: Selected Estimates for Seven States
    (Washington, D.C.: The Urban Institute, September 1994), pp. 61-89, and
    descriptions of estimates reviewed in U.S. General Accounting Office,
    Illegal Aliens: Assessing Estimates of Financial Burden on California,
    GAO/HEHS-95-22 (Washington, D.C.: Nov. 28, 1994), and Illegal Aliens:
    National Net Cost Estimates Vary Widely, GAO/HEHS-95-133 (Washington,
    D.C.: July 25, 1995).

    56A National Academy of Sciences' (NAS) workshop discussed in Edmonston
    and Lee, Local Fiscal Effects of Immigration, raised the issue of
    including capital costs. Although NCES cautions that annual figures may
    vary considerably from year to year, one solution may be to use a summary
    figure, such as a 5-year average. The NAS workshop, however, noted "the
    applicability of average cost or marginal cost may be time sensitive,"
    depending on whether a school system has "significant excess student
    capacity" or becomes overcrowded (p. 16).

    o
    Its limitations are that it does not account for the many complexities of
    costs in this area-which, as we outlined in the background section,
    include local-area cost differentials, variation in individual student
    needs, differences in school capacity, and potentially other factors.57

    Considering its advantages and disadvantages, we believe that
    state-bystate multiplication is a logical approach that could yield a
    rough approximation of state-by-state costs. As we outlined above,
    government data or estimates needed for using this approach are not
    currently available. Although NCES provides data on per pupil expenditures
    by state, DHS's state-by-state estimates of the illegal immigrant
    population do not break out age groups. Moreover, DHS's state-by-state
    estimates have methodological limitations that make them uncertain, yet
    DHS has not estimated ranges or otherwise characterized the degree of
    uncertainty associated with specific estimates.

    In the future, the Census Bureau may provide age-group estimates of
    illegal immigrants by state.

    Although there are a number of challenges, if state-level estimates of
    illegal alien children are successfully developed and validated then
    reasonably reliable (if somewhat rough) approximations of state-by-state
    costs could be calculated, using the state-by-state multiplication
    approach. This would be especially the case if others are able to refine
    this information by estimating illegal alien children's school attendance.

        Local-Area Refinement of the State-by-State Multiplication Approach

    The local-area refinement approach is a logical extension of
    state-by-state multiplication and attempts to generate greater precision
    by taking account of local variations in school costs.58 Multiplications
    would be conducted separately for different areas-for example, cities,
    counties, or groups of counties-and then summed across all areas of the
    state. Thus,

    57For example, the diversity (versus homogeneity) of languages and
    backgrounds of illegal immigrant children enrolled in a particular school
    district may affect costs.

    58In responding to our survey, New York (State Department of the Budget,
    Education Unit) pointed to geographic cost differences within states,
    noting that "If the unauthorized foreign-born students are clustered in
    the regions of the state where education is more expensive, as is most
    likely the case in large states like New York and California, using the
    average cost in the state as a whole will underestimate the true cost of
    educating these students." NAS noted cost variations across geographic
    areas within states (Edmonston and Lee, Local Fiscal Effects of Illegal
    Immigration, p. 14).

    if large numbers of illegal alien schoolchildren attend schools with
    higher or lower costs than the state average, this would be reflected in
    the cost estimates. This approach is appropriate for states with
    significant immigrant populations that exhibit local-area variation in
    both school costs and numbers of illegal alien schoolchildren.

    o
    The local-area refinement approach has the same advantages as
    stateby-state multiplication, and it uses more specific local-area data.

    o
    Its limitations are suggested by a review of other methods (discussed
    below) that account for differences in student needs or school capacity,
    each of which can affect costs.

    NCES collects and maintains current per pupil expenditure and capital
    outlay data, which are available at the school district level, but
    government information on illegal alien schoolchildren is not available.
    In the future, the Census Bureau's plan may, if successfully implemented,
    help quantify the population of school-age illegal alien children in key
    counties.

        Student-Needs Refinement of the State-by-State Multiplication Approach

    The student-needs refinement of the state-by-state multiplication approach
    can build on either of the two approaches we described above, by
    accounting for specific individual student needs that may affect education
    costs. As we indicated in the background section, costs may be higher for
    children in poverty or with limited English proficiency than for other
    children-and both poverty and limited English proficiency may characterize
    many illegal alien children. Moreover, of the 20 states responding to our
    survey, 5 indicated that because of special needs (such as for ELL
    programs), efforts to estimate the costs of educating illegal alien
    children should consider these additional cost factors.59 Using a
    costfunction approach to statistical analysis allows estimation of cost
    factors associated with meeting the needs of students with specific
    characteristics.60

    59The NAS workshop also pointed to program-specific variations in costs,
    for example, ELL (Edmonston and Lee, Local Fiscal Effects of Illegal
    Immigration, p. 15).

    60See, for example, William Duncombe, "Estimating the Cost of an Adequate
    Education in New York," CPR Working Paper 44, Center for Policy Research,
    Maxwell School, Syracuse University, Syracuse, New York, February 2002.
    http://wwwcpr.maxwell.syr.edu/faculty/duncombe/special%20report/specialreport.htm
    (May 22, 2004).

    o
    The main advantage of this approach is that by focusing on individual
    students, it takes account of more determinants of cost than the other
    approaches outlined above.

    o
    The main disadvantage is the complexity involved in estimating cost
    factors, as well as requirements for data that may not be available.
    Additionally, this approach does not account for varying school capacity
    (see below).

    There are two key issues in implementing the student-needs-refinement
    approach:

    1.
    It requires data based on separate cost accounting for programs designed
    to meet special student needs. NCES state-by-state and school-district
    data do not include separate information on the cost of either ELL
    programs or programs designed to compensate for poverty (and associated
    learning disadvantages). However, information on revenues from federal and
    state sources for related programs (for example, bilingual education) are
    collected in the Annual Survey of Local Government Finances-School
    Systems, conducted by the Census Bureau.

    2.
    It also requires estimates of the English proficiency and the poverty
    status of illegal alien school children. The Census Bureau's plan does not
    envision such estimates, but Census Bureau staff told us that other
    government agencies or researchers could expand on the information the
    Census Bureau provides by, for example, using additional assumptions and
    models to achieve indirect estimates of illegal alien children with
    limited English proficiency.61

    School-Capacity Approach
    The incremental cost of adding a student to a classroom, school, or school
    district may be much higher or lower than the average per pupil
    expenditure, depending on the capacity of the classroom, school, or
    district in question. To illustrate, adding one student to a classroom and
    school that has the capacity to easily accommodate the student would not

    61Refer back to the earlier section entitled The Census Bureau's Plans for
    Estimating Illegal Immigrants Are Preliminary.

    require additional capital outlays, such as building a new facility.62 In
    contrast, if that school were at or above capacity, the reverse might be
    true.63

    Various experts have suggested that-at least in some circumstances-a
    capacity-based approach to cost estimation may produce more meaningful
    results than the other approaches. For example, an NAS workshop on the
    fiscal effects of immigration indicated that "Over time, [education] costs
    are a function of the capacity utilization level, not simply the number of
    additional children."64

    In general, three cost categories can be distinguished, as shown in table
    1. Category 1 costs do not vary with enrollment increases or decreases.
    Category 2 costs tend to change in a predominantly linear fashion when
    students are added. Category 3 costs, which may be related to growth in
    enrollment, tend to increase or decrease in step jumps rather than in a
    linear fashion; these may be more difficult to predict.

    62Consistent with this is the notion that when enrollments increase,
    average per pupil expenditures may initially decline. Of course, if more
    students are added, a point may come at which-even for a school with
    initial excess capacity-one or more teachers must be added, overcrowding
    will occur, and additional classroom space must be acquired or new school
    must be built.

    63An example is given in Brad R. Humphreys, "A Report on Incremental Costs
    and Benefits Associated with Increasing Enrollment at UMBC," Department of
    Economics, University of Maryland Baltimore County, Baltimore, Maryland,
    May 17, 2003. In preparing this report, we conducted a preliminary
    analysis of education costs in new-growth immigration states (including
    the 5 states on the right in fig. 1, and 5 other states). We found that
    per pupil expenditures in these 10 new-growth states increased by a larger
    amount than in other states, taken as a group. However, we could not
    conclude that there was a connection between immigration and the change in
    per pupil expenditures, because there was considerable overall growth in
    these states' total populations. And even after high percentage growth in
    the foreign-born populations in these states, foreign-born persons
    remained a relatively small percentage of these states' total populations.

    64Edmonston and Lee, Local Fiscal Effects of Immigration, p. 16.

    Table 1: Cost Categories Relevant to the School-Capacity Approach

    Cost category Cost example

    1. Fixed costs  o  maintaining a school board

    o  salary of the superintendent of schools

    2. Variable costs that correspond directly to the number of students  o
    new textbooks  o  other materials purchased for each student

    3. Costs incurred when capacity is expanded  o  adding teachers

    o  adding on to an existing school or building a new school

    Source: GAO analysis.

    For a classroom with excess capacity, the only costs associated with
    adding a single student would be category 2 costs.65 Where capacity is
    limited or already stretched, both category 2 and category 3 are relevant.
    Calculating category 3 costs is difficult. However, studies to explore the
    incremental costs of illegal alien children might be approached by
    developing matched pairs of school districts-that is, school districts
    that appear to have many relevant characteristics in common but that
    differ with respect to enrollment of illegal alien schoolchildren over
    time.

    o  	The advantage of the school-capacity approach is that it reflects
    important classroom and school factors for which the other approaches do
    not account.

    o  	The main disadvantages are its complexity and requirements for
    extensive, specific data that may not be available.

    Separate data for each cost category in table 1 are not necessarily easily
    accessed. Although some expenditures within a category (such as paper
    supplies, books, and periodicals in category 2) can be broken out in NCES
    data, the costs of adding teachers because of expanding enrollments could
    probably be estimated only by undertaking a special study, such as that
    suggested above. In the future, the Census Bureau may be able to supply
    the data needed to (1) help identify candidate counties or districts for
    such studies and (2) track trends in the estimated numbers of illegal
    alien schoolchildren in these areas over time. NCES school-expenditure
    data could then be compared over time-ideally, before and after a period
    of

    65In fact, the slightly larger class size would, all other things being
    equal, tend to result in a decline in average per pupil expenditures.

      Observations

    Agency Comments

    substantial growth in the illegal alien enrollments for one of the two
    school districts.

    Considering our findings, we believe that the government information that
    is available is not sufficient to reliably quantify the costs of educating
    illegal alien schoolchildren. All approaches to estimating these costs
    require data or estimates of the number of illegal alien schoolchildren.
    Neither state nor local governments collect this information, and federal
    agencies do not provide estimates.

    Although DHS estimates the resident illegal immigrant population, its
    estimates are subject to unspecified levels of uncertainty; further, DHS
    estimates do not break out age groups. The Census Bureau plans to develop
    age-group estimates, but it is too early to evaluate its plans. If
    successfully implemented, the plan calls for national estimates to be made
    available by 2007 with state and perhaps local estimates by 2009.

    If more data on the numbers and characteristics of illegal alien
    schoolchildren were to become available, then it would be appropriate to
    conduct an in-depth analysis of the methodological alternatives that could
    be supported by those data. If feasible, analyses aimed at producing
    comparative estimates, based on more than one approach, could shed
    considerable light on the issue of education costs. They could do so by
    indicating not only the expenditure levels based on the numbers of illegal
    alien pupils and the average per pupil expenditures by state or local
    area. They could also do so by providing information on whether estimated
    expenditures are appreciably different when adjusted to reflect these
    students' needs or the capacity of the schools they attend or both.

    We provided a draft of this report to the Census Bureau, DHS, and NCES.
    The agencies informed us that they had no formal comments, but we received
    informal comments from the Census Bureau and NCES on minor technical
    points and made changes in the report as appropriate.

    As agreed with your office, we will be sending copies of this report to
    the Secretary of the Department of Homeland Security, the Director of the
    National Center for Education Statistics, the Director of the Census
    Bureau, and various congressional committees. We will also make copies
    available to others on request. In addition, the report will be available
    at no charge on the GAO Web site at http://www.gao.gov.

    If you or your staff would like to discuss any of the issues we present
    here,
    please call me at (202) 512-2700 or Judith A. Droitcour, who served as
    project director on this study, at (202) 512-9145. Other major
    contributors
    to this report include Eric M. Larson, Mona H. Sehgal, Seyda Wentworth,
    and Timothy Carr.

    Sincerely yours,

    Nancy R. Kingsbury,
    Managing Director
    Applied Research and Methods

      GAO's Mission

    Obtaining Copies of GAO Reports and Testimony

    The General Accounting 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.

    The fastest and easiest way to obtain copies of GAO documents at no cost
    is through the Internet. GAO's Web site (www.gao.gov) contains abstracts
    and fulltext files of current reports and testimony and an expanding
    archive of older products. The Web site features a search engine to help
    you locate documents using key words and phrases. You can print these
    documents in their entirety, including charts and other graphics.

    Each day, GAO issues a list of newly released reports, testimony, and
    correspondence. GAO posts this list, known as "Today's Reports," on its
    Web site daily. The list contains links to the full-text document files.
    To have GAO e-mail this list to you every afternoon, go to www.gao.gov and
    select "Subscribe to e-mail alerts" under the "Order GAO Products"
    heading.

    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. General Accounting 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: Web site: www.gao.gov/fraudnet/fraudnet.htm

      Waste, and Abuse in E-mail: fraudnet@gao.gov

    Federal Programs Automated answering system: (800) 424-5454 or (202)
    512-7470

    Jeff Nelligan, Managing Director, NelliganJ@gao.gov (202) 512-4800

    Public Affairs 	U.S. General Accounting Office, 441 G Street NW, Room 7149
    Washington, D.C. 20548
    *** End of document. ***