No Child Left Behind Act: Additional Assistance and Research on  
Effective Strategies Would Help Small Rural Districts (23-SEP-04,
GAO-04-909).							 
                                                                 
To improve the academic achievement of the nation's 48 million	 
school-aged children, the No Child Left Behind Act (NCLBA)	 
introduced significant changes to state, district, and school	 
accountability for student performance and teacher		 
qualifications. Congress has raised concerns about difficulties  
rural districts face implementing NCLBA. GAO is providing NCLBA  
implementation information on (1) key challenges rural states and
districts face, (2) strategies rural districts have developed,	 
(3) expenditures and resources related to rural districts'	 
compliance, and (4) guidance and assistance the Department of	 
Education (Education) is providing. To address these objectives, 
GAO conducted a nationally representative survey of rural and	 
nonrural school districts. Also GAO interviewed officials in	 
rural states and districts and Education officials.		 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-04-909 					        
    ACCNO:   A12764						        
  TITLE:     No Child Left Behind Act: Additional Assistance and      
Research on Effective Strategies Would Help Small Rural Districts
     DATE:   09/23/2004 
  SUBJECT:   Academic achievement				 
	     Aid for education					 
	     Education or training costs			 
	     Educational standards				 
	     Educational testing				 
	     Elementary school students 			 
	     Performance measures				 
	     Rural schools					 
	     School districts					 
	     Secondary school students				 
	     Teacher education					 
	     Teachers						 
	     Personnel qualifications				 

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GAO-04-909

United States Government Accountability Office

GAO

                       Report to Congressional Requesters

September 2004

NO CHILD LEFT BEHIND ACT

  Additional Assistance and Research on Effective Strategies Would Help Small
                                Rural Districts

Corrections made on 10/05 to change 86 to 85 in the 2nd paragraph, line 4,
page 2 and to correct figure 2 on page 4.

GAO-04-909

[IMG]

September 2004

NO CHILD LEFT BEHIND ACT

Additional Assistance and Research on Effective Strategies Would Help Small
Rural Districts

What GAO Found

Rural districts faced some challenges in meeting NCLBA provisions to a
greater extent than nonrural districts. For example, rural district
officials were more likely than nonrural district officials to report
challenges presented by a large enrollment of economically disadvantaged
students who may live in communities lacking resources such as libraries.
Rural districts also identified small school size and geographic isolation
as greatly affecting their ability to implement NCLBA. Rural officials we
interviewed said that limited access to teacher training facilities and
Internet line maintenance difficulties impeded NCLBA implementation
efforts.

Rural district officials reported using some strategies, such as training
for teachers, to the same extent as nonrural respondents, to help meet
student proficiency provisions and implement teacher qualification
requirements of NCLBA. Rural districts were more likely to increase
computer capacity than nonrural districts. However, small rural districts
were less likely than other rural districts to report using certain
strategies, such as teacher mentoring.

Rural state and district officials we interviewed identified some specific
expenditures related to NCLBA, such as those related to analyzing
assessment results and providing tutoring services to students. However,
district officials were unable to determine total expenditures made to
implement NCLBA, in part because their accounting records were not
maintained in a way that tracked expenditures by NCLBA categories; states
we contacted did not require districts to report separately on NCLBA
expenditures. Besides state and local funds, officials reported using
multiple federal programs to implement NCLBA, such as the Rural Education
Achievement Program (REAP).

Since 2002, Education has provided NCLBA guidance and assistance to all
states and districts, and since April 2003, it has focused on rural
education issues by issuing new guidance, establishing a task force on
rural issues, and awarded a grant in September 2004 for a rural education
research center. However, rural officials indicated that further
assistance would be helpful for small rural districts that are
experiencing difficulties in providing teacher development opportunities
and identifying effective remedial services to improve student
achievement. Currently, research on the effectiveness of different
strategies to improve student performance is limited.

United States Government Accountability Office

Contents

Letter

Results in Brief
Background
Rural Districts and States Faced Challenges in Implementing

NCLBA

Rural and Nonrural Districts Generally Reported Using Similar Strategies
to Implement NCLBA, but Small Rural Districts Were Less Likely to Use Them

Rural Districts Identified Some Specific Expenditures Made for NCLBA
Implementation and Used Multiple Funding Sources to Support Implementation
Efforts

Education Provided Many Types of Assistance, but Rural Officials

Said Additional Assistance Would Be Helpful Conclusions Recommendations
for Executive Action Agency Comments and Our Evaluation

                                       1

                                      4 7

12

19

27

36 40 41 42

Appendix I	Scope and Methodology 44 Other Methodology 47

Appendix II Comments from the U.S. Department of Education

Appendix III GAO Contacts and Staff Acknowledgments 51

GAO Contacts 51 Staff Acknowledgments 51

Related GAO Products

Tables

Table 1: Characteristics of Small Rural, Other Rural, and Nonrural
Districts, 2001-02 8

Table 2: Percentages of Rural and Nonrural District Superintendents
Reporting Challenges in Implementing NCLBA's Teacher Qualification
Requirements 14

Table 3: Percentages of Small Rural and Other Rural District
Superintendents Reporting Additional Challenges in Implementing Various
NCLBA Provisions 16

Table 4: Percentages of Rural and Nonrural District Superintendents
Reporting Specific Strategies to Meet Student Proficiency Goals 19

Table 5: Percentages of Rural and Nonrural District Superintendents
Reporting Specific Strategies to Implement NCLBA's Highly Qualified
Teacher Provisions 21

Table 6: Percentages of Rural and Nonrural District Superintendents
Reporting the Use of Distance Learning Technology in Implementing NCLBA's
Highly Qualified Teacher Provisions 23

Table 7: Percentages of Rural District Superintendents Reporting the Use
of REAP Funds for Purposes Associated with NCLBA Implementation 34

Table 8: Actions Taken by Education to Assist States with Implementation
of NCLBA and Their Intended Purpose 37 Table 9: Site Visit States and
School Districts 47

Figures

Figure 1: Small Rural and Other Rural Districts 3 Figure 2: Rural States
Contacted 4 Figure 3: Percentages of Small Rural District Superintendents

Reporting Use of Specific Strategies to Help Schools Meet
Student Proficiency Goals Compared with Percentages of
Other Rural District Superintendents 24

Figure 4: Percentages of Small Rural District Superintendents Reporting
Use of Specific Strategies to Meet NCLBA's Teacher Qualification
Requirements Compared with Percentages of Other Rural District
Superintendents 26

Abbreviations

AYP adequate yearly progress
CCD Common Core of Data
ESA educational service agency
K-12 kindergarten through 12th grade
LEA local education agency
NCLBA No Child Left Behind Act
NCES National Center for Education Statistics
REAP Rural Education Achievement Program

This is a work of the U.S. government and is not subject to copyright
protection in the United States. It may be reproduced and distributed in
its entirety without further permission from GAO. However, because this
work may contain copyrighted images or other material, permission from the
copyright holder may be necessary if you wish to reproduce this material
separately.

United States Government Accountability Office Washington, DC 20548

September 23, 2004

The Honorable Kent Conrad
Ranking Minority Member
Committee on the Budget
United States Senate

The Honorable Susan Collins
Chairman
Committee on Governmental Affairs
United States Senate

The Honorable Michael Enzi
United States Senate

The Honorable Tim Johnson
United States Senate

In an effort to improve the academic achievement of all of the nation's
48 million school-aged children, the No Child Left Behind Act (NCLBA)
introduced significant changes to how states, districts, and schools are
held accountable for their students' academic performance and teachers'
qualifications. The Congress, as well as state and district education
officials, has expressed concerns that many rural districts are
encountering difficulties in implementing NCLBA provisions. NCLBA
requires districts and schools to assess students' reading, math and
science abilities and measure the results against a level of proficiency
that
has been established by the state. As a condition for receiving federal
funds, NCLBA currently requires states to ensure that every student
becomes proficient in reading and math by school year 2013-14. NCLBA
also requires that 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 2005-06 school year. To meet requirements
teachers must have a bachelor's degree, be state-certified to teach, and
demonstrate subject matter competence in each core academic subject
that they teach. Because of the small size and geographic isolation of
many
rural districts and schools, there is a concern that these districts and
schools may find it difficult to implement some NCLBA provisions. In the
2001-02 school year, rural districts comprised 25 percent of all school
districts in the country.

As a result of concerns that rural states and districts may have
difficulties meeting some NCLBA requirements, we are providing you with
information about implementation issues. This study addresses the
following questions:

1. 	What key challenges do rural states and districts face in meeting
student proficiency provisions and teacher qualification requirements of
NCLBA?

2. 	What strategies have rural districts developed to meet student
proficiency provisions and teacher qualification requirements of NCLBA?

3. 	What expenditures and funding sources are related to rural districts'
compliance with NCLBA?

4. 	What guidance and assistance is the Department of Education
(Education) providing?

To answer these questions, we used multiple methodologies, including a
survey, site visits, and interviews with Education officials. We conducted
a survey of a stratified, nationally representative sample of 1,215 school
districts and received a response rate of 85 percent. We surveyed rural
and nonrural districts so that we could determine whether and to what
extent rural districts differed from nonrural districts. We used a
definition of rural that focused on places that were distant from
metropolitan areas. We categorized our sample as follows:

o  	Rural districts. We defined districts as rural if they were 55 miles
or farther from a metropolitan statistical area.

o  	Nonrural districts. We defined districts as nonrural if they were
located less than 55 miles from a metropolitan statistical area.

To obtain information from the most rural school districts, we further
stratified our sample by size. The literature suggests that smaller
districts may face unique challenges.

o  	Small rural districts. We defined districts as small rural if they
were 55 miles or farther from a metropolitan area and had 300 or fewer
students.

o  	Other rural districts. We defined districts as other rural if they
were 55 miles or farther from a metropolitan statistical area but had more
than 300 students.

We used Education's Common Core of Data (CCD) to draw the sample of school
districts for our survey. Figure 1 presents the distribution of small
rural and other rural districts based on the definition we use that
incorporated distance from metropolitan area.

Figure 1: Small Rural and Other Rural Districts

Source: GAO analysis of Education's 2001-02 Common Core of Data.

In addition to the survey, we made site visits to six states-Maine,
Mississippi, Montana, Nebraska, North Dakota, and South Dakota. In
addition, we conducted telephone interviews with officials in four states-
Alaska, Iowa, Kansas, and Vermont. We selected these states because they
were the most rural states in the country, based on the percentage of
their school districts in rural communities, the percentage of their
students attending schools in rural communities, and the average distance
between the school district in the state and the nearest metropolitan
statistical area as a measure of geographic isolation. In addition, we
included Wyoming because of the large geographic distance that its school
districts cover. We selected school districts to visit in these states
based on variation in

student enrollment, geographic isolation, school proficiency, and
demographic characteristics. Figure 2 shows the rural states that we
visited and contacted by telephone.

Figure 2: Rural States Contacted

Source: GAO analysis of Education's 2001-02 Common Core of Data.

We also conducted telephone interviews with educational association
representatives and other experts, met with Education officials, and
reviewed guidance and data from Education. In some cases, our survey and
site visits predated Education's guidance that addressed some issues
relevant to rural schools and districts. When this occurred, it was
identified in the report in the context of related findings. For a more
detailed explanation of our methodology, see appendix I. We conducted our
work in accordance with generally accepted government auditing standards
between August 2003 and August 2004.

Results in Brief	Rural districts we surveyed faced challenges in meeting
NCLBA student proficiency goals and implementing teacher qualification
requirements and faced some of these challenges to a greater extent than
nonrural districts.

In terms of meeting NCLBA's student proficiency goals, officials in rural
districts were more likely than those in nonrural districts to report that
a large enrollment of economically disadvantaged students created
challenges. These students may not have the community resources, such as
libraries and computers, that may be associated with improved academic
performance. Rural districts were more likely to report difficulties in
offering competitive salaries to teachers, limiting their ability to
recruit teachers; 52 percent of officials in rural districts reported this
as a challenge compared with 36 percent of officials in nonrural
districts. In our analysis of small rural districts, we found that they
were more likely than other rural districts to report that school size and
geographic isolation were factors that affected NCLBA implementation.
About half of small rural districts, compared with about a quarter of
other rural districts, reported school size as greatly affecting their
ability to implement student proficiency provisions. For example,
officials in small rural districts told us that limited personnel made it
difficult to release teachers and administrators for attending Education's
conferences and training. These conferences and training are designed to
help teachers and administrators better understand what student
proficiency goals are and how they can help their students meet them. In
addition, rural district officials indicated that they typically had few
staff, which created difficulties completing tasks associated with meeting
NCLBA requirements, such as developing and disseminating reports on school
progress.

Rural and nonrural districts generally reported using some similar
strategies, such as teacher training to increase subject matter knowledge,
to meet student proficiency provisions and implement teacher qualification
requirements of NCLBA. However, differences between rural and nonrural
districts were found in the extent to which they reported the use of other
strategies. For example, rural districts were more likely to use distance
learning, such as receiving training online, for providing instruction to
teachers in implementing teacher qualification requirements. Small rural
districts were less likely to report the use of some strategies, such as
teacher mentoring programs, than other rural districts. For example, about
half of small rural districts reported offering mentoring programs for
teachers, compared with about three-quarters of other rural districts.
Factors such as having very few teachers, existing teachers having to
teach multiple subjects and grade levels, and large distances to other
rural districts limit small rural districts' pool of teachers available to
serve as mentors for other teachers.

Rural state and district officials we interviewed identified some specific
NCLBA related expenditures such as some teacher training and paying for

staff to supervise students while they received instruction from online
tutors. However, officials found it difficult to determine all
expenditures made to implement NCLBA, primarily because their accounting
records were not maintained in a way that categorized expenditures
according to whether or not they were associated with NCLBA requirements.
NCLBA does not require states or districts to report separately on
expenditures related to implementation. Further, projecting expenditures
that will be needed in the future to meet the goals of NCLBA is difficult
because necessary data are often not available to produce such estimates.
For example, it is difficult to project expenditures needed for meeting
student proficiency provisions because there is insufficient research on
what strategies will help all students reach academic proficiency goals.
State and rural district officials reported using multiple funding sources
to support their NCLBA implementation efforts. Besides state and local
funds, they relied on federal appropriations under NCLBA, and the majority
of rural districts reported receiving funds provided under the Rural
Education Achievement Program (REAP).

Education has provided all states and districts with guidance and assisted
them in a variety of ways; however, officials from rural states and
districts, including small rural districts, told us further assistance
would be helpful in addressing their issues. Beginning in 2002, after the
passage of NCLBA, Education provided guidance applicable to all states and
districts, and communicated with state officials through site visits and
conferences. For example, Education sent a team of experts to every state
to obtain information on their challenges and provide assistance on
implementing the teacher qualifications requirements of NCLBA. Since April
2003, Education's actions have focused more directly on rural education
issues. Education introduced new flexibilities that were intended, among
other things, to assist rural states with meeting student proficiency
provisions and implementing teacher qualification requirements. For
example, under some circumstances, teachers in rural districts are allowed
extra time-up to 3 years-to meet teacher qualification requirements. Also,
states can now use a single state test for teachers to demonstrate subject
matter competency for core academic subjects that they teach instead of a
separate test for each subject taught. This could be especially helpful to
rural districts and schools where a single teacher might have to teach
multiple subjects. Education also established a Rural Education Taskforce
to coordinate and focus rural education efforts within the department.
Further, Education has recently awarded a grant to establish a National
Center for Research and Development in Rural Education. In addition,
states we contacted provided districts with guidance and assistance to
help them implement NCLBA, and most rural districts surveyed found

state assistance helpful. However, even with state and Education
assistance, a majority of the rural districts surveyed reported that their
implementation issues have not been fully addressed. For example, almost
three-quarters of rural district officials responding to our survey
reported the need for information on remedial services that will help
students meet academic proficiency goals. In addition, small rural
districts and those that may be very isolated continued to face unique
challenges in recruiting, retaining, and training teachers, and lacked
strategies to address them. Education officials told us they are
continuing to work on rural issues and provide more guidance in an effort
to assist rural states.

To assist rural states in meeting the provisions of NCLBA, we are
recommending that Education provide additional assistance on
implementation approaches small rural districts can use to address their
unique challenges and direct its National Research and Development Center
on Rural Education to focus on effective, scientifically based methods
that can be applied to improve student performance in small rural
districts.

In its comments on a draft of this report, the department discussed but
did not explicitly agree or disagree with our recommendations. For both
recommendations, Education provided new information that was incorporated,
as appropriate, in the report.

                                   Background

The NCLBA of 2001 amended and reauthorized the Elementary and Secondary
Education Act, the largest and most comprehensive federal education law. 1
Title I of NCLBA provides funds to states for educating students from
low-income families and is the single largest federal program supporting
education in kindergarten through 12th (K-12) grade.2 Districts receive
Title I funds based on a formula that incorporates, among other things,
the number of children in poverty. Approximately 56 percent of all schools
are eligible to receive Title I funds, compared with 65 percent of rural
schools.

1NCLBA was signed into law as Pub. L. No.107-110.

2Title I, Part A of the Elementary and Secondary Education Act, allocated
almost $12 billion in fiscal year 2003 to serve disadvantaged children in
approximately 90 percent of the nation's school districts.

Rural districts comprised 25 percent of all school districts in the
country. Rural schools and districts, on average, have fewer students than
nonrural schools and districts and tend to be more geographically
isolated. Moreover, rural school districts are more likely to be comprised
of one, two, or three schools, whereas the number of schools in urban and
suburban districts is typically higher. Further, in our analysis we found
that 11 percent of all school districts are small rural districts. (See
table 1 for comparisons between very small rural, other rural, and
nonrural districts.)

Table 1: Characteristics of Small Rural, Other Rural, and Nonrural
Districts, 2001-02

                                                       Small  Other  
                                       Characteristics  rural rural  Nonrural 
                               Percentage of districts     11     14 
                Average number of students in district    126  1741      4015 
                             Average school enrollment     77  368        560 
                 Average number of schools in district      2      5 
                Average number of students per teacher     11     16 
                       Percentage of minority students     16     33 
           Percentage of students participating in the               
                                                  free               
                      and reduced school lunch program     41     42 
                                Average per pupil cost $9,420 $6,970   $7,820 

Source: GAO analysis of Education's 2001-02 Common Core of Data and 2001
U.S. Census Bureau's Public Elementary-Secondary Education Finance Data.

Note: Valid data on students' participation in the free and reduced school
lunch program were not available for Arizona, Connecticut, Tennessee, and
Wyoming.

In addition to the characteristics listed in Table 1, small rural
districts may have unique geographic characteristics that distinguish them
from other districts. Small rural districts can exist in unique locations,
such as small islands off the coasts of states, usually making air or sea
transportation a necessity. Small rural districts can also be located in
mountainous areas with difficult terrain and roads that may not be
passable for some part of the year because of extreme weather conditions.
These weather conditions can also affect accessibility to electrical
power. Small rural districts can also be located long distances from other
districts, towns, and universities.

In recent years, the Congress and other parts of the federal government
have demonstrated a growing interest in rural schools. The House and
Senate Rural Education Caucuses, consisting of bipartisan groups of

members of Congress, were formed to advance the education interests of
rural schools and districts. Further, the Congress authorized a Rural
Education Achievement Program (REAP) to help rural districts compete for
and make more effective use of federal grants. REAP was designed to help
rural districts that may lack the personnel and resources to compete
effectively for federal competitive grants. It is comprised of two
programs: (1) The Small, Rural School Achievement program authorizes the
Secretary of Education to award formula grants directly to eligible school
districts; (2) The Rural and Low-Income Schools program is designed to
address the needs of rural, low-income schools, and authorizes the
Secretary to award formula grants to state educational agencies, which in
turn award subgrants to eligible school districts either competitively or
on a formula basis. The funds can be used for many activities, including
teacher recruitment and retention, professional development, and
educational technology. The Congress appropriated approximately $168
million for REAP funding in fiscal year 2003. Finally, the National Center
for Education Statistics (NCES) has made improvements in its
classification of schools to accommodate more information about location,
making it possible to develop more refined information about rural
education. 3 NCES also established a rural education data section on its
Website, called Navigating Resources for Rural Schools.

NCLBA was designed to raise the academic achievement of students and the
qualifications of teachers, and states, districts, and schools are
currently in their third year of its implementation. Key provisions of the
law included the following:

Academic content standards and yearly academic assessments. NCLBA requires
that states develop and implement academic content and achievement
standards in math, reading/language arts, and science, and that annual
assessments are aligned to these standards. States must administer annual
student assessments that are aligned with state standards. Beginning in
the 2005-06 school year, state assessments in math and reading/language
arts must be administered every year in grades 3 through 8 and once in
high school, and by 2007-08, states must also measure students' science
achievement. All students, including students

3NCES is part of the Department of Education and is the primary federal
entity for collecting, analyzing, and reporting data related to education
in the United States and other nations.

with limited English proficiency and those with disabilities, are required
to participate in assessments.

Adequate yearly progress and student proficiency goals. NCLBA requires
states to develop annual goals for adequate yearly progress (AYP) that
schools and districts must meet to ensure that every student becomes
proficient in math and reading/language arts by school year 2013-14. The
annual goals on state assessments and the final target of 100 percent
student proficiency applies to all students and those in designated
groups, including economically disadvantaged students, major racial and
ethnic groups, students with disabilities, and students that have limited
English proficiency. Schools must also show that 95 percent of their
students- overall and within each subgroup-participated in the
assessments. In addition to including annual assessment results, high
schools must include students' graduation rate, and elementary and middle
schools must include one other academic indicator determined by the state
to assess whether they made annual progress.

Teacher qualification requirements. Teachers of core academic subjects
must be certified to teach by their state, have a bachelor's degree, and
demonstrate subject matter competency in each core academic subject they
teach by the end of school year 2005-06. Subject matter competency can be
demonstrated in either of two ways: (1) successful completion of an
academic major, coursework equivalent to a degree, or advanced
certification in each subject or (2) passing a high, objective, uniform
state standard of evaluation developed by the state to certify teachers'
knowledge of the subjects they teach. In addition to teachers,
paraprofessionals are required to have two years of college, or an
associate's degree, or a rigorous standard of quality on formal state or
local assessment. Improving teacher qualifications is identified in the
NCLBA as a strategy to raise student academic achievement. For example, by
learning new instructional approaches and enhancing subject matter
expertise, teachers will be better equipped to help students learn.

School choice. After 2 years of not making adequate progress toward
reaching student proficiency goals, schools receiving Title I funds must
offer all their students the option to transfer to a higher-performing
public school within the district. Under circumstances where no viable
transfer options exist-as in districts with only one school serving all
grade levels, districts are expected, to the extent practicable, to make
arrangements with other districts to accept their transfer students and
may offer supplemental educational services.

Supplemental educational services. After 3 or more years of not making
adequate progress toward reaching student proficiency goals, schools
receiving Title I funds must offer supplemental educational services, such
as tutoring in reading and math, to low-income students in the school.
States are required to provide a list of acceptable providers of
supplemental educational services to school districts and monitor the
performance of the provider, including success in improving student
performance.

In addition, NCLBA requires that all federally funded instruction,
technical assistance, and professional development activities be supported
by scientifically based research. However, this type of research is
limited in the education field. For example, this body of research does
not generally include the use of control groups and randomly assigned
subjects in experiments, techniques used in physical science research to
show that outcomes are caused by program interventions and not other
factors. Education is currently expanding its grant awards to support
scientifically based research in education.

State education officials play a major role in the implementation of NCLBA
in their states and districts. Some key decisions to be made by state
officials include:

o  	Developing academic content standards and assessments for math,
reading/language arts, and science, and determining the level of
proficiency each student must reach on assessments.

o  	Defining the criteria for state certification of teachers and
identifying tests teachers are required to take to demonstrate subject
matter competence.

o  	Determining the smallest number of students that must be enrolled in a
school, as well as in designated student groups, necessary for their test
results to be used in determining whether a school has met proficiency
goals. States have selected a wide range of numbers for this purpose; the
majority of states set their group size minimums at between 25 and 45
students.

o  	Deciding whether or not they will accept NCLBA funding and thus agree
to the implementation of NCLBA requirements in their state.

o  	Developing a plan for submission to Education that, among other
things, demonstrates how the state will meet requirements for setting
annual goals and measuring student progress.

Education provides technical assistance to help states understand the law
and for monitoring their progress in meeting the law's student proficiency

  Rural Districts and States Faced Challenges in Implementing NCLBA

provisions and teacher qualification requirements. The Secretary of
Education is required to report to the Congress annually regarding state
progress in implementing various requirements, including how many of their
schools were identified for improvement.

Rural districts faced challenges in meeting student proficiency goals and
implementing teacher qualification requirements of NCLBA and faced some of
them to a greater extent than nonrural districts. State officials we
interviewed also cited challenges to implementing student proficiency
provisions on both the state and the district level. Rural districts also
identified small school size and geographic isolation as greatly affecting
their ability to implement NCLBA.

Rural Districts Reported Similar Challenges as Nonrural Districts in
Meeting Student Proficiency Goals but Faced Some of Them to a Greater
Extent than Nonrural Districts

Rural districts were more likely than nonrural districts to report some
challenges in meeting student proficiency goals. For example, officials in
about 52 percent of rural districts surveyed reported that a large
enrollment of economically disadvantaged students created challenges to
meeting student proficiency goals; about 40 percent of nonrural districts
reported this as a challenge.4 During our site visits, several rural
district officials with large numbers of economically disadvantaged
students told us that these students generally did not have structures in
their communities or homes that are typically associated with improved
academic performance. For example, some communities did not have libraries
near where many of their students lived. As a result, during our site
visits rural district officials noted their economically disadvantaged
students often required more resources and instruction time at the school
than other students to meet student proficiency goals. Another challenge
reported to a greater extent by officials in rural districts than nonrural
districts was declining student enrollment. This could result in reducing
the number of teachers in a school or district, and the remaining teachers
assuming additional responsibilities for subjects taught.

4All percentage differences reported from the survey have sampling errors
of no more than plus or minus 10 percentage points, at a 95 percent
confidence level, unless otherwise noted. In our analysis of the survey
data, we combined responses that were reported to a "great" or "very
great" extent. References in the report that describe the frequency of
occurrence of a particular response reflect this combined category. For
example, all reported responses for challenges to implementation were
identified by respondents as occurring to a "great" or "very great"
extent.

Rural and nonrural districts reported some challenges to the same extent,
such as a large enrollment of students with disabilities. About half of
both rural and nonrural district officials reported large enrollment of
students with disabilities to be affecting their ability to meet student
proficiency goals. Students with disabilities often require more services
and assistance to help them achieve academic proficiency. For example,
students with learning disabilities may require additional services from a
reading resource teacher. Further, several rural state and district
officials explained that although most students with disabilities
participated in the standard state assessment tests, they may require
extended time and other accommodations to take these tests. Officials
noted that offering such accommodations or services in rural areas may be
difficult due to limited staff available to provide them or the increased
cost of transporting students to sites where services could be received. A
quarter of both rural and nonrural districts noted that it was challenging
to provide services, such as tutoring or after-school enrichment, to help
students achieve proficiency.

Rural state officials we interviewed also identified several difficulties
in implementing student proficiency provisions. For example, rural state
officials cited difficulties performing administrative duties, such as
developing state plans and notifying districts of improvement actions
required under the law. Most rural state officials we contacted noted that
their state education offices had few staff yet were responsible for
meeting the same requirements as all other states. In addition to having a
limited number of staff responsible for multiple tasks, most state
officials said that they did not always have the information on and
explanation of the latest guidance from Education. Although Education was
making efforts to get information to the states, rural state officials
told us that they had few administrative staff to act on that information
once it arrived.

Rural Districts Faced Some Challenges to a Greater Extent than Nonrural
Districts in Implementing Teacher Qualification Requirements

Rural districts were more likely than nonrural districts to identify
certain challenges to implementing NCLBA's teacher qualifications
provisions. (See table 2.)

Table 2: Percentages of Rural and Nonrural District Superintendents
Reporting Challenges in Implementing NCLBA's Teacher Qualification
Requirements

                                                  Percentage of Percentage of
                                             rural district nonrural district
                                   Challenges superintendents superintendents

                   NCLBA's highly qualified teacher provision

Competing in salary with other school districts for
highly qualified teachers 52

Few professional development opportunities for
teachers 15

Source: GAO survey data.

Notes: Percentages above show the proportion of respondents who reported
being affected by a particular factor to a great or a very great extent.

Each difference between rural and nonrural districts in this table is
significant at the 95 percent confidence level.

More than half of officials in rural districts reported that it was a
challenge to offer competitive salaries to teachers, compared with about
one-third of officials in nonrural districts. According to rural district
officials, as well as organization representatives we spoke with, it was
often difficult for school districts to recruit and retain teachers when
the salaries they offered were low. One rural district official we spoke
with told us that it was difficult for her district to recruit new
teachers because teacher salaries in her state were so low; average
teacher salaries in her state were among the lowest in the nation. Recent
data show that teacher salaries in the 10 most rural states, excluding
Alaska, rank among the lowest in the nation, generally reflecting regional
differences in the cost of living.5 However, officials in rural districts
noted that other factors, such as geographic isolation, also affected
their ability to recruit and retain teachers. Additionally, 15 percent of
rural district superintendents reported having few professional
development opportunities for teachers as a factor that affected their
ability to implement NCLBA's highly qualified teacher requirements, while
6 percent of nonrural district superintendents reported this as a factor.
In rural districts it is not uncommon for schools to be separated by long
distances from the nearest college or training facility and have limited
access to the Internet. Some district staff, such as those in isolated
communities, may have to travel three or more hours to reach training
facilities; others, such as those

5See GAO, DOD Overseas Schools: Compensation Adequate for Recruiting and
Retaining Well-Qualified Teachers, GAO-03-19 (Washington, D.C.: December
2002).

located on island districts, must use planes or boats to travel to
training. Rural state officials we interviewed also expressed concerns
about implementing teacher qualification requirements similar to those
reported by survey respondents. In particular, they noted the challenge of
ensuring that all teachers demonstrate subject matter competency in the
subject that they teach by the deadline in the law. Even though states had
several options for teachers to demonstrate subject matter competency,
including a state-developed test, officials did not know whether these
alternatives could be developed within the required time frames.

Rural Districts Faced Additional Implementation Challenges Related to
Small Size and Isolation

Rural districts also identified small school size and geographic isolation
as greatly affecting their ability to meet student proficiency provisions
and implement teacher qualification requirements of NCLBA, with the small
rural districts more likely than other rural districts to report these
factors. (See table 3.) According to our definition of rural districts,
all were isolated, that is, 55 miles or farther from metropolitan areas.
However, those rural districts that were also small-fewer than 300
students-were more likely to report isolation as a challenge. The majority
of nonrural districts did not report these factors as challenges.

Table 3: Percentages of Small Rural and Other Rural District
Superintendents Reporting Additional Challenges in Implementing Various
NCLBA Provisions

                                         Percentage of small Percent of other
                                                rural district rural district
                                   Challenges superintendents superintendents

                     NCLBA's student proficiency provision

Very small school size 52

Geographic isolation 39

NCLBA's highly qualified teacher requirement

Very small school size 54

Geographic isolation 51

                               Small school size

Source: GAO survey data.

Notes: Percentages above show the proportion of respondents who reported
being affected by a particular factor to a great or a very great extent.

We calculated confidence intervals for our study using methods that are
appropriate for a stratified, probability sample. For the percentages
presented in this report, we are 95 percent confident that the results we
would have obtained if we had studied the entire population are within
plus or minus 10 percentage points of our results.

Small school size was associated with several difficulties for schools
trying to implement NCLBA's student proficiency provisions, according to
survey results and our site visit interviews. About half of small rural
district officials we surveyed reported school size as a factor affecting
their ability to implement student proficiency provisions, compared with
about onefourth of officials in other rural districts. Officials we
visited also cited difficulties related to small school size, such as
having fewer administrative staff and limited expertise that reduced their
capacity to perform tasks associated with NCLBA provisions. For example,
for small administrative staff, completing the paperwork associated with
NCLBA- such as preparing and distributing reports on assessment
results-was a substantive addition to their workload. Further, district
staff often had to assume multiple roles, which reduced the amount of time
they could spend on collecting and disseminating information on promising
implementation strategies, as well as designing and implementing them to
raise student performance. Some school district superintendents in single
K-12 school districts explained that they had to fulfill the duties of
superintendent as well as those of principal and teacher at their K-12
schools. Furthermore, limited personnel made it difficult to release
teachers and administrators to attend conferences and receive training
that might help them address student proficiency goals. One rural district
official told us that he could not afford to allow his staff to take off
time to attend training on assessments because substitute teachers were
difficult

to find. Moreover, officials told us that rural states in which these
districts were located had few staff themselves, which limited their
ability to provide assistance to the districts. In addition, districts not
meeting student proficiency goals faced difficulties in offering
supplemental educational services to students because of the small school
size. According to some rural officials, providers were reluctant to
provide services in rural districts because the small number of children
who may need these services do not provide a profitable business
opportunity.

Small school size also created difficulties for schools trying to
implement NCLBA's teacher qualification requirements, which slightly more
than half of small rural districts reported as a challenge, compared with
about onequarter of other rural districts. On average, 77 students are
enrolled in schools in small rural districts and rural state and district
officials told us that some small rural schools might have only two or
three students in each grade, requiring teachers to take responsibility
for teaching multiple subjects across different grade levels. For example,
officials in one rural district we contacted explained that its three
teachers were responsible for teaching every subject to 15 students
enrolled in grades K-12. Many district officials we spoke with said that
such small student enrollment made it more challenging for teachers to
meet the definition of highly qualified in each core academic subject they
teach. It also made it difficult for teachers to take time off to attend
professional development classes because substitutes were generally not
available in small districts.

In March 2004, Education issued new guidance allowing states to administer
a single evaluation to determine competency in multiple core academic
subjects. However, some state officials told us that developing a test to
gauge teachers' competency in every core subject was a formidable task
that would require time, expertise, and other resources. Additionally,
while guidance extended the time for obtaining subject matter competency
to existing teachers in some rural districts, extending time for teachers
to meet the requirements did not address the underlying problem of a lack
of professional development opportunities. 6

6In March 2004, Education issued guidance with new flexibility for states
to allow some rural districts up to 3 years for multiple subject teachers
who are highly qualified in one subject to become highly qualified in the
additional subjects they teach.

Geographic isolation

Geographic isolation created difficulties for districts to implement NCLBA
provisions, particularly the supplemental educational services component.
During our site visits, district officials explained that they were often
unable to use supplemental educational service providers on approved state
lists. Officials stated that traveling long distances to meet the
providers was generally not a viable option for students, and thus they
choose not to offer them. For example, when one rural district made an
effort to offer supplemental educational services, it took students 3
hours to reach the provider's site. According to state and district
officials, the use of online service providers as an option was difficult
in some small rural districts, especially those where severe weather
conditions and physical features such as mountains made it difficult to
establish and maintain Internet lines. Many of the rural school district
superintendents we interviewed in states such as Montana, Alaska, South
Dakota, North Dakota, and Maine noted that frequent power outages and poor
transmissions hindered the use of distance learning. Other officials
explained that even when Internet capabilities were established, it was
difficult to recruit technical maintenance personnel to isolated rural
areas.

Geographic isolation was also associated with difficulties in implementing
teacher qualification requirements, according to district officials. About
half of small rural districts identified geographic isolation as greatly
affecting their ability to implement teacher qualifications provisions,
compared with about one-third of other rural districts. Several district
officials we interviewed also said that geographic isolation made it
difficult for current teachers to obtain the training they need to become
certified in every subject taught. Because long distances and boundaries
such as mountains or bodies of water can separate small rural districts
from training opportunities, rural districts may need to rely on atypical
means to get there. For example, the superintendent of one very small and
isolated rural district we spoke with reported that traveling by air or
boat was the only option to reach the nearest college where his teachers
could receive appropriate training. In another district, officials said
that the nearest college where teachers and paraprofessionals could obtain
the necessary credentials was more than 600 miles away.

Additionally, the remote environment could be a deterrent to new teachers
seeking employment. During our site visits, districts officials explained
that geographic remoteness impeded the ability of rural districts to
recruit and retain teachers because of the lack of social opportunities,
severe weather conditions, and long distances to the nearest metropolitan
area. For example, officials from several very isolated districts we spoke
with explained that at times weather was so severe that teachers and other

  Rural and Nonrural Districts Generally Reported Using Similar Strategies to
  Implement NCLBA, but Small Rural Districts Were Less Likely to Use Them

school staff were forced to live in the school until severe weather
conditions subsided.

Rural and nonrural districts used similar strategies, such as providing
training for teachers, to meet student proficiency provisions and teacher
qualification requirements of NCLBA. However, small rural districts were
less likely than other rural districts to use the strategies for
implementation of these provisions.

Rural and Nonrural Districts Used Some Similar Strategies in Implementing
Student Proficiency Provisions

The primary strategies used to meet student proficiency goals, reported by
about 90 percent of both rural and nonrural district superintendents
surveyed, were remedial services, such as tutoring for students, and
additional training for teachers. (See table 4.)

Table 4: Percentages of Rural and Nonrural District Superintendents
Reporting Specific Strategies to Meet Student Proficiency Goals

                                                  Percentage of Percentage of
                                             rural district nonrural district
                                     Strategy superintendents superintendents

Provided remedial services to students at risk

a

of failing 89

Provided additional training for teachers 90

Provided test opportunities for studentsa 77

Provided additional computer capabilitya 76

a

                        Provided teacher mentoring 62 75

Source: GAO survey data.

a

We calculated confidence intervals for our study using methods that are
appropriate for a stratified, probability sample. For the percentages
presented in this report, we are 95 percent confident that the results we
would have obtained if we had studied the entire population are within
plus or minus 10 percentage points of our results.

Among rural districts we contacted, most offered tutoring, extended day
and summer programs, or other remedial services to help students improve
academically. For example, one rural district we visited made after-school
tutoring in reading and math available to students four nights

per week, while another rural district extended its academic program by
two hours and introduced Saturday programs to help raise students'
academic achievement. Officials told us that such in-school programs were
particularly valuable in rural areas lacking other enrichment
opportunities. Furthermore, to help meet adequate yearly progress
provisions related to high school graduation rates, one school district
implemented a mentoring program for students in grades 6-12 by district
staff, while another was establishing an alternative high school for
recent dropouts on the campus of a local community college; officials in
both districts indicated that the purpose of these programs was to help
increase graduation rates among high school students. Consistent with what
the survey respondents reported, some rural districts we visited also
provided additional training for teachers to help improve the level of
instruction to students. Those strategies included, for example, training
on ways to more effectively teach reading and math, as well as training on
assessments required under NCLBA. However, many of the strategies cited by
district officials were used even before NCLBA, and officials were
uncertain about the effectiveness of these strategies in helping all
students meet academic proficiency goals.

Although they reported doing so to a lesser extent, rural and nonrural
districts also used other strategies to implement student proficiency
provisions, and differences were found in the extent to which rural and
nonrural districts used many of them. (See table 4.) For example, rural
districts were less likely than nonrural districts to offer mentoring for
teachers-62 percent of rural district superintendents reported the use of
this strategy compared with 75 percent of nonrural district
superintendents. Mentoring programs, which employ the skills and
experience of a more senior teacher to assist newer teachers, can serve a
variety of purposes. One rural district we visited, for example, offered
mentoring to better familiarize teachers with standards-based curriculum
and to enhance the quality of instruction they provide to students.
However, several officials noted that rural districts might experience
difficulties offering such mentoring opportunities due to their limited
resources and small staff. On the other hand, rural districts were more
likely to increase computer capacity, such as adopting distance learning
technology in order to provide video class instruction, than nonrural
districts. Officials in some rural states also reported on their efforts
to invest in statewide technology initiatives to help districts improve
their technological capability and use technology, such as distance
learning, for raising students' academic achievement. One rural state we
visited, for example, launched an initiative to provide every 7th and 8th
grader in the state with a laptop computer, thus enabling students in even
the most

remote rural areas in that state to gain access to a wide array of
academic opportunities available through the Internet. Several officials,
however, were concerned about the effectiveness of online instruction for
lowachieving and younger students who may need direct teacher contact.

Additionally, other strategies for meeting student proficiency goals were
reported, although they were used by less than half of rural and nonrural
superintendents. For example, less than half of both rural and nonrural
district superintendents reported coordinating with regional educational
service agencies (ESA) in an effort to help students attain academic
proficiency goals.7

Rural and Nonrural School Rural districts also used a variety of
strategies to implement NCLBA Districts Used Similar teacher qualification
requirements; the use of most of these strategies by Strategies in
Implementing rural districts was not different from their use by nonrural
districts,

according to survey results. The primary strategies used by the majority
ofTeacher Qualification all districts were teacher and paraprofessional
training and disseminationRequirements of information to schools on
exemplary practices. (See table 5.)

Table 5: Percentages of Rural and Nonrural District Superintendents
Reporting Specific Strategies to Implement NCLBA's Highly Qualified
Teacher Provisions

                                              Percentage of     Percentage of 
                                             rural district nonrural district 
                                   Strategy superintendents   superintendents 
             Provided training for teachers              83 
                Disseminated information on                 
                                  exemplary                 
                       practices to schools              74 

Encouraged paraprofessionals to meet teacher
qualification requirements and become teachers 58

Obtained services from ESAs 50

Source: GAO survey data.

Note: The differences between rural and nonrural districts in this table
are not significant at the 95 percent confidence level.

7The term "educational service agency" refers to a regional public
multiservice agency authorized by state statute to develop, manage, and
provide services or programs to school districts.

Likewise, these strategies were cited by rural state and district
officials that we visited. Many rural states and districts we visited
provided teachers and paraprofessionals with professional development
opportunities to help them obtain the necessary qualifications. For
example, in one rural state we visited, officials said they developed
training programs for teachers to obtain subject area certifications. They
also said that most of their teachers who needed to become highly
qualified chose to take advantage of these state-funded programs because
they could obtain the necessary coursework free of charge. In another
rural state, one small and isolated rural district offered courses in the
school to paraprofessionals for which they could receive credits from a
local community college. Several rural districts we visited were
collecting and sharing information on exemplary practices in raising
students' academic performance with district staff. For example, in one
rural district visited, officials learned of another state developing
individualized education programs for each student, not just students with
disabilities, and disseminated information on this approach for staff in
their own district to adopt.8

The strategy for implementing teacher qualification requirements that
rural districts were more likely to use than nonrural districts was
distance learning for providing instruction to teachers and
paraprofessionals, as well as for students to receive instruction from a
highly qualified teacher in another location. (See table 6.)

8Under the Individuals with Disabilities Education Act, an individualized
education program must be developed for each student with a disability to
state the student's current levels of education performance, establish
measurable annual goals, and outline special education and related
services to be provided to the student. A state discussed here, however,
adopted this practice for all students, not just those with disabilities.

Table 6: Percentages of Rural and Nonrural District Superintendents
Reporting the Use of Distance Learning Technology in Implementing NCLBA's
Highly Qualified Teacher Provisions

                                              Percentage of     Percentage of 
                                             rural district nonrural district 
                                   Strategy superintendents   superintendents 
         Used distance learning for teacher              47 
                                   training                 
          Used distance learning to provide                 
                                   a highly                 
         qualified teacher in the classroom              35 

Source: GAO survey data.

Note: Each difference between rural and nonrural districts in this table
is significant at the 95 percent confidence level.

Among rural districts contacted, some used distance learning for teachers
or paraprofessionals to take classes to meet NCLBA's qualification
requirements, an approach that officials indicated was very helpful in
rural districts located far away from higher learning institutions.
Officials also cited rural districts using distance learning to provide
courses to students by a highly qualified teacher when one was not
available in the school. However, rural state and district officials,
although citing advantages of distance learning, faced challenges in using
technology, such as limited capacity or Internet connection difficulties.
Moreover, small rural districts did not always know how to make best use
of available technology and were unaware of ways in which this technology
could be used to meet the requirements and the goals of NCLBA. For
example, one small rural district we visited had distance learning
technology and high-speed Internet connections in place, but officials
indicated that none of the students were taking online classes yet, and at
the time of our visit, they did not have the information on online
professional development options for teachers.

Other strategies for meeting teacher qualification requirements were
reported as well, although less than half of rural and nonrural district
superintendents reported using them. For example, about 40 percent of both
rural and nonrural district superintendents reported establishing
partnerships with higher education institutions to train teachers, and
more than 10 percent of rural and nonrural districts created agreements
with other school systems for purposes such as sharing highly qualified
teachers. Officials indicated that some of these strategies might be
difficult to implement in rural areas. For example, even though some
districts were making attempts to share teachers, large distances made it
difficult for rotating teachers to travel from one district to the next.

Small Rural Districts Were Less Likely to Use Some Strategies than Other
Rural Districts

Among rural districts, small rural districts were less likely to report
using some strategies, such as teacher mentoring and remedial services, to
meet student proficiency goals than other rural districts. (See fig. 3.)

Figure 3: Percentages of Small Rural District Superintendents Reporting
Use of Specific Strategies to Help Schools Meet Student Proficiency Goals
Compared with Percentages of Other Rural District Superintendents

Percentage of district superintendents

100

95

                                                 90 80 70 60 50 40 30 20 10 0

ertoring

en

m

                                      ial

                        edrovidedremservices incentives

r students fo

                                school structure

rovidedteach P

                                     edvid

roP

                                       P

Strategy

Small rural districts

Other rural districts

Source: GAO survey data.

Note: Each difference between small rural and other rural districts in
this table is significant at the 95 percent confidence level.

For example, about half of small rural districts reported offering
mentoring to teachers, compared with about three-quarters of other rural
districts. Small rural districts may experience greater difficulties
offering mentoring programs for teachers than other rural districts since
they typically have even fewer teachers, those they have are more likely
to teach multiple subjects and grade levels, and they are located farther
from other districts-factors that limit their pool of teachers to serve as

mentors to other teachers. Likewise, although most rural districts used
remedial services such as tutoring, a smaller percentage of
superintendents from small rural districts than superintendents from other
rural districts reported offering these services to meet districts'
student proficiency goals-81 percent compared with 95 percent. Rural
district officials noted that offering remedial services to students was
difficult because the distances students had to travel home were large and
road conditions were poor, thus minimizing the amount of time that
students could spend in school to participate in remedial programs. Other
strategies for meeting student proficiency goals were generally as likely
to be reported by superintendents from small rural as by those from other
rural districts, and included coordinating with ESAs, providing additional
computer capacity, and offering incentives or bonuses for teachers.

Small rural districts were also less likely than other rural districts to
use certain strategies for meeting teacher qualification requirements.
(See fig. 4.)

Figure 4: Percentages of Small Rural District Superintendents Reporting
Use of Specific Strategies to Meet NCLBA's Teacher Qualification
Requirements Compared with Percentages of Other Rural District
Superintendents

Percentage of district superintendents 100

90

                                       84

80

70

60

50

40

30

20

10 0 ith

Established partnerships whigher education institutions

isseminated information D

plary practices

emx

on e

to meet the requirements ed paraprgEncoura

                          essionals becoming teac sher

of rfo

Strategy

Small rural districts

Other rural districts

Source: GAO survey data.

Note: Each difference between small rural and other rural districts in
this table is significant at the 95 percent confidence level.

For example, about a quarter of small rural districts established
partnerships with higher education institutions to help teachers become
highly qualified, compared with almost half of other rural districts.
Similarly, fewer than half of superintendents from small rural districts
reported encouraging paraprofessionals to become highly qualified in order
to increase their supply of teachers who met NCLBA's qualification
requirements, compared with almost 70 percent of superintendents from
other rural districts. Officials indicated that establishing partnerships
with higher education institutions or sending paraprofessionals for
training was

difficult in small and isolated rural areas, since the nearest
institutions were far away. According to one official working with many
small rural districts, it was also not cost-effective for higher education
institutions to send their representatives to these districts to offer
training on-site, given a very small number of staff in small rural areas.
Other strategies for ensuring that teachers met NCLBA's qualifications
requirements were generally as likely to be reported by superintendents
from small rural districts as by those from other rural districts, and
included provision of training to teachers, increases of teacher salaries,
and the use of services for teachers offered by ESAs, among others.

Rural state and district officials identified some specific expenditures
that they associated with implementation of NCLBA, such as those related
to assessments and services to help students meet academic proficiency
goals. However, officials were unable to determine all NCLBA
implementation expenditures, in part because their accounting records were
not maintained in a way that tracked expenditures by NCLBA categories.
States are not required to report separately on expenditures related to
NCLBA implementation, nor have any of the states we contacted required
their districts to do that. Officials reported relying on various funding
sources to support their implementation efforts, including different
federal programs, as well as state and local funds.

  Rural Districts Identified Some Specific Expenditures Made for NCLBA
  Implementation and Used Multiple Funding Sources to Support Implementation
  Efforts

Officials Cited Specific Expenditures Made for Implementing NCLBA

Officials in states and districts we visited cited specific
assessment-related expenditures, including the cost of administering
assessments and collecting and analyzing assessment results in order to
identify students' academic needs and to inform parents and the community
of schools' progress. For example, officials in one district visited
indicated that they had to add 2 additional days into teachers' contracts
to allow teachers enough time to administer and score assessments.
Officials also indicated that assessment-related expenditures involved
those for training teachers on new assessments. For example, officials in
one district said that the district paid for a trainer to conduct a 2-day
training to familiarize staff with new assessments.

Officials also identified expenditures related to schools' and districts'
efforts to meet student proficiency goals, including those for providing

remedial services to students and improving the curriculum. For example,
one rural district we visited invested in a remedial reading program,
afterschool tutoring sessions, and a summer program to improve students'
proficiency. Another rural district paid an educational research
organization to review the district's math curriculum and make
recommendations for improvement.

In addition, officials in states and districts we contacted cited some
expenditures related to meeting NCLBA's teacher qualifications
requirements, including the direct costs of classes and professional
development programs that teachers and paraprofessionals attended, as well
as other costs associated with teachers and paraprofessionals taking steps
to meet the necessary qualifications. For example, one small, isolated
district we visited paid for teachers to enroll in a semester-long
distance learning class, while several others reimbursed paraprofessionals
for taking college courses to meet NCLBA requirements. Officials also
indicated that sending teachers to training led to other expenditures,
such as hiring substitutes while teachers attended training or covering
travel expenses for teachers who were sent to training.

Finally, officials identified expenditures related to the provision of
supplemental educational services and school choice in districts and
schools not meeting student proficiency goals. In addition to covering
providers' fees, expenditures for supplemental educational services
included those used to purchase supplies and pay staff to supervise
students. For example, in one rural district, where only online providers
were available, officials said that expenditures would have to be made to
cover the cost of software and an on-site staff person to monitor students
while they received online instruction. Rural state and district officials
also indicated that they expected the cost of transportation for students
eligible for public school choice under NCLBA to be very high, but those
expenses have generally not materialized because choice options have been
so limited in rural areas.

Difficulties Exist in Determining and Projecting NCLBA Implementation
Expenditures

Although state and district officials identified specific expenditures
associated with NCLBA implementation, difficulties exist in determining
all NCLBA implementation expenditures. District officials were unable to
identify all of their current expenditures made for NCLBA purposes, since
their accounting records were not maintained in a way that categorized
current expenditures according to whether or not they were associated with
NCLBA requirements. NCLBA does not require states to report separately on
expenditures related to NCLBA implementation, and none of

the states we contacted required their districts to do so. Our review of
the accounting records for one district we visited disclosed that for
fiscal years 2002 and 2003 expenditures were placed in general expense
categories. For example, supplies purchased for use in providing extended
day programs, which were expanded due to NCLBA, were placed in the same
"Supplies" category as supplies purchased for typical school day
instruction. Similarly, salaries paid for teaching during the extended day
programs were placed in the same "Salaries" category as salaries paid for
teaching during the regular school day; overtime pay and substitute costs,
which officials often attributed to NCLBA, were also placed in this
"Salaries" category. An official in that district indicated that it might
be possible to report on NCLBA-specific expenditures if the district
changed the way accounting records were maintained, but doing this would
be time-consuming.

In addition to the difficulties identifying all current expenditures
associated with NCLBA implementation efforts, it is also difficult to
determine what expenditures would have to be made in the future to meet
NCLBA goals. One reason for this difficulty is that research and data
needed to project total expenditures for meeting NCLBA goals are often not
available. For example, research does not consistently suggest what
strategies will help all students meet student proficiency goals. In fact,
district officials told us they did not know which of the existing
strategies would enable students to improve academic performance to the
extent sufficient to reach NCLBA's student proficiency goals. As a result,
projected NCLBA expenditures based on expanding current strategies, such
as those made for tutoring or after-school programs, may not represent the
actual expenditures needed to meet student proficiency goals if these
strategies prove to be either insufficient to help students meet these
goals or are more than what is needed. Similarly, states and districts
currently do not know how many students will use the school choice option
under NCLBA and attend a different school within their district.
Consequently, the true number of students who would require transportation
could be higher or lower than what may be currently assumed, resulting in
a potentially inaccurate estimate of transportationrelated expenditures
that districts might incur.

Another reason why projecting total NCLBA expenditures is difficult is
that different assumptions are made about what costs should be included.
Currently, a consensus does not exist on whether expenditures that
originated prior to NCLBA but are now being used to help meet NCLBA goals
should be included in the estimate of total NCLBA expenditures. For
example, officials often cited remedial programs for students and

professional development for teachers as being related to NCLBA, but these
programs may already have been in place prior to passage of the law. This
may have been true particularly for states that implemented systems for
measuring student proficiency prior to NCLBA or in states that were
already striving for goals and outcomes similar to those associated with
NCLBA. In addition, it may be difficult to determine the extent to which
NCLBA may lead some districts to redirect expenditures to more efficient
purposes-such as identifying and providing services to at-risk students in
earlier grades to reduce the need for subsequent services.

The accounting and conceptual difficulties we identified have affected the
total expenditure estimates produced by existing studies, resulting in a
wide range of estimates across the studies. 9 For example, one study
included expenditures for various strategies that will be provided to help
students meet proficiency goals, including summer school, in-school
tutoring, and extended day programs; on the other hand, another study
included expenditures for 6 additional weeks of academic instruction to
help students meet these goals. As a result, the studies resulted in
different estimates of the total expenditures that would be needed to meet
student proficiency provisions of NCLBA.

As states and districts have more time to implement NCLBA or if the
studies estimating NCLBA expenditures become more focused on either
specific provisions of the law or on particular locations in which the law
is

9These studies included Driscoll, William, and Howard Fleeter, Projected
Costs of Implementing the Federal "No Child Left Behind Act" In Ohio
(Columbus, OH: Levin, Driscoll , & Fleeter, December 12, 2003);
AccountabilityWorks, NCLB under A Microscope: A Cost Analysis of the
Fiscal Impact of the No Child Left Behind Act of 2001 on States and Local
Education Agencies (Washington, D.C.:Education Leaders Council, January
2004); Mathis, William J., The Federal "No Child Left Behind" Law: Should
Vermont Take the Money? (Vermont Society for the Study of Education,
October 22, 2002); New Hampshire School Administrators Association,
Analysis of Cost Impact of ESEA No Child Left Behind Act on New Hampshire
(Penacook, NH: November 19, 2002); the Minnesota Office of the Legislative
Auditor, Evaluation Report: No Child Left Behind (St. Paul, MN: Program
Evaluation Division, March 2004). A number of studies have estimated the
cost of providing a certain level of education, yet they did not directly
estimate the cost of NCLBA. For example, see Myers, John, and Justin
Silverstein, Calculation of the Cost of a Suitable Education in Montana in
2001-2002 Using the Professional Judgment Approach (Denver, CO: Augenblick
& Myers, Inc., August 2002) and Duncombe, William, Estimating the Cost of
an Adequate Education in New York (Syracuse, NY: Center for Policy
Research, Syracuse University, February 2002). While these studies may be
helpful in thinking about potential approaches to estimating total
expenditures related to NCLBA, they were not directly relevant to NCLBA
implementation efforts. We also reviewed NCLBA cost estimates developed by
Kansas State Department of Education and a school district in Utah.

implemented, these difficulties may be mitigated. For example, as
districts have more time to identify which of their schools are required
to offer school choice to their students and as more parents learn about
this option, data will become available on how many students will make use
of school choice. In addition, instead of trying to estimate the total
expenditures associated with implementing NCLBA, it may be less difficult
to focus on individual NCLBA provisions, such as assessments and teacher
qualification requirements. Given the differences in approaches that
states and districts can use to meet the requirements of the law, it may
be less difficult to determine NCLBA expenditures incurred by a particular
district, rather than to try to determine expenditures for all districts
in the state or for all states across the country. For example, some
school districts required to offer school choice might have a school
available for students to transfer to within their own district, while
other districts might choose to enter into agreements with other districts
to offer school choice; depending on whether students will have to travel
within their own district or outside of it to attend a different school,
transportation expenditures associated with offering school choice may be
different across districts. 10 Thus, focusing on expenditures associated
with the school choice provision in one particular district at a time may
be less difficult than attempting to determine a single estimate for
school choice expenditures across the entire state. States, researchers,
and education organizations have been working on developing methodologies
to identify NCLBA expenditures. Some states and districts told us they are
trying to find a method to document NCLBA expenditures separately from
their expenditures on other state initiatives. Researchers in the
education finance area have also been exploring methods for estimating
expenditures. Education organizations, such as the Council of Chief State
School Officers have also been working on developing approaches to

10In its recent study, GAO developed a model for estimating states'
assessment expenditures by analyzing expenditure data from seven states.
The study provided three estimates of total state spending between fiscal
years 2002 and 2008 for test development, administration, scoring, and
reporting-ranging from $1.9 billion to $5.3 billion-largely depending on
the type of scoring method that tests chosen by the states would require.
For example, GAO estimated that total state expenditures will be about
$1.9 billion if states use all multiple choice questions, which are
machine-scored, but $5.3 billion if states choose tests with a mixture of
multiple-choice questions and a limited number of open-ended questions
that require students to write their responses and that have to be
hand-scored. See GAO, Title I: Characteristics of Tests Will Influence
Expenses; Information Sharing May Help States Realize Efficiencies,
GAO-03-389 (Washington, D.C.: May 8, 2003).

identify specific activities used to implement NCLBA, as well as
expenditures made for each of those activities. 11

Officials Used Multiple Funding Sources to Support NCLBA Implementation
Efforts

Rural district officials responding to the survey identified various
funding sources as being very helpful in the implementation of NCLBA,
including different federal programs, as well as state and local funds.
Although the Congress has appropriated billions of dollars for
education-more than $37 billion for K-12 education in fiscal year 2004-the
largest portion of district revenue typically comes from state and local
sources of funds. According to the U.S. Census Bureau's Public
Elementary-Secondary Education Finance Data, districts received, on
average, roughly 7 percent of their revenues from federal funds in 2001,
but federal funds tended to make up a slightly higher proportion of total
revenue for rural districts than they did for nonrural districts. Other
major district revenues included state funds (approximately 50 percent)
and local funds (approximately 40 percent). Rural districts received a
somewhat larger portion of their revenues from state funds and a smaller
portion from local funds than nonrural districts.

Officials reported using various federal funding sources for their
implementation efforts. According to survey results, Title I was one of
the primary sources of federal funds, and more than 60 percent of rural
district superintendents reported this source of funds as being very
helpful for implementing NCLBA. In rural states and districts contacted,
Title I funds were used for various initiatives designed to improve
student achievement and teacher qualifications. For example, in one state
contacted, officials indicated that Title I funds were used by the rural
districts for remedial services in reading and math, initiatives to help
increase academic achievement of students with limited English
proficiency, and professional development programs for teachers.

More than half of rural district superintendents responding to the survey
also reported that Title II funds for improving teacher qualifications
were very helpful with NCLBA implementation efforts, and officials
contacted reported using these funds to help their staff meet NCLBA's
qualification

11The Council of Chief State School Officers is a nonpartisan, nationwide,
nonprofit organization of public officials who head departments of
elementary and secondary education in the states, the District of
Columbia, the Department of Defense Education Activity, and five U.S.
extra-state jurisdictions. Its goals are to provide leadership, advocacy,
and technical assistance on major educational issues.

requirements. 12 For example, in one state visited, officials indicated
that Title II funds were used to develop a portfolio-based assessment for
teachers to demonstrate subject matter competency, as required under
NCLBA.13 In addition, while the survey results showed that only 14 percent
of rural district superintendents reported that Impact Aid was very
helpful for NCLBA implementation, it played a large role among rural
districts we visited that had a large proportion of Native American
students; in two districts visited, officials told us that Impact Aid
constituted almost half of the districts' budgets.14 In rural districts
visited, Impact Aid funds were used for purposes such as providing
remedial services for students and tuition for paraprofessionals to take
college courses and become qualified under NCLBA.

Rural districts also used REAP funds for a variety of purposes associated
with NCLBA implementation, including providing remedial services to
students and professional development to teachers. 15 Almost 70 percent of
rural district superintendents responding to the survey indicated that
they received REAP, and the majority of them reported using or having
plans to use REAP to address technology needs of students and teachers,
provide remedial and supplemental educational services to students, and
offer

12Title II, Part A, of the Elementary and Secondary Education Act, Teacher
and Principal Training and Recruiting Fund, provides grants to state and
local educational agencies, state higher education agencies, and eligible
partnerships to implement strategies for improving teacher and principal
quality, as well as to increase the number of highly qualified teachers,
principals, and assistant principals. For fiscal year 2004, $2.93 billion
was appropriated under this program.

13Portfolio-based assessment provides for teachers' subject-matter
competency to be determined on the basis of teachers' educational and
professional credentials and experiences.

14The Impact Aid program (now Title VIII of the Elementary and Secondary
Education Act) provides assistance to school districts with a large number
of children living on Indian reservations, military bases, low-rent
housing properties, or other federal lands. School districts use Impact
Aid for various purposes, including salaries of teachers and teacher
aides, textbooks, after-school and special enrichment programs, and
remedial tutoring. For fiscal year 2004, $1.2 billion was appropriated
under this program.

15REAP was designed to help rural districts that may lack the personnel
and resources to compete effectively for federal competitive grants. It is
composed of two programs: (1) the Small, Rural School Achievement program
authorizes the Secretary of Education to award formula grants directly to
eligible school districts; (2) the Rural and Low-Income Schools program is
designed to address the needs of rural, low-income schools and authorizes
the Secretary to award formula grants to state educational agencies, which
in turn award subgrants to eligible school districts either competitively
or on a formula basis.

professional development for teachers to help them meet NCLBA's
qualification requirements. (See table 7.)

Table 7: Percentages of Rural District Superintendents Reporting the Use
of REAP Funds for Purposes Associated with NCLBA Implementation

Percentage of rural Purpose district superintendents

Technology needs of students and teachers

Supplemental educational services to students

Remedial services to students in preparation for annual assessments

Professional development to help teachers meet NCLBA qualification
requirements

Annual assessments (e.g., developing and administering assessments,
preparing report cards, disseminating information on assessment results,
data management for reporting results)

Professional development to help paraprofessionals meet NCLBA
qualification requirements

After-school or extended day programs

Recruitment of highly qualified teachers

Recruitment of qualified paraprofessionals

School choice

Source: GAO survey data.

In rural states and districts visited, officials reported that REAP funds
have been of great assistance in implementing various initiatives to meet
the goals of NCLBA. For example, some rural districts visited used REAP to
provide tutoring and after-school programs for students falling behind,
while others used REAP for programs to improve students' reading skills.
Some districts also used REAP for teacher qualifications initiatives, such
as sending teachers to training, offering signing bonuses to attract
teachers to a rural location, or funding distance learning and video
conferencing infrastructure to enable teachers in geographically isolated
areas to take classes to raise their qualifications.

In addition to making additional funds available to eligible rural
districts, REAP also allows eligible districts to spend funds under
certain programs, such as the Safe and Drug-Free School Program, for
activities beyond what those programs intended. For example, districts may
choose to use

funds allocated under technology and antidrug programs for initiatives to
help students reach academic proficiency.16 In many rural states
contacted, officials indicated that this flexibility facilitated their
efforts to implement NCLBA by allowing them to direct funds to areas where
they were most needed to meet NCLBA's goals. For example, in one rural
state contacted, officials reported that many of their districts used Safe
and Drug-Free School Program funds to support their technology
initiatives, which, in turn, helped with implementing some of the
provisions of NCLBA.

Among rural district superintendents responding to the survey, 84 percent
reported receiving E-Rate funds since the passage of NCLBA.17 Rural
officials we contacted indicated that these funds facilitated their
efforts to implement the law. For example, beginning with school year
2004-05, some rural districts in a state that we contacted will use E-Rate
funds to finance distance learning infrastructure for offering
professional development to teachers. In another rural state, the
technology infrastructure created with the help of E-Rate helped ensure
that students in isolated rural areas could take classes taught by highly
qualified teachers in other locations. Several district officials noted
that E-Rate discounts enabled them to provide or sustain Internet access,
thus offering learning opportunities to students that may have otherwise
been unavailable in rural areas.

In addition to using federal funds, rural districts used state and local
funds to implement NCLBA. For example, a few rural districts we visited
used

16Rural districts eligible for REAP funds have the flexibility to use
funds under the following programs for activities beyond those that the
programs intend: Subpart 2 of Part A of Title II (Improving Teacher
Quality State Grants); Part D of Title II (Educational Technology State
Grants); Part A of Title IV (Safe and Drug-Free Schools and Communities);
Part A of Title V (State Grants for Innovative Programs). Funds can be
used for activities authorized under the following programs: Part A of
Title I (Improving the Academic Achievement of the Disadvantaged); Part A
of Title II (Improving Teacher Quality State Grants) and Part D of Title
II (Educational Technology State Grants); Title III (Language Instruction
for Limited English Proficient and Immigrant Students); Part A of Title IV
(Safe and Drug-Free Schools and Communities), Part B of Title IV (21st
Century Community Learning Centers); and Part A of Title V (State Grants
for Innovative Programs). Additional information on these programs is
available on Education's website at www.ed.gov.

17The E-Rate program, created as part of the Telecommunications Act of
1996, provides discounts on telecommunications services, Internet access,
and internal connections to libraries and schools in the United States.
Through disbursement of over $10 billion in discounted services since
1997, the E-Rate has helped ensure Internet access in most schools and
libraries in the country.

  Education Provided Many Types of Assistance, but Rural Officials Said
  Additional Assistance Would Be Helpful

state funds to improve technology and offer programs to students via
mechanisms such as interactive TV. In another rural district visited,
local property taxes were used to reimburse staff for taking college
courses to raise their qualifications.

Since the passage of NCLBA, Education has provided guidance and assisted
all states in a variety of ways, but officials from rural states and
districts, including small rural districts, stated that more assistance
would be helpful to fully address their issues. Education has posted on
its Website current NCLBA implementation guidance and communicated with
state officials in all states through telephone calls, conferences, and
visits. Education has employed an evolving approach to assistance by
providing more information and expanded guidance as it learned more from
state officials regarding questions and issues they had difficulty
addressing. Since April 2003, Education has devoted more attention to
rural issues. However, officials in rural states we interviewed told us
that additional assistance addressing their unique challenges, such as the
extreme challenges faced by small and isolated rural districts, would be
beneficial.

Education Provided Many Since the passage of NCLBA, Education has provided
general assistance

Types of Assistance 	and guidance to all states in several ways in order
to help them implement the legislation. (See table 8.)

Table 8: Actions Taken by Education to Assist States with Implementation
of NCLBA and Their Intended Purpose

Efforts to assist states Purpose

Websites providing current guidance on Clarify requirements of NCLBA to
help implementation, promising practices, and states correctly implement
legislation and scientific research. share information among states and
districts

on successful practices taken to implement

NCLBA

State visits-Teacher Assistance Corps 	Obtain information on state efforts
and challenges and advise states on implementation of NCLBA teacher
requirements

Conferences and workshops 	National and regional conferences to explain
guidance, provide information on strategies, answer questions and obtain
information from states and districts on their challenges

Superintendents' Hotline 	To respond to questions from district
superintendents on NCLBA and its implementation

Source: GAO analysis of Education's documents and interviews with
Education officials.

Education's website contained information on guidance, regulations, and
legislation. The website featured large sections devoted to NCLBA,
including frequently asked questions and other useful information. For
example, key requirements, such as those related to teacher
qualifications, were highlighted with references to guidance. Education's
website also included links to other websites. For example:

o  	A website on teacher qualifications (April 2004) that identified best
practices for meeting teacher requirements. The Website also announced
plans to hold teacher workshops on strategies for improving student
proficiency.

o  	A website on supplemental educational services (May 2004) that
provided information to administrators, teachers, and parents on lessons
learned and available resources for providing supplemental educational
services. The site also included links to websites of all state
departments of education.

o  	A website for promising practices in offering school choice (May 2004)
to assist districts in offering parents the choice of sending their child
to another school if the child's current school was in need of
improvement.

Education also provided assistance through state visits, conferences, and
a hotline for superintendents. In the summer of 2003, Education organized

teams of experts, called Teacher Assistance Corps teams. These teams-
composed of federal and state education officials, teachers, principals,
superintendents, leaders from higher education, and others-visited every
state education department to obtain information on how states were
implementing teacher qualification provisions and the challenges they were
facing, as well as to provide assistance to states on implementing these
provisions. The teams completed visits to all states in April 2004.
Education also held several regional and national conferences to assist
states with NCLBA implementation. The conferences provided state and
district officials with the opportunity to meet Education's staff, discuss
implementation issues, and learn about recently issued guidance. In
January 2004, Education established a Superintendents' Hotline to provide
a single point where district superintendents could go to seek answers to
their questions on NCLBA implementation. In addition to receiving
Education's assistance, states we contacted provided districts with
guidance and assistance to help them implement NCLBA, such as conducting
workshops on NCLBA's requirements and disseminating information through
state websites. State officials told us that they have spent considerable
time and resources on these efforts, including the development of state
plans that provide a road map for districts to implement the law. Rural
districts surveyed reported assistance from the state department of
education as the most helpful, as compared to federal and local agencies
and other organizations.

Education Has Become More Focused on Rural Education Issues

Since April 2003, Education has focused more efforts on rural education
issues. At that time, Education established a Rural Education Task Force
to coordinate and focus rural education efforts within the department and,
according to the Executive Director of the task force, to bring together
senior level personnel to identify rural issues and solutions. According
to the information provided by the Executive Director, the task force has
met with the Congressional Rural Caucus and several national education
organizations. The task force also organized a virtual town hall meeting,
hosted by the Secretary of Education, on how rural communities are using
technology to meet the goals of NCLBA. The event was a live webcast to
allow school officials from across the country to learn more about how
their colleagues are using technology to achieve the goals and meet the
requirements of NCLBA. The Executive Director also indicated that the task
force contributed to developing the new flexibilities for rural states
that addressed some of their challenges, such as those related to
qualifications for teachers of multiple subjects. He said he believed that
rural states and districts currently had all the flexibilities that they
needed to implement NCLBA. The Executive Director added, however, that

discussion would continue on whether there is any other work for the
taskforce to do in assisting rural states and districts.

Education issued new flexibilities in guidance in March 2004. According to
Education officials, the information that rural state officials provided
to visiting Education teams, along with other communications with state
officials, was used by Education to develop the flexibilities. The new
flexibilities were intended, among other things, to assist rural states
with teacher qualification and student proficiency provisions of NCLBA.
For example, under some circumstances, teachers in rural districts are
allowed extra time-up to 3 years-to meet the teacher qualification
requirements, and states can now use a single state test for teachers to
demonstrate subject area knowledge in multiple subjects and grades. These
flexibilities may be helpful to some rural districts, since teachers in
small rural districts may be expected to teach multiple subjects. In
addition, schools may average student participation in assessment over a
3-year period, which may make it easier for small rural schools to meet
NCLBA's assessment participation requirement.

Education is also overseeing a research center for rural education. In
response to congressional legislation, Education funds national research
and development centers that examine a wide range of education topics in
order to provide information on educational practices and outcomes
contributing to successful school performance. On September 14, 2004,
Education awarded a grant for the National Center for Research and
Development in Rural Education. According to Education's Cooperative
Agreement with the grantee, the purpose of the center is to develop, test,
and disseminate new approaches to improve teaching and learning, and
ultimately student achievement. The grant proposal and the cooperative
agreement documents contain several research initiatives to address
challenges rural districts face. According to the agreement document, the
research agenda is focused on the implementation and evaluation of
school-wide strategies that enhance rural students' academic, behavioral,
and social adjustment across the elementary and middle school years and
two supplemental studies related to distance learning and career
exploration for rural high school students. However, there was no mention
of any research directed to the unique challenges faced by small rural
districts such as frequent inaccessibility to technology-based
initiatives. Education has also given other grants, including one to the
National Association of State Boards of Education that focus on assisting
rural states.

Rural State and District Officials Cited the Need for More Technical
Assistance and Information on Services That Will Help Improve Student
Performance

Conclusions

Many districts reported the need for more assistance at the time our
survey was administered in January 2004, and officials that we contacted
reported that Education's current assistance did not fully address their
unique issues. For example, almost three-quarters of rural district
officials responding to the survey reported the need for additional
assistance on remedial services that will help students meet academic
proficiency goals. Officials we contacted said they did not know which
strategies would help students reach student proficiency goals or the
extent to which strategies currently in use should be maintained,
modified, or eliminated. Currently, scientific research on the
effectiveness of different strategies to improve student performance is
limited.

Officials from some states we contacted between October 2003 and April
2004 told us that while Education's on-site teacher qualification teams
did seek information on challenges these states were facing, they did not
always respond to their questions. State officials with unanswered
questions were concerned that they may be out of compliance with the law.
Education officials told us that because they were continually developing
new policies and flexibilities in guidance to respond to states' concerns,
some questions could not be answered during Education's visits to the
states.

Most state officials told us that the guidance received from Education for
implementing various parts of NCLBA was helpful, but officials from nine
states we interviewed cited concerns, such as guidance being in draft
form, changing frequently, or not being issued in a timely manner for
meeting NCLBA requirements. In response to these concerns, Education
officials told us it was challenging to provide the support states needed
to meet NCLBA requirements given the short time frames for issuing
guidance to implement NCLBA provisions and the differences in education
systems among states. Education officials said that they were continuing
to address rural issues.

NCLBA seeks to make fundamental changes in public education by challenging
federal, state, and local education officials to reevaluate the way
education has been delivered. For the first time, the Congress has
specified a deadline for when it expects all students to reach proficiency
on state assessments, showing that students possess knowledge of the
subject matter in accordance with state standards. Achieving the goal of
having all students proficient will be a formidable challenge for all
states, districts, schools, and students. However, educators in rural
areas may

face additional challenges, primarily related to the small size of rural
school districts and their geographic isolation.

Education made considerable efforts and progress in promulgating
regulations, providing assistance, and working with states during the
first two and a half years of NCLBA implementation. States also have
devoted significant time and resources in developing state plans and
working with districts to meet NCLBA requirements and deadlines. As a
result of these efforts, many states are becoming better positioned to
meet the 2014 deadline that all students be proficient. Yet, these efforts
have not always been as successful for states with small rural districts
because of the unique challenges they face. Small rural districts comprise
11 percent of all school districts in the country.

Officials in states with small rural districts, as well as the district
officials, reported on the difficulties they were having implementing
NCLBA provisions. Although Education issued guidance that provides
additional flexibilities to help rural areas, challenges still exist.
Rural districts are held accountable for student performance to the same
extent as all other districts, so in the third year of NCLBA
implementation, additional assistance from Education would likely help
students in rural districts, particularly small rural districts, fully
benefit from NCLBA.

Further, rural districts, as well as nonrural districts, reported that
they needed information on what strategies are most effective in helping
improve students' performance. Currently, scientifically based research on
the effectiveness of various remedial services is limited, particularly
research on effective strategies that takes into account the challenges
that small and geographically isolated districts face. Without information
from scientifically based research studies on effective remedial services,
particularly services that can be used in these districts, students may
not achieve the levels of academic progress sufficient for meeting state
proficiency goals. In addition, without this information, districts would
not know what expenditures they would need to make to better position
themselves for meeting the goals of NCLBA.

Because of the challenges small rural districts face, we recommend that
the Secretary of Education provide additional assistance to states on
approaches small rural districts can use to implement student proficiency
provisions and teacher qualification requirements, including the
application of new flexibilities.

  Recommendations for Executive Action

  Agency Comments
  and Our Evaluation

To assist rural states in meeting student proficiency provisions of NCLBA,
we are recommending that Education--through its recently established
National Research and Development Center on Rural Education--focus on
effective, scientifically based methods to improve student performance,
and that it conduct studies on the services that can help small rural
districts meet students proficiency provisions in light of the unique
challenges that these districts face.

We provided a draft of this report to Education for review and comment.
Education's written comments are reproduced in appendix II. The department
discussed but did not explicitly agree or disagree with our
recommendations. For both recommendations, Education provided new
information that was incorporated, as appropriate, in the report. In
addition, we modified the report to address Education's two technical
comments.

In response to our recommendation that Education provide additional
assistance to states on approaches small rural districts can use, the
department commented that it intends to provide such assistance. In its
comments, Education provided some additional information on the actions
already taken and stated that it plans to take action to help states and
districts, including those districts in rural areas. However, some of
these actions do not address the unique challenges of small rural school
districts, such as those with limited access to the Internet. Therefore,
we continue to recommend that Education focus some assistance to address
the needs of these small rural school districts.

Regarding our second recommendation, that Education use its new National
Research and Development Center on Rural Education to address the unique
challenges small rural districts face, Education commented that through
the center, it would initiate a long-term program of research to implement
and evaluate professional development strategies to enhance rural
students' performance. Education awarded the research grant to fund this
center on September 14, 2004, after it had received and reviewed our
report. Education noted in its comments that the center will conduct
research programs that will be helpful to rural districts, such as the
effectiveness of web-and video-based programs. However, our findings have
shown such programs may not be appropriate for some small, isolated rural
districts that often have limited access to technology. On the basis of
our review of the awarded grant proposal, we found that it contained no
indication that the center would direct any research to specifically focus
on challenges and strategies applicable to small, isolated

rural districts. Therefore, we continue to recommend that through the
center Education conduct studies on approaches that can help small rural
districts meet student proficiency provisions in light of the unique
challenges these districts face.

Unless you publicly announce its contents earlier, we plan no further
distribution until 30 days after the date of this letter. At that time, we
will send copies of this report to the Secretary of Education, appropriate
congressional committees, and others who are interested. We will also make
copies available to others upon request. In addition, the report will be
available at no charge on GAO's Web site at http://www.gao.gov. If you
have any question about this report, please call me at (202) 512-7215. Key
contributors are listed in appendix III.

Marnie S. Shaul, Director Education, Workforce, and

Income Security Issues

                       Appendix I: Scope and Methodology

In conducting our work, we administered a mail survey to a nationally
representative sample of 1,215 school district superintendents. The survey
was conducted between January 19, 2004, and March 26, 2004. We analyzed
survey data and identified significant results. The response rate for the
survey was 85 percent.

The study population for the survey consisted of public school districts
contained in the Department of Education's Common Core of Data (CCD) Local
Education Agency (LEA) file for the 2001-02 school year, the latest year
for which data were available. We reviewed the documentation for this file
and conducted electronic testing of the file we received. Based on these
reviews, we determined that the file was sufficiently reliable for our
purposes. In addition, we determined the data were sufficiently accurate
to serve as our study population. From this file, we identified a
population of 14,396 school districts in the 50 states.

Sample. The sample design for this survey was a stratified sample of 1,215
LEAs in the study population. To enable us to compare rural districts with
nonrural districts, we categorized our sample as follows:

o  	Rural districts. We defined districts as rural if they were 55 miles
or farther from a metropolitan statistical area.

o  	Nonrural districts. We defined districts as nonrural if they were
located less than 55 miles from a metropolitan statistical area.

The distance of 55 miles was chosen because it reflects the 25 percent of
districts in the country located farthest from a metropolitan statistical
area. This definition allowed us to analyze those districts that may be
experiencing special challenges due to their geographic isolation.

To ensure that we obtained information from most rural school districts,
we further stratified our sample by size as follows:

o  	Small rural districts. We defined districts as small rural if they
were 55 miles or farther from a metropolitan area and had 300 or fewer
students.

o  	Other rural districts. We defined districts as other rural if they
were 55 miles or farther from a metropolitan statistical area but had more
than 300 students.

Appendix I: Scope and Methodology

Estimates. All estimates produced from the district sample in this report
were for a target population defined as all public school districts in the
50 states for the 2003-04 school year. Estimates of this target population
were formed by weighting the survey data to account for both sample design
and the response rates for each stratum.

Sampling error. Because we surveyed a sample of school districts, our
results were estimates of a population of school districts and thus were
subject to sampling errors associated with samples of this size and type.
Our confidence in the precision of the results from this sample was
expressed in the 95 percent confidence intervals. The 95 percent
confidence intervals are expected to include the actual results for 95
percent of the samples of this type. We calculated confidence intervals
for our study results using methods that were appropriate for a
stratified, probability sample. For the percentages presented in this
report, we were 95 percent confident that the results we would have
obtained if we had studied the entire study population were within plus or
minus 10 percentage points of our results, unless otherwise noted. For
example, we estimated that 39 percent of small rural school districts
identified geographic isolation as a challenge in meeting the highly
qualified teacher provisions of the No Child Left Behind Act (NCLBA). The
95 percent confidence interval for this estimate would be no wider than
plus or minus 10 percent, or from 29 percent to 49 percent.

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

Prior to fielding the questionnaire, we met with two outside experts in
October 2003 to discuss the survey and listen to their suggestions. On the
basis of these suggestions, the survey was revised. It was pretested with
5 district superintendents in rural and nonrural districts in November and
December of 2003. We conducted these pretests to ensure that the
respondents understood the questions and could provide the answers to
them. Following these pretests, the survey underwent additional, mostly
minor, revisions. Data edits and estimation programs were independently
verified to ensure that programming errors did not affect our estimates.
To reduce nonresponse, we sent a follow-up mailing to all school districts
that had not responded to the survey by our deadline, followed by
telephone calls to nonresponding districts.

Appendix I: Scope and Methodology

Site visits. To obtain information on rural districts' experiences with
implementing the accountability and teacher quality provisions of NCLBA,
we made site visits and conducted telephone interviews with the 10 most
rural states: Alaska, Iowa, Kansas, Maine, Mississippi, Montana, Nebraska,
North Dakota, South Dakota, and Vermont. These states represented the most
rural states in the country based on the percentage of their school
districts in rural communities, the percentage of their students attending
schools in rural communities, and the average distance between the school
districts in the state and the nearest metropolitan statistical area as a
measure of geographic isolation. We made site visits to 6 states-Maine,
Mississippi, Montana, Nebraska, North Dakota, and South Dakota, visiting
state education officials, as well as officials in two or three local
school districts in each state (see table 9). We selected school districts
to visit on the basis of variation in student enrollment, geographic
isolation, school performance, and demographic characteristics. In
addition, we consulted with state education officials in helping us select
local school districts that were in need of improvement. We conducted
telephone interviews with officials in Alaska, Iowa, Kansas, and Vermont.
We spoke with state education officials in each of these states, as well
as with officials in three Alaska districts. We also conducted telephone
interviews with state education officials in Wyoming because of the large
geographic distance that school districts in that state cover.

                       Appendix I: Scope and Methodology

                Table 9: Site Visit States and School Districts

State Local school district

Alaska 	Haines Borough Kuspuk Pelican City

Maine 	School Administrative District 34, Belfast School Administrative
District 49, Fairfield Steuben School Department

Mississippi Jefferson County North Panola

Montana 	Box Elder Browning

Nebraska 	Creighton Santee Wheeler Central

North Dakota 	Mandaree Selfridge

South Dakota	Isabel Todd County

Source: GAO data.

Note: Interviews with state and district officials in Alaska were
conducted by telephone.

Other Methodology 	We also conducted interviews with educational
association representatives and other experts, met with Education
officials, and reviewed guidance and data from Education. We conducted our
work in accordance with generally accepted government auditing standards
between August 2003 and August 2004.

Appendix II: Comments from the U.S. Department of Education

Appendix II: Comments from the U.S. Department of Education

Appendix II: Comments from the U.S. Department of Education

Appendix III: GAO Contacts and Staff Acknowledgments

GAO Contacts 	Harriet C. Ganson (202) 512-7042 or [email protected] Mary E.
Roy (202) 512-7072 or [email protected]

Staff In addition to those named above, the following individuals made
important contributions to this report: Natalya Bolshun, Daniele
Acknowledgments Schiffman, Cynthia Decker, Kris Braaten, Jessica Botsford,
Jean McSween, John Mingus, Corinna Nicolaou, Robert Owens, and Jay Smale.

Related GAO Products

Special Education: Additional Assistance and Better Coordination Needed
among Education Offices to Help States Meet the NCLBA Teacher
Requirements. GAO-04-659. Washington, D.C.: July 15, 2004.

Student Mentoring Programs: Education's Monitoring and Information Sharing
Could Be Improved. GAO-04-581. Washington, D.C.: June 25, 2004.

Title I: Characteristics of Tests Will Influence Expenses; Information
Sharing May Help States Realize Efficiencies. GAO-03-389. Washington,
D.C.: May 8, 2003.

No Child Left Behind Act: More Information Would Help States Determine
Which Teachers Are Highly Qualified. GAO-03-631. Washington, D.C.: July
17, 2003.

Elementary and Secondary Education: Ed-Flex States Vary in Implementation
of Waiver Process. GAO/HEHS-99-17. Washington, D.C.: November 13, 1998.

Rural Development: Profile of Rural Areas. GAO/RCED-93-40FS. Washington,
D.C.: April 29, 1993.

Rural Development: Rural America Faces Many Challenges. GAO/RCED-93-35.
Washington, D.C.: November 20, 1992.

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