No Child Left Behind Act: Improved Accessibility to Education's  
Information Could Help States Further Implement Teacher 	 
Qualification Requirements (21-NOV-05, GAO-06-25).		 
                                                                 
The No Child Left Behind Act (NCLBA) of 2001 established	 
qualification requirements that teachers of core academic	 
subjects must meet by the end of the 2005-2006 school year.	 
Congress has appropriated approximately $3 billion a year through
the Title II, Part A (Title II), of NCLBA for teacher improvement
programs since the law was passed. With the deadline approaching 
for all teachers to meet the requirements, GAO was asked to	 
examine (1) the status of state efforts to meet NCLBA's teacher  
qualification requirements, (2) the use of Title II funds in	 
selected districts, and (3) how the U.S. Department of Education 
(Education) monitors states and assists them with implementation 
of the requirements. To obtain this information, GAO reviewed	 
teacher qualifications data submitted to Education by 47 states, 
conducted site visits to 6 states selected for variance in	 
factors such as teacher requirements and geographic location,	 
visited 11 school districts across these states identified as	 
high-need, and interviewed national experts and Education	 
officials.							 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-06-25						        
    ACCNO:   A41877						        
  TITLE:     No Child Left Behind Act: Improved Accessibility to      
Education's Information Could Help States Further Implement	 
Teacher Qualification Requirements				 
     DATE:   11/21/2005 
  SUBJECT:   Aid for education					 
	     Educational standards				 
	     Educational testing				 
	     Employment requirements				 
	     Federal/state relations				 
	     Funds management					 
	     Monitoring 					 
	     Teacher education					 
	     Professional development				 

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GAO-06-25

Contents

Letter 1

Results in Brief 3
Background 5
States Have Made Progress in Meeting Teacher Qualification Requirements,
but Challenges Remain 16
Visited School Districts Most Often Used Title II Funds for Professional
Development 27
Education Monitored States and Offered Assistance on Implementing the
Requirements, but Some of Education's Information Was Not Readily
Accessible 36
Conclusions 43
Recommendation for Executive Action 44
Agency Comments and Our Evaluation 44
Appendix I Activities on Which States and Districts Can Spend Title II,
Part A, Funds 46
Appendix II State-Reported Percentage of Core Academic Classes Taught by
Teachers Meeting NCLBA's Teacher Qualification Requirements in the
2003-2004 School Year 48
Appendix III Sample HOUSSE Procedures from Two States Visited 50
Appendix IV Comments from the U.S. Department of Education 53
Appendix V GAO Contact and Staff Acknowledgments 54
Related GAO Products 55

Tables

Table 1: Major Findings from Education's Title II Monitoring 38
Table 2: NCLBA's Criteria for HOUSSE Procedures 39
Table 3: Title II, Part A, State Activities 46
Table 4: Title II, Part A, District Activities 47

Figures

Figure 1: Federal Teacher Qualification Criteria 8
Figure 2: Phase-in of Teacher Qualification Requirements 11
Figure 3: Overview of HOUSSE Point Systems in Site Visit States 19
Figure 4: Information on Teacher Qualifications Available through
Education's Web Site, as of August 2005 43

Abbreviations

HOUSSE High Objective Uniform State Standard of Evaluation

IDEA Individuals with Disabilities Education Act

LEA local education agency

NCLBA No Child Left Behind Act

TAC Teacher Assistance Corps

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United States Government Accountability Office

Washington, DC 20548

November 21, 2005

The Honorable John A. Boehner Chairman The Honorable George Miller Ranking
Minority Member Committee on Education and the Workforce House of
Representatives

Although research over the past 10 years has shown that teachers play a
significant role in improving student performance, many teachers,
especially those in high-poverty districts, lack competency in the
subjects they teach. Recognizing this, the Congress passed the No Child
Left Behind Act of 2001 (NCLBA), which established qualification
requirements for the nation's approximately 3 million public school
teachers, and made states, districts, and schools responsible for ensuring
that teachers meet these requirements. Specifically, the act requires that
teachers of core academic subjects such as math and science be "highly
qualified" by the end of the 2005-2006 school year. 1 To meet the
requirements, teachers must (1) have at least a bachelor's degree, (2) be
certified to teach by their state, and (3) demonstrate subject matter
competency in each core academic subject they teach. Under the act,
teachers may demonstrate subject matter competency through different
avenues, including a state-developed High Objective Uniform State Standard
of Evaluation (HOUSSE). State HOUSSE procedures give veteran
teachers-generally those with 1 or more years of experience-the
opportunity to demonstrate subject matter competency through teaching
experience, professional development, coursework, and other activities. If
teachers do not meet the requirements, school districts may be required to
take certain actions, such as providing additional professional
development.2

1 In its October 21 letter to the states, the Department of Education
(Education) indicated that states demonstrating a good-faith effort to
meet the teacher qualification requirements will have until the end of
2006-2007 school year for all teachers to become highly qualified.
Education acknowledged the effects of Hurricane Katrina on the ability of
some states to meet the teacher qualification requirements by the
deadline, and noted in this and other correspondence that it will work
with affected states and school districts to determine whether any
flexibility will be needed with regard to implementing these requirements.
As of October 21, Education had not granted any waivers regarding the
teacher qualification requirements to affected states, but indicated that
it may consider certain waivers or additional flexibility, depending on
state's needs. Education indicated in a September 21 letter to Louisiana
that it may extend the deadline for reporting on the state's
implementation of NCLBA provisions, including reporting on the status of
teachers in meeting the requirements, if the states determine that
additional time is needed. In response to Mississippi's request for a
waiver of the teacher qualification requirements, Education noted in a
September 12 letter to the state that it would continue to review this
matter and would like more information to assess the state's specific
needs. Finally, Education noted in a September 21 letter to Texas that it
will postpone its monitoring visit to assess the state's implementation of
the teacher qualification requirements, originally scheduled for December
2005.

To help states and districts meet NCLBA's teacher qualification
requirements, the Congress has appropriated approximately $3 billion a
year in grants through the Title II, Part A (Title II), of NCLBA since the
law was passed. This amount constituted about 7 percent of all federal
funds made available to states in 2004 for supporting education in
kindergarten through 12th grade. Title II replaced the Eisenhower
Professional Development and Class-Size Reduction programs, allowing
states and districts to use funds for similar purposes, including training
of teachers and hiring of additional teachers to reduce class size, as
well as various other activities to help recruit, retain, and develop
teachers. The Department of Education (Education) monitors states'
implementation of NCLBA and provides assistance to states to help them
understand the teacher qualification requirements in the act and
appropriate uses of Title II funds.

In our prior work, we found that states and districts faced challenges in
ensuring that teachers met the requirements and also generally did not
have data systems that could track teacher qualifications by subject in
order to determine teachers' status in meeting the requirements for those
subjects.3 In response to congressional requests, we are providing
information on (1) the status of state efforts to meet NCLBA's teacher
qualification requirements, (2) the use of Title II funds in selected
districts, and (3) how Education monitors states and assists them with
implementation of the requirements.

To obtain this information, we used multiple data collection methods.
First, to provide a national perspective, we reviewed teacher
qualification data in the consolidated performance reports that 47 states
submitted to Education for the 2003-2004 school year, the latest year for
which these reports were available. The remaining 3 states, the District
of Columbia, and Puerto Rico did not provide these data to Education. We
identified several factors that affect the accuracy of these data and
preclude a comparison of classes taught by teachers meeting the
requirements across states. However, on the basis of our work, we
determined state-reported percentages could be used to demonstrate how
close a particular state was to reaching the goal of having all its
teachers meet the requirements. The extent of the data limitations is not
currently known, and Education has followed up with all states to obtain
additional information on their processes for collecting these data.
Second, to provide information on how selected states and districts are
implementing the requirements and using Title II funds, we visited and
interviewed officials in 6 states-California, Colorado, Kansas, Maryland,
Rhode Island, and Tennessee-to collect in-depth information on their
efforts to meet teacher qualification requirements and use of Title II
funds. These states were selected for variance in procedures for teachers
to demonstrate subject matter competency, reported quality of their data
systems, amount of Title II funds received, and geographic location. At
the time of our site visits, none of the states had been visited for
monitoring purposes by Education. Across these states, we visited 11 of
the nation's 14,466 school districts, including both urban and rural
districts that state officials had identified as high-need based on their
poverty level and teacher challenges they experienced. We also interviewed
officials from Education, national education organizations, and teachers'
unions. In addition, we reviewed Title II monitoring reports completed by
Education as of July 2005. Finally, we analyzed Education's documents and
Web site, legislation, and other materials related to the teacher
qualification requirements and Title II funds. We conducted our work
between November 2004 and October 2005 in accordance with generally
accepted government auditing standards.

2 In its October 21 letter to the states, Education indicated that it
reserves the right to take appropriate action including the withholding of
funds if states are not in compliance with the statutory teacher
qualification requirements or are not making a good-faith effort to ensure
that all teachers meet the qualification requirements.

3 See GAO, 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).

                                Results in Brief

The data reported by 47 states to Education suggest that the majority of
core academic classes were taught by teachers who met NCLBA requirements
during the 2003-2004 school year. States have improved in their ability to
track and report the percentage of core academic classes taught by
teachers who met NCLBA qualification requirements, but several limitations
affect the quality and precision of state-reported data, making it
difficult to determine the exact percentage of core academic classes
taught by teachers meeting the requirements. Five of the 6 states that we
visited had HOUSSE procedures in place that offered multiple options for
veteran teachers-generally those with 1 or more years of experience-to
demonstrate subject matter competency, such as through a combination of
experience, academic coursework or professional development, and
leadership or service activities. Three of these states also used other
methods of evaluating teachers' subject matter knowledge as part of their
HOUSSE procedures, such as observing teachers' performance or assessing
teachers' contributions to student achievement. Despite the number of ways
allowed for teachers to demonstrate subject matter competency, state and
district officials and national association representatives told us that
teachers providing instruction in multiple core academic subjects, such as
teachers in rural schools with a small teaching staff, would likely face
difficulty in meeting the requirements by the deadline of school year
2005-2006.

The 11 school districts that we visited used Title II funds to provide
professional development for teachers, particularly in core academic
subjects. Officials in the majority of these districts also told us that
NCLBA's emphasis on student achievement and on strategies supported by
research had led to improvements in the kinds of professional development
they funded with Title II funds. Officials in 7 of the 11 districts
indicated that they continued to use Title II funds to support class size
reduction efforts, but some district officials told us that they had begun
shifting emphasis from class size reduction to professional development.
In identifying appropriate uses of Title II funds, most districts that we
visited considered student achievement needs and then targeted programs,
such as professional development, to those academic subjects where
students were lagging behind. However, only a few of these efforts
targeted specific groups of teachers, such as teachers in high-poverty
schools. Title II funds are generally a small part of total funds
available to the districts for teacher initiatives, and districts visited
also used non-Title II funds to address their teachers' needs, including
other federal, state, and local funds. For example, one district used
other federal funds to help teachers prepare for subject matter exams;
another district used private foundation funds to provide financial
incentives for teachers who accepted positions in the district's most
struggling schools.

Education monitored states' efforts to meet the teacher qualification
requirements through its Title II monitoring process and offered
assistance to states and districts that included professional development
for teachers, on-site visits, and guidance. In the 20 state monitoring
reports that Education had issued as of July 2005, it identified several
areas of concern related to states' implementation of the teacher
qualification requirements. For example, one frequent finding was that
states did not require teachers of history, geography, civics/government,
or economics to demonstrate subject matter competency in each subject
taught, as required under NCLBA, but instead allowed them to demonstrate
competency in the broad subject of social studies. Education also offered
a variety of assistance both to the nation's approximately 3 million
public school teachers and to state officials responsible for implementing
the requirements. To assist teachers, Education offered professional
development opportunities during 2004 and 2005 that were attended by about
4,500 teachers and distributed 255,000 "Toolkit for Teachers" information
packets. Assistance to state officials included site visits to discuss
NCLBA's teacher qualification requirements and offer technical assistance,
information on innovative state and local initiatives, and guidance.
Education officials said that the department's Web site has been an
important part of their efforts to implement NCLBA's teacher qualification
requirements. However, officials from most states and districts that we
visited told us that they were unaware of some of these resources or had
difficulty locating them, even though they use Education's Web site to
access information on teacher requirements and programs. For example,
officials from 4 states told us that information on other states' efforts
to improve teacher qualifications would be helpful, but they were unaware
that Education offered this online. Our review of Education's Web site
found that resources on NCLBA's teacher qualification requirements were
located on several different Web pages that were sometimes not linked,
making it challenging to find them.

To help states address the issues of teacher quality and ensure that all
teachers meet NCLBA's qualification requirements, we are recommending that
the Secretary of Education explore ways to make the Web-based information
on teacher qualification requirements more accessible to users of its Web
site through such activities as more prominently displaying the link to
state teacher initiatives or enhancing the capability of the search
function.

                                   Background

The NCLBA of 2001 amended and reauthorized the Elementary and Secondary
Education Act, the largest and most comprehensive federal education law.
The focus of this legislation is on improving students' academic
performance. A growing body of research has shown that teacher
effectiveness is a significant factor in improving students' academic
performance. Research has also shown that many children, especially those
in high-poverty and high-minority schools, are assigned to teachers who
lack knowledge of the subjects they teach. For example, a 2004 report
stated that one out of four high school courses was being taught by
teachers without a college major, or even a minor, in the subject taught,
and that students in high-poverty classrooms were more likely to be
assigned to such teachers than students in low-poverty classrooms.4

Historically, states have been responsible for developing and
administering their education systems, and most states have delegated the
authority for operating schools to local governments. States and local
governments provide most of the money for public elementary and secondary
education. Education reported that 49 percent of the revenue for public
elementary and secondary education in the 2001-2002 school year came from
state sources, 43 percent came from local sources, and 8 percent came from
federal sources.5 As a result, state and local dollars fund most major
expenses, such as teacher salaries, school buildings, and transportation.
Although the autonomy of districts varies, states are responsible for
monitoring and assisting their districts that, in turn, monitor and assist
their schools.

The federal government has played a limited but important role in
education. Education's mission is to ensure equal access to education and
promote educational excellence throughout the nation by, among other
things, supporting state and local educational improvement efforts,
gathering statistics and conducting research, and helping to make
education a national priority. Education is responsible for providing
assistance to states to help them understand the provisions or
requirements of applicable laws and oversees and monitors how states
implement them. With the passage of NCLBA, which requires public school
teachers to be highly qualified in every core academic subject they teach,
6 the federal government for the first time established specific criteria
for teachers.

The act requires all teachers of core academic subjects to have a
bachelor's degree, state certification, and demonstrable subject matter
competency for each core subject taught.7 Under the act, teachers may not
have state certification requirements waived on an emergency, temporary,
or provisional basis. According to the Education Commission of the States,
every state required 4 years of college preparation for teacher
certification as of 1974. However, ensuring that all teachers are
certified and can demonstrate competency in the subject matter they teach
presents a new challenge for many states. Allowable ways for teachers to
demonstrate subject matter competency vary depending upon a teacher's
experience and the grade level being taught. (See fig. 1.) For example,
elementary teachers new to the profession must pass a state test to
demonstrate subject knowledge and teaching skills. States have the
flexibility to identify and approve such tests for new teachers, as well
as establish the passing scores on the tests. Middle school and high
school teachers have a number of options available to them for
demonstration of subject matter competency, including a college major or a
state test in the subject taught. In addition to the options available for
new teachers, veteran teachers have an additional avenue for demonstrating
subject matter competency through their state's HOUSSE procedures.8

4 "The Real Value of Teachers," Thinking K-16, Vol. 8, Issue 1 (The
Education Trust, Winter 2004).

5 U.S. Department of Education, National Center for Education Statistics,
The Condition of Education 2005. (U.S. Department of Education, Institute
of Education Sciences, 2005).

6 Core subjects include English, reading or language arts, mathematics,
science, foreign languages, civics and government, economics, arts,
history, and geography.

7 NCLBA requirements make an exception in the certification requirement
for charter school teachers. The law provides that teachers in charter
schools meet the certification requirements set forth in their state's
charter school law regarding certification or licensure. A recent GAO
survey found that officials in 13 of the 39 surveyed states reported that
their state law exempted charter school teachers from certification
requirements.

8 We use the term "veteran teacher" to refer to teachers who are not new
to the teaching profession. Education's August 2005 guidance says that
states have the authority to define which teachers are new and not new to
the profession, as long as these definitions are reasonable. According to
the guidance, Education believes that teachers with less than 1 year of
experience should be considered new and therefore must meet subject matter
competency requirements using the methods allowable for new teachers.

Figure 1: Federal Teacher Qualification Criteria

aMust be a rigorous state test assessing subject and teaching skills in
reading, writing, mathematics, and other areas of the basic elementary
curriculum.

bMust be a rigorous state test in the academic subject taught.

cAn example is the attainment of a National Board Certification in the
subject and grade level taught.

States can make the HOUSSE option available to veteran teachers at all
grade levels. The act sets forth some general criteria for states to use
in developing an acceptable evaluation standard. For example, the standard
must be developed in a way that provides objective and coherent
information about the teacher's attainment of core content knowledge, must
be aligned with state academic content and student achievement standards,
and must be uniformly applied to all teachers of the same subject and
grade level in the state.

In March 2004, Education announced additional flexibilities to help
teachers who deliver instruction in multiple core academic subjects and
science teachers meet the requirements. Education announced that veteran
teachers who provide instruction in multiple core academic subjects will
be able to demonstrate their subject matter competency through a single
set of procedures, such as a single, streamlined HOUSSE covering multiple
academic subjects. Education also announced that teachers in eligible
rural areas who teach multiple core academic subjects and meet the
requirements in at least one of those subjects would have additional time
to demonstrate subject matter competency in the other subjects. Further,
Education allowed states to rely on their own certification requirements
for science to determine specific science areas in which teachers will be
required to demonstrate subject matter competency. For example, if a state
certified teachers in the general field of science, then a teacher may
demonstrate subject matter competency in the general science area instead
of each separate science subject, such as physics or biology.

According to Education's August 2005 nonregulatory guidance, the NCLBA
teacher qualification requirements apply to special education teachers who
provide instruction in core academic subjects, such as teachers in
self-contained classrooms.9 These teachers may demonstrate subject matter
competency by using any of the options allowed to other teachers under
NCLBA.

Qualification requirements for special education teachers were modified in
the December 2004 reauthorization of the Individuals with Disabilities
Education Act (IDEA).10 The reauthorized IDEA allowed some special
education teachers additional flexibility in terms of meeting subject
matter competency requirements. First, new special education teachers at
the elementary level who are teaching exclusively children with
significant cognitive disabilities may use the state HOUSSE procedures to
demonstrate subject matter competency, an option otherwise reserved under
NCLBA to veteran teachers.11 Second, new special education teachers who
teach multiple core academic subjects exclusively to special education
students and already meet the requirements in mathematics, language arts,
or science, have 2 years after hiring to demonstrate subject matter
competency in the other subjects taught. Teachers in this second category
may also do this through the HOUSSE process, including a single evaluation
covering all academic subjects taught. Finally, veteran special education
teachers who teach multiple core academic subjects exclusively to special
education students have the option of demonstrating subject matter
competency through a multisubject HOUSSE, consolidated to assess teachers'
subject matter knowledge in multiple subjects through a single process.

9 A self-contained classroom is one in which the students stay with their
teacher all day and for all academic subjects. In these classrooms, the
special education teacher is responsible for providing instruction in more
than one core academic subject and thus would need to demonstrate subject
matter competency in each of the subjects taught.

10 IDEA is the primary federal law that addresses the educational needs of
students with disabilities. Among other provisions, the law mandates that
a free appropriate public education be made available to all eligible
children with disabilities and requires an individualized education
program for each student.

11 Under IDEA, states can determine the level of instruction provided by
middle and high school teachers who teach students with significant
cognitive disabilities. If the level of instruction that is being provided
is equivalent to the level of instruction at the elementary level, the
requirements for elementary teachers apply.

The deadline for teachers to meet the requirements depends on the type of
school in which they work. Starting with the first day of the 2002-2003
school year, all new teachers hired into school programs supported with
Title I funds must demonstrate compliance with the requirements
immediately upon hire.12 Most other teachers have until the end of
2005-2006 school year to meet the requirements in the law. The current
timelines for teachers to meet the requirements are shown in figure 2.13

12 Title I, Part A, of the Elementary and Secondary Education Act,
allocated more than $12 billion in fiscal year 2004 to serve disadvantaged
students in approximately 90 percent of the nation's school districts.

13 In October 2005, Education announced that states showing sufficient
effort in implementing the teacher qualification requirements but still
falling short of having all their teachers meet them by the end of
2005-2006 school year, will be able to negotiate with Education a plan for
achieving that goal by the end of 2006-2007 school year.

Figure 2: Phase-in of Teacher Qualification Requirements

Prior GAO work found that states and districts were experiencing
challenges implementing NCLBA's teacher qualification requirements. Among
the most commonly cited challenges were difficulties with teacher
recruitment and retention resulting from factors such as low teacher pay,
lack of adequate professional development opportunities, and difficulty
developing and implementing state data systems for tracking teacher
qualifications.14 We found that challenges were especially acute in small,
isolated rural districts where teachers often had to teach multiple
subjects across different grade levels.15 Furthermore, although we found
that all states required that special education teachers have a bachelor's
degree and be certified to teach-two of the three NCLBA teacher
qualification requirements-many states did not require them to demonstrate
subject matter competency. As the result, we concluded that
state-certified special education teachers who were assigned to teach core
academic subjects might not be positioned to meet NCLBA requirements.16 In
the aftermath of Hurricane Katrina, states and districts faced with large
numbers of displaced teachers and students may have additional challenges
tracking teacher qualification status and ensuring that all teachers meet
the requirements by the deadline. Education indicated that it will work
with affected states and school districts to determine what flexibility
will be needed with regard to implementing the teacher qualification
requirements.

14 See GAO-03-631.

15 See GAO, No Child Left Behind Act: Additional Assistance and Research
on Effective Strategies Would Help Small Rural Districts, GAO-04-909
(Washington, D.C.: Sept. 23, 2004).

Federal funding for teacher initiatives was provided prior to NCLBA, but
the act increased the level of funding to help states and districts
implement the teacher qualification requirements. Prior to NCLBA, the
Eisenhower Professional Development and Class-Size Reduction programs
provided funds to the states primarily for professional development in
mathematics and science and efforts to reduce class size for students in
kindergarten through third grade. Title II replaced these two programs,
providing states and districts with approximately $2.85 billion for fiscal
year 2002 to help them implement various initiatives for raising teacher
and principal qualifications-$740 million more than provided in fiscal
year 2001 under the previous two programs. In fiscal year 2004, Title II
provided $2.93 billion to states and districts through Improving Teacher
Quality State Grants.

The formula currently used to allocate funds to states and districts is
similar to the formula used under the Eisenhower Professional Development
and the Class-Size Reduction programs and takes into account poverty and
student enrollment. Specifically, the amount of Title II funds that each
state or district receives is based on its 2001 allocation under the two
previous programs, the number of children aged 5 to 17, and the number of
those children residing in families with incomes below the poverty line.17
After reserving up to 1 percent of the funds for administrative purposes,
states allocate 95 percent of the remaining funds to the districts. They
retain 2.5 percent to support state-level teacher initiatives and allocate
the remaining 2.5 percent to the state agency for higher education to
support partnerships between higher education institutions and high-need
districts that work together to provide professional development to
teachers.

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

17 For 2004, the poverty threshold was $19,484 annually for a family of
four.

While there is no formula in NCLBA for districts to allocate funds to
specific schools, the act requires states to ensure that districts target
funds to those schools with the highest number of teachers who are not
highly qualified, the largest class sizes, or that have been identified to
be in need of improvement. In addition, districts applying for Title II
funds from their states are required to conduct a districtwide needs
assessment to identify their teacher quality needs. Among other things,
the needs assessment should identify those needs that must be addressed if
the district is to have all its teachers meeting NCLBA's requirements by
the deadline. The needs assessment should take into account activities
needed to provide teachers with the means for helping students meet
challenging state and local academic achievement standards. Districts must
involve teachers in the development of their needs assessment and may
consider a variety of factors, such as teacher and student achievement
data and projections of professional development necessary to help all
teachers meet NCLBA's qualification requirements.

Under Title II, acceptable uses of funds include teacher certification
activities, professional development in a variety of core academic
subjects, and recruitment and retention initiatives, including hiring
teachers in order to reduce class size. (See app. I for state and district
authorized activities.) Some of these activities, such as recruitment of
new teachers and professional development in math and science, could be
funded under the Eisenhower Professional Development and Class-Size
Reduction programs as well. However, states and districts have more
flexibility in how to spend Title II funds than was previously possible.
For example, while under the Class-Size Reduction Program, funds could be
spent on financial incentives and mentoring programs for new teachers
only, Title II funds can be used for existing teachers as well, if the
district identifies a need. While the Eisenhower program focused primarily
on professional development in math and science, allowable activities
under Title II may include any subject. Under NCLBA, professional
development is considered to be an important component of the overall
strategy to improve the quality of teaching and raise student achievement,
and the law provides the definition of professional development.18

In addition to using Title II funds for the purposes of raising teacher
qualifications, districts can also transfer these funds to most other
NCLBA programs to meet their educational priorities. Specifically,
districts are allowed to transfer up to 50 percent of the funds allocated
to them under most major NCLBA programs, including Title II, into other
programs under NCLBA.19 Thus, for example, districts may transfer a
portion of their Title II funds into Title I for initiatives designed to
improve student achievement.

Regardless of whether or not districts transfer funds under the
transferability option, they can spend non-Title II funds, such as Title I
funds, to support teacher initiatives. Under NCLBA, districts are required
to spend at least 5 percent of their Title I funds on helping teachers
meet the qualification requirements. Additionally, schools in the district
that do not meet their student proficiency goals for 2 or more consecutive
years are required to spend at least 10 percent of their Title I funds to
provide the school's teachers and principals with high-quality
professional development.

States must prepare and publicly disseminate an Annual State Report Card
with information on the professional qualifications of teachers in the
state, the percentage of such teachers on emergency or provisional
credentials, and the percentage of core academic classes being taught by
teachers who do not meet NCLBA's teacher qualification requirements.
Further, Title I of NCLBA requires districts and schools to inform parents
about the qualifications of their children's teachers. Districts are
required to notify parents of all students attending Title I schools that
they have the right to request information about the qualifications of
their child's teacher. Schools must further notify parents if their child
has been taught by a teacher who did not met NCLBA's teacher qualification
requirements for 4 or more consecutive weeks.

18 NCLBA defined professional development in Title IX of the act. Among
other things, the definition emphasizes the type of professional
development that increases teachers' academic knowledge, gives teachers
the knowledge and skills to provide students with the opportunity to meet
challenging state content and student achievement standards, is sustained
and intensive rather than short-term, and increases teachers'
understanding of effective instructional strategies that are based on the
principles of scientifically based research.

19 Under Title VI of NCLBA, a district meeting its annual student
proficiency goals may transfer up to 50 percent of the funds allocated
under any of the following programs: Title II, Part A (Improving Teacher
Quality State Grants); Title II, Part D (Educational Technology State
Grants); Part A of Title IV (Safe and Drug-Free Schools and Communities);
and Part A of Title V (State Grants for Innovative Programs). Districts
not meeting their student proficiency goals for at least 2 years are
identified for improvement and cannot transfer more than 30 percent of
their funds under any given program. Districts not meeting their goals for
at least 4 years are identified for corrective action and are prohibited
from transferring funds under this option.

The accountability provisions under Title I of NCLBA require every state
and district receiving Title I funds to develop and submit a plan for how
it intends to meet the teacher qualification requirements, along with
other provisions of the act such as adopting challenging academic content
and student achievement standards. The state plan must establish each
district's and school's annual measurable objectives for increasing the
number of teachers meeting qualification requirements and receiving
high-quality professional development with the goal of ensuring that all
teachers meet the requirements by the end of the 2005-2006 school year. In
addition, beginning with the 2002-2003 school year, districts receiving
Title I funds are required to annually report to the state on their
progress toward state-set objectives, and all states are required to
submit an annual report to Education detailing state progress in meeting
the annual measurable objectives regarding teacher qualification
requirements. Under NCLBA, school districts that do not ensure that their
teachers meet the qualification requirements must implement certain
actions, such as additional professional development. However, their
overall funding levels from Education are not affected.20 If states do not
meet the requirements for reporting on the qualifications of their
teachers, the Secretary of Education has the authority under NCLBA to
withhold state administrative funds.

20 Under Section 2141 of NCLBA, if the district falls short of its annual
measurable objectives for ensuring that teachers meet qualification
requirements for 2 consecutive years, it has to develop an improvement
plan. During the development of the improvement plan, the state must
provide technical assistance to the district and to any schools served by
the district that would enable it to meet its teacher qualification
objectives. If the district continues to fall short of its annual
measurable objectives and is also failing to meet its annual student
proficiency goals for 3 consecutive years, the state has to enter into an
agreement with the district. Under that agreement, the state works with
the district to develop professional development strategies for teachers
and principals to help the district meet its teacher qualification
objectives, and in most cases the district cannot use Title I funds for
hiring new paraprofessionals.

Education monitors states' progress in implementing the requirements under
both Title I and Title II of the act, as well as provides assistance to
them. Beginning with the 2002-2003 school year, Title I of the act
requires Education to publicly report the annual progress of states,
districts, and schools in meeting the measurable objectives for ensuring
that all teachers meet the qualification requirements by the deadline.

  States Have Made Progress in Meeting Teacher Qualification Requirements, but
                               Challenges Remain

The available data suggest that the majority of core academic courses were
taught by qualified teachers in 2003-2004. States have made progress in
tracking and reporting teacher qualification data, but challenges remain
in reporting precise results. States offered multiple options for veteran
teachers to demonstrate subject matter competency as part of their HOUSSE
procedures, but the rigor of these procedures varied across the states
that we visited. Selected state and district officials told us that
certain groups of teachers would likely face challenges meeting the
requirements by the 2005-2006 deadline.

Most States Reported That the Majority of Teachers Are Qualified, but Some Data
Issues Remain

The data reported by 47 states suggest that the majority of core academic
classes were taught by teachers who met NCLBA requirements during the
2003-2004 school year.21 Most of these states reported that nearly all of
their core academic classes were being taught by teachers who met the
requirements. However, data for most states appear to show that core
academic classes in low-poverty schools were more likely to be taught by
teachers who met the requirements than classes in high-poverty schools. 22
The data also suggest that a higher percentage of elementary school
classes were taught by teachers who met the requirements than secondary
school classes. State-reported percentages for each of the 47 states are
shown in appendix II.23 Data limitations preclude a comparison among
states but, on the basis of our work, we determined state-reported
percentages could be used to demonstrate how close a particular state was
to reaching the goal of having all its teachers meet the requirements.

21 These states include approximately 97 percent of all public school
students in the country.

22 High-poverty and low-poverty schools are respectively those in the top
and bottom quartiles of poverty in the state; most states based this on
the percentage of students eligible for free or reduced lunch in the
school.

23 Education has followed up with four of the five entities that did not
provide data. Officials indicated that changing definitions and challenges
with data systems were among the reasons for not providing data.
References to Education's efforts to collect and assess teacher
qualifications data from the states includes the work completed by
Education's data quality contractor.

States have improved in their ability to track and report the percentage
of core academic classes taught by teachers who met NCLBA qualifications.
Reports from 2002 and 2003 from national education organizations, such as
the Education Commission of the States, showed that few states were able
to track and report these data. Similarly, in our 2003 report on the NCLBA
teacher qualification provisions, officials in 7 of the 8 states we
visited told us they did not have data systems capable of tracking teacher
qualifications for each core subject.24 But by 2005, 47 states reported
teacher qualification data to Education for the 2003-2004 school year.
Officials in the 6 states that we visited told us that they had improved
their data systems, either by creating a new system or by redesigning
their existing system to collect information required under NCLBA. For
example, several states merged their state-level teacher qualification
systems with their district-level class assignment systems to enable them
to determine whether classes were being taught by teachers who met the
requirements. Education officials also told us the 2003-2004 data had
considerably improved from earlier years and that next year's data will
accurately reflect the status of state efforts to implement the teacher
qualification requirements.

Despite this progress, several issues limit the quality and precision of
state-reported data and make it difficult to determine the exact
percentage of core academic classes taught by teachers meeting NCLBA
qualification requirements. First, district officials in 3 of the 6 states
that we visited told us that they had excluded classes taught by special
education teachers from their calculations;25 state officials in all 6
site visit states said these teachers faced particular challenges in
meeting the requirements. Second, states relied on the data districts
provided, but state officials generally noted that data collection
processes varied by district, and that the quality of the data could vary
as well. For example, two districts that we visited in 1 state reported
data that were based on an incorrect assumption about which teachers met
the requirements,26 and therefore included some teachers as meeting the
requirements when they had not. Education also identified data problems in
13 of the 20 states for which it issued monitoring reports by July 2005.27
The impact and magnitude of these problems on state reports is unclear;
state-reported data may under- or overstate the percentage of classes
taught by teachers who met the requirements, depending on the nature of
the data problem. Education has contracted with a research organization to
follow up with states to identify any data issues that may have affected
state-reported data, such as states excluding certain teachers subject to
NCLBA's qualification requirements from their calculations.28

24 As part of that study, GAO visited California, Connecticut, Illinois,
Iowa, Maryland, North Carolina, Delaware, and Wyoming. See GAO-03-631.

25 Special education teachers must be included if they teach core academic
subjects.

26 District officials in this state told us that teachers with emergency
certification and a plan to meet the requirements counted as meeting the
requirements.

States Offered Multiple Options for Veteran Teachers to Meet the Requirements

Five of the 6 site visit states had HOUSSE procedures in place for veteran
teachers-those generally with 1 or more years of experience-to demonstrate
subject matter competency, and the procedures included many different
options for teachers to use as part of HOUSSE. The HOUSSE procedures in
these states included the use of a point system that allowed veteran
teachers to demonstrate subject matter competency by earning points in
categories of experience, academic coursework or professional development,
and leadership or service activities, as well as for evidence of
publications, presentations, or awards. Colorado officials said they did
not have a HOUSSE but allowed teachers to demonstrate subject matter
competency through options typically included in other states' HOUSSE
procedures, such as a combination of college coursework and professional
development options.29 Figure 3 presents an overview of HOUSSE point
systems from the 5 states we visited that had them in place. (App. III
shows HOUSSE point systems from 2 site visit states.)

27 These states did not overlap with our site visit states. Education's
findings are discussed in a subsequent section of this report.

28 Education's contractor plans to issue a report on its findings
regarding state teacher qualifications data in fall 2005.

29 Colorado allowed teachers to demonstrate subject matter competency
through accumulation of 24 college or professional development credits. Up
to one-fourth of these credit hours could be accumulated through travel
relevant to the subject area taught, such as travel to Greece for a
history teacher. Officials there indicated that to count travel toward
demonstration of subject matter competency, a teacher would need to
explain what was learned as the result of this travel and how this
knowledge would contribute to student performance, as well as demonstrate
how the travel enhanced his or her content knowledge. The responsibility
for ensuring the relevance of travel is with the districts, and state
officials did not know how often this option was actually used.

Figure 3: Overview of HOUSSE Point Systems in Site Visit States

aKansas and Maryland required teachers to earn a minimum number of points
in this category.

bThe maximum points listed are for regular education teachers. Special
education teachers may have different maximums.

cMaryland required elementary teachers to earn a minimum of 40 points in
this category and middle and high school teachers a minimum of 30 points.

dMaryland combined leadership, activities, service, awards, presentations
and publications into a single category with a maximum of 10 points.

eTennessee allowed teachers to earn up to 40 points for classroom teaching
experience and up to an additional 12 points for teaching content courses
at a postsecondary institution.

fTennessee recently revised its evaluation system to emphasize assessment
of teachers' subject matter knowledge. This updated evaluation system
places greater emphasis on the content taught and is performed by
evaluators trained in the new evaluation format. Teachers evaluated under
the new system can use that as a stand-alone option for meeting all the
subject matter competency requirements under the state's HOUSSE. Teachers
evaluated under the old system can earn up to 30 points through the
state's point system-up to 20 of those points can be earned for positive
evaluations, and up to 10 points are given to teachers who attained an
advanced level of performance under the Tennessee Career Ladder Evaluation
System, which had been in existence between 1985 and 1997. Although
teachers can continue using the former versions of state evaluations to
earn points toward demonstration of subject matter competency, officials
indicated that the new evaluation system is now used statewide to assess
the performance of all teachers.

In addition to the categories above, the point systems in two states that
we visited also included the option for teachers to demonstrate subject
matter competency through advanced certification. Teachers in Maryland and
Tennessee could earn all of the required points by achieving National
Board Certification.30

In addition to the point system, the HOUSSE procedures in some site visit
states offered alternatives for demonstrating subject matter competency.
For example, teachers in Tennessee could demonstrate subject matter
competency through multiple observations of their performance completed by
trained evaluators or the data showing their effect on student
achievement. Teachers in California who were unable to obtain the required
number of points through the point system could use evidence of positive
evaluations of their performance in the classroom or prepare a portfolio
of their work.31

Our review of HOUSSE procedures in states that we visited, particularly
the analysis of the points they allowed teachers to count for different
activities, showed that they varied in the weight given to these
activities. The extent to which certain activities reflect teachers'
subject matter knowledge may affect the rigor of these procedures.32 For
example, as shown in figure 3, Rhode Island allowed experience to count
for about one-fourth of the 100 points required for demonstrating subject
matter competency, but the other 4 states with HOUSSE procedures allowed
experience to count for about one-half of the points to be earned.
Officials in Colorado indicated that they had chosen not to count
experience toward teachers' demonstration of subject matter competency
because they did not believe that experience would necessarily translate
into improved subject knowledge. However, Colorado permitted relevant
travel to count toward demonstration of subject matter competency, whereas
the other states did not explicitly include travel in their HOUSSE.

30 The National Board for Professional Teaching Standards offers National
Board Certification in subject areas such as English language arts and
mathematics, requiring teachers to create a portfolio demonstrating their
work in the subject area and exercises to demonstrate their subject matter
knowledge. For more information, please see http://www.nbpts.org/.

31 Officials in California explained that their teacher preparation
program included subject-specific coursework, and they expected that their
veteran teachers would count points for college coursework and experience
before counting points for other activities on the state's HOUSSE.

32 Education had not yet monitored these states at the time of our site
visits.

Some site visit states also set a minimum number of points to be earned in
certain categories, while other states did not require teachers to earn
points from those categories. Specifically, Kansas and Maryland required
teachers to earn at least a portion of the total number of points they
needed to demonstrate subject matter competency through college
coursework, while other states did not require a minimum number of points
in that category. States also differed in the number of categories in
which teachers had to earn points. For example, teachers in Rhode Island
were required to earn points from at least three different categories,
such as college-level coursework and professional development in the
content area. In contrast, teachers in Maryland could earn all points
necessary for demonstration of subject matter competency from a single
category. California, Kansas, Rhode Island, and Tennessee also set a
requirement that some activities had been completed within a recent period
of time.33 For example, Kansas required professional development and
service activities to have taken place within the last 6 years to earn
points toward demonstrating subject matter competency under HOUSSE.

Some of the options that site visit states permitted as part of their
HOUSSE procedures relied on improved student performance or observations
of teachers' classroom performance. Tennessee allowed teachers to
demonstrate subject matter competency by using data that show their actual
contribution to students' achievement in that subject.34 To use this
option for the purposes of demonstrating subject matter competency,
teachers must demonstrate that the most recent 3-year average gain in the
achievement of their students is not detectably different from or is
better than the average gain for all students in the state. At the same
time, Tennessee and California both counted positive evaluations of
teachers' classroom performance as evidence that could be counted toward
subject matter competency. Although both states based these evaluations on
uniform performance standards established by the state, officials in these
states told us that they did not oversee the implementation of these
evaluations. As a result, we determined that they could not effectively
ensure the quality of evaluations. While we did not conduct an in-depth
review of how the evaluations of teachers' performance were carried out,
we identified two areas of concern for using this method as an objective
state standard. First, the number and duration of the evaluation sessions
may not provide enough information to determine subject matter competency.
Second, these evaluations may be conducted by personnel who are also
responsible for hiring and retaining teachers in the district, and thus
these evaluators may not be objective. In one small rural district that we
visited, the assistant superintendent responsible for evaluating the
teachers' subject matter competency told us that the evaluation process
was subjective.

33 Officials in California noted that the recency requirement applies to
professional development activities accepted under the state's HOUSSE.
Specifically, teachers can earn points only for those professional
development activities that had been completed after the adoption of the
state's professional development standards in 1997.

34 Such data are available for teachers through the Tennessee Value-Added
Assessment System.

Finally, while most states that we visited tried to ensure that activities
accepted as part of their HOUSSE procedures were connected to the subject
area that the teacher taught, Maryland's HOUSSE procedure awarded points
for activities not directly related to the subject matter, such as
professional development on instructional strategies and principles.
Officials there indicated that the majority of points had to be earned
from activities specific to the subject matter, and that the state's
HOUSSE procedure sought to recognize both subject matter knowledge and the
teachers' general teaching expertise.

Some educational experts have noted that the rigor of HOUSSE procedures
varied across states and expressed concerns that states whose procedures
offered less rigorous options may not adequately assess teachers' subject
matter knowledge. The experts we interviewed told us that teachers who are
not required to engage in activities directly related to accumulating
subject matter knowledge, such as completing college coursework in a
subject, may not increase their knowledge of the subject taught. In
addition, the experts commented that if experience is heavily emphasized,
teachers may not get the subject matter knowledge they need to be
effective in the classroom. States with less rigorous procedures may not
bring about improvements in teachers' content knowledge or student
performance. Officials from Education confirmed that the rigor of HOUSSE
procedures varied across states, as is permitted under NCLBA.

Selected States and Districts Faced Implementation Challenges

Although numerous ways exist for veteran teachers to demonstrate subject
matter competency, officials in site visit states and districts and
national association representatives told us that some teachers providing
instruction in multiple core academic subjects, such as special education
teachers and teachers in rural areas and specialized school settings, may
not meet the requirements by the deadline. Officials in the states that we
visited noted that special education teachers would have the greatest
difficulty in meeting the requirements by the deadline, because they were
originally certified in special education rather than in a specific
academic content area. In addition, special education teachers frequently
provide instruction in multiple core academic subjects at the secondary
level, creating challenges in meeting the requirements for each subject.
Officials also noted that teachers in rural districts may face similar
challenges. For example, an official in one state described a rural
district landlocked by mountains where three high school teachers were
responsible for teaching all classes across all subjects and grades at the
high school level, and therefore had to meet the requirements for each
subject. Although under IDEA and Education's guidance certain special
education and rural teachers who already meet the requirements in one core
academic subject have additional time to meet the requirements for the
other subjects, officials were still concerned about whether these
teachers will be able to meet the requirements for all of the subjects.
Officials also reported challenges for middle school teachers who
frequently provide instruction in multiple core academic subjects,35 as
well as teachers in specialized school settings, such as schools for
students dismissed from their regular schools as a result of behavioral
problems. Officials from two districts in one state that we visited told
us that they had a large number of these specialized schools, and
officials there indicated that teachers often had to teach multiple
subjects to the same group of students, making it difficult for them
because they had to meet the subject matter requirements in each subject
taught. Education allowed states to streamline HOUSSE procedures by
developing a method for veteran teachers of multiple core academic
subjects to demonstrate subject matter competency in all those subjects
through a single procedure. One of the states that we visited offered a
streamlined HOUSSE procedure for its teachers of multiple core academic
subjects. However, officials in the other states that we visited did not
have a single HOUSSE procedure for teachers of multiple subjects, and some
of them indicated that they would like more information on how to develop
one.

Officials in states and districts that we visited also told us that
schools will continue to have difficulty recruiting math and science
teachers who meet the requirements. Schools had difficulty recruiting
these secondary teachers even before NCLBA. These recruitment shortfalls
will likely continue after the 2005-2006 deadline passes, in part because
thereafter all newly hired teachers of core academic subjects, not just
those in Title I schools, will have to demonstrate their subject matter
competency before entering the classroom. Some state and district
officials told us that they were unable to restrict hiring to teachers who
met the requirements because there were not enough candidates who had met
the requirements to fill all of the open positions. One state is altering
its emergency certificate to incorporate a time limit; this certificate
will allow teachers to provide instruction for up to 2 years before they
have to fully meet the subject matter competency requirements.36 While
state officials responsible for teacher licensing in the state
acknowledged that the new certificate does not meet the requirements of
NCLBA, they indicated that school districts might not be able to fill all
their open positions with teachers who meet the requirements.

35 According to the Department of Education, states have the flexibility
to determine whether middle school teachers-such as sixth grade teachers
in some districts-will have to meet the requirements for elementary or
secondary teachers, depending on the degree of rigor and technicality of
the subject matter that the teacher will need to know in relation to the
state's content standards and academic achievement standards for the
subjects that will be taught.

We also found that 8 of the 11 districts either did not notify parents
when their children were assigned to teachers who did not meet the
requirements, as required under the act, or did not make the notification
entirely clear to the parents. Five districts in the states that we
visited did not send the letters to the parents, with some district
officials stating that they did not know that the letters had to be sent.
Officials in one state instructed districts not to send the letters until
the 2005-2006 deadline had passed. Three districts in another state sent
letters to the parents, but these letters did not explicitly indicate that
the teacher did not meet the requirements of the law. For example, one
district's letter said that the teacher "is a dedicated professional who
will always work in the best interest of your child" and "holds a
probationary certificate" without explaining to the parents that
probationary certificates do not meet NCLBA's requirements.37

36 The new certificate will allow teachers with significant subject matter
competency coursework to teach for up to 2 years as long as they
demonstrate progress toward meeting the subject matter requirements. After
meeting the subject matter requirements, they can move into one of the
state's alternative certification programs to obtain a teaching
certificate. Under NCLBA, teachers in alternative certification programs
are considered to have met the requirements as long as they receive
high-quality professional development and intensive supervision, assume
the functions of a teacher for no more than 3 years, and demonstrate
satisfactory progress toward obtaining state certification.

Additionally, some officials did not know about other aspects of the
requirements, such as actions required for teachers not meeting the
requirements and to whom the requirements applied. For example, officials
in two states told us that they did not know what actions districts or
schools should take against teachers who did not meet the requirements by
the deadline. Officials in one district had fired teachers because they
did not meet the requirements. Other districts generally had not fired
teachers who did not meet the requirements but wanted to know whether they
should. There are no actions specified in the NCLBA with respect to
teachers' conditions of employment for those who do not meet the
requirements by the deadline. In addition, officials in one district did
not know until our visit that all teachers of core academic subjects-not
just those in Title I schools-would have to meet the requirements by the
end of 2005-2006 school year.

Education acknowledged the challenges that states may face in ensuring
that all teachers meet the requirements by the end of 2005-2006 school
year. On October 21, 2005, Education announced that states may have until
the end of the 2006-2007 school year to ensure that all their teachers
meet the requirements if they can demonstrate that they are making
good-faith effort toward that goal. As evidence of good-faith efforts,
states will need to meet the following four conditions: (1) show that the
state's requirements for teachers to demonstrate that they are highly
qualified are consistent with the law, (2) meet the requirements for
parental notification and public reporting, (3) provide complete and
accurate teacher qualification data to Education in January 2006 for the
2004-2005 school year, and (4) take action to ensure that poor and
minority students are not taught by teachers who do not meet the
requirements at a higher rate than other students. The letter also stated
that no federal funds will be withheld from states if they are unable to
ensure that all their teachers meet the requirements by the end of
2005-2006 school year, as long as these states are implementing the law
and making a good-faith effort to reach that goal.

37 Education monitors state and district efforts on this requirement
through its Title I monitoring. NCLBA does not make any provisions for
penalties for districts failing to make this notification.

Despite the challenges experienced, state officials reported progress in
better positioning themselves to meet NCLBA requirements. Although our
2003 report showed that states we visited generally did not have data
systems capable of tracking teacher qualifications for each core subject
teachers taught,38 officials told us that they had improved their data
systems since then. All of the states that we visited had either created a
new data system or redesigned their existing data systems to collect
information required under NCLBA. For example, several states merged their
state-level teacher qualification systems with their district-level class
assignment systems to enable states to determine whether classes were
being taught by teachers who met the requirements. Another state
redesigned its data system so that it would capture teachers' status in
meeting the requirements.

In addition to improving data systems, state officials also reported
taking steps to help more teachers meet the requirements. For example, one
of the states developed HOUSSE procedures that could be used to
demonstrate subject matter competency across multiple subjects. Under
those HOUSSE procedures, the same allowable activities, such as
professional development and leadership positions, could be counted for
more than one subject. Most states that we visited made some changes in
certification requirements or professional development standards to make
them more consistent with the requirements of NCLBA. For example, two
states created a separate certificate for middle school teachers that
incorporated subject matter competency requirements-a change that would
ensure that middle school teachers have demonstrated subject matter
competency.

District officials also reported taking steps, such as changing their
personnel policies, to ensure that more of their teachers meet the
requirements. For example, officials in two districts told us that they
had encouraged principals to consider dismissing teachers who were not on
track to meet the requirements. In another state, districts were
reassigning teachers to positions for which they met the requirements, and
one district's officials instituted a policy of preventing teachers from
transferring to any positions for which they did not meet the
requirements. Officials in most districts also told us that they have
incorporated NCLBA's teacher qualification criteria into their screening
of new candidates. Further, officials from 6 of the 11 districts that we
visited told us that they were reducing the number of teachers with
emergency credentials.

38 See GAO-03-631.

    Visited School Districts Most Often Used Title II Funds for Professional
                                  Development

The 11 districts that we visited used Title II funds to support
professional development for teachers, particularly in core academic
subjects. Officials in the majority of these districts indicated that
NCLBA had led to improvements in the kinds of professional development
they funded with Title II funds. Seven of the 11 districts that we visited
also continued to use the funds for class size reduction efforts. However,
district officials told us that they have begun shifting emphasis from
class size reduction to initiatives focused on improving teacher
qualifications. Most districts that we visited considered student
achievement needs in identifying appropriate uses of Title II funds and
targeted the funds to programs designed to help teachers address those
needs. Few initiatives in these districts targeted specific groups of
teachers, such as teachers in high-poverty schools. In addition to using
Title II, district officials told us they used various other funding
sources to support their teacher initiatives, including other federal,
state, and local funds.

All Visited Districts Used Title II Funds for Professional Development, and Many
of Them Used These Funds for Class Size Reduction

All districts that we visited used Title II funds to provide professional
development to teachers and focused their efforts on improving the quality
of instruction in core academic subjects such as reading and math. For
example, one district used Title II funds to provide summer workshops on
research-based instructional strategies in reading and paid for
instructional coaches to support classroom teachers throughout the year.
Two districts reported spending Title II funds on math coaches who perform
tasks such as working with teachers to develop lessons that reflected
states' academic standards and assisting them in using students' test data
to identify and address students' academic needs. In four districts, Title
II professional development expenditures included the cost of
instructional materials, and in one district Title II funds paid for
substitute teachers while regular teachers attended training.

In addition to spending for professional development in core academic
subjects, officials in 10 of the 11 districts reported using Title II
funds on professional development in other areas, such as on general
teaching strategies and professional development for nonteaching staff.
Most of these districts used at least some Title II funds for professional
development that focused on teaching skills and general teaching
strategies. For example, one district used Title II funds to support a
program for all teachers during their first 3 years of employment with the
district, including biweekly workshops on classroom management, student
assessment, and parental involvement. Another district used the funds to
help teachers understand the instructional needs of gifted and talented
students and to adjust teaching methods to best address those students'
needs. Seven districts also used Title II funds to offer professional
development for nonteaching staff, such as school administrative
personnel. For example, one district coordinated with a postsecondary
institution to train assistant principals on becoming more effective
educational leaders, while another district used the funds to develop
guidance counselors and social workers employed in the district's schools.

Officials in the majority of the districts that we visited told us that
NCLBA's emphasis on student achievement and on strategies supported by
research had led to improvements in the kinds of professional development
they funded with Title II funds. Officials said they had become much more
selective when approving professional development providers, looking for
those programs that focused on intensive, research-based instructional
strategies. In one district, for example, officials said that before
NCLBA, providers were often selected on the basis of their long-standing
relationship with the district, whereas now the district approved only
those providers whose programs could be substantiated by research-based
evidence of effectiveness. They also indicated that they had moved away
from onetime workshops and begun to emphasize ongoing professional
development that provided teachers with opportunities to reinforce and
apply concepts learned. Furthermore, district officials that we
interviewed reported greater emphasis on professional development
opportunities in core academic subjects in which NCLBA required students
to be assessed. While officials in some districts said that they were
moving in the direction of higher-quality professional development even
before NCLBA, several of them indicated that the passage of the act added
urgency to these efforts.

Officials in 7 of the 11 districts that we visited told us that they also
used Title II funds to hire additional teachers to reduce class size.
Districts focused their class size reduction efforts on specific grades,
depending on their needs and other funding sources available. For example,
one district visited focused its Title II-funded class size reduction
efforts on the eighth grade because the state already provided funding for
reducing class size in other grades. Officials in another district told us
they planned to spend most of their Title II allocation on class size
reduction because class size reduction funding from the state was
insufficient. While class size reduction may contribute to teacher
retention and result in a more individualized approach to student
instruction, it also increases the number of classrooms that need to be
staffed. As a result, districts that are already having problems with
teacher recruitment may find it difficult to find enough teachers who meet
NCLBA's qualification requirements to staff these classrooms. For example,
one district visited used about one-third of Title II funds for class size
reduction, but district officials indicated that recruitment difficulties
forced them to continue to hire teachers who did not meet NCLBA's
qualification requirements.

Our previous work found that classroom reduction expenditures amounted to
more than 50 percent of total Title II funds that districts spent during
2002-2003 school year,39 a finding consistent with Education's review of
districts' Title II spending during the same time period.40 Officials in
states that we visited and educational organization representatives that
we interviewed told us that districts continued to spend funds on
activities developed under the previous program. However, some state
officials told us that they were encouraging districts to expand their
traditional uses of these funds and to place a greater emphasis on
initiatives designed to increase teachers' effectiveness in the classroom.

In 6 districts that we visited, officials told us that they had begun
shifting away from class size reduction efforts to placing greater
emphasis on initiatives for existing teachers. For example, 2 of the
districts stopped spending Title II funds on class size reduction efforts,
and another district planned to eliminate class size reduction
expenditures in the next school year. Officials in 2 other districts told
us that while they still funded class size reduction efforts, they had
reduced the amount of Title II funds they spent for this purpose. District
officials indicated that they were now redirecting funds to support
initiatives designed to improve teachers' subject matter knowledge and
instructional skills, such as professional development.

In addition to undertaking professional development and class size
reduction efforts, 6 of the districts that we visited used Title II funds
to support recruitment and retention activities. For example, 2 districts
used the funds to advertise open teaching positions, as well as to attend
recruitment events outside of the district to identify qualified
candidates. Another district used Title II funds to expand its alternative
certification program, which allowed qualified candidates to teach while
they worked to meet requirements for certification. Two districts used
Title II funds for bonuses to attract successful administrators. To
promote greater retention among new teachers, 3 districts used Title II
funds for mentoring activities. For example, 1 of these districts reported
using the funds to provide two trained mentors for every new teacher. Ten
of the 11 districts that we visited did not use Title II funds to support
programs that offered additional pay to teachers based on their
performance or other qualifications. A few officials cited reasons for not
using such programs, such as the expense or the difficulties in ensuring
that they are implemented fairly.

39 Our survey of a nationally representative sample of school districts
during 2002-2003 school year showed that classroom reduction expenditures
accounted for 56 percent of total Title II funds districts spent. See
GAO-03-631.

40 Education's survey of a nationally representative sample of school
districts showed that they spent 58 percent of Title II funds on teachers'
salaries to reduce class size during 2002-2003 school year. See "Improving
Teacher Quality in U.S. School Districts; Districts' Use of Title II, Part
A, Funds in 2002-2003," Policy and Program Brief, U.S. Department of
Education, February 6, 2004.

Six of the districts that we visited reported taking advantage of NCLBA's
transferability option, with most of them transferring Title II funds into
Title V. Under Title V, districts receive funding to support local
education reform efforts in a broad range of areas, including activities
to improve the academic achievement of all students and raise teacher
effectiveness. For example, one district transferred Title II funds into
Title V for initiatives designed to address students' academic needs, such
as assessing their reading skills. Districts officials indicated that they
preferred to transfer funds into Title V because it afforded them the most
flexibility in spending the funds. However, one district transferred Title
II funds into Title I to provide academic services in reading and math to
middle school students.

In addition to participating in activities funded with districts' own
Title II allocations, teachers also took part in activities supported
through Title II grants to universities and in state-level Title II
initiatives. Three of the four university-based grantees that we visited
focused on providing professional development to teachers in math or
science. For example, one program reviewed offered a 2-week summer math
workshop to prepare teachers for the subject matter exams that, if passed,
could be used to demonstrate subject matter competency. Another university
grantee developed a standards-based online math program for middle school
teachers based on the math questions that students most frequently missed
on the state's assessment. While university officials administering that
program said that it could be used for teachers to earn points toward
demonstration of subject matter competency under NCLBA, they did not know
how many participants in the program had not yet met the requirements or
how many districts allowed teachers to apply their participation toward
earning points through the state's HOUSSE. Additionally, states used a
portion of Title II funds retained by state departments of education to
support professional development for teachers in core academic subjects.
In two states that we visited, officials reported that state Title II
initiatives specifically targeted teachers who had not met the subject
matter competency requirements of NCLBA; these initiatives either offered
them professional development in core academic subjects or reimbursed them
for taking college courses in the subjects taught.

Visited Districts Considered Student Achievement Needs in Identifying Uses of
Title II Funds

Officials in the districts that we visited said that in deciding what
specific initiatives should be funded with Title II funds, such as the
types of professional development programs for teachers, they considered
student achievement needs and targeted the funds to programs designed to
help teachers address those needs.41 To identify student achievement
needs, these officials said that their districts examined students'
results on state assessments and a school's progress in meeting annual
student proficiency goals in core academic subjects, as required under
NCLBA.42 The districts then targeted their Title II funds to programs for
teachers to improve instruction in those subjects in which students were
lagging behind. For example, officials in one district said that because
math was an area in which schools did not meet annual student proficiency
goals, the district's Title II expenditures were targeted to professional
development programs in math. In another district, the superintendent
indicated that his district had placed the primary focus of its Title II
initiatives on reading in early grades because schools in the district had
not met reading proficiency goals for elementary students in the past.
Some districts considered student achievement results in combination with
other factors to identify most appropriate uses of federal funds. For
example, officials in one district said that they looked at both schools'
student assessment results and teacher experience levels when deciding
where to place Title II-funded instructional coaches.

41 Two of the 11 districts reported using additional criteria in making
Title II funding decisions.

42 NCLBA requires states to develop annual measurable objectives for
adequate yearly progress that schools and districts must meet to ensure
that every student becomes proficient in math and reading/language arts by
school year 2013-2014.

Officials in the districts that we visited said that they involved a
variety of stakeholders, such as teachers and parents, to help them
identify district needs that could be addressed with Title II funds. The
nature of stakeholder involvement varied across the districts that we
visited. For example, several districts administered a survey to teachers,
parents, and students, asking them about their perceptions of the district
and its needs. Another district administered an online professional
development survey to its teachers, asking them to assess the type of
professional development activities received. District officials said they
used the results of these surveys to decide how to best spend Title II
funds. In other districts, officials considered stakeholders' perspectives
in less structured ways. For example, in one district that did not have a
separate process for gathering stakeholders' views prior to making funding
decisions, officials said that stakeholders' perspectives were still
considered as the result of the superintendent's regular meetings with
school officials and parent groups across the district.

While most districts that we visited targeted Title II funds to subject
areas that presented academic challenges to students, only a few of the
Title II funded initiatives were directed to specific groups of teachers,
such as teachers in high-poverty schools or teachers who had not yet met
the requirements of NCLBA. One district that we visited targeted Title II
dollars to teachers in high-poverty schools, funding initiatives such as
reimbursing these teachers for taking college classes necessary for them
to meet state certification requirements and providing tuition for
teachers in alternative certification programs who agreed to teach in
high-poverty schools. In four districts that we visited, officials
reported having initiatives specifically for teachers who had not yet met
NCLBA's qualification requirements. Some of these initiatives offered
reimbursement to teachers for taking college courses or other professional
development that they could use to demonstrate compliance with NCLBA's
requirements. Other initiatives helped teachers prepare for subject matter
exams and reimbursed the registration fees of those who passed them to
demonstrate subject matter competency in the subject taught. While many
professional development programs supported with Title II funds were not
necessarily targeted to teachers who still needed to meet the
requirements, teachers who had not met the requirements could count their
participation toward demonstration of subject matter competency under
NCLBA by earning points through their state's HOUSSE.

In each of the districts that we visited, any teacher could participate in
at least some professional development or other programs supported with
Title II funds, and district officials indicated that they had made
efforts to address district-wide teacher needs. Ten of the 11 districts
that we visited had a large number of high-poverty schools,43 and by
focusing on districtwide teacher needs, district officials could also
address the needs of teachers who provided instruction to low-income
students. For example, the superintendent of 1 district, in which all
teachers could participate in Title II initiatives, credited the
professional development funded through Title II with the narrowing of the
achievement gap between the district's low-income and other students. The
statutory formula that states used to allocate Title II funds to the
districts takes into consideration their poverty levels,44 and several
officials we interviewed told us they believed Title II funds were
generally reaching districts with the greatest need.

Visited Districts Used Non-Title II Funds to Support Teacher Initiatives

Title II funds are generally a small part of total funds available to the
districts for teacher initiatives, and visited districts used various
non-Title II funds to address their teacher needs, including other
federal, state, and local funds. In two districts, for example, officials
told us that Title II funds represented less than half of all the funds
they spent on teacher initiatives. Moreover, districts received federal
funds under different programs, and Title II constitutes a relatively
small proportion of all federal funds they could use for teacher
initiatives. In one district visited, for example, Title II funds
constituted about 13 percent of the total federal funds available, with
the bulk of the district's federal money coming from Title I. Our prior
work also showed that districts planned to spend much larger percentages
of other federal, state, and local funds than Title II funds on
teacher-related activities, but in high-poverty districts Title II funds
constituted a larger share of total funds spent on these activities than
in low-poverty districts.45

43 We visited one district that did not have high-poverty schools but was
chosen because of its rural location.

44 After awarding to each district the amount of Title II funds equivalent
to what the district received in fiscal year 2001 under the Eisenhower
Professional Development and Class-Size Reduction programs, the state
allocates any excess funds to the districts based on the following
formula: 20 percent of the excess funds must be distributed based on the
district's relative number of individuals ages 5 through 17 residing in
the area served by the district; 80 percent of the excess funds must be
distributed based on the relative number of individuals ages 5 through 17
residing in the area served by the district who are also from families
with incomes below the poverty line.

45 See GAO-03-631.

Although Title II was one of many resources available to the districts,
many district officials we interviewed said that Title II funds played a
significant role in their teacher improvement efforts. For example,
officials in one district credited Title II-funded professional
development with helping teachers prepare for subject matter tests they
needed to pass in order to demonstrate subject matter competency under
NCLBA. In another district, officials said that their initiatives to
support teachers, such as coaches, would not have been possible without
Title II funding.

Districts that we visited supported a variety of teacher programs with
non-Title II funds. Among other federal funds, Title I was one of the most
frequently cited sources for supporting teacher initiatives. For example,
two districts used Title I funds to hire coaches or consultants to help
individual teachers in high-poverty schools become more effective in the
classroom. A few of the initiatives funded with Title I were specifically
designed to help teachers meet NCLBA's qualification requirements. For
example, one district used the funds to reimburse teachers who passed the
subject matter exam for their registration fees and for taking additional
college coursework to help them meet NCLBA's subject matter competency
requirements. In addition to using federal funds, districts also used
state funds for teacher initiatives. For example, districts in one state
received funds from the state for activities such as professional
development to support all beginning teachers. Finally, districts used
local and private funds to support various teacher initiatives. For
example, one district used local funds to reimburse teachers for taking
additional courses to raise their qualifications, while another district
used private foundation funds to provide housing allowances for
high-performing teachers who accepted positions in the district's most
struggling inner-city schools.

Two districts that we visited had implemented or planned to implement
differential compensation programs that offered financial rewards to
teachers, such as onetime bonuses or salary increases, based on their
performance or other qualifications. One school district in Tennessee made
recruitment, retention, and salary bonuses available to teachers who had
demonstrated a record of effectiveness and taught in some of the
district's neediest schools.46 To assess teachers' eligibility for these
bonuses, the district used the data showing teachers' impact on student
performance available through the state's system of measuring students'
achievement gains from year to year. This initiative is currently
supported with both Title I and Title II funds. A school district in
Colorado approved a plan for a districtwide differential compensation
system that would provide teachers with multiple opportunities to increase
their yearly pay, including gaining additional knowledge and skills,
assuming positions in hard-to-fill subjects or hard-to-staff schools,
earning successful performance evaluations, or meeting annual objectives
for students' performance.47 This initiative will be funded through a
local property tax increase that will create a trust fund to ensure that
the new pay system can be permanently sustained.48 While officials in that
district acknowledged that Title II funds could be used to support
differential compensation initiatives, they indicated that Title II alone
could not sustain this system.

46 Hamilton County Schools is an urban school district in Chattanooga,
Tennessee, with 79 schools, 2,674 full-time teachers, and student
enrollment of 40,494 in the 2004-2005 school year.

Officials in the districts that we visited said that they did not look at
Title II funds in isolation from other funds when making funding
decisions, but rather they attempted to leverage different funding sources
available to address their teacher needs. For example, officials in one
district said that the district's use of Title I funds for teacher
recruitment purposes allowed them to focus Title II funds on the coaching
program for teachers.

47 Denver Public Schools is an urban school district in Denver, Colorado,
with 154 schools, 4,061 teachers, and student enrollment of 72,901 in the
2004-2005 school year.

48 In November 2005, Denver voters approved a property tax increase that
will be used to finance the differential compensation system. Beginning on
January 1, 2006, all new teachers will be automatically enrolled in the
new system; current teachers will be able to opt into the system over the
first 7 years or remain in the current system.

     Education Monitored States and Offered Assistance on Implementing the
  Requirements, but Some of Education's Information Was Not Readily Accessible

Education monitored states and offered assistance to help teachers meet
NCLBA's teacher qualification requirements. In its monitoring reports,
Education identified areas of concern related to states' implementation of
the teacher qualification requirements. Education's assistance efforts
included professional development opportunities and information packets on
NCLBA's requirements. The agency also conducted site visits to states to
discuss NCLBA's teacher qualification requirements and offer technical
assistance. Although several key resources about NCLBA's teacher
requirements can be reached only through Education's Web site, officials
in most states and districts that we visited told us that they had
difficulty locating these resources or were unaware of them. Our review of
Education's Web site showed that several key resources on NCLBA's teacher
qualification requirements were located on different Web pages that were
not linked, making it challenging to find them.

Education Monitored States' Implementation of Teacher Qualification Requirements

Education provided written feedback to states on their implementation of
NCLBA's teacher qualification requirements through the Title II monitoring
process. Education began Title II monitoring in June 2004 and, as of July
15, 2005, had conducted monitoring visits to 29 states and the District of
Columbia and released reports documenting findings to 20 of the states.
Reports were generally released to states about 1 to 3 months after the
monitoring visit. Education officials reported that states had an
opportunity to respond prior to the release of monitoring reports, and to
develop a plan to address findings. None of our site visit states received
a monitoring report in time to be included in this analysis.

In these 20 monitoring reports, Education issued findings to states that
did not fully implement NCLBA requirements. States most frequently
received findings for not ensuring that teachers hired into Title I
schools or with Title II funds met the teacher requirements (14 states),
as required by NCLBA. Another frequent finding was that state-reported
data did not adequately reflect the status of teachers in meeting the
requirements (13 states). For example, several states could not report
data on the percentage of classes taught by teachers not meeting NCLBA's
teacher qualification requirements for special education or secondary
school classes.

In addition, some states received findings for not requiring certain
teachers to demonstrate subject matter competency as required under NCLBA.
For example, 9 states received findings for allowing teachers of history,
geography, civics/government, or economics to demonstrate subject matter
competency in the broad area of social studies instead of in each subject
taught. Seven states received findings for not requiring new elementary
school teachers to demonstrate competency in the manner required by NCLBA.
Education found that all 7 states had not implemented a test for new
elementary school teachers to demonstrate subject matter competency or the
test was optional. Eight states received findings related to the
demonstration of competency for middle and high school teachers, and 7
states received findings related to the demonstration of competency for
special education teachers. In states that did not require certain
teachers to demonstrate competency as required by NCLBA, state data do not
fully reflect the percentage of classes taught by teachers who met NCLBA
teacher qualification requirements.

Table 1 lists the major findings related to NCLBA's teacher qualification
requirements.

Table 1: Major Findings from Education's Title II Monitoring

Teacher qualification requirements that states did Number of states 
not fully implement                                    with finding 
Hiring                                             
Did not ensure that teachers hired into Title I                     
schools or with Title II funds met the             
requirements                                                     14
Reporting and data                                 
Did not include all required data elements on                    10 
state report card                                  
State-reported data did not adequately reflect the                  
status of teachers in meeting the requirements                   13
Demonstration of subject matter competency         
Did not require a state test for new elementary                     
teachers to demonstrate subject matter competency                 8
Requirements for veteran elementary teachers were                   
not sufficient to demonstrate subject matter       
competency                                                        5
Requirements for middle or high school teachers                     
were not sufficient to demonstrate subject matter  
competency                                                        8
Did not require teachers of history, geography,                     
civics/government, or economics to demonstrate     
subject matter competency in each subject taught                  9
Did not require special education teachers to                       
demonstrate subject matter competency in subjects  
taught or have not determined the status of these  
teachers                                                          7
State HOUSSE procedures did not meet criteria in                  1 
the law                                            
Development of annual measurable objectives and plan for meeting
the requirements                                   
Did not develop annual measurable objectives for                    
districts and schools                                            12

Source: GAO analysis of Education's Title II monitoring reports.

Note: Information presented for 20 monitoring reports reviewed by GAO.

Of the 20 states that received monitoring reports, 19 states did not
receive a finding regarding their HOUSSE procedures, even though some
experts have questioned the rigor of HOUSSE procedures in many states.
Through the monitoring process, Education is reviewing state HOUSSE
procedures to ensure that they are consistent with NCLBA's criteria. Table
2 lists NCLBA's criteria for state HOUSSE procedures.

Table 2: NCLBA's Criteria for HOUSSE Procedures

States can establish a process for evaluating teacher knowledge and 
ability based on the standard that meets the following criteria:    
Is set by the state for both grade-appropriate academic subject     
matter knowledge and teaching skills                                
Is aligned with challenging state academic content and student      
academic achievement standards and developed in consultation with   
core content specialists, teachers, principals, and school          
administrators                                                      
Provides objective, coherent information about the teacher's        
attainment of core content knowledge in the academic subjects       
taught                                                              
Is applied uniformly to all teachers in the same academic subject   
and the same grade level throughout the state                       
Takes into consideration, but not be based primarily on, the time   
the teacher has been teaching in the academic subject               
Is made available to the public upon request                        
May involve multiple objective measures of teacher competency       

Source: NCLBA, Pub.L. No. 107-110, section 9101(23)(C)(ii).

As long as their HOUSSE procedures meet each of NCLBA's criteria, states
have had flexibility in developing HOUSSE under NCLBA. Among 19 states
with HOUSSE procedures that were determined to meet NCLBA's criteria were
one state with a HOUSSE that allowed for evaluations of teachers'
classroom performance and several states in which teachers meet HOUSSE
requirements by being fully certified to teach their subject. Education
officials noted that evaluations of teachers' performance could be
accepted as part of state HOUSSSE procedures as long as they are rigorous
and objective measures of teachers' subject matter knowledge that are
based on multiple observations and performed by trained evaluators. In
addition, Education officials told us that while teacher certification in
itself would not be sufficient for demonstration of subject matter
competency, several states provided evidence that was accepted by
Education showing that their certification requirements met the criteria
for HOUSSE in the law. In the one state that received a finding related to
its HOUSSE, teachers were allowed to earn more than half of the points
necessary to meet HOUSSE requirements through experience. The state
received a finding because NCLBA does not allow HOUSSE to be based
primarily on teaching experience.

Eleven of the 20 state monitoring reports included written commendations
from Education for state efforts to improve professional development,
strengthen teacher preparation, or develop data systems that track teacher
qualifications. Eight states received commendation for improving or
offering high-quality professional development for teachers. For example,
Arkansas was commended for requiring every teacher to complete 60 hours of
professional development each year and devoting considerable state funding
to professional development. Seven states were commended for strengthening
teacher preparation. For example, Georgia was commended for aligning all
teacher preparation to state standards for student learning. Six states
were commended for new or improved data systems for tracking teacher
qualifications. For example, Mississippi received a commendation for
tracking teachers' qualifications, certifications, and assignments, and
linking those factors to individual students' progress.

Education Offered Assistance to Teachers and States on the Implementation of
Teacher Qualification Requirements

Education offered several types of assistance to help the nation's 3
million public school teachers meet NCLBA's teacher qualification
requirements, including professional development opportunities. Education
offered professional development opportunities workshops in which about
4,500 teachers have participated since June 2004. These workshops and
related materials were also made available online free of charge. Teachers
accessed these workshops online through Education's Web site or through
www.teacherquality.us, a Web site Education uses to provide information on
Education's teacher initiatives. In addition, teachers can determine
whether their state would accept these workshops as credit toward the
state HOUSSE requirement online. As of September 2005, all states and the
District of Columbia were awarding points for teachers' participation in
these workshops as part of their HOUSSE procedures or for teacher
recertification.

Education also offered assistance directly to teachers to help them
understand NCLBA's requirements and gave teachers an opportunity to
provide feedback about what additional support they need. Education
distributed 255,000 "Toolkit for Teachers" information packets that
provide information about NCLBA's teacher qualification requirements. The
toolkit addressed frequently asked questions that are relevant to
teachers, such as whether NCLBA's teacher qualification requirements apply
to special education teachers. In addition, Education offered a series of
teacher roundtables that gave teachers an opportunity to share their views
with Education officials on how Education can support them in the
classroom.

Education provided technical assistance to state officials from all 50
states through site visits by the Teacher Assistance Corps (TAC). TAC
visits, which took place prior to Education's monitoring of NCLBA's
teacher qualification requirements, were intended to help states implement
the requirements, according to Education officials. The TAC teams that
conducted site visits were composed of Education officials and experts.
Education characterized these visits as "conversations without
consequences" and did not provide written feedback to states based on the
TAC visits. Education officials said that TAC teams discussed HOUSSE
procedures, the collection of data on teacher qualifications, the best use
of Title II funds, and other issues. Officials from two of the six states
that we visited said that TAC suggestions helped them implement their
HOUSSE procedures. Three other states that we visited said that TAC teams'
suggestions were not useful in their circumstances. For example, officials
in one state said that Education's suggestion that small rural districts
share teachers to ensure that students are taught by teachers who meet
NCLBA's requirements was impractical given the distance between schools.
Based on difficulties that states identified during TAC visits, Education
offered science teachers and teachers of multiple subjects, including
rural teachers, additional flexibility in meeting NCLBA's teacher
requirements.

Through TAC visits, Education officials identified state and local
initiatives that they considered to be innovative ways of improving
teacher qualifications. Such initiatives addressed teacher certification
and licensing, professional development, and other topics. In an effort to
share information on these state and local initiatives with policy makers
or others, Education posted information about these initiatives on
www.teacherquality.us.

Education has provided guidance and hosted meetings for state officials on
the implementation of NCLBA's teacher qualification requirements.
Education's guidance answered questions about NCLBA's teacher
qualification requirements and Title II, such as when teachers with
alternative certification can be considered as having met NCLBA's teacher
requirements. Education officials reported that they update their guidance
periodically to answer new questions about the teacher requirements, most
recently in August 2005. In addition, Education convenes state Title II
directors once a year to provide updates on the implementation of NCLBA's
teacher requirements.

Education has also funded several projects that work to improve the
preparation and increase the numbers of special education teachers. For
example, one center compared special education teachers prepared in
alternative certification programs with their counterparts from
traditional preparation programs.

Some Information on Education's Web Site Was Not Readily Accessible

According to Education officials, Education's Web site has been an
important part of their outreach efforts regarding NCLBA's teacher
qualification requirements. Several of the resources related to
implementation of the teacher qualification requirements, such as the
Teacher Toolkit and state innovative practices, are now available only
through Education's Web site. However, officials from most states and
districts that we visited who use Education's Web site to access
information on teacher programs or requirements told us that they were
unaware of some of Education's teacher resources or had difficulty
accessing those resources. For example, although all of the states we
visited accepted Education's professional development for credit toward
recertification or HOUSSE, district officials from only 3 of the 11
districts we spoke with were aware of these opportunities or that they
were available online. Moreover, officials in 4 of the states that we
visited told us that they wanted to know more about other states'
initiatives to improve teacher qualifications but were not aware that
Education had made this information available online or did not know how
to access the information. In the states that we visited, several state
and local officials mentioned that they attempted to find information by
using Education's search function but often had trouble finding what they
needed.

In our review of Education's Web site, we found that information and
resources on the teacher qualification requirements were located on
several different Web pages that sometimes were not linked, making the
information difficult to locate. For example, state initiatives were
available through the "Teachers" section of Education's Web site and not
through the "Administrators" section, even though state and local
administrators would likely find this information more useful than
teachers would. See figure 4 for the description of teacher qualification
information included on different sections of Education's Web site.

Figure 4: Information on Teacher Qualifications Available through
Education's Web Site, as of August 2005

                                  Conclusions

Since we last reported on the status of implementing the teacher
qualification requirements in our 2003 report, state and district
officials have taken steps to implement these requirements, such as
reducing the number of uncertified teachers and developing data systems to
track teachers' qualifications. In addition, Education officials indicated
that states have taken steps to raise teacher qualifications through
changes in state certification systems.

Although states have made progress in tracking teacher qualifications data
and reporting on their status in meeting the requirements, difficulties
remain in identifying teachers who do not meet the requirements. This may
be a challenge, particularly because a number of states did not include
all teachers in their calculations or faced other data issues. Where data
challenges exist, Education and the states may not have the information
necessary to direct assistance to where it is most needed. This may result
in some teachers not receiving appropriate support to help them meet the
requirements. Education is working on identifying data challenges and
addressing them through its monitoring visits and other technical
assistance to states. Until these data issues are resolved, state reports
on their status in meeting the teacher qualification requirements should
be viewed as preliminary.

To facilitate state and district implementation efforts, Education relies
extensively on its Web site as one of its principal means for providing
information and implementation resources for states and districts.
However, state and district officials told us that they were unaware of
some of the information resources that Education made available and had
difficulty locating other known sources of information on Education's Web
site. Consequently, states and districts may not be taking full advantage
of the opportunities and flexibilities made available by Education that
would help them meet teacher qualification goals. Further, without this
information, some states and districts may not be correctly applying the
requirements, thus jeopardizing the ability of their teachers to meet the
requirements by the deadline. This may impede efforts to increase student
performance and ensure that all students reach state standards.

Finally, even when all teachers have met NCLBA's qualification
requirements, it is unclear whether their doing so will have the expected
effect on student performance. Under the law, states have considerable
flexibility in developing requirements for teachers to demonstrate subject
matter competency. The rigor of these requirements varied across states.
Consequently, it remains to be seen how different state requirements will
affect the quality of instruction and student performance.

                      Recommendation for Executive Action

We recommend that the Secretary of Education explore ways to make the
Web-based information on teacher qualification requirements more
accessible to users of its Web site. Specifically, the Secretary may want
to more prominently display the link to state teacher initiatives, as well
as consider enhancing the capability of the search function.

                       Agency Comments and Our Evaluation

We provided a draft of this report to Education for review and comment. In
its letter, Education agreed with our recommendation, indicating that the
department has already taken steps to address it. Specifically, the
department is reviewing how teacher qualification information on the
"Teachers" section of its Web site can be better integrated with related
information on other Web sites, including teacherquality.us. Education's
written comments are reproduced in appendix IV.

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

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

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

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

Table 3 lists our summaries of the authorized activities on which states
can spend Title II funds and shows the five categories we used to group
them. After reserving 1 percent of the total Title II allocation to the
state for administrative activities, states retain only 2.5 percent of the
remaining 99 percent for state activities.

Table 3: Title II, Part A, State Activities

Category                 Activity                                      
Accountability              1. Developing systems to measure the       
                               effectiveness of professional development  
                               programs and strategies to document        
                               improvements in students' academic         
                               achievement                                
                               2. Ensuring that teachers use challenging  
                               state academic content standards, assessments,
                               and student achievement standards to improve
                               their teaching practices and their student's
                               achievement                                
Certification               3. Reforming teacher and principal         
                               certification                              
                               4. Reforming tenure and implementing tests for
                               subject matter knowledge                   
                               5. Promoting license and certification     
                               reciprocity agreements with other states for
                               teachers and principals                    
                               6. Providing programs that establish, expand,
                               or improve alternative routes for state    
                               certification, especially for highly qualified
                               individuals in the areas of mathematics and
                               science                                    
Professional development    7. Conducting programs that provide        
                               support to teachers, such as those that    
                               provide teacher mentoring and use          
                               assessments that are consistent with       
                               student academic achievement standards     
                               8. Providing professional development for  
                               teachers and principals                    
                               9. Developing or assisting local educational
                               agencies (LEAs) in developing and using proven
                               innovative strategies for intensive        
                               professional development programs that are 
                               both cost-effective and easily accessible  
                               10. Encouraging and supporting the training of
                               teachers and administrators to integrate   
                               technology into curricula and instruction, 
                               including training to improve their ability to
                               use data to improve their teaching         
                               11. Providing assistance to teachers to enable
                               them to meet certification, licensing, or  
                               other Title II requirements needed to become
                               highly qualified                           
Recruitment and             12. Developing or assisting LEAs to        
retention                   develop, merit-based performance systems   
                               and strategies that provide pay            
                               differentials and bonus pay for teachers   
                               in academic subjects in which there is     
                               high need                                  
                               13. Developing projects and programs to    
                               encourage men to become elementary teachers
                               14. Establishing and operating a statewide 
                               clearinghouse and programs for the         
                               recruitment, placement, and retention of   
                               teachers                                   
                               15. Assisting LEAs and schools in recruiting
                               and retaining highly qualified teachers,   
                               including specialists in core subjects     
                               16. Developing or assisting LEAs to develop
                               teacher advancement initiatives that promote
                               professional growth and emphasize multiple 
                               career paths and pay differentiation       
Technical assistance        17. Fulfilling the state agency's          
                               responsibility to properly and efficiently 
                               carry out the administration of programs,  
                               including providing technical assistance   
                               to LEAs                                    
                               18. Assisting LEAs to develop and implement
                               professional development programs and school
                               leadership academies for principals and    
                               superintendents                            

Source: NCLBA Pub.L. No. 107-110, section 2113.

Table 4 lists our summaries of the authorized activities on which
districts can spend Title II funds and shows the two categories we used to
group them. After reserving 1 percent of the total Title II allocation to
the state for administrative activities, states allocate 95 percent of the
remaining 99 percent to the districts.

Table 4: Title II, Part A, District Activities

Category        Activity                                             
Professional       1. Providing professional development activities  
development        for teachers and principals that improve their    
                      knowledge of their core subjects and effective    
                      instructional strategies                          
                      2. Carrying out professional development activities
                      designed to improve the quality of principals and 
                      superintendents                                   
                      3. Carrying out teacher advancement initiatives to
                      promote professional growth and to emphasize multiple
                      career paths and pay differentiation              
                      4. Carrying out programs and activities that are  
                      designed to improve the quality of teachers, such as
                      professional development programs, merit pay programs,
                      and testing teachers in the subjects they teach   
Recruitment and    5. Developing and implementing mechanisms to      
retention          assist schools in effectively recruiting and      
                      retaining highly qualified teachers and           
                      principals                                        
                      6. Developing and implementing initiatives to retain
                      highly qualified teachers and principals, particularly
                      in schools with a high percentage of low-achieving
                      students, including programs that provide teacher 
                      mentoring and incentives                          
                      7. Carrying out programs and activities related to
                      exemplary teachers                                
                      8. Developing and implementing initiatives to assist
                      schools in recruiting and hiring teachers, including
                      providing financial incentives and establishing   
                      programs that train and hire special education and
                      other teachers, recruit qualified professionals from
                      other fields, and provide increased opportunities for
                      minorities, individuals with disabilities, and others
                      9. Hiring highly qualified teachers in order to reduce
                      class size, particularly in the early grades      

Source: NCLBA Pub.L. No. 107-110, section 2123.

Appendix II: State-Reported Percentage of Core Academic Classes Taught by
Teachers Meeting NCLBA's Teacher Qualification Requirements in the
2003-2004 School Year  Appendix II: State-Reported Percentage of Core
Academic Classes Taught by Teachers Meeting NCLBA's Teacher Qualification
Requirements in the 2003-2004 School Year

                            All High-poverty Low-poverty Elementary Secondary 
States               schools      schools     schools    schools   schools 
Alabama                   77           68          79         80        77 
Alaska                    np           np          np         np        np 
Arizona                   96           96          96         98        94 
Arkansas                  np           np          np         np        np 
California                52           40          60         49        53 
Colorado                  91           90          92         95        86 
Connecticut               99           98          99         99        99 
Delaware                  73           68          74         74        72 
District of Columbia      np           np          np         np        np 
Florida                   89           87          91         94        85 
Georgia                   97           97          98         98        95 
Hawaii                    73           71          73         90        68 
Idaho                     97           98          96         98        97 
Illinois                  98           93         100         np        np 
Indiana                   96           94          97         96        97 
Iowa                      95           96          95         97        94 
Kansas                    95           96          95         98        93 
Kentucky                  95           98          95         99        92 
Louisiana                 90           87          92         95        86 
Maine                     90           91          91         93        89 
Maryland                  67           47          78         73        64 
Massachusetts             94           88          96         95        92 
Michigan                  92           92          93         97        89 
Minnesota                 99           98          99         99        98 
Mississippia              93           89          95         97        91 
Missouri                  96           92          97         np        np 
Montana                   99           98          99         99        98 
Nebraska                  91           90          95         98        90 
Nevada                    64           59          75         71        51 
New Hampshire             73           69          73         76        70 
New Jersey                94           88          96         94        95 
New Mexico                67           63          72         74        65 
New York                  92           81          97         92        94 
North Carolina            85           82          87         88        82 
North Dakota              77           83          73        100        56 
Ohio                      93           91          95         93        93 
Oklahoma                  98           97          98         98        98 
Oregon                    87           85          89         97        85 
Pennsylvania              97           92          99         np        np 
Puerto Rico               np           np          np         np        np 
Rhode Island              76           77          74         75        75 
South Carolina            75           68          79         75        75 
South Dakota              93           89          93         94        91 
Tennessee                 58           57          50         60        51 
Texas                     92           92          93         97        93 
Utah                      69           65          73         80        70 
Vermont                   np           np          np         np        np 
Virginia                  95           92          97         96        94 
Washington                99           99          99        100        99 
West Virginia             96           97          95         97        95 
Wisconsin                 98           96          99         99        98 
Wyoming                   99           99          99        100        98 

Source: U.S. Department of Education, State Consolidated Performance
Reports.

Notes: We identified several factors that affect the accuracy of these
data and preclude a comparison of classes taught by teachers meeting the
requirements across states. However, on the basis of our work, we
determined state-reported percentages could be used to demonstrate how
close a particular state was to reaching the goal of having all its
teachers meet the requirements. All numbers have been rounded to the
nearest whole figure.

aThese data exclude classes that have students from both elementary and
secondary grades.

Np = data were not provided by the states.

Appendix III: Sample HOUSSE Procedures from Two States Visited  Appendix
III: Sample HOUSSE Procedures from Two States Visited

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

Appendix V: A  Appendix V: GAO Contact and Staff Acknowledgments

GAO Contact

Marnie S. Shaul, (202)512-7215, [email protected]

Staff Acknowledgments

Harriet Ganson (Assistant Director) and Natalya Barden (Analyst-in-Charge)
managed all aspects of the assignment. Scott Spicer, Katharine Leavitt,
and Deborah Edwards made significant contributions to this report. Other
key contributors to this report included Jessica Botsford, Richard
Burkard, Emily Leventhal, Jonathan McMurray, Jean McSween, John Mingus,
and Shannon VanCleave.

Related GAO Products  Related GAO Products

No Child Left Behind Act: Education Could Do More to Help States Better
Define Graduation Rates and Improve Knowledge about Intervention
Strategies. GAO-05-879. Washington, D.C.: Sept. 20, 2005.

No Child Left Behind Act: Most Students with Disabilities Participated in
Statewide Assessments, but Inclusion Options Could Be Improved.
GAO-05-618. Washington, D.C.: July 20, 2005.

Charter Schools: To Enhance Education's Monitoring and Research, More
Charter School-Level Data Are Needed. GAO-05-5. Washington, D.C.: Jan. 12,
2005.

No Child Left Behind Act: Education Needs to Provide Additional Technical
Assistance and Conduct Implementation Studies for School Choice Provision.
GAO-05-7. Washington, D.C.: Dec. 10, 2004.

No Child Left Behind Act: Improvements Needed in Education's Process for
Tracking States' Implementation of Key Provisions. GAO-04-734. Washington,
D.C.: Sept. 30, 2004.

No Child Left Behind Act: Additional Assistance and Research on Effective
Strategies Would Help Small Rural Districts. GAO-04-909. Washington, D.C.:
Sept. 23, 2004.

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.

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

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

(130434)

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Report to Congressional Requesters

United States Government Accountability Office

GAO

November 2005

NO CHILD LEFT BEHIND ACT

Improved Accessibility to Education's Information Could Help States
Further Implement Teacher Qualification Requirements

GAO-06-25

www.gao.gov/cgi-bin/getrpt?GAO-06-25.

To view the full product, including the scope

and methodology, click on the link above.

For more information, contact Marnie Shaul at (202) 512-6778 or
[email protected].

Highlights of GAO-06-25, a report to congressional requesters

November 2005

NO CHILD LEFT BEHIND ACT

Improved Accessibility to Education's Information Could Help States
Further Implement Teacher Qualification Requirements

The No Child Left Behind Act (NCLBA) of 2001 established qualification
requirements that teachers of core academic subjects must meet by the end
of the 2005-2006 school year. Congress has appropriated approximately $3
billion a year through the Title II, Part A (Title II), of NCLBA for
teacher improvement programs since the law was passed. With the deadline
approaching for all teachers to meet the requirements, GAO was asked to
examine (1) the status of state efforts to meet NCLBA's teacher
qualification requirements, (2) the use of Title II funds in selected
districts, and (3) how the U.S. Department of Education (Education)
monitors states and assists them with implementation of the requirements.
To obtain this information, GAO reviewed teacher qualifications data
submitted to Education by 47 states, conducted site visits to 6 states
selected for variance in factors such as teacher requirements and
geographic location, visited 11 school districts across these states
identified as high-need, and interviewed national experts and Education
officials.

What GAO Recommends

GAO recommends that the Secretary of Education explore ways to make the
Web-based information on teacher qualification requirements more
accessible to users of its Web site. In comments, Education officials
agreed with our recommendation and reported taking actions to address it.

Data reported to Education by 47 states suggest that the majority of core
academic classes were taught by teachers who met NCLBA requirements during
the 2003-2004 school year. States have improved in their ability to track
and report the percentage of core academic classes taught by teachers who
met NCLBA qualification requirements, but several limitations on the
quality and precision of state-reported data make it difficult to
determine the exact percentage of core academic classes taught by teachers
meeting the requirements. Five of the 6 states that we visited allowed
veteran teachers to demonstrate subject matter competency through a
state-developed procedure called High Objective Uniform State Standard of
Evaluation (HOUSSE). Officials in states and districts that we visited
said that teachers of multiple subjects, such as teachers in rural schools
with a small teaching staff, would likely face challenges meeting the
requirements by the 2005-2006 deadline.

The 11 school districts that we visited all used Title II funds to provide
professional development, and most used Title II funds to reduce class
size. Officials in the majority of these districts indicated that NCLBA
had led to improvements in the kinds of professional development they
funded with Title II funds. Although officials in over half of the
districts indicated that they continued to use Title II funds to reduce
class size, an activity that was supported under a federal program that
predated NCLBA, some district officials told us that they had shifted
funds away from class size reduction to initiatives designed to improve
teachers' subject matter knowledge and instructional skills, such as
professional development. All districts that we visited reported
considering student achievement data and targeting Title II funds to
improve instruction in the academic subjects in which students were
lagging behind. In the 11 districts, few efforts funded with Title II
targeted specific groups of teachers, such as teachers in high-poverty
schools. Title II funds constituted a small proportion of total funds that
districts could use for teacher improvement initiatives, and all districts
that we visited used several other funding sources to support their
teacher programs.

Education monitored state efforts to meet the teacher qualification
requirements and offered multiple types of assistance to help teachers
meet the requirements. In monitoring states, Education has found several
areas of concern, such as states not ensuring that certain newly hired
teachers met NCLBA's requirements. Education's assistance has included
professional development for teachers and site visits to provide technical
assistance to state officials. Education officials said that their Web
site has been an important tool for disseminating resources about the
requirements, but officials from most states and districts that we visited
told us that they were unaware of some of these resources or had
difficulty locating them, despite frequently using the Web site.
*** End of document. ***