No Child Left Behind Act: Education Should Clarify Guidance and  
Address Potential Compliance Issues for Schools in Corrective	 
Action and Restructuring Status (05-SEP-07, GAO-07-1035).	 
                                                                 
The No Child Left Behind Act of 2001 (NCLBA) focused national	 
attention on improving schools so that all students reach	 
academic proficiency by 2014. In the 2006- 2007 school year,	 
about 4,500 of the 54,000 Title I schools failed to make adequate
yearly progress (AYP) for 4 or more years. Schools that miss AYP 
for 4 years are identified for corrective action, and after 6	 
years, they must be restructured. GAO examined (1) the		 
characteristics of Title I schools in corrective action and	 
restructuring; (2) the actions that schools in corrective action 
and restructuring implemented; (3) the assistance those schools  
received from districts and states; and (4) how Education	 
supports states in their efforts to assist these schools. GAO	 
administered two Web-based surveys to a nationwide sample of	 
schools in corrective action and restructuring status and	 
conducted site visits to five states.				 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-07-1035					        
    ACCNO:   A75650						        
  TITLE:     No Child Left Behind Act: Education Should Clarify       
Guidance and Address Potential Compliance Issues for Schools in  
Corrective Action and Restructuring Status			 
     DATE:   09/05/2007 
  SUBJECT:   Academic achievement				 
	     Comparative analysis				 
	     Education						 
	     Educational testing				 
	     Federal funds					 
	     Federal/state relations				 
	     Performance measures				 
	     Program evaluation 				 
	     Public schools					 
	     School districts					 
	     School management and organization 		 
	     Schools						 
	     Students						 
	     Corrective action					 
	     Program goals or objectives			 

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GAO-07-1035

   

     * [1]Results in Brief
     * [2]Background

          * [3]States and Districts Are Held Accountable for the Performanc
          * [4]Both Districts and States Provide Technical Assistance to Sc
          * [5]Education Provides Assistance to States and Districts and Mo

     * [6]Schools in Corrective Action and Restructuring Were More Oft

          * [7]Schools in Corrective Action and Restructuring Were Concentr
          * [8]Schools in Corrective Action and Restructuring Served a High
          * [9]The Number of Schools in Corrective Action and Restructuring

     * [10]Most Schools Used a Corrective Action or Restructuring Optio

          * [11]Among Schools in Corrective Action, Almost All Took at Least
          * [12]Among Schools in Restructuring, Almost Two-Thirds Implemente
          * [13]A Higher Percent of Schools That Fully Implemented Improveme

     * [14]Many Schools in Corrective Action and Restructuring Did Not

          * [15]Many Schools in Corrective Action and Restructuring Did Not
          * [16]Most Schools Received Some Assistance from State Educational

     * [17]Education Provides Technical Assistance and Research on Scho
     * [18]Conclusions
     * [19]Recommendations
     * [20]Agency Comments and Our Evaluation
     * [21]Objective 1: Analysis of School Characteristics
     * [22]Objectives 2 and 3: Implementation of Corrective Action and

          * [23]Corrective Action Survey

               * [24]Sample Design and Errors
               * [25]Response Rate

          * [26]Restructuring Survey

               * [27]Sample Design and Errors
               * [28]Response Rate

          * [29]Combined Surveys
          * [30]Site Visits

     * [31]Objective 4: Education's Efforts to Support State Implementa
     * [32]GAO Contact
     * [33]Acknowledgments
     * [34]GAO's Mission
     * [35]Obtaining Copies of GAO Reports and Testimony

          * [36]Order by Mail or Phone

     * [37]To Report Fraud, Waste, and Abuse in Federal Programs
     * [38]Congressional Relations
     * [39]Public Affairs

Report to Congressional Requesters

United States Government Accountability Office

GAO

September 2007

NO CHILD LEFT BEHIND ACT

Education Should Clarify Guidance and Address Potential Compliance Issues
for Schools in Corrective Action and Restructuring Status

GAO-07-1035

Contents

Letter 1

Results in Brief 3
Background 6
Schools in Corrective Action and Restructuring Were More Often Located in
Urban School Districts and Served Higher Percentages of Minority, Poor,
and Middle-School Students Than Other Title I Schools 13
Most Schools Used a Corrective Action or Restructuring Option, but Some
May Not be Meeting NCLBA Requirements 22
Many Schools in Corrective Action and Restructuring Did Not Receive All
Required Assistance through Their School Districts; However, Most Received
Assistance from Their State 31
Education Provides Technical Assistance and Research on School
Improvement, Including Some Specific Information on School Restructuring
35
Conclusions 38
Recommendations 39
Agency Comments and Our Evaluation 39
Appendix I Scope and Methodology 41
Objective 1: Analysis of School Characteristics 41
Objectives 2 and 3: Implementation of Corrective Action and Restructuring
and State and District Assistance 44
Objective 4: Education's Efforts to Support State Implementation 50
Appendix II Number of Schools in Corrective Action, Planning for
Restructuring, and Implementing Restructuring, by State in 2005-2006 and
2006-2007 51
Appendix III Comments from the Department of Education 53
Appendix IV GAO Contacts and Acknowledgments 55
Related GAO Products 56

Tables

Table 1: Timeline for Implementing Interventions for Schools That Do Not
Make Adequate Yearly Progress 8
Table 2: Allowable Activities for Schools in Corrective Action and
Restructuring 9
Table 3: NCLBA Technical Assistance Districts Are Required to Ensure for
Schools Identified for Improvement, Including Those in Corrective Action
and Restructuring 10
Table 4: Education, State, and District Responsibilities for Monitoring
States, Districts, and Schools Identified for Improvement 12
Table 5: Percentage of Schools in Corrective Action and Restructuring and
All Other Title I Schools in 2005-2006, by Locale 14
Table 6: Percentage of Schools Nationwide in Corrective Action and
Restructuring in the Top 5 School Districts in School Year 2005-2006 14
Table 7: Percentage of Students with Selected Characteristics, Comparing
Schools in Corrective Action and Restructuring with All Other Title I
Schools, by Locale 17
Table 8: Percentage of Schools in Corrective Action and Restructuring
Compared to All Other Title I Schools, by Grade Level 18
Table 9: Grade Level Definitions 42
Table 10: School Districts Selected for Site Visits 49
Table 11: Number of Schools in Corrective Action, Planning Restructuring,
and Implementing Restructuring, by State in 2005-2006 and 2006-2007 51

Figures

Figure 1: Number of Title I Schools Identified for Corrective Action,
Planning for Restructuring, and Implementing Restructuring in 2005-2006 13
Figure 2: Number of Schools in Corrective Action and Restructuring in
School Year 2005-2006, by State 15
Figure 3: Number of Schools in Corrective Action and Restructuring for the
3 Most Recent School Years 19
Figure 4: Change in the Number of Schools in Corrective Action and
Restructuring from 2005-2006 to 2006-2007, by State 21
Figure 5: Corrective Actions Allowed under NCLBA and Estimated Percentage
of Schools That Implemented Each Action in 2005-2006 23
Figure 6: Restructuring Options Allowed under NCLBA and Estimated
Percentage of Schools That Implemented Each Option 25
Figure 7: Among Schools Implementing "Other" Major Restructuring,
Estimated Percentage of Schools Implementing Various Activities 27
Figure 8: The Estimated Percentage of Schools in Corrective Action and
Restructuring That Received Each Form of Required Technical Assistance
through Districts in School Year 2005-2006 32
Figure 9: Estimated Percentage of Schools in Corrective Action and
Restructuring in 2005-2006 That Received State Assistance 35
Figure 10: Education's Content and Regional Centers 36

Abbreviations

AYP adequate yearly progress
CCD Common Core of Data
CSPR Consolidated State Performance Reports
Education Department of Education
ESEA Elementary and Secondary Education Act of 1965
IASA Improving America's Schools Act of 1994
NCLBA No Child Left Behind Act of 2001
SES supplemental education services

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United States Government Accountability Office
Washington, DC 20548

September 5, 2007

The Honorable Edward M. Kennedy
Chairman
The Honorable Michael B. Enzi
Ranking Member
Committee on Health, Education, Labor, and Pensions
United States Senate

The Honorable Edward M. Kennedy
Chairman
The Honorable Michael B. Enzi
Ranking Member
Committee on Health, Education, Labor, and Pensions
United States Senate

The Honorable Christopher J. Dodd
Chairman
The Honorable Lamar Alexander
Ranking Member
Subcommittee on Children and Families
Committee on Health, Education, Labor, and Pensions
United States Senate

The Honorable Christopher J. Dodd
Chairman
The Honorable Lamar Alexander
Ranking Member
Subcommittee on Children and Families
Committee on Health, Education, Labor, and Pensions
United States Senate

Over the past 40 years, the Elementary and Secondary Education Act of 1965
(ESEA) has authorized billions of dollars in federal grants to states and
school districts to improve educational opportunities for economically
disadvantaged students. Despite this investment, the academic performance
of disadvantaged students is still substantially lower than that of more
advantaged students. Congress, with the enactment of the No Child Left
Behind Act of 2001 (NCLBA)^1--the most recent reauthorization of
ESEA--sought to address this issue by holding public schools accountable
for the academic performance of their students by requiring that all
students reach proficiency in reading, math, and science by 2014. In
particular, districts and schools receiving funds under Title I of NCLBA
are required to take certain actions when students do not make sufficient
progress toward meeting state proficiency targets.^2 However, many Title I
schools, which comprise over half of all public schools and serve about 26
million students, continue to struggle to raise student achievement. In
the 2006-2007 school year, about one-fifth of the 54,000 Title I schools
had failed to make adequate yearly progress (AYP) for at least 2
consecutive Over the past 40 years, the Elementary and Secondary Education
Act of 1965 (ESEA) has authorized billions of dollars in federal grants to
states and school districts to improve educational opportunities for
economically disadvantaged students. Despite this investment, the academic
performance of disadvantaged students is still substantially lower than
that of more advantaged students. Congress, with the enactment of the No
Child Left Behind Act of 2001 (NCLBA)^123--the most recent reauthorization
of ESEA--sought to address this issue by holding public schools
accountable for the academic performance of their students by requiring
that all students reach proficiency in reading, math, and science by 2014.
In particular, districts and schools receiving funds under Title I of
NCLBA are required to take certain actions when students do not make
sufficient progress toward meeting state proficiency targets. However,
many Title I schools, which comprise over half of all public schools and
serve about 26 million students, continue to struggle to raise student
achievement. In the 2006-2007 school year, about one-fifth of the 54,000
Title I schools had failed to make adequate yearly progress (AYP) for at
least 2 consecutive years, and about 4,500 of these schools had not made
AYP for 4 or more years. Under NCLBA, when a Title I school does not make
AYP for 4 years, the school enters corrective action, and the district
must take a statutorily prescribed action to improve the school, such as
replacing selected teaching staff. If the school fails to make AYP for 6
years, the district is required to restructure the school by changing how
the school is governed. Such changes may include closing the school and
re-opening it as a charter school or turning the operation of the school
over to the state educational agency. As annual goals leading up to the
2014 deadline continue to increase, more schools are expected to enter
corrective action and restructuring and will be required to take major
action to improve.

^1Pub. L. No. 107-110.

^2In this report, we refer to Title I, Part A of NCLBA as "Title I." Other
Parts of Title I (Parts B through I) generally are targeted at specific
populations or purposes and are commonly referred to by their program
names, such as Education of Migratory Children.

However, little is known about what specific corrective actions or
restructuring options schools are currently implementing nationwide, the
extent to which these actions are associated with making AYP, and the
support that schools in corrective action and restructuring have received
from school districts and states as they attempt to improve student
performance. In order to shed light on these issues and help the Congress
prepare for reauthorization of the NCLBA, you asked GAO to answer the
following questions: (1) What are the characteristics of Title I schools
in corrective action and restructuring? (2) To what extent have schools in
corrective action and restructuring implemented corrective actions or
restructuring options? (3) What assistance have schools in corrective
action and restructuring received from districts and states? and (4) How
has the Department of Education (Education) supported states in their
efforts to assist schools in corrective action and restructuring status?

To provide information on these topics, we collected data through multiple
methods. We obtained data on which schools were in corrective action and
restructuring for the 2005-2006 school year. States reported these data to
Education through the Consolidated State Performance Report process, which
collects annual information from states on ESEA programs. We matched data
on these schools with additional data in Education's Common Core of Data
(CCD), conducted descriptive analyses of selected characteristics, and
compared them to all other Title I schools. We also administered two
Web-based surveys sent to 470 principals in a nationwide sample of schools
in corrective action and restructuring during the 2005-2006 school year.
We administered the surveys between January and March 2007 and received a
combined response rate of about 70 percent. Percentage estimates from the
surveys have margins of error of plus or minus 8 percentage points using a
95 percent confidence interval, unless otherwise noted. While we did not
fully validate specific information that school officials reported in our
survey, we took several steps, including corroborating evidence of some
schools' improvement status, to ensure that the information provided by
school officials was sufficiently reliable for the purposes of this
report. We conducted site visits to 5 states (California, Illinois,
Maryland, New York, and Pennsylvania) and 10 school districts with schools
in corrective action, restructuring, or both, as well as 20 schools in
those districts. The states, districts, and schools selected for site
visits not only provided variation across such characteristics as
geographic location and district size, but also generally resembled all
schools in corrective action and restructuring in terms of students'
racial, ethnic, and economic characteristics. Together, schools in these 5
states accounted for over 59 percent of schools in corrective action and
restructuring nationally in the 2005-2006 school year. We also interviewed
state officials from several states (Idaho, South Dakota, Texas, and
Virginia) that had few schools in correction action or restructuring to
obtain information on how their state educational agencies are working
with districts on school improvement issues. We reviewed relevant federal
laws, regulations, and agency guidance and interviewed Education officials
to obtain information about how they monitor and provide assistance to
states and districts. We also interviewed officials in some of Education's
comprehensive and regional assistance centers. We analyzed relevant
Education documents and studies and reports issued by policy and research
organizations on schools in corrective action and restructuring and
interviewed staff in many of these organizations. See appendix I for
detailed information on both surveys as well as our other data collection
methods. We conducted our work from August 2006 through August 2007 in
accordance with generally accepted government auditing standards.

^3Of the 4,509 schools that had not made AYP for 4 or more consecutive
years, 2,330 were in corrective action; 937 were planning for
restructuring; and 1,242 were in restructuring status.

Results in Brief

The 2,790 Title I schools nationwide in corrective action and
restructuring status in the 2005-2006 school year--comprising about 5
percent of all Title I schools and serving over 2 million students--were
more frequently located in urban school districts and a few states and
served higher percentages of poor, minority, and middle-school students
than other Title I schools. Nationwide, almost two-thirds of the 1,155
corrective action and 1,635 restructuring schools were in urban districts,
compared to about one-quarter of other Title I schools. Five
states--California, Illinois, Michigan, New York, and
Pennsylvania--collectively had over 60 percent of these schools, but less
than 30 percent of all Title I schools. When compared to all other Title I
schools, those in corrective action and restructuring served more than
twice as many racial or ethnic minority students--96 percent compared to
37 percent--and a higher percentage of students who were economically
disadvantaged--83 percent compared to 54 percent. More than twice as many
of these schools served middle school students as compared to all other
Title I schools. Nationwide, the number of schools in corrective action
and restructuring increased substantially to 4,509 in the 2006-2007 school
year from 2,790 in the previous year. As state proficiency targets
continue to increase until they reach 100 percent by 2014, the number of
schools in corrective action and restructuring may grow, because many
schools now in early stages of improvement may continue to struggle to
make AYP.

Though many schools had implemented a corrective action or restructuring
option, some schools may not be meeting NCLBA requirements. Among schools
in corrective action status, we estimate that 94 percent implemented at
least one required corrective action and that about three-quarters used
more than one corrective action. Hiring an outside expert and changing the
internal structure of the school were the most frequently implemented
actions, with each implemented by about 60 percent of schools. However,
based on our survey, we estimate that 6 percent of schools did not take
any of the required corrective actions. About a third continued corrective
actions implemented during earlier years of school improvement after
entering corrective action status. Education officials told us that if a
school had previously implemented a corrective action, an additional
action might not be required if the school provided evidence that the
intervention is producing results that are likely to enable the school to
exit improvement status. As of July 2007, Education had not developed
guidance on when continuing prior actions without implementing a new one
is acceptable. About 60 percent of schools in restructuring implemented a
restructuring option as required by NCLBA, and the two most frequently
selected options were "other" major restructuring, such as reconfiguring
the grade levels served by the school, and replacing selected school
staff. Yet many schools in restructuring may not have undertaken
restructuring options as prescribed under NCLBA. States are required to
report annually to Education on the measures taken to address the
achievement problems of schools in improvement status, including schools
in corrective action and restructuring. However, Education does not
require states to report on the specific measures taken for each school,
and therefore, the department has limited information on whether states
have found that some districts may not be in compliance with NCLBA
requirements. A much higher percentage of schools that fully implemented
activities, regardless of which activity they chose, made AYP compared
with those that had not fully implemented activities. Nevertheless, we
found that no one particular corrective action or restructuring option was
associated with making AYP, nor was the number of activities undertaken
associated with AYP.

We estimate that 42 percent of the schools in corrective action and
restructuring did not receive all required types of assistance through
their school district, although most received discretionary assistance
from their state educational agency. Districts are required to ensure that
several types of assistance are provided to all schools in improvement
status, including those in corrective action and restructuring. This
assistance ranges from analyzing student assessment data to revising
school budgets so that resources are allocated to improvement efforts.
NCLBA generally does not require states to provide specific kinds of
assistance to schools in corrective action and restructuring. However
states are required to develop a statewide system of support, including
school support teams that are available to provide technical assistance to
schools and districts. We estimate that most schools received some type of
assistance from the state. For example, 60 percent of schools received
assistance from a state support team and almost two-thirds received help
from instructional experts or highly skilled educators. Additionally,
almost half of the schools received state funds that were used for school
improvement activities such as professional development.

Education provides technical assistance and research primarily through its
Comprehensive Centers Program. The department replaced its former
assistance centers and various education consortiums with 16 regional
centers and 5 content centers to meet the requirements of the Education
Sciences Reform Act of 2002. These centers are to help low performing
schools and districts close achievement gaps and meet the goals of NCLBA.
The centers provide assistance and research to states on developing
approaches for improving schools. In addition, Education has expanded the
material in its Web-based What Works Clearinghouse to address a greater
number of topics and revised its district and school improvement guidance
by adding more material on school restructuring. While the clearinghouse
had little information on promising practices for schools in corrective
action and restructuring, Education is developing an initiative targeted
to principals, teachers, and other educators that is to develop practical
steps to improve schools on the basis of scientifically based research
identified by the clearinghouse and may have information on school
restructuring by the end of 2007.

To enhance school efforts to increase student achievement, we recommend
that Education provide guidance to districts on when schools may continue
previously implemented corrective actions rather than taking new ones. We
also recommend that Education obtain more specific information from states
on the specific improvement activities implemented by each school in
corrective action and restructuring as well as more specific information
on compliance issues states identified as part of their monitoring
activities. Finally, we recommend that the department take additional
steps through its monitoring process to ascertain whether states are
ensuring that districts provide the assistance required by NCLBA.
Education agreed with our recommendations and stated it would explore
options for providing more guidance, gathering additional information from
states, and improving its monitoring activities.

Background

Under NCLBA, states are required to establish performance goals and hold
their Title I schools accountable for students' performance by determining
whether or not schools have made AYP. Schools that have not met their
state's performance goals for 2 or more consecutive years are identified
for improvement and must implement certain activities that are meant to
improve student academic achievement. Districts and states play a role in
this process by providing technical assistance to schools. In addition,
states are responsible for monitoring district and school compliance with
NCLBA. Education provides states and districts with guidance on school
improvement and monitors states for compliance with NCLBA requirements.

States and Districts Are Held Accountable for the Performance of Their Schools
and Must Take Action to Improve Student Achievement When Schools Do Not Make AYP
for 2 or More Years

Prior to NCLBA, the Congress attempted to hold states accountable for the
annual performance of their schools by requiring them to collect
assessment data, develop criteria to determine whether schools and
districts were performing satisfactorily, and conduct student assessments.
The 1994 reauthorization of ESEA--Improving America's Schools Act
(IASA)--required that schools be designated for improvement for failure to
make AYP for 2 consecutive years and that districts take corrective action
as a final intervention for schools that repeatedly missed AYP.^4 However,
under IASA states assessed AYP in different ways and used different
measures to evaluate school performance. NCLBA added several new
provisions to address these differences and to strengthen accountability.
These provisions include:

^4Pub. L. No. 103-382.

           o The requirement that states develop plans that include academic
           standards and establish performance goals for meeting AYP that
           would lead to 100 percent of their students being proficient in
           reading, mathematics, and science by 2014.^5 To measure their
           progress, states were required to establish academic proficiency
           goals for making AYP and to administer an annual assessment to
           students in most grade levels.^6 In addition, each school's
           assessment data must be disaggregated in order to compare the
           achievement levels of students within certain designated groups
           with the state's proficiency targets. These student groups include
           the economically disadvantaged, major racial and ethnic groups,
           students with disabilities, and those with limited English
           proficiency, and each of these groups generally must make AYP in
           order for the school to make AYP.
           o A timeline for implementing specific interventions based on the
           number of years the school missed AYP.^7 For a school that fails
           to meet AYP for 2 consecutive years, districts must offer students
           in these schools the opportunity to transfer to a
           higher-performing public school in the district, and after the
           third year, they must also offer supplemental education services
           (SES), such as tutoring. In addition, the school must also develop
           an improvement plan in consultation with the district, school
           staff, parents, and outside experts. These plans, which are
           subject to district approval, must incorporate strategies to
           address the specific academic issues that caused the school to be
           identified for improvement. Under NCLBA, if a school fails to make
           AYP for 4 consecutive years, it is required to implement one of
           the corrective actions identified in the legislation. In addition,
           a new intervention to change the governance of schools--school
           restructuring--was introduced for schools that miss AYP for 5 or
           more years. (See table 1.) Districts are responsible for selecting
           and implementing the corrective actions and restructuring options
           for these schools. Schools exit improvement status if they make
           AYP for 2 consecutive years.

^5This requirement applies to all states and students in public schools
regardless of whether the school receives Title I funding or not.

^6Students in grades 3 to 8 must be annually assessed in reading and
mathematics, while high school students are only required to be assessed
once in these subjects. Assessments in science, which were first required
under NCLBA in school year 2007-2008, are required at least once in grades
3 to 8, grades 6 to 9, and grades 10 to 12. 20 U.S.C. S 6311(b)(3)(C)(v) -
(vii).

^7The timelines and other requirements for these improvement strategies
are outlined in 20 U.S.C. S 6316(b).

Table 1: Timeline for Implementing Interventions for Schools That Do Not
Make Adequate Yearly Progress

Adequate yearly   School status in the next  NCLBA interventions for Title 
progress          year                       I schools                     
First year missed Not Applicable             None                          
Second year       Needs Improvement (First   Required to offer public      
missed            Year of Improvement)       school choice^a               
Third year missed Needs Improvement (Second  Required to offer public      
                     Year of Improvement)       school choice and SES         
Fourth year       Corrective Action (Third   Implement certain corrective  
missed            Year of Improvement)       actions and offer public      
                                                school choice and SES         
Fifth year missed Planning for Restructuring Plan for a change in          
                     (Fourth Year of            governance and offer public   
                     Improvement)               school choice and SES^b       
Sixth year missed Implementation of          Implement a change in         
                     Restructuring (Fifth Year  governance and offer public   
                     of Improvement)            school choice and SES         

Source: GAO analysis of NCLBA and Education's regulations.

aAt this stage, the school must also develop the school improvement plan.

bWhile NCLBA does not require that corrective actions must be continued
after a school enters restructuring, Education officials noted that in
practice, many schools continue corrective actions after entering
restructuring status.

Schools in corrective action must implement at least one of six activities
such as replacing selected school staff or implementing a new
curriculum.^8 Schools that do not make AYP after 5 years must plan for
restructuring, which means that the district must decide how to change the
school's governance. Restructuring, the most severe of the NCLBA
interventions, requires that the school implement a major change to how
the school is operated, such as reorganizing into a public charter school
or contracting with an outside organization such as a private management
company to operate the school.^9 If the school does not make AYP during
the planning phase, the school enters restructuring. The corrective action
and restructuring activities allowed under NCLBA are shown below in table
2. NCLBA does not address actions that districts must take after
implementing restructuring and the school continues to fail to make AYP.
Education officials said that they have encouraged states and districts to
continue to try different interventions with these schools.

^820 U.S.C. S 6316(b)(7).

^920 U.S.C. S 6316(b)(8).

Table 2: Allowable Activities for Schools in Corrective Action and
Restructuring

Corrective actions                  Restructuring options                  
The district must implement at      The district must implement at least   
least one of the following actions: one of the following options:          
                                                                              
      o Replace the school staff who      o Reopen the school as a charter    
      are relevant to the failure to      school                              
      make AYP                            o Replace all or most of the school 
      o Institute and fully implement     staff (which may include the        
      a new curriculum                    principal) who are relevant to the  
      o Significantly decrease            failure to make AYP                 
      management authority at the         o Contract with another             
      school level                        organization or company to operate  
      o Appoint an outside expert to      the school                          
      advise the school on its            o Turn the operation of the school  
      progress toward making adequate     over to the state                   
      yearly progress                     o Implement any other major         
      o Extend the school year or the     restructuring of the school's       
      school day                          governance, such as:                
      o Restructure the internal                                              
      organizational structure of the             o Expand or narrow the      
      school                                      grades served;              
                                                  o Close the school and      
                                                  re-open it as a theme       
                                                  school (for example, a math 
                                                  and science academy)        

Source: GAO analysis of NCLBA (20 U.S.C. S 6316(b)(7) and (8)) and
Education's guidance.

Both Districts and States Provide Technical Assistance to Schools in Improvement

The school district bears the primary responsibility for ensuring that its
schools in improvement, including those in corrective action and
restructuring, receive technical assistance, although the state also plays
a role in providing assistance. The purpose of the district's assistance
is to strengthen and improve the school's instructional program by helping
the school address the issues that caused it to make inadequate progress
in student achievement.^10 Specifically, the district must ensure that
each school identified for improvement receives assistance based on
scientifically based research in three areas: analysis of student
assessment data, identifying and implementing instructional strategies,
and analysis of the school budget, as shown in table 3 below.^11

^10Districts are required to ensure that their schools receive this
technical assistance, but they do not have to provide it directly
themselves. Instead, they may elect to provide it through other entities
such as an institution of higher education, private organizations,
educational service agencies, or other entities with experience in helping
schools improve academic achievement. 20 U.S.C. S 6316(b)(4)(B)(iv).

Table 3: NCLBA Technical Assistance Districts Are Required to Ensure for
Schools Identified for Improvement, Including Those in Corrective Action
and Restructuring

Data analysis                                                              
                                                                              
The district must ensure that school staff receive assistance in analyzing 
student assessment data to identify and develop solutions in areas such as 
                                                                              
      o Instructional deficiencies                                            
      o Parental involvement and professional development requirements        
Identification and implementation of strategies                            
                                                                              
The district must ensure that the school receives help to identify and     
implement                                                                  
                                                                              
      o Instructional strategies and methods that are grounded in             
      scientifically based research and address specific issues that cause    
      the school to be identified for improvement                             
      o Professional development relevant to implementation of such           
      strategies and methods                                                  
Budget analysis                                                            
                                                                              
The district must ensure that the school is provided with                  
                                                                              
      o Assistance in analyzing and revising its budget to fund activities    
      most likely to increase student achievement                             

Source: GAO analysis of NCLBA.

The state educational agencies are also responsible for making several
forms of technical assistance available to schools in improvement and
overseeing the improvement activities of districts. States generally are
required to reserve and allocate 4 percent of the state's total Title I
allocation for school improvement activities, with 95 percent of these
funds going directly to the districts. States are to prioritize their
assistance to districts that, among other things, serve the lowest
achieving schools, such as those in corrective action and restructuring.
They also are required to develop and sustain a statewide system of
support that provides technical assistance to schools, with a priority
given to those in improvement status. In addition, in developing the
statewide system of support, the state agency must:

           o Establish school support teams to work in schools throughout the
           state that are identified for improvement. The purpose of these
           teams is to assist schools to strengthen their instructional
           programs and must include individuals who are knowledgeable about
           scientifically based research and practice and its potential for
           improving teaching and learning.

           o Designate and use distinguished teachers and principals who are
           chosen from Title I schools and have been especially successful in
           improving academic achievement.

           o Devise additional approaches to improve student performance, for
           example, by drawing on the expertise of other entities, such as
           institutions of higher education, educational service agencies, or
           private providers of scientifically based technical assistance.

^1120 U.S.C. S 6316(b)(4) and 34 C.F.R. S 200.40.

Education Provides Assistance to States and Districts and Monitors for
Compliance

Education provides assistance to states in implementing NCLBA and monitors
states for compliance. Specifically, Education provides assistance to
states and districts in several ways such as issuing regulations,
providing guidance and policy letters, and through its comprehensive
centers. For example, the department published nonregulatory guidance that
was specific to schools in improvement and provided information on the
actions that districts and states must take to reform their schools in
compliance with NCLBA.^12 To help build the capacity of states to meet
NCLBA goals, Education awarded almost $57 million in fiscal year 2006 to
the 21 comprehensive centers. These include 16 regional centers
established to provide technical assistance to states within defined
geographic areas. In addition, Education established five content centers
that work closely with the regional centers to provide technical
assistance to states on school improvement. One content center focuses on
school improvement issues.

Education monitors each state agency to determine, among other issues,
whether the state is ensuring that districts are implementing NCLBA
requirements for school improvement. Education, the state agency, and
districts all play a role in ensuring that schools are meeting NCLBA
requirements. Their monitoring responsibilities are presented in table 4.

^12See LEA and School Improvement: Non-Regulatory Guidance (Department of
Education, Washington, D.C.: July 21, 2006).

Table 4: Education, State, and District Responsibilities for Monitoring
States, Districts, and Schools Identified for Improvement

Stakeholder              Roles and responsibilities                        
Education                Monitor states to assess the extent to which      
                            states provide leadership and guidance for        
                            districts and schools in implementing policies    
                            and procedures that comply with NCLBA             
State educational agency Monitor districts to ensure they are              
                                                                              
                               o Meeting NCLBA requirements for such things   
                               as school choice, providing SES, and providing 
                               technical assistance to schools identified for 
                               improvement;                                   
                               o Providing guidance to their Title I schools  
                               to ensure they are complying with NCLBA        
                               program requirements; and                      
                               o Ensuring that schools identified for         
                               improvement, corrective action, or             
                               restructuring implement required activities    
School district          Monitor Title I schools identified for            
                            improvement for developing the school improvement 
                            plan and implementation of school improvement     
                            activities, including parental involvement        
                            activities                                        

Source: GAO analysis of NCLBA and Education's monitoring plan for Title I
programs.

Education monitors states in two ways: (1) routinely gathers and analyzes
data collected from Web-based searches and documents, such as Consolidated
State Performance Reports,^13 and (2) on-site visits at least once every 3
years to monitor state compliance with Title I. During these site visits,
states are monitored to ensure that they are complying with Title I
program requirements, which includes providing the necessary guidance and
support to schools that are in improvement, including those in corrective
action and restructuring. In addition, according to Education's monitoring
guidelines, Education officials visit selected districts in each state and
ask for evidence on how schools are implementing required actions and
meeting timeframes. Once the review is complete, Education issues a report
to the state containing findings, recommendations, and required actions
needed to address identified problems. A state is generally given 30
business days to respond to the findings and required actions and also to
provide a timeline for addressing each issue. A state with significant
findings may have conditions attached to its Title I Grant and if it fails
to adequately address the identified deficiencies, the Secretary generally
may withhold the state's Title I funds that are used for state
administration until all requirements have been satisfied.

^13State may apply and report annually on multiple ESEA programs through a
single consolidated application and report. These annual reports include
information on numerous ESEA programs.

Schools in Corrective Action and Restructuring Were More Often Located in Urban
School Districts and Served Higher Percentages of Minority, Poor, and
Middle-School Students Than Other Title I Schools

Schools in corrective action and restructuring status in the 2005-2006
school year were more frequently located in urban school districts and a
few states and served higher percentages of minority, poor, and
middle-school students than other Title I schools.^14 In the 2005-2006
school year, 2,790 Title I schools were in corrective action, planning for
restructuring, or implementing restructuring (see fig. 1). These schools
comprised about 5 percent of all Title I schools and served over 2 million
students. Data for the 2006-2007 school year show that the numbers of
schools in corrective action and restructuring are growing, a trend that
is likely to continue.

Figure 1: Number of Title I Schools Identified for Corrective Action,
Planning for Restructuring, and Implementing Restructuring in 2005-2006

^14The number of schools in corrective action, planning for restructuring
or implementing restructuring are from the 2005-2006 school year. Their
characteristics and comparisons to all other Title I schools are based on
data from the 2004-2005 school year, the latest data available at the time
we began our analyses. The Common Core of Data (CCD) refers to schools as
Title I eligible. For the purposes of our analysis, we refer to these
school as Title I schools.

Schools in Corrective Action and Restructuring Were Concentrated in Urban Areas
and a Few States

Schools in corrective action and restructuring were predominantly located
in urban areas, especially compared to all other Title I schools, as shown
in table 5.

Table 5: Percentage of Schools in Corrective Action and Restructuring and
All Other Title I Schools in 2005-2006, by Locale

                           Schools in corrective action and All other Title I 
Locale                                     restructuring           schools 
Urban                                                 63                27 
Suburban                                              22                26 
Town/Rural                                            15                44 

Source: GAO analysis of data provided by Education.

Note: Locale data for 3 percent of all other Title I schools were missing.

Examples of urban areas with relatively higher numbers of schools in
corrective action and restructuring include Chicago, Detroit, Los Angeles,
New York, and Philadelphia. Nationwide, school districts in these 5 cities
alone contained over 25 percent of all schools in corrective action and
restructuring, as shown in Table 6. By comparison, these 5 districts
contained less than 4 percent of all other Title I schools.

Table 6: Percentage of Schools Nationwide in Corrective Action and
Restructuring in the Top 5 School Districts in School Year 2005-2006

School district     Schools in corrective action and restructuring 
City of Chicago                                                 10 
New York City                                                    7 
Los Angeles Unified                                              3 
Philadelphia City                                                3 
Detroit City                                                     2 

Source: GAO analysis of data provided by Education.

Note: Three other school districts (local educational agencies) each had 2
percent of the total of schools in corrective action and restructuring:
Hawaii Department of Education (56 schools), the District of Columbia
Public Schools (45 schools), and Baltimore City Public Schools (42
schools). The Hawaii Department of Education and the District of Columbia
Public Schools each serves simultaneously as a state educational agency
and a local educational agency (school district). New York City reported
its number of schools by regions within the school district. For our
report, we summed across regions within New York City to arrive at one
number for the district as a whole.

Consequently, schools in corrective action and restructuring were
concentrated in a few states. Five states--Illinois, New York, California,
Pennsylvania and Michigan--collectively had over 60 percent of these
schools, but less than 30 percent of all Title I schools nationwide. In
contrast, a majority of states had 20 or fewer schools in corrective
action and restructuring, as shown in figure 2.

Figure 2: Number of Schools in Corrective Action and Restructuring in
School Year 2005-2006, by State

In general, states with large numbers of schools identified for
improvement when NCLBA was passed had more schools in corrective action
and restructuring in the 2005-2006 school year than those with few schools
in improvement in 2001.^15 Prior to NCLBA, states had identified schools
for improvement, and when NCLBA was passed in the 2001-2002 school year,
it generally required states to maintain the prior improvement status of
schools.^16 Consequently, many schools that were in earlier stages of
improvement in school year 2001-2002 entered corrective action and
restructuring in subsequent years.

Schools in Corrective Action and Restructuring Served a Higher Percentage of
Minority, Economically Disadvantaged, and Middle School Students, Compared to
All Other Title I Schools

Schools in corrective action and restructuring also had a much higher
percentage of racial or ethnic minority students compared to all other
Title I schools (96 percent compared to 37 percent) and also enrolled a
higher percentage of economically disadvantaged students (83 percent
compared to 54 percent).^17 These differences varied substantially when
the location of the school is accounted for, as seen in table 7.

^15We also analyzed these data taking into account the number of schools
as a percentage of all Title I schools by state. In general, states with a
higher percentage of Title I schools in improvement when NCLBA was passed
also had a higher percentage in schools in corrective action and
restructuring in 2005-2006.

^1620 U.S.C. S 6316(f).

^17For this analysis, we compared the percentage of students who are
members of racial or ethnic minority groups or who qualified for free- or
reduced priced meals in the median schools when all schools were ranked by
the percent of those characteristics in the schools.

Table 7: Percentage of Students with Selected Characteristics, Comparing
Schools in Corrective Action and Restructuring with All Other Title I
Schools, by Locale

                           Schools in corrective action and All other Title I 
Locale                                     restructuring           schools 
                                      Minority status       
Urban                                                 98                84 
Suburban                                              93                34 
Rural/Town                                            93                11 
                                      Poverty status        
Urban                                                 83                70 
Suburban                                              81                45 
Rural/Town                                            83                49 

Source: GAO analysis of data provided by Education.

Note: The table shows the percentage of students who are members of racial
or ethnic minority groups or who qualified for free-or reduced-priced
meals in the median schools (by locale) when all schools were ranked by
the percent of those characteristics in the schools.

Schools in corrective action and restructuring varied in terms of the
grade level of students that they served. Compared with all other Title I
schools, middle schools were considerably over-represented among schools
in corrective action and restructuring while primary schools were
underrepresented, as seen in table 8.^18

^18Our finding on middle schools is similar to findings in other reports.
See U.S. Department of Education, National Assessment of Title I Interim
Report, Vol 1: Implementation, Institute of Education Sciences
(Washington, D.C.: February 2006); and Center on Education Policy, NCLB:
Middle Schools are Increasingly Targeted for Improvement (Washington, D.C:
2006). We found no notable difference between the percentage of middle
schools in corrective action and restructuring and the percentage of all
other Title I schools based on whether they were located in an urban,
suburban, or rural area.

Table 8: Percentage of Schools in Corrective Action and Restructuring
Compared to All Other Title I Schools, by Grade Level

                           Schools in corrective action and All other Title I 
Grade level                                restructuring           schools 
Primary                                               52                70 
Middle                                                32                15 
High                                                  12                10 
Other                                                  4                 5 

Source: GAO analysis of data provided by Education.

Note: For the purposes of our analysis, we used the definitions of
primary, middle, and high schools provided in the CCD, as described in
appendix I of this report.

Several factors might explain why middle schools are over-represented.
Evidence from the National Assessment of Educational Progress--especially
for many of the urban school districts with numerous schools in corrective
action or restructuring--shows that the percentage of students who score
at a proficient level or above in math is generally lower in middle
schools than in elementary schools.^19 Other factors may also include
being less qualified than their peers in elementary or middle schools,
teachers in middle schools, and social and emotional challenges associated
with students as they make the transition into middle schools.^20 Yet
another reason may be that because of NCLBA provisions about the minimum
number of students in a school that would comprise a designated student
subgroup, middle schools typically have to make AYP for more student
subgroups than elementary schools.^21

^19Results for reading are mixed, with proficiency rates higher for some
district's or groups of middle school students than elementary school
students, but lower for others. See U.S. Department of Education, The
Nation's Report Card: Reading 2005. NCES 2006-451 (Washington, D.C.:
October, 2005). See The Nation's Report Card: Mathematics 2005. NCES
2006-453 (Washington, D.C.: October, 2005); The Nation's Report Card:
Trial Urban District Assessment Mathematics, 2005, NCES 2006-457r
(Washington, D.C.: February 2006); The Nation's Report Card: Trial Urban
District Assessment Reading, 2005. NCES 2006-455r (Washington, D.C.:
February 2006).

^20RAND, Focus on the Wonder Years: Challenges Facing the American Middle
School (Santa Monica, Calif.: 2004).

^21Center on Education Policy, NCLB: Middle Schools Are Increasingly
Targeted for Improvement, NCLB Policy Brief 2 (Washington, D.C.: 2005).

The Number of Schools in Corrective Action and Restructuring Has Increased
Considerably from Last Year and May Continue to Do So

Data for the 2006-2007 school year showed that the number of schools in
corrective action and restructuring has increased. In 2006-2007, there
were 4,509 schools in corrective action and restructuring compared to
2,790 the year before, an increase of over 60 percent, and more than twice
as many schools compared to just 2 years earlier. (See fig. 3.)

Figure 3: Number of Schools in Corrective Action and Restructuring for the
3 Most Recent School Years

Note: For the 2004-2005 school year, we used data from the National
Assessment of Title I: Interim Report which had only one category for
schools in restructuring and did not distinguish between schools planning
for restructuring and those implementing restructuring. Also, this report,
which was not updated, included data from some states that had not
completed decisions for schools appealing their improvement status,
resulting in fewer schools ultimately identified than was reported.

Additionally, 41 states had more schools in corrective action and
restructuring whereas only 8 states had fewer.^22 (See fig. 4 and see app.
II for a comprehensive list of the number of schools in corrective action
and restructuring in each state.) Most notably, in 2006-2007, the state of
Florida had 574 schools in those categories compared to only 32 such
schools in 2005-2006. According to a Florida state official, this increase
is attributable to the fact that many schools have been struggling to meet
the increasing proficiency targets. Other states with large increases
include California (increase of 376 schools) and Massachusetts (increase
of 118 schools). A few states, such as Michigan, had fewer schools in
corrective action and restructuring in 2006-2007 compared to the prior
year. In Michigan's case, it is not clear whether the decrease was related
to state or district reform efforts, changes in criteria making it easier
for schools to make AYP, or some combination of these factors.^23

^22The number of schools in corrective action and restructuring for one
state did not change between school years 2005-2006 and 2006-2007, and
another state had yet to finalize its data for 2006-2007.

^23See Center on Education Policy, What Now? Lessons from Michigan about
Restructuring Schools and Next Steps Under NCLB (Washington, D.C.: 2007).

Figure 4: Change in the Number of Schools in Corrective Action and
Restructuring from 2005-2006 to 2006-2007, by State

Note: Missouri did not submit to Education its final list of schools
identified for improvement in the 2006-2007 school year.

The general trend toward higher numbers of schools in corrective action
and restructuring may continue. As of the 2006-2007 school year, more
schools were identified for improvement than at any time since such data
were tracked under IASA. As proficiency targets continue to increase up to
100 percent by 2014, many schools identified for improvement may not make
AYP. Consequently, if these schools cannot meet the increasing proficiency
targets, they will enter corrective action and ultimately restructuring.

Most Schools Used a Corrective Action or Restructuring Option, but Some May Not
be Meeting NCLBA Requirements

Our survey results indicated that a majority of schools in corrective
action and restructuring implemented required activities; however, in some
cases schools may not be in compliance with NCLBA requirements.^24
Although many schools in corrective action implemented multiple corrective
actions, some did not take any corrective action. A majority of
restructuring schools implemented a required restructuring option, but
based on our survey results, about 40 percent of schools did not take any
of the 5 restructuring options required by NCLBA, one of which is a broad
category referred to as "other" major restructuring. Although there was no
relationship between any of the specific activities and whether a school
made AYP, a higher percentage of schools that fully implemented
improvement activities made AYP compared with those that had not fully
implemented activities.

Among Schools in Corrective Action, Almost All Took at Least One Corrective
Action, but Some May Not Have Taken an Action As Required by NCLBA

Among schools in corrective action status, we estimate that 94 percent
implemented at least one corrective action from those specifically
identified by NCLBA, and about three-quarters had used more than one
corrective action. Hiring an outside expert and changing the internal
structure of the school were the most frequent actions, with each
implemented by about 60 percent of schools. Outside experts are used to
advise the school on its progress toward making adequate yearly progress.
Among schools that changed their internal structures, about 85 percent
increased small group work and about 75 percent reorganized the school
schedule to increase opportunities for professional development. Many
schools also reduced class size, created small learning communities, and
implemented team teaching as part of the changes to the organizational
structure. In addition to hiring outside experts and changing internal
structure, about 40 percent of schools changed the curriculum. A smaller
percentage of schools implemented certain forms of corrective actions such
as extending the school year or day or decreasing management authority at
the school level. Some officials explained that extending the school year
or day would be costly to the district because teacher salaries may have
to increase to compensate for the additional instructional time. For the
majority of schools, district officials played a significant role in
determining the action taken. Figure 5 shows the allowed corrective
actions and the percentage of schools implementing each action.

^24All survey findings are based on what school officials reported through
GAO's Web-based or paper survey. We did not verify whether schools had
implemented the activities they reported taking.

Figure 5: Corrective Actions Allowed under NCLBA and Estimated Percentage
of Schools That Implemented Each Action in 2005-2006

Note: These sum to more than 100 percent because some schools implemented
more than one action.

Based on our survey, we estimate that 6 percent of schools in corrective
action status did not take corrective actions. For example, in one school
we visited, the principal told us that the school had not implemented any
changes during its year in corrective action. He told us that the district
provided no input on the required actions and that the state educational
agency approved the school improvement plan without comment.

About a third of schools that went into corrective action in 2005-2006 did
not take a new corrective action in that year. These schools took
corrective action in earlier years of improvement and did not implement
any further corrective actions after entering corrective action status.
For example, some schools indicated that the school used an outside expert
or implemented a new curriculum in previous school years and had not
implemented any additional corrective actions the year in which the school
entered corrective action status. Education officials told us that if a
school implemented a corrective action in earlier stages of improvement
(year 1 or 2 of improvement), an additional corrective action might not be
required. They explained that whether a district must take additional
actions depends in part on whether the school is showing improvement in
student achievement. If the school showed evidence that the intervention
is producing results that are likely to enable the school to exit
improvement status, an additional corrective action might not be
necessary. On the other hand, Education officials noted that if the data
indicates that the previous corrective actions have not addressed the
school's achievement problems they would expect the district to take
additional corrective action. While it may be appropriate in some cases
for schools to continue implementing the same actions, Education officials
acknowledged that they have not provided written guidance on when
continuing prior actions without implementing a new one would be
acceptable.

Department officials told us that while they had conducted Title I
monitoring in every state, they had not found compliance issues
specifically related to corrective action from their monitoring visits.
States are required to conduct annual reviews of district progress in part
to ensure that districts are carrying out their responsibilities, one of
which is taking at least one corrective action when necessary. However,
states generally do not report to Education district noncompliance, such
as failure to take corrective actions as required. Under NCLBA, states are
required to annually submit to Education and make widely available the
measures taken to address the achievement problems of schools in
improvement status, including schools in corrective action. However,
Education does not require states to report on the measures taken for each
school. Instead, Education requires states to provide a brief summary of
the measures taken across the state. Consequently, Education lacks
information on which action was taken by each school, whether schools are
taking actions at all, and whether or not states have taken any actions
against schools or districts for failure to comply with NCLBA.

Among Schools in Restructuring, Almost Two-Thirds Implemented a Restructuring
Option; However, Many Schools May Not Be in Compliance with NCLBA Requirements

We estimate that a majority of schools in restructuring had implemented at
least one of the five restructuring options allowed by NCLBA.^25 According
to NCLBA, each of these options is to result in a major change to the
school's governance. As figure 6 shows, about 40 percent of the schools
implemented the "other" major restructuring of the school's governance,
which can include such actions as expanding or narrowing the grades served
or creating smaller learning communities within the school.^26 We estimate
that 27 percent of schools replaced all or most of the staff related to
the school's performance issues.

Figure 6: Restructuring Options Allowed under NCLBA and Estimated
Percentage of Schools That Implemented Each Option

^25The information provided in this section pertains only to those schools
that were in the implementation stage of restructuring in 2005-2006 school
year. This section does not pertain to schools that were planning for
restructuring.

^26Another study found similar results for schools implementing
restructuring in the state of California. See Center on Education Policy,
Beyond the Mountains: An Early Look at Restructuring in California
(Washington, D.C.: 2007).

Of the 40 percent of schools that selected "other" major restructuring of
the school's governance, 44 percent created smaller learning
communities--an approach taken by some of the schools we visited.^27 For
example, one middle school we visited created "academies" within the
school. Each academy had its own theme, and students stay within the
academy as they are promoted from grade to grade. Another 37 percent of
schools that chose the "other" option narrowed or expanded the range of
grades served within the school, for example, changing a
kindergarten-through-grade-five elementary school to a kindergarten-
through-grade-eight school. In one district we visited, officials reported
that a kindergarten-through-grade-eight model creates a more positive
learning environment than middle schools do as it creates a sense of
family and relationships in schools. Figure 7 shows the various types of
restructuring activities taken by schools implementing "other" major
restructuring.^28

^27Margins of error for estimates pertaining to schools that implemented
"other" major restructuring do not exceed 15 percent.

^28These categories reflect the examples of "other" major restructuring
provided in Education's 2006 guidance.

Figure 7: Among Schools Implementing "Other" Major Restructuring,
Estimated Percentage of Schools Implementing Various Activities

In addition to the "other" major restructuring option, in an estimated 27
percent of restructuring schools, all or most of the staff (primarily
teachers and principals) who were relevant to the failure to make AYP were
replaced. The schools we visited that replaced staff varied in terms of
whether teachers, principals, or both were replaced. Our survey indicated
that for many of these schools, it was difficult or very difficult to
recruit new teachers as replacements.

Very few schools in restructuring had contracted with an entity, such as a
private management organization, become a charter school, or been taken
over by the state. Some states may not have authorized all restructuring
options under state law or policy, which may explain why fewer schools
have taken these options. For example, according to a recent report, while
some states have policies that permit districts to turn schools over to
private management or to reopen schools as charter schools, others do
not.^29 In three of the five states we visited, state officials reported
that their state educational agencies currently do not take over
schools.^30 In one of these states, turning over school management to the
state agency is permissible under state policy, but officials told us that
the state does not have the capacity or expertise to do so.^31 The amount
of time it takes to plan for such a change may also be a factor in why
these options are not often selected. For example, a district official
reported that the district did not have sufficient time during the
restructuring planning process to seriously consider reopening as a
charter school, contracting with a private management company, or turning
the operation of the school over to the state. In about 70 percent of
schools, the district played a significant role in determining the
restructuring option taken.

Although a majority of schools implemented a restructuring option, about
40 percent of the schools that were in restructuring did not take any of
the 5 restructuring options prescribed under NCLBA, according to our
survey results. Several principals of schools that had not restructured
did not know why an option was not taken. In other cases, principals
believed that the school board or district had decided not to restructure.
In addition, one of the surveyed schools and some school and district
officials we visited did not believe restructuring was necessary when
student achievement was improving. For example, officials at one of the
schools we visited that was planning for restructuring indicated that the
district and school administration had determined that no changes were
needed because they were confident that the actions already taken were
helping students.

Nonetheless, about half of the schools that did not take one of the five
restructuring options engaged in a variety of school improvement efforts.
Some of these efforts may fall under the "other" major restructuring
option, while others do not appear to be consistent with NCLBA
requirements for restructuring. For example, one school implemented a new
curriculum as a restructuring option, while at another school extra
funding was used for small group instruction and after-school programs,
both of which more closely resemble corrective action under NCLBA. In
addition, in two districts we visited, officials allowed schools that were
improving to continue efforts started under prior stages of improvement.
However, we could not determine based on the information reported by
survey respondents whether these activities would be considered
restructuring under NCLBA. Further, several Education officials we spoke
with could not determine whether or not the actions schools reported
taking were in compliance without more information from the schools, such
as other on-going districts efforts.

^29Education Week (Editorial Projects in Education), "Quality Counts:
2007. From Cradle to Career: Connecting American Education from Birth to
Adulthood," (Bethesda, Md.: January 2007).

^30According to the same report, many states currently authorize turning
over school management to the state educational agency through state
policy. (Education Week (Editorial Projects in Education), (January 2007).

^31Another state educational agency we visited attempted to take over
schools, but state officials told us that the state legislature prevented
it from doing so.

Similar to our finding that many schools may not be implementing a
restructuring option, Education's 2006 interim report on Title I stated
that very few schools in restructuring status implemented a restructuring
option prescribed by NCLBA, though many implemented actions NCLBA
specifies for the corrective action stage of school improvement.^32
Despite these findings, department officials told us that they did not
have any monitoring findings related to restructuring requirements, nor
did they know whether any states had found districts that had not
implemented restructuring requirements, although they did find
deficiencies in some districts' review of school improvement plans.

Education's monitoring tools and reporting requirements do not fully
address issues of compliance. While Education's state monitoring tool
includes questions about how states monitor the implementation of school
improvement plans, Education officials acknowledged that the department
may be able to strengthen its monitoring tool to determine whether state
oversight of districts is adequate to ensure compliance. Also, since
states are not required to report district noncompliance to Education and
Education does not require states to report on the specific corrective
actions and restructuring options taken to address the achievement
problems of each school, federal officials have limited information on
areas in which there are compliance issues as well as the extent to which
districts are complying.

^32Department of Education, National Assessment of Title I Interim Report,
Vol. 1: Implementation, Institute of Education Sciences (Washington, D.C.:
February 2006). Education explained its findings in part by noting that
the survey did not specify whether schools were planning restructuring or
implementing restructuring.

A Higher Percent of Schools That Fully Implemented Improvement Activities Made
AYP

We estimate that over a third of schools that fully implemented a
corrective action or restructuring option made AYP, as opposed to 16
percent of schools that had mostly or partially implemented improvement
activities.^33 Several officials noted, and research shows, that school
improvement efforts take more than a year to affect student achievement,
so it is possible that these activities will help these schools make AYP
over the next several years. Many district and school officials we
interviewed told us that implementing a new curriculum takes time and that
other improvement efforts can take several years to fully implement and to
see results. Other factors also can affect school improvement efforts. For
example, among the schools that made AYP, 76 percent of principals
believed teacher quality helped or greatly helped school improvement
activities in their school, opposed to only 53 percent among schools that
had not made AYP.^34 In addition to teacher quality, around 80 percent of
school officials believed that instructional support and resources, such
as teacher aides and computers, helped or greatly helped their school
improvement efforts. Schools lacking such support may find implementation
of corrective action and restructuring more challenging.

Based on our survey results, none of the specific corrective actions or
restructuring options was associated with making AYP, nor was making AYP
associated with the number of activities undertaken, and these findings
are consistent with recent research on school improvement.^35 Many school
officials believed that other factors affected student achievement and
therefore, the schools' ability to make AYP. About 80 percent of school
principals believed that community poverty impeded student achievement,
while two-thirds believed community violence impeded achievement. We found
similar views during our site visits.^36 For example, at two schools we
visited, officials noted that the presence of gangs in the neighborhood
affected student achievement, and teachers at one school commented that it
was unsafe for students to visit the community library after dark. Several
school and district officials observed that poverty affected students'
academic efforts. School officials noted that many poor students cannot
stay late at school because they have family obligations, such as taking
care of younger children. In addition, about two-thirds of school
principals believed that student mobility (moving from one school to
another) impeded student achievement, and several officials said that
districtwide or statewide curricula had been implemented, in part, to
address widespread student mobility by establishing a consistent
instructional approach across schools. Moreover, we estimate that nearly
half of school officials believed that low student attendance impeded
student achievement at their school. This finding was more prevalent among
schools that had not made AYP compared to schools that had made AYP.
Finally, several activities were undertaken by very few schools, such as
state takeover or extending the school year, so these activities'
association with AYP could not be accurately assessed in this study.

^33Our findings throughout this section are based on analyses that did not
allow us to determine whether the type of school improvement activity,
level of implementation, or number of activities taken caused schools to
make AYP. However, we did test for whether these factors were related to
making AYP, and found no statistically significant relationships. The RAND
Corporation has conducted a study that emphasizes the importance of
implementation of school reform efforts. See RAND, Evaluating
Comprehensive School Reform Models at Scale: Focus on Implementation
(2006), Arlington, VA.

^34Among schools that made AYP, the 95 percent confidence interval for
this estimate ranges from 65 percent to 87 percent of principals who
believed teacher quality helped or greatly helped school improvement
activities in their school.

^35Mintrop, H. and Trujillo, T., "Corrective Action in Low-Performing
Schools: Lessons for NCLB Implementation from First-Generation
Accountability Systems," Education Policy Analysis Archives, Vol. 13,
Issue 48 (December 2005) and Ronald C. Brady, Can Failing Schools be
Fixed? (Thomas B. Fordham Foundation, Washington, D.C.: January 2003).

Many Schools in Corrective Action and Restructuring Did Not Receive All Required
Assistance through Their School Districts; However, Most Received Assistance
from Their State

We estimate that more than 40 percent of the schools in corrective action
and restructuring did not receive all of the required technical
assistance, such as data analysis and professional development, through
their school district, but most of the schools received some technical
assistance from their state. While states generally are not required to
provide specific kinds of assistance to schools, they are required to
develop a statewide system of support that is available to schools and
districts and to provide technical assistance to schools if the district
fails to do so. Most schools reported receiving technical assistance from
their state educational agency, such as help from instructional experts or
highly skilled educators.

^36Our prior work has also documented some administrative challenges
associated with student mobility. See [40]GAO-05-879 , No Child Left
Behind Act: Education Could Do More to Help States Better Define
Graduation Rates and Improve Knowledge about Intervention Strategies
(Washington, D.C.: Sept. 20, 2005).

Many Schools in Corrective Action and Restructuring Did Not Receive All Required
Assistance through Districts

We estimate that 42 percent of the schools in corrective action and
restructuring had not received all of the required assistance in school
year 2005-2006 while about 56 percent did. Schools most frequently
received technical assistance related to professional development (92
percent) and instructional strategies (90 percent). However, only about 70
percent received assistance with analyzing the school budget to ensure
that resources were allocated toward improving student achievement. We
also found, based on our survey results, that 7 out of 313 schools (about
2 percent) in corrective action and restructuring received no assistance.
(See fig. 8 for the percentage of schools receiving each type of required
technical assistance.)

Figure 8: The Estimated Percentage of Schools in Corrective Action and
Restructuring That Received Each Form of Required Technical Assistance
through Districts in School Year 2005-2006

Education officials noted that through their monitoring site visits they
found that some districts had not provided all of the assistance required.
In these instances, Education officials said states could withhold Title I
funds from the districts that are out of compliance. However, Education
could not tell us how often states take actions against districts for not
providing required assistance, because according to one Education
official, Education did not collect this information from states.

Generally, school officials we met with told us that the district was
actively involved in providing assistance to their schools. Almost all
school principals and teachers that we interviewed specifically emphasized
district efforts to train their administrators and teaching staff to
analyze and use student testing data to target their instruction to areas
of academic weakness and to students that needed additional assistance. In
addition, they said that districts had targeted resources to provide
professional development and implement effective instructional practices.
For example, in most districts we visited, school officials said that
literacy or math coaches had been hired to provide staff development or to
work with teachers to identify instructional practices to improve
instruction. Also, in some schools we visited, officials told us that
districts assisted the schools in their efforts to increase parental
involvement. For example, in New York City, the district helped some
schools by approving a parent coordinator position to get parents more
involved in their schools. Officials in some districts also reported
reviewing school budgets to ensure that resources are allocated to
programs that target student performance. In regard to budget assistance,
district officials in Chicago told us that they must approve budgets of
all schools in restructuring. In addition, principals in two California
schools reported that the district reviewed their budgets and recommended
expenditures that targeted school improvement activities.

Most Schools Received Some Assistance from State Educational Agencies, and
Almost Half of Schools Received State Funds for School Improvement

Most schools received some assistance from their state educational agency,
and almost half received state funds for school improvement. States are
required to develop a statewide system of support that is available to
assist districts. As a part of this system, states must create school
support teams, which are composed of various participants, including
highly qualified or distinguished educators, such as teachers and
principals who can assist the school in strengthening its instructional
program to improve student achievement. We estimate that about 65 percent
of schools received assistance from their state educational agency in
developing the school improvement plan, and 60 percent received assistance
from a school support team (fig. 9). Although state educational agencies
generally are not required to provide specific kinds of technical
assistance to schools in corrective action and restructuring, they are
required to ensure that districts are providing all of the required
assistance to schools identified for improvement, and if the district has
not, state educational agencies must step in and provide the assistance.

An estimated 47 percent of the schools in corrective action and
restructuring received state funds for school improvement activities in
addition to federal Title I funds. While state funds were used for many
different kinds of school improvement activities, more than 75 percent of
the schools surveyed used the funds for professional development
activities, classroom support such as instructional and resource
materials, or both. In addition, officials in four of the five states we
visited told us that schools received state funds for school improvement
activities. Maryland provides its schools guidelines on how the funds can
and cannot be used and the guidelines emphasize that whenever possible,
the funds should be used to improve instruction, such as purchasing
textbooks or hiring more school staff. Schools in California and New York
apply for state funds and must include a plan for how the funds will be
used.

Figure 9: Estimated Percentage of Schools in Corrective Action and
Restructuring in 2005-2006 That Received State Assistance

Education Provides Technical Assistance and Research on School Improvement,
Including Some Specific Information on School Restructuring

Education provides technical assistance and research results to states
primarily through its Comprehensive Centers Program, consisting of 16
regional centers and 5 content centers (fig. 10). The department replaced
its former assistance centers and various education consortiums to meet
the requirements of the Education Sciences Reform Act of 2002.^37 The
primary task of the content centers is to provide knowledge and assistance
by experts in school improvement to regional centers. The regional centers
are to provide technical assistance to states on a wide range of topics
related to NCLBA, in part based on information provided by the content
centers.

^37The comprehensive centers under this program replaced the former
Comprehensive Regional Assistance Centers, the Regional Technology in
Education Consortia, the Eisenhower National Clearinghouse for Mathematics
and Science Education, and the Regional Mathematics and Science Education
Consortia.

Figure 10: Education's Content and Regional Centers

One content center, the Center on Innovation and Improvement, provides a
variety of services related to school improvement. The center developed a
guide, Handbook on Restructuring and Substantial School Improvement,^38
which it has disseminated to regional centers, state educational agencies,
and other organizations. The handbook provides information on using
student data to identify a restructuring option and focusing instruction
on state standards, among other topics. Other services include the
center's annual 2-day training for representatives from the regional
centers and additional workshops throughout the year on various
improvement topics. The center produced a series of Web-based seminars
during the spring and summer of 2007, also based on the handbook, for use
by the regional centers. In addition, each regional center has developed
an annual work plan, negotiated with the states for which it is
responsible. For example, the New York Regional Center provides assistance
to the state of New York and has negotiated a work plan with several goals
related to school improvement. One goal is to help the New York State
Education Department build its school improvement capacity by assisting
with delivery of research-based professional development related to
adolescent literacy.

^38See Herbert J. Walburg, editor. "Handbook on Restructuring and
Substantial School Improvement" (Center on Innovation and Improvement,
Lincoln, Ill.: 2007).

Education developed the What Works Clearinghouse to review studies of
educational interventions to determine which studies were conducted with a
sound methodology and to what extent the interventions are effective. The
clearinghouse has reviewed studies on topics such as preventing dropouts
and increasing elementary and middle school achievement in mathematics.
While these topics are likely to be of interest for schools in corrective
action and restructuring, the clearinghouse has not reviewed studies that
specifically deal with practices employed by schools in corrective action
and restructuring. Moreover, several state, district, and school officials
we interviewed indicated that they needed more information on practices
for improving schools in corrective action and restructuring. For example,
an official in one district told us that they had been attempting to
create their own approaches to improve schools, but said that there was
insufficient information, from federal or other sources, on improvement
practices. Recognizing the need for information that may be more suited
for teachers, principals, and other educators, Education officials
reported that the department will launch a Web site in September 2007
related to their initiative, Doing What Works. Through this initiative,
Education would review studies identified by the clearinghouse and develop
materials, called "practice guides" for educators. According to Education,
a practice guide on school restructuring is in development and may be
available by the end of 2007.

In addition to the Comprehensive Centers and What Works Clearinghouse
programs, Education implemented a variety of other initiatives that may
assist officials in their efforts to improve schools. The department
revised its guidance in July 2006 to provide more information on school
restructuring. In addition, Education operates 10 Regional Education
Laboratories that provide research on a variety of topics. For example,
the Northwest Regional Education Laboratory is currently examining
statewide systems of support and the factors that have helped schools make
AYP. The laboratories are also available to provide assistance to any
entity, such as school districts or schools, that may request information
from them. Other resources include the Support for School Improvement
newsletter, developed by the Council of Chief State School Officers and
funded in part by Education. The newsletter focuses on topics such as
school improvement policies and closing achievement gaps among student
groups. Education also funds a clearinghouse for Comprehensive School
Reform, which disseminates research on effective approaches to school
reform through publications such as a recent report on what improvement
practices might work for schools in restructuring.^39

Conclusions

Schools that reach corrective action and restructuring status face many
challenges in raising the achievement levels of their students. These
schools typically serve low-income students, and many report that factors
such as neighborhood violence and student mobility pose additional
challenges to engaging students and improving their academic performance.
While most of these schools have implemented activities that are required
by NCLBA, it is possible that a significant number of schools have not.
Although Education has made efforts to provide guidance to districts on
what actions are required and when, the department's efforts do not
address several specific issues that would allow states, districts, and
schools to make well informed decisions that are in compliance with NCLBA.
For example, many schools in corrective action continued efforts
implemented previously but did not implement a new action. While this
course of action may be a reasonable and appropriate path for some schools
to take, Education has not provided guidance to districts delineating when
continuing a corrective action--and not taking an additional one--is
appropriate and when it is not. Without written guidance, some districts
and schools that are not demonstrating sustained improvement may continue
previous efforts in order to avoid having to make more changes. On the
other hand, some districts may not know they can comply with NCLBA by
continuing an action that is moving their schools forward and instead may
be struggling to choose another prescribed activity that is not needed.

While Education monitors states to ensure compliance with NCBLA--and has
found deficiencies in some districts' reviews of schools' improvement
plans--department officials told us that they were unaware that some
districts may not be implementing the required corrective action and
restructuring activities because they do not collect that specific
information. Collecting information on the activities of schools in
corrective action and restructuring and on compliance issues identified by
states would better position Education to target its guidance and
monitoring on areas of greatest need.

^39Learning Point Associates, School Restructuring Under No Child Left
Behind: What Works When? A Guide for Education Leaders. (Naperville, Ill.:
2007).

Finally, our review indicates that many schools may not be receiving all
the types of assistance that they are supposed to receive through their
districts. However, Education officials told us that they have not found
any instances in which schools in corrective action and restructuring have
not received required assistance, and officials noted that Education does
not track the extent to which states also have found such incidences.
Schools that are not receiving this assistance might not be able to make
the kinds of dramatic improvement needed for their students, in part
because they may not be receiving the resources to improve as envisioned
by NCLBA.

Recommendations

The Secretary of Education should:

           o Ensure that guidance is provided to states and districts about
           when it may be appropriate to allow schools to continue corrective
           action implemented in earlier years of improvement and not take a
           new activity as the school moves into corrective action status.

           o Obtain more specific information from states on district
           implementation, such as the primary activity that each school in
           corrective action and restructuring is implementing as well as
           more specific information on compliance issues states have
           identified as part of their monitoring activities. This
           information should be analyzed to identify areas where further
           federal guidance is needed and to ensure that areas of
           noncompliance are being addressed by states.

           o Take additional steps through Education's monitoring process to
           ascertain whether states are ensuring that districts provide the
           assistance required by NCLBA.

Agency Comments and Our Evaluation

Education provided us with written comments on a draft of this report.
Education agreed with our three recommendations to provide more guidance
to states and districts, obtain more information on district
implementation of corrective action and restructuring activities, and take
additional steps to determine whether districts are providing assistance
required by NCLBA. Specifically, Education agreed to explore options for
sharing guidance on when schools may continue a corrective action while
not taking a new one and commented that it will explore sharing guidance
that address other issues related to schools in corrective action and
restructuring that it has asked states to identify. While Education noted
that it is generally informed on the actions taken in schools in
corrective action and restructuring, it agreed that more information is
needed from states on district implementation of corrective action and
restructuring activities and that it will consider options for gathering
additional evidence on how states ensure that districts are complying with
corrective action and restructuring requirements. Finally, Education
agreed to consider ways for revising its monitoring procedures in order to
obtain more information on how states determine whether districts are
providing technical assistance to these schools, the types of assistance
they provide, and the actions states take to address areas of
noncompliance. See appendix III for Education's comments. Education also
provided us with a few technical comments that we incorporated.

We are sending copies of this report to the Secretary of Education 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 [41]http://www.gao.gov .

Please contact me at (202) 512-7215 if you or your staff have any
questions about this report. Contact points for our Offices of
Congressional Relations and Public Affairs may be found on the last page
of this report. Major contributions to this report are listed in appendix
IV.

Cornelia M. Ashby
Director, Education, Workforce, and Income Security
Issues

Appendix I: Scope and Methodology

To address the objectives of this study, we used a variety of methods. To
obtain a national perspective, we conducted descriptive analyses of
characteristics of schools in corrective action and restructuring and
compared them to all other Title I schools nationwide. We selected a
nationally representative sample of these schools and conducted two
Web-based surveys--one of principals whose schools were in corrective
action and another for schools implementing restructuring--to obtain
information on implementation of corrective action and restructuring and
school district and state assistance to such schools. We also conducted
site visits during which we interviewed state, district, and school
officials representing 5 states and 10 school districts within these
states, and we conducted phone interviews with state officials from 4
other states. We spoke with officials at Education involved in oversight
and implementation of corrective action and restructuring in schools and
reviewed Education's data on schools identified for improvement. We also
interviewed several experts in the field of school improvement. We
reviewed federal laws, regulations, and agency guidance. We conducted our
work from August 2006 through August 2007 in accordance with generally
accepted government auditing standards.

Objective 1: Analysis of School Characteristics

To address the first objective, we obtained lists of schools in corrective
action, planning for restructuring, and implementing restructuring status
and their school districts from Education. States submitted these lists to
Education through the No Child Left Behind Act (NCLBA) Consolidated State
Performance Reports (CSPR) for school year 2004-2005, which contained each
school's improvement status for the 2005-2006 school year, among other
data. Because states provided the names of schools in corrective action
and restructuring in their 2004-2005 CSPRs, these schools comprised the
national population of such schools. In some cases, states used different
labels for identifying schools in corrective action and restructuring. For
example, one state identified schools in corrective action by labeling
them as "Year 3" schools. When states used terms other than corrective
action and restructuring to indicate schools' improvement status, we
contacted state officials to clarify the label the state used. Education
also provided us with numbers of schools in corrective action and
restructuring for the 2006-2007 school year, which we compared to numbers
from prior years. On the basis of our review of the data on improvement
status for school years 2005-2006 and 2006-2007, we determined these
sources to be sufficient for the purposes of our work. We used the lists
of schools in corrective action and restructuring for the 2005-2006 school
year to develop our survey samples and for comparisons with other Title I
schools not identified as needing improvement.

Also in the CSPR, states provided each school's nationally unique
identification number, allowing us to link data on these schools with data
provided in Education's Common Core of Data (CCD). The CCD is a database
of Education's National Center for Education Statistics, which annually
collects data from state educational agencies about all public schools,
public school districts, and state educational agencies in the United
States. At the time we began our analysis, the latest CCD data available
were from the 2004-2005 school year. Although we based our analysis on
schools in corrective action and restructuring in 2005-2006, the
characteristics were based on one year prior. Upon linking schools
identified in the CSPR to those in the CCD, we obtained data on the
following characteristics:

           o locale: whether the school was located was in an urban,
           suburban, or rural area or town;

           o minority status: the percent of students in the school
           classified as American Indian/Alaskan Native, Asian/Pacific
           Islander, Black/Non-Hispanic, or Hispanic;

           o poverty status: the percent of students in the school who
           qualified for free- or reduced-priced meals; and

           o grade levels served: whether primary, middle, or high school
           grades. To define these levels, we used the definitions provided
           in the CCD, as listed in table 9.

Table 9: Grade Level Definitions

Grade level served Low grade             High grade 
Primary            Pre-kindergarten to 3 Up to 8    
Middle             4 to 7                4 to 9     
High               7 to 12               12         

Source: Common Core of Data.

Schools that did not fit these grade-level configurations were classified
as "other," meaning any other combination, from the low grades of
prekindergarten, kindergarten or first grade up to twelfth grade,
consistent with the CCD definition.

We compared the percentage of schools in corrective action and
restructuring with all other Title I schools within each category of the
characteristics of locale and grade levels served. For minority status and
poverty status, we compared schools in corrective action and restructuring
with all other Title I schools by comparing the characteristics of the
median school within each group.^1 The median is the school in the middle
of a list of schools when they are listed from highest to lowest along any
given characteristic, such that one-half of the schools are listed above
and the other half are listed below that school. For example, when all
corrective action and restructuring schools were listed from highest to
lowest in terms of poverty status, the school in the middle of that list
had a poverty rate of 96 percent. In contrast, when all other Title I
schools were listed from highest to lowest, the school in the middle of
that list had a poverty rate of 37 percent. We chose to use the median
school instead of calculating the average for all schools or all students,
because so many schools had high rates of poverty and minority student
representation, that the median more accurately characterized the typical
school in our dataset than did the average.

We performed a series of tests and took additional steps as needed to
assess the reliability of the data used. For the lists of schools obtained
in the CSPR and the CCD, we checked to ensure that data were consistent,
that subtotals added to overall totals and that data provided for 1 year
bore a reasonable relationship to the next year's data and to data
reported elsewhere, including state education reports. We also spoke with
Education officials about their follow-up efforts to verify the data. At
the time of our review, Education reported that the 2004-2005 data had
been verified.

On the basis of our review of these data, we determined these sources to
be sufficiently reliable for the purposes of our work. We also considered
school improvement-related findings from Education studies, including the
National Assessment of Title I Interim Report, Vol. 1: Implementation
(2006). To ensure the findings from these studies were sufficiently
reliable, we reviewed each study's methodology, including data sources and
analyses, limitations, and conclusions. We found these studies to be
sufficiently reliable for the purposes of our work.

^1We also used locale (urban, suburban, town/rural) to enhance our
analyses of minority status and poverty status in order to account for the
clustering of minority students and students who are poor in urban areas.

Objectives 2 and 3: Implementation of Corrective Action and Restructuring and
State and District Assistance

To address the second objective on school's implementation of corrective
action and restructuring and the third objective on district and state
assistance, we designed and administered two Web-based surveys to a
nationally representative sample of school principals: one for schools in
corrective action and one for schools in restructuring, as of the
2005-2006 school year. The surveys were conducted between January and
March 2007. To obtain the maximum number of responses, we sent follow-up
e-mail notifications with a link to the surveys to those who had not
completed the survey approximately 1 week after the initial launch and
additional six follow-up notifications every week thereafter. In addition,
approximately 3 weeks after the Web surveys began, we provided a mail
survey to those who had not responded. The surveys included questions
about corrective actions or restructuring options the school had taken.
Both surveys included questions about factors that may have influenced
student achievement and assistance provided by the state and district. We
also conducted site visits to 5 states and 10 school districts and 20
schools within these states, during which we conducted interviews and
obtained documentation on school improvement efforts and related topics.
Finally, we reviewed Education's regulations, guidance, and monitoring
tools and interviewed department officials about monitoring and guidance
related to corrective action and restructuring. Specifically, we reviewed
the NCLBA, associated regulations, Local Education Agency and School
Improvement Guidance (revised July 2006), monitoring tools and indicators
used during Education's site visits, and selected monitoring reports and
findings.

Corrective Action Survey

  Sample Design and Errors

Based on data obtained from the CSPR, the study population of 1,163
schools consisted of all public Title I schools that were in corrective
action in the 2005-2006 school year. We selected a random sample of
schools in the population and calculated the sample size to achieve a
precision of plus and minus 8 percent at the 95 percent confidence level
for an expected proportion of 50 percent.^2 To ensure the sample sizes
were adequate, we set the sample size assuming we would obtain a 70
percent response rate. The total sample size was 240 schools. In the
sample, each school in the population had a known, nonzero probability of
being selected. Each selected school was subsequently weighted in the
analysis to account statistically for all the schools in the population,
including those that were not selected.

^2Since the margin of error for a proportion estimate with a given sample
size is greatest at 50 percent, we were conservative when planning the
sample size.

Because we surveyed a sample of schools, survey results are estimates of a
population of schools and thus are subject to sampling errors that are
associated with samples of this size and type. Since we followed a
probability procedure based on random selections, our sample is only one
of a large number of samples that we might have drawn. As each sample
could have provided different estimates, we express our confidence in the
precision of our particular sample's results as a 95 percent confidence
interval (for example, plus or minus 8 percentage points). This is the
interval that would contain the actual population value for 95 percent of
the samples we could have drawn. As a result, we are 95 percent confident
that each of the confidence intervals in this report will include the true
values in the study population. We excluded 8 of the sampled schools,
because they were not in corrective action status in the 2005-2006 school
year, were not Title I schools or had closed, and therefore were
considered out of scope. All estimates produced from the sample and
presented in this report are representative of the in-scope population.
All percentage estimates included in this report have margins of error of
plus or minus 8 percentage points or less, unless otherwise noted.

We took steps to minimize nonsampling errors that are not accounted for
through statistical tests, like sampling errors. In developing the Web
survey, we conducted several pretests of draft instruments. We pretested
the survey instrument with school officials in Aurora, Illinois; Berkeley,
California; and Orange, New Jersey, between October and November 2006. We
selected schools in these states because they contained large numbers of
schools in corrective action and thus it was likely that schools from
these states would be included in our sample. In the pretests, we were
generally interested in the clarity of the questions and the flow and
layout of the survey. For example, we wanted to ensure definitions used in
the surveys were clear and known to the respondents, categories provided
in closed-ended questions were complete and exclusive, and the ordering of
survey sections and the questions within each section was appropriate. We
revised the survey on the basis of information we gathered in the
pretests.

A second step we took to minimize nonsampling errors was using a Web-based
survey. By allowing respondents to enter their responses directly into an
electronic instrument, this method automatically created a record for each
respondent in a data file and eliminated the need for and the errors (and
costs) associated with a manual data entry process. To further minimize
errors, programs used to analyze the survey data and make estimations were
independently verified to ensure the accuracy of this work.

While we did not fully validate specific information that school officials
reported in our survey, we took several steps to ensure that the
information was sufficiently reliable for the purposes of this report. For
example, data from mailed surveys were double-keyed to ensure data entry
accuracy, and the information was analyzed using statistical software. We
obtained corroborating evidence of schools' improvement status when the
information provided by the school conflicted with the information we had
received from the Department of Education. In addition, we verified the
responses of those schools that reported that the school had made AYP.
When survey responses did not align with the information that we obtained
from state Web sites and school report cards, we made changes to the
survey responses based on documentary evidence. After the survey was
closed, we also made comparisons between select items from our survey data
and another national-level data set.^3 We found our survey data were
reasonably consistent with the external sources. On the basis of our
checks, we believe our survey data are sufficiently reliable for the
purposes of our work.

  Response Rate

We received survey responses from 68 percent of the Title I schools in
corrective action in our sample. After the survey was closed, we analyzed
the survey respondents to determine if there were any differences between
the responding schools, the nonresponding schools, and the population. We
performed this analysis for four characteristics--percentage of minority
students, percentage of students with free lunch, region, and locale. We
found no significant differences between the estimates for the survey
respondents and the overall population values for these characteristics.
On the basis of the 68 percent response rate and this analysis, we chose
to include the survey results in our report and produce sample-based
estimates to the population of schools in corrective action in the
2005-2006 school year.

^3We compared our district survey data to data on schools in corrective
action reported by Education in the National Assessment of Title I Interim
Report , Vol. 1: Implementation, Institute of Education Sciences
(Washington, D.C.: February 2006).

Restructuring Survey

  Sample Design and Errors

The study population of 920 schools consisted of public Title I schools
that were implementing restructuring in the 2005-2006 school year. This
population was obtained from the CSPR data provided by Education, as
described above. We used the same sample design for the restructuring Web
survey as the design used for the corrective action survey. The total
sample size was 230 schools.

We determined that 12 of the sampled schools were out of scope because
they were not implementing restructuring in the 2005-2006 school year. All
estimates produced from the sample and presented in this report are
representative of the in-scope population. All percentage estimates
included in this report have margins of error of plus or minus 8
percentage points or less, unless otherwise noted.

As with the corrective action survey, we took steps to minimize
nonsampling errors. We pretested the survey instrument with school
officials in Detroit, Michigan and Syracuse, New York, between October and
November 2006. We selected schools in these states because the states
contained large numbers of schools implementing restructuring and thus it
was likely that schools from these states would be included in our sample.
The pretests were conducted in the same manner as those done for the
corrective action survey. On the basis of the pretests, the Web instrument
underwent some revisions. Again, use of a Web-based survey also minimized
nonsampling errors as did independently verifying programs used to analyze
the survey data and make estimations.

Steps taken to ensure that the information was sufficiently reliable for
the purposes of this report mirror those taken for the corrective action
survey, including obtaining corroborating evidence of schools' improvement
status when the information provided by the school conflicted with the
information we had received from the Department of Education. When a
survey response did not align with the information that we obtained from
state Web sites and school report cards, we made changes based on our
documentary evidence. We checked a sample of schools that claimed to have
made AYP to verify these responses and found that the responses were
accurate. Again, we made comparisons between select items from our survey
data and other national-level data sets,^4 and found our survey data were
reasonably consistent with the external sources. On the basis of our
checks, we believe our survey data are sufficient for the purposes of our
work.

  Response Rate

We received survey responses from 74 percent of the Title I schools
implementing restructuring in our sample. After the survey was closed, we
analyzed the survey respondents to determine if there were any differences
between the responding schools, the nonresponding schools, and the
population, as was done for the corrective action survey. We found no
significant differences between the estimates for the survey respondents
and the overall population values for these characteristics. On the basis
of the 74 percent response rate and this analysis, we chose to include the
survey results in our report and produce sample-based estimates to the
population of schools in restructuring in the 2005-2006 school year.

Combined Surveys

Many of the questions on the corrective action survey and restructuring
survey were the same. For example, on both surveys we asked about the
assistance provided by the state and district, the factors that impeded or
facilitated student achievement, and the factors that helped or hindered
implementation of school improvement efforts. For such questions, we
combined the survey responses for reporting purposes. We weighted the
respondents so that the estimates are for the in-scope combined population
of corrective action and implementing restructuring schools. Because we
surveyed a sample of schools, our results are estimates of a population of
Title I schools in corrective action and implementing restructuring and
thus are subject to sampling errors that are associated with samples of
this size and type. All percentage estimates included in this report have
margins of error of plus or minus 8 percentage points or less, unless
otherwise noted.

^4We compared our district survey data to data on schools in restructuring
reported by Education in the National Assessment of Title I Interim
Report, Vol. 1: Implementation, Institute of Education Sciences
(Washington, D.C.: February 2006). We also compared our survey data to
data on schools in restructuring reported by the Center on Education
Policy in Wrestling the Devil in the Details: An Early Look at
Restructuring in California (Washington, D.C.: February 2006).

Site Visits

To understand corrective action and restructuring implementation at the
local level, we conducted site visits to 5 states and 10 districts and 20
schools within these states between October 2006 and March 2007. The 5
states we chose were: California, Illinois, Maryland, New York, and
Pennsylvania. Together, these 5 states had 59 percent of schools in
corrective action and restructuring nationwide in the 2005-2006 school
year and are located in a variety of geographic regions. We interviewed
state officials on state efforts to oversee and assist schools in
corrective action and restructuring.

Within each of the 5 states, we visited 2 school districts, for a total of
10 school districts, as shown in table 10. The 10 districts were selected
because they had experience implementing corrective action and
restructuring. When viewed as a group, the districts also provided
variation across characteristics such as geographic location and district
size.

Table 10: School Districts Selected for Site Visits

School District                       City, State         
Baltimore City Public School System   Baltimore, Md.      
Brentwood Union Free School District  Brentwood, N.Y.     
Chicago Public Schools                Chicago, Ill.       
East Aurora School District #131      Aurora, Ill.        
Los Angeles Unified School District   Los Angeles, Calif. 
New York City Department of Education New York, N.Y.      
Pomona Unified School District        Pomona, Calif.      
Prince George's County Public Schools Upper Marlboro, Md. 
School District of Philadelphia       Philadelphia, Pa.   
York City School District             York, Pa.           

Source: GAO.

During the site visits, we interviewed state and district officials as
well as officials representing 20 schools, including principals, teachers,
and other school staff involved with school improvement activities in
order to provide in-depth information and illustrative examples of our
more general findings. The selected schools resembled the population of
schools in corrective action and restructuring in terms of the grade
levels served, and the students' racial, ethnic, and economic
characteristics. While in many cases district officials selected the
schools we visited, all of the schools had experience implementing
corrective action or restructuring. Through our interviews with state,
district, and school officials, we collected information on corrective
actions and restructuring options implemented, factors affecting student
achievement, and state and district assistance provided to schools in
corrective action and restructuring.

Objective 4: Education's Efforts to Support State Implementation

To address the fourth objective on Education's efforts to assist states'
implementation of corrective action and restructuring provisions, we
conducted interviews with representatives of the offices of Title I,
Planning, Evaluation, and Policy Development, What Works Clearinghouse,
Comprehensive Centers Program, and General Counsel. We also interviewed
officials with the Center on Innovation and Improvement, the California
and New York Regional Centers, and the Northwest Regional Education
Laboratory.

In addition, we interviewed experts in the field on school improvement,
including those at the American Institutes for Research, Center on
Education Policy, Council of the Great City Schools, Council of Chief
State School Officers, Education Commission of the States, and RAND
Corporation. We reviewed several studies on school improvement, corrective
action, and restructuring.

Appendix II: Number of Schools in Corrective Action, Planning for
Restructuring, and Implementing Restructuring, by State in 2005-2006 and
2006-2007

Table 11: Number of Schools in Corrective Action, Planning Restructuring,
and Implementing Restructuring, by State in 2005-2006 and 2006-2007

                                   2005-2006                                      2006-2007
              Corrective  Planning for  Implementing         Corrective  Planning for  Implementing  
State             Action Restructuring Restructuring  Totals     Action Restructuring Restructuring Totals
Alabama                       0            13         27        40           3             5      18    26 
Alaska                       34             5          8        47          35            30      12    77 
Arizona                      25            20          4        49          36            12      14    62 
Arkansas                      4             1          0         5          54            19       4    77 
California                  406           153        247       806         482           343     357 1,182 
Colorado                     22            13          3        38          21            16      14    51 
Connecticut                   4             0          6        10          63             1       6    70 
Delaware                      2             0          0         2           3             0       1     4 
District of                  45             0          0        45          33             0       0    33 
Columbia                                                                                                   
Florida                      32             0          0        32         544            30       0   574 
Georgia^a                    19             0         66        85          23            19      48    90 
Hawaii                        2            13         41        56          38             3      50    91 
Idaho                         0             0          0         0          12             0       0    12 
Illinois                    151           211         20       382          93           177     138   408 
Indiana                      10             9          6        25          18             6       9    33 
Iowa                          0             0          0         0           4             0       0     4 
Kansas                        0             2          0         2           3             2       0     5 
Kentucky                      3             6          0         9          56             1       5    62 
Louisiana                    23             0          6        29           3             4       0     7 
Maine                         0             0          0         0           4             0       0     4 
Maryland                      6             6         41        53          15             2      46    63 
Massachusetts                32            10         19        61         129            24      26   179 
Michigan                     22            40         58       120          46            16      37    99 
Minnesota                     7             1          0         8          10             3       0    13 
Mississippi                   0             1          1         2          12             0       1    13 
Missouri^b                    0             7          0         7                                         
Montana                       0             0         30        30           4             1      31    36 
Nebraska                      0             2          0         2           0             1       0     1 
Nevada                       16             2          0        18          18             9       0    27 
New Hampshire                 1             0          0         1           2             0       0     2 
New Jersey                   34            61          0        95         100            16      49   165 
New Mexico                   16            28         24        68          29            17      48    94 
New York                     95            43        147       285          67            77     166   310 
North                        12             5          0        17          59            10       2    71 
Carolina                                                                                                   
North Dakota                  3             2          3         8           3             2      14    19 
Ohio                         25            24         29        78          76            19      33   128 
Oklahoma                      3             3          4        10          10             3       2    15 
Oregon                        0             1          0         1           9             0       1    10 
Pennsylvania                 30             5         83       118          29            15      63   107 
Rhode Island                  6             2          0         8           9             2       2    13 
South                        26             6          7        39          69            27      10   106 
Carolina                                                                                                   
South Dakota                 13             0          2        15           7            12       2    21 
Tennessee                     0            13         24        37          10             1      19    30 
Texas                         3             0          0         3          33             2       0    35 
Utah                          1             0          1         2           0             0       1     1 
Vermont                       0             0          0         0           2             0       0     2 
Virginia                      9             3          0        12          12             2       2    16 
Washington                    6             9          0        15          26             4       8    38 
West Virginia                 1             0          1         2           6             0       1     7 
Wisconsin                     6             7          0        13           7             4       2    13 
Wyoming                       0             0          0         0           3             0       0     3 
Totals                    1,155           727        908     2,790       2,330           937   1,242 4,509 

Source: GAO analysis of Education data.

^aFor the 2005-2006 school year, Georgia required schools in corrective
action to plan for restructuring. We reported these schools as in status
as corrective action.

^bFor the 2006-2007 school year, Missouri had yet to report which of its
schools were identified for improvement, corrective action, or
restructuring.

Appendix III: Comments from the Department of Education

Appendix IV: GAO Contacts and Acknowledgments

GAO Contact

Cornelia M. Ashby, (202) 512-7215, [42][email protected]

Acknowledgments

Bryon Gordon, Assistant Director, and Elizabeth Morrison managed the
assignment. Cara Jackson, Jason Palmer, and Nancy Purvine made significant
contributions to this report in all aspects of the work. Susannah Compton,
Nancy Hess, Jean McSween, and Jerome Sandeau provided analytical
assistance. Sheila McCoy provided legal support, and Karen Burke developed
the report's graphics.

Related GAO Products

Teacher Quality: Approach, Implementation, and Evaluation of Key Federal
Efforts. [43]GAO-07-861T . Washington, D.C.: May 17, 2007.

No Child Left Behind Act: Education Actions May Help Improve
Implementation and Evaluation of Supplemental Educational Services.
[44]GAO-07-738T . Washington, D.C.: April 18, 2007.

No Child Left Behind Act: Education Assistance Could Help States Better
Measure Progress of Students with Limited English Proficiency.
[45]GAO-07-646T . Washington, D.C.: March 23, 2007.

Reading First: States Report Improvements in Reading Instruction, but
Additional Procedures Would Clarify Education's Role in Ensuring Proper
Implementation by States. [46]GAO-07-161 . Washington, D.C.: February 28,
2007.

No Child Left Behind Act: Education Actions Needed to Improve
Implementation and Evaluation of Supplemental Educational Services.
[47]GAO-06-1121T . Washington, D.C.: September 21, 2006.

No Child Left Behind Act: Education Actions Needed to Improve Local
Implementation and State Evaluation of Supplemental Educational Services.
[48]GAO-06-758 . Washington, D.C.: August 4, 2006.

No Child Left Behind Act: States Face Challenges Measuring Academic
Growth. [49]GAO-06-948T . Washington, D.C.: July 27, 2006.

No Child Left Behind Act: Assistance from Education Could Help States
Better Measure Progress of Students with Limited English Proficiency.
[50]GAO-06-815 . Washington, D.C.: July 26, 2006.

No Child Left Behind Act: States Face Challenges Measuring Academic Growth
That Education's Initiatives May Help Address. [51]GAO-06-661 .
Washington, D.C.: July 17, 2006.

No Child Left Behind Act: Improved Accessibility to Education's
Information Could Help States Further Implement Teacher Qualification
Requirements. [52]GAO-06-25 . Washington, D.C.: Nov. 21, 2005.

No Child Left Behind Act: Education Could Do More to Help States Better
Define Graduation Rates and Improve Knowledge about Intervention
Strategies. [53]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.
[54]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. [55]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.
[56]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. [57]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. [58]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. [59]GAO-04-659 . Washington, D.C.: July 15, 2004.

Student Mentoring Programs: Education's Monitoring and Information Sharing
Could Be Improved. [60]GAO-04-581 . Washington, D.C.: June 25, 2004.

No Child Left Behind Act: More Information Would Help States Determine
Which Teachers Are Highly Qualified. [61]GAO-03-631 . Washington, D.C.:
July 17, 2003.

Title I: Characteristics of Tests Will Influence Expenses; Information
Sharing May Help States Realize Efficiencies. [62]GAO-03-389 . Washington,
D.C.: May 8, 2003.

(130594)

References

Visible links
  40. http://www.gao.gov/cgi-bin/getrpt?GAO-05-879
  41. http://www.gao.gov/
  42. mailto:[email protected]
  43. http://www.gao.gov/cgi-bin/getrpt?GAO-07-861T
  44. http://www.gao.gov/cgi-bin/getrpt?GAO-07-738T
  45. http://www.gao.gov/cgi-bin/getrpt?GAO-07-646T
  46. http://www.gao.gov/cgi-bin/getrpt?GAO-07-161
  47. http://www.gao.gov/cgi-bin/getrpt?GAO-06-1121T
  48. http://www.gao.gov/cgi-bin/getrpt?GAO-06-758
  49. http://www.gao.gov/cgi-bin/getrpt?GAO-06-948T
  50. http://www.gao.gov/cgi-bin/getrpt?GAO-06-815
  51. http://www.gao.gov/cgi-bin/getrpt?GAO-06-661
  52. http://www.gao.gov/cgi-bin/getrpt?GAO-06-25
  53. http://www.gao.gov/cgi-bin/getrpt?GAO-05-879
  54. http://www.gao.gov/cgi-bin/getrpt?GAO-05-618
  55. http://www.gao.gov/cgi-bin/getrpt?GAO-05-5
  56. http://www.gao.gov/cgi-bin/getrpt?GAO-05-7
  57. http://www.gao.gov/cgi-bin/getrpt?GAO-04-734
  58. http://www.gao.gov/cgi-bin/getrpt?GAO-04-909
  59. http://www.gao.gov/cgi-bin/getrpt?GAO-04-659
  60. http://www.gao.gov/cgi-bin/getrpt?GAO-04-581
  61. http://www.gao.gov/cgi-bin/getrpt?GAO-03-631
  62. http://www.gao.gov/cgi-bin/getrpt?GAO-03-389
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